Bundesverband Alternative Investments e.V. (BAI)

BAI welcomes legislative initiatives to promote infrastructure investments

The Bundesverband Alternative Investments e.V. (BAI) welcomes the draft bill published yesterday for the second law to strengthen company pension schemes and amend other laws (2nd Company Pension Strengthening Act). An important component of the draft is the revision and expansion of the investment options for the pension funds concerned, particularly in the infrastructure segment. Among other things, the draft includes the introduction of an independent quota of 5% for infrastructure investments, which is not at the expense of other existing quotas.

01. July 2024

The draft of the 2nd Company Pension Strengthening Act is closely linked to the discussion draft recently presented by the Federal Ministry of Finance on the promotion of investments by investment funds in renewable energies and infrastructure (Infrastructure Promotion Act). This draft contains important changes to fund supervisory law (KAGB) with regard to infrastructure investments, as well as significant improvements to the Investment Tax Act, including an expansion and flexibilization of the investment catalog with regard to infrastructure assets and project companies.

BAI Managing Director Frank Dornseifer assesses the two drafts as follows: "The BAI has repeatedly pointed out that the sustainable transformation or energy transition cannot be financed without the fund industry and the institutional and private investors behind it. In its Climate Barometer 2023, KfW puts the financing required to achieve the legally enshrined goal of climate neutrality in Germany by 2045 at around five trillion euros, which corresponds to an average annual investment requirement of a good 190 billion euros, whereby the largest share cannot be borne by the public sector. The legislative initiatives that have now been presented address precisely the areas of action that we have been addressing and, overall, they are therefore to be viewed positively. Not only will legal certainty be created along the investment value chain in the future, but above all long-standing inconsistencies in supervisory and tax law, which have damaged the competitiveness of Germany as a fund location, will be eliminated."

Dornseifer continues: "Whether German or foreign investors now make corresponding investments in infrastructure or renewable energies in Germany also depends largely on other factors, in particular risk-return aspects. Pension funds also have to pursue specific return targets for their investors, policyholders, pension recipients, etc.. And the strategic and tactical asset allocation is aligned accordingly. In other words, locations and assets are in competition. This is precisely why the German energy industry and the Association of Municipal Enterprises recently emphasized in a joint position paper that "many of the German energy transition projects do not have a sufficiently attractive risk-return profile from the perspective of private investors" and that "competing investments therefore often [promise] better returns with lower risks". Particularly in view of the overarching objective of managing the energy transition and sustainable transformation together with private and institutional investors, I believe that further measures are required in addition to these two legislative initiatives. One central aspect could be to establish a dedicated infrastructure project company, into which - on the one hand - state infrastructure projects are brought in and bundled, so that standardization and, above all, scalability is achieved; on the other hand, the public sector and private investors can invest together via this project company, as is the case with the KfW Growth Fund, for example, which has successfully established itself. The Sustainable Finance Advisory Board itself also proposed such a cooperative financing model at the beginning of the year, as have the energy industry and the Association of Municipal Enterprises in their joint position paper on the so-called energy transition fund."


Standpunkt zur Energiewende und der Rolle der Fondsbranche

Standpunkt „Neue Finanzierungsmodelle für die Energiewende“

BAI Stellungnahme zum InfrastrukturFörderG

BAI Stellungnahme zum Zukunftsfinanzierungsgesetz

BAI Studie “Between Short-term Headwinds and Strong Long-term Tailwinds: Infrastructure 2024 - Focus on Germany”


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Press contact:
Bundesverband Alternative Investments e.V. (BAI)
Frank Dornseifer
Managing Director
Poppelsdorfer Allee 106
53115 Bonn
Tel.: +49 (0)228-96987-50
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