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.

Regarding the consultation on the ESMA Guidelines on presentation of risk factors in the prospectus Deutsches Aktieninstitut points out the right balance between the objective of ESMA to avoid overly generic/lengthy descriptions of risk factors and flexibility for issuers in their assessment of relevant risk factors to be included in the prospectus. Proportionality and coherence are key factors for guidance on risk factors. For instance, the requirement for specificity should not result in the obligation for issuers to disclose trade secrets. Nor should issuers be prohibited to continue to use the presentations of the risk factors of their annual financial report for its prospectuses. This is also important in order not to confuse investors facing different risk factors in different reports/documents. The coherent description of the same risk factors also promotes comparability and thus serves to protect investors.

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