Position Papers

With our position papers we engage in political debates and expert discussions regarding capital market issues - representing the interests of our members. Each year, numerous and detailed positions cover the various areas of our work: the primary market, the secondary market, the governance of listed companies and the economic education.

Below you will find our position papers which focus on European legislation - mostly in English and partially in German language. All our positions including papers with focus on national topics you will find on our German website.

This position paper on ESMA's draft technical advice on the Market Abuse Regulation raises the concern that the notifications of managers' transactions will likely create misleading signals. According to ESMA's proposal transactions will have to be notified even if the manager has no discretion as to whether the purchase/sale of the share will take place. From Deutsches Aktieninstitut's point of view the notification of such 'passive transactions' would clearly contradict the regulatory objective.

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