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.

We offer a lot evidence of rules inconsistent with other provisions or rules running counter to overarching principles. Among others the increased level of bureaucracy is contradictory to the idea of facilitating the capital market finance and therefore against the Capital Market Union. To avoid such inconsistent regulation, the EU regulators should conduct a meaningful and convincing impact assessment in advance of every new rule. To solve the problem of inconsistent level 1- and level 2-textes, the crucial points have to be decided on level 1. In addition, to faciliate the application of EU law, the legislators have to develop consolidated versions of level 1-textes, including the level 2-rules.

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