Invest Europe

CS3D Position Paper for Interinstitutional Negotiations

Positions & consultation responses

15 Jun 2023

The CS3D proposal, developed by the Commission primarily with large non-financial companies in mind, still does not cater appropriately for investment firms in relation to their investment activities. It does not acknowledge a fundamental principle of company law: investors, as shareholders in a company do not systematically manage the businesses that they invest in. This paper outlines the core issues that policymakers need to resolve before agreeing on the final version of the Directive.