Regulating costs for shareholder communication and identification in line with the future (in German)

The ARUG II reformed the processes of shareholder communication and shareholder identification. A new cost regulation that adequately manages the reimbursement of expenses incurred by intermediaries would have great added value for all parties. The legal clarity gained would enable standardized billing of the intermediaries' expenses and thus avoid unnecessary expenditure by the parties.

However, the content of such a regulation must include that issuers only have to pay costs to intermediaries to an appropriate extent. The law itself establishes that only the necessary expenses of the intermediaries are reimbursable, based on methods that correspond to the respective state of the art. It will be important to appreciate this appropriately in enacting a cost regulation. In any case, expenses based on outdated communication and transmission techniques should not be required of issuers.