Union Investment welcomes the opportunity to contribute to this Call for Evidence. As the asset manager within the German cooperative financial network, we managed 146.6 bn in accordance with Art. 8/9 SFDR at the end of 2024. In this regard, the SFDR review is highly relevant to us and we support the idea to establish product categories.
Union Asset Management Holding AG
Company · Germany · EU Transparency Register 35378765850-63
Counts here are a floor, never a total: they cover the 326 consultation files tracked so far (29,503 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 925 companies & groups on this site, they rank #514 by legislative files engaged — a count of participation, not a measure of influence.
Declares membership of
- Union Investment is i.a. member of the national associations BVI (Bundesverband Investment und Asset Management e.V),…
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026).
- Register category
- Companies & groups
- Head office
- Frankfurt am Main, Germany
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
Union Asset Management Holding AG filed 2 positions between 30 May 2025 and 3 Jun 2025, across 2 of the 326 legislative files tracked here.
What they argued
Union Investment welcomes the opportunity to provide feedback to the European Commissions (EC) Call for Evidence (CfE) in addition to the parallel DG FISMA consultation. For the purposes of the CfE, we would like to highlight three key aspects: UCITS investment limits: There is currently an unlevel playing field between ETFs, for which a 20% (exceptionally 35%) issuer limit may apply and actively managed funds which…
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers — not evidence of coordination, and we do not suggest any.
- IDEE ECONOMICHE www.idee-economiche.it · 2 files in common
- DigitalTrade4.EU · 2 files in common
- French Banking Federation · 2 files in common
- Insurance Europe · 2 files in common
- Gesamtverband der Deutschen Versicherungswirtschaft e.V. (GDV) · 2 files in common
Showing 5 of 32.
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