In the answer to the consultation of the European Commission to the Green bond standard Deutsches Aktieninstitut demands a practice-oriented arrangement. In particular, it must be taken into account that green bonds can also be issued by companies if their business model is largely ecological. In addition, the reporting effort must be reduced.


The European Central Bank is plannung a central technical plattform for the issuance of bonds (European Destribution of Debt Instruments, EDDI). In a preliminary comment Deutsches Aktieninstitut is rather sceptical about the project as the pan-European primary market for debt instruments is already now well structured and organised. A public intervention in the current processes thus needs to be justified properly.


Deutsches Aktieninstitut welcomes the objective to strengthen the role of Germany as a top location for digitization and being a leader in using new technologies like blockchain. In this context, electronic securities and token regulation are important steps to increase the attractiveness of the German capital market.


Deutsches Aktieninstitut urges the EU Commission to reflect consequently the needs of companies seeking capital market finance and using derivates for risk management purposes in the Capital Markets Union. The current direction of the Capital Market Union still fails to meet this objective. This position paper has been contributed to the mid term review of the Capital Market Union project.


Regarding the consultation of the Prospectus Directive, Deutsches Aktieninstitut recommends to facilitate the prospectus regime, especially with regard to prospectuses concerning so called secondary issuances. In our view, in the case of secondary issuances it is not necessary to mention in a prospectus what has already been published due to obligations of other provisions such as the Transparency Directive and is therefore accessible for anyone.


In its comments Deutsches Aktieninstitut supports the European Commission’s initiative on building a Capital Markets Union. Further to the steps proposed by the Commission the demand-side of capital markets should, however, be addressed more precisely. This applies especially to the aspect of corporate finance. In addition, a cumulative impact-assessment of the regulatory initiatives launched in the aftermath of the financial crisis is necessary in order to identify and remove barriers for ...

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ESMA consults on standards for the approval and publication of prospectuses, their advertisement and the incorporation of external information by reference. Among other issues the drafted Regulatory Technical Standards would limit the documents being able to be incorporated by reference and raise high legal burdens on the advertisement regarding the issuance of securities. Deutsches Aktieninsitut urges ESMA to stay within its mandate which does not encompass these powers.


The joint letter to the EU-Commission (with BDI and VDT) addresses the debate on the technical regulatory standards regarding the liquidity coverage ratio (LCR) under Basel III. The definition of asset backed securities which are acknowledged as high quality liquid assets under the LCR should be appropriate and should carefully take into consideration well-established standards regarding securitisation of SME loans.


According to the analysis of Deutsches Aktieninsitut the role of money market funds for the cash management and the financing of non--financial companies will likely decrease. This will be the consequence of the EU Commission's porposed for a regulation of money markets funds. This position paper which is co-signed by the Bundesverband der Deutschen Industrie (BDI) explains in detail the concerns of non-financial companies.



Deutsches Aktieninstitut on the BaFin draft circular regarding key information documents (in German)



Position of Deutsches Aktieninstitut in regard of the government draft bill of the "Bundesschuldenwesengesetz" - here: German Bond Act (in German



Position of Deutsches Aktieninstitut in regard of the government draft bill of the revised Stock Corporation Act 2012 (in German)



Comment of Deutsches Aktieninstitut on the EU regulation of the rating market



Response of Deutsches Aktieninstitut to ESMA - Retail Cascade


The study provides an empirical analyses of both the potential and the willingness of the German "Mittelstand" to raise capital by the means of an intial public offering. It is revealed that 1,250 medium sized companies have a good starting positon and that "Mitttelstand" companies are still rather sceptic with regard on IPO. The study also aims at discussing some of the prejudices among those who are sceptic.