Comments

The Association of German Banks takes part in the legislative process by publishing comments and position papers.

Current Comments

Comments

21st of January 2026

Input on a revised Delegated Act concerning standards for sustainability reporting

under the Corporate Sustainability Reporting Directive (CSRD)

The German Banking Industry Committee (DK) has taken a position on the revision of the ESRS and the EU taxonomy as part of the participation process initiated by the Federal Ministry of Justice and Consumer Protection (BMJV).

Comments

20th of January 2026

Rethinking Payments – Wholesale Settlement Solutions as an Anchor

Strengthening Europe’s Sovereignty in Interbank Payments through Blockchain with a Distribution Solution!

This paper examines the Eurosystem’s initiatives Pontes and Appia and explains why today’s architectural choices will shape Europe’s financial sovereignty tomorrow. It makes the case for a distribution-based approach as the most effective way to combine innovation, efficiency, and robust regulatory control.

Comments

30th of December 2025

GBIC Comments on the Draft Implementing Act for EUDIW User Onboarding under eIDAS 2.0

The statement relates to the European Commission’s draft implementing act on the onboarding of users to the European Digital Identity Wallet (EUDIW) under the amended eIDAS-Regulation (eIDAS 2.0).

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