Comments

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

Current Comments

Comments

18th of August 2025

Savings and Investments Union – EU-Commission’s targeted consultation

BdB has commented on selected issues raised by the EU Commission’s targeted consultation on the integration of EU capital markets. You will find more information in the comments.

Comments

8th of August 2025

Implementation of the amended Distance Selling Directive (EU 2023/2673)

Of 22 November 2023 into German law

The German Banking Industry Committee (DK) has issued a statement on the draft bill (RefE) of the Federal Ministry of Justice and Consumer Protection (BMJV) for a ‘Law Amending Consumer Contract and Insurance Law’ dated 9 July 2025.

Comments

29th of July 2025

Position paper on the implementation of the DORA requirement “Encryption in Use”

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