German Property Federation (ZIA)

The European Commission’s digital omnibus aims to clarify, simplify and harmonise the application of key elements of European data law, in particular data protection law. The Zentrale Immobilien Ausschuss e.V. (ZIA), as the umbrella organisation for the German real estate industry, warmly welcomes this European initiative.

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The European Commission, through the Digital Package and the planned Digital Omnibus, pursues the objective of simplifying the European regulatory framework, reducing adminis-trative burdens, and enhancing the coherence of digital policy rules.

The German Property Federation (ZIA) welcomes the European Commission's initiative to review the EU Taxonomy's Climate Delegated Act and thus the technical screening criteria (TSC). Given the high proportion of EU-wide CO emissions of more than one third, the Climate Taxonomy has the potential to play a key role in the building sector to mobilise the capital necessary for decarbonisation.

The following is a summary of the opinion of the Central Real Estate Committee (ZIA) on the revision of the Energy Performance of Buildings Directive. The full opinion is attached as a document to this feedback.

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The real estate sector is clearly committed to the European climate goals as well as to the Paris Agreement. The buildings sector in the EU accounts for 40 % of energy consumption and 36 % of greenhouse gas emissions. Residential and commercial immovable property is therefore the key to achieving the climate objectives.

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ZIA welcomes the revision of the EU Taxonomy Delegated Act and Technical Screening Criteria (TSC). The taxonomy has potential to mobilize capital for building sector decarbonization, but practical challenges have prevented full realization of this potential. Main Recommendations 1.

ZIA represents nearly 40 AIFMs managing real estate and infrastructure funds with assets under management in the hundreds of billions. While ZIA has supported the SFDR's approach of mobilizing private capital for sustainable investments from the outset, the current framework has created inconsistencies, excessive bureaucracy, and reporting burdens.

ZIA's more than 400 members include around 40 AIFM that manage real estate funds with assets in the triple-digit billion range. ZIA expressly supports the European sustainable finance agenda, and particularly the SFDR.

EXECUTIVE SUMMARY ZIA German Property Federation is in favour of exploiting the potential of data more than before. Particularly with regard to climate and environmental protection and achieving the goals of the Green Deal, the introduction of digital building infrastructure for measuring consumption can help reduce CO2 emissions.

The Central Real Estate Committee (ZIA) welcomes the Affordable Housing Act initiative as a concrete step towards the implementation of the European Affordable Housing Plan. The growing challenges in European housing markets require a coordinated policy response.

Filed in German · English published by the European Commission

ZIA broadly supports the faithful transposition of Basel III standards, but the current calibration generates structural constraints on real estate finance that are neither risk-proportionate nor aligned with the Union's housing and climate objectives.

The real estate industry is particularly affected by the Interest Limitation Rule due to its struc-turally capital-intensive orientation and long-term debt financing structures. The current design of the Interest Limitation Rule acts less as a targeted anti-abuse instrument but rather as a systematic investment barrier.

ZIA German Property Federation welcomes the opportunity to comment on the European Commission proposal (Banking Package 2021). Even though we see improvements compared to the initial package of the Basel Committee, the proposal will inevitably lead to more difficult financing conditions for the economy. The envisaged amendments are insufficient to absorb the negative economic consequences.