> The topic of the congress - triggered, among other things, by the debate started by the Federal Constitutional Court on the traceability of standardization - certainly led to the border areas between transparency and efficiency of standardization. Prof. Dr. Udo Steiner from the University of Regensburg, on the other hand, sees the situation very clearly. “There is no legal sentence in current constitutional law to the effect that sub-statutory legal norms that are issued without formal justification suffer from a formal error and are therefore void (according to German doctrine),” explains the former Federal Constitutional Judge. Such a legal sentence cannot be accepted from the Basic Law in conjunction with the legally regulated cases of an obligation to give reasons (e.g.: Section 9 Para. 8 BauGB) and the obligation to give reasons under Union law (Article 296 Para. 2 TFEU). This also corresponds to the current case law. And he explicitly adds: “The same applies to sub-statutory legal norms that do not require an executive act to develop their legal effect,” which concerns so-called self-executing legal norms. And in Steiner's opinion, the legislature, which bears political and constitutional responsibility for the administrative procedural law of sub-statutory legal norms, is not logically accused of unconstitutional omission if it has not yet provided for a general formal obligation to provide reasons for sub-statutory legal norms.
So the G-BA is fine with it?

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