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.

The three European supervisory authorities EBA, EIOPA and ESMA have consulted the Regulatory Technical Standards (RTS) on ESG disclosure requirements for investors. On the occasion of the consultation, we are calling for greater consideration to be given to the indirect reporting effects on enterprises of the producing industries. The RTSs should not predefine what is meant by the taxonomy-relevant "do no significant harm". There must be a uniform, lean set of indicators for the RTS, the EU taxonomy and the CSR-Directive to ensure that reporting obligations do not get out of hand.

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