Sustainable Finance Lobbying Overview: Deutsche Bank has had mostly positive engagement on sustainable finance policy, with a significant proportion of engagement from asset management subsidiary DWS.

Top-line Messaging on Sustainable Finance Policy: DWS has stated support for the 2050 net-zero target, and Deutsche Bank has generally supported action by the financial sector on climate. In a joint investor statement to governments in 2022, DWS advocated for action to keep the global temperature rise to 1.5C. However, in 2021, Deutsche Bank argued against Germany's earlier net-zero commitment by 2045 and for a continued role for GHG emissions intense investments. Deutsche Bank has stated broad support for the EU's Action Plan on Sustainable Finance on its websites and its 2020 CDP response it encouraged policy that drives positive action but without a clear position on whether to restrict negative action (i.e. fossil-fuel energy investments).

Position on Regulated Corporate ESG Disclosure: Both Deutsche Bank and DWS appear to offer broad support for mandatory ESG corporate disclosures in corporate reporting but have sometimes opposed ambitious regulations in response to policymakers. In its 2020 CDP response, Deutsche Bank supported regulated corporate ESG disclosure and in a website article in 2021 further supported policy to improve regulated corporate ESG disclosure, including regulatory implementation of Scope 3 emissions. DWS has also offered broad support for regulated ESG corporate disclosures in website articles and consultation responses. In a joint investor statement in 2022, DWS advocated for mandatory TCFD implementation and 1.5 pathway-aligned transition plans. Likewise, in a 2021 letter to the SEC, Deutsche Bank stated support for a regulated corporate ESG disclosure framework. However, in response to the SEC consultation in 2022 on Climate-Related Disclosures for Investors, Deutsche Bank did not support the 1% materiality threshold and requested an extension to the implementation deadline, particularly referring to issues with gathering data for Scope 3 emissions disclosure. In 2022, DWS stated support for an ambitious global sustainability reporting in response to the International Sustainability Standards Board (ISSB), advocating for increased ambition in some areas and suggesting a double materiality approach. . However, Deutsche Bank offered a much more cautious approach, suggesting disclosure requirements should be more principles-based “so that the costs of implementing the disclosures do not outweigh the benefits”. Deutsche Bank urged alignment of the European Sustainability Reporting Standards (ESRS) to the ISSB in response to the European Financial Reporting Advisory Group (EFRAG) in 2022. It further suggested the standards should “limit the level of detail required and adopt a principle-based approach”. DWS offered a similar position regarding the ESRS, arguing that all mandatory disclosure requirements were not material for all companies and arguing that Scope 3 emissions disclosure is complex.

Position on Taxonomies: During 2019-2020, Deutsche Bank was generally supportive of the EU taxonomy in website articles, consultations and in the media. However, a 2019 DWS whitepaper argued that regulatory requirements based on the taxonomy should be voluntary. In feedback to the European Commission's consultation on the Renewed Sustainable Finance Strategy in 2020, Deutsche Bank supported the EU taxonomy, particularly its use by the public sector, but opposed its expansion to cover environmentally harmful activities. Deutsche Bankalso argued that it was not possible to meet the taxonomy’s requirements due to lack of available data in a 2021 news release. In a 2022 whitepaper, it also highlighted the need for taxonomies to be “dynamic and adaptive” and that the EU taxonomy does not fully capture the ongoing transition and financing needs.

Position on ESG Standards, Labels & Benchmarks: In a 2019 whitepaper, DWS stated support for an EU Green Bond Standard and supported the EU's climate benchmarks with some minor concerns around the methodology used. In feedback to the Commission consultation on the Renewed Sustainable Finance Strategy in 2020, Deutsche Bank supported the need for verification of the EU Green Bond Standard, as well as the Commission’s suggestions for new ESG labels and benchmark. However, it argued for a less prescriptive approach to the EU Ecolabel in 2020.

Position on Integrating ESG into Investor Duties: Prior to 2021, DWS has stated support for the EU's work to integrate ESG considerations into fiduciary duty in website posts and whitepapers. In 2020, Deutsche Bank supported considering adverse sustainability impacts as part of fiduciary duty, although suggested a flexible approach to how retail clients are asked about their sustainability preferences.

Position on the integration of ESG factors into prudential regulation and risk management: In a 2020 press release, Deutsche Bank offered broad support for prudential regulatory rules that encourages greater ESG deployment of capital.

Lobbying Transparency: DWS has stated some policy positions in whitepapers, but there does not appear to be a centralized disclosure of lobbying activities or any group level disclosure, with positions scattered throughout various website articles. Deutsche Bank has disclosed some of its trade association memberships, but has not given any further details of its governance of indirect influence. DWS has also listed trade group memberships on its website with some details on working groups it is involved in.