German Property Federation (ZIA)

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.

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.

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

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.