EU Listing Act: Simplify prospectuses for practical use

We expressly welcome the objective of the EU Listing Act to simplify the preparation of a prospectus and make it more cost-effective. The publicly available information due to the existing comprehensive reporting and disclosure requirements for listed companies enable a significant reduction of the prospectus. This benefits investors and companies.

In order to achieve these goals, we believe it is important that the proposed simplifications of the EU follow-up prospectus are also applied to the base prospectus. In practice, this prospectus is used almost exclusively by issuers for the issuance of follow-on bonds.

In addition, a detailed analysis of the proposal shows that certain changes, probably unintentionally, lead to significant difficulties, legal ambiguities and liability risks for issuers. We are committed to ensuring that these changes are remedied in the course of the legislative proceedings.