Comments

Comments on the proposal for a Directive for the further harmonisation of insolvency law

The German banking industry committee rejects, above all, the introduction of a pre-pack procedure and a simplified liquidation procedure for micro-entities, which is intended in the light of an improvement of the Capital Markets Union.

Added the need for correction of the definitions under Article 2q.

The publication of the comments of 16 March 2023 on the European Commission's proposal for a directive on the harmonization of insolvency law to improve the Capital Markets Union can be found in the link section.

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Stellungnahme zu einem Richtlinienvorschlag der Europäischen Kommission

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GBIC interpretation of the DORA constellation

‘ICT service as part of a regulated financial service’

The background to the paper is the Q&A of the European Supervisory Authorities (EBA, ESMA, EIOPA) of 22 January 2025, which provides the EU Commission's clarification on this constellation.