European Fund and Asset Management Association

EFAMA welcomes the opportunity to contribute to the European Commission's initiative to establish a European company. Our views, at this stage, focus on the need to safeguard shareholder rights and to enable effective stewardship policies for all companies accessing public markets. Please find attached our comments.

EFAMA welcomes the European Commissions Digital Fitness Check and its objective of reviewing the EU Digital Rulebook. We consider that several horizontal digital regulations overlap with existing financial legislation, creating unnecessary duplication for asset managers. EFAMA therefore encourages the Commission to prioritise simplification and regulatory coherence across the digital rulebook.

The Commissions initiative to simplify EU law in direct taxation, with its focus on reducing administrative burdens, eliminating outdated/overlapping rules, and improving consistency and application across Member States, is urgently needed to ensure the EU's competitiveness.

The European Fund and Asset Management Association (EFAMA) supports the objectives of the Shareholder Rights Directive (SRD) I and II and welcomes a targeted revision to address existing identified impediments and ensure greater exercise of shareholder rights.

EFAMA believes the following elements require due consideration in the draft implementing regulation (the Draft): 1. Multiple options (Art. 1(3)(b-c)) According to our understanding, the ability to choose multiple options to clarify the nature and extent of the beneficial interest and the beneficial owners (BO) for legal arrangements and legal entities is intended to provide flexibility when more than one option…