Position papers

2020

  March 2020

AECM NEFI comments on the TF to enable Member States to further support the economy in the COVID-19 outbreak

  PDF

March 2020
AECM ELTI NEFI members actions to mitigate economic effects of the corona outbreak 6 April 9:00H
PDF

  March 2020
  AECM comments on the SME Strategy
  PDF

March 2020
AECM comments on mitigating economic effects of the corona outbreak
PDF

  March 2020
  AECM Position on Anti-Money-Laundering
  PDF

March 2020
AECM Position on the Sustainable Europe Investment Plan
PDF

  March 2020
  AECM Position on the Just Transition Fund
  PDF

January 2020
AECM Position on the transposition of the finalised Basel III rules into EU law
PDF

2019

December 2019
AECM Sustainability Memorandum
PDF
October 2019
AECM, Eurochambres and SMEuntited joint comments for the upcoming trilogue on the taxonomy proposal
PDF
September 2019
AECM comments on the EBA Draft Guidelines on loan origination and monitoring
PDF
September 2019
AECM comments to the targeted review of the GBER
PDF
September 2019
Joint comments of AECM, EAPB, ELTI and NEFI on the State of Play regarding InvestEU
PDF
August 2019
AECM comments on the InvestEU draft Investment Guidelines including Annex
PDF
July 2019
AECM comments on 2012 State aid modernization package, railways guidelines and short-term export credit insurance – fitness check
PDF
July 2019
AECM comments as to the de minimis Regulation
PDF
July 2019
AECM comments as to State aid instruments for agriculture, forestry and rural areas
PDF
June 2019
AECM comments on the application of state aid rules
PDF
April 2019
AECM priorities for the next legislative period
PDF
March 2019
Joint comments on the taxonomy proposal (2018/0178(COD))
PDF
March 2019
AECM and SMEunited Joint comments on the Taxonomy Draft Report
PDF
February 2019
Position of the European Association of Guarantee Institutions (AECM) on the Commission’s decision to prolong for two years seven sets of state aid rules, otherwise expiring in 2020, and launch an evaluation on the application of EU state aid rules adopted as part of the State Aid Modernization (SAM) process
PDF
February 2019
AECM, EAPB, ELTI, NEFI and SMEunited joint position paper: Comments on SME-related aspects of the proposed InvestEU Programme
PDF

2018

December 2018
Position paper on Commission’s proposal on Common Provisions Regulation (CPR ) European Regional Development Fund (ERDF ) and Cohesion Fund ( CF )
PDF
December 2018
AECM and EAPB joint Statement on current developments concerning the InvestEU Programme
PDF
November 2018
AECM and SMEunited comments on the proposal for a regulation establishing the InvestEU Programme
PDF
October 2018
AECM’s suggestions to resolve double documentation within the 5th Anti-Money-Laundering Directive
PDF
July 2018
EU financial instruments under the multiannual financial framework (MFF) 2021 to 2027: Comments of UEAPME and AECM on the proposal of the European Commission for a regulation establishing the InvestEU Programme
PDF
June 2018
Joint Position Paper on Financing Energy Efficiency measures in buildings: Reflections on the creation of a coherent approach in a multi-level governance system – AECM-EAPB- NEFI – UEAPME
PDF
June 2018
Annex – AECM members feedback on Energy Efficiency
PDF
June 2018
AECM’s comments on the financial instruments in the agricultural sector: The CAP After 2020
PDF
May 2018
AECM’s contribution to the review of the SME definition
PDF
April 2018
AECM’s contribution to Performance of Rural Development Programmes of the 2007-2013 period
PDF
April 2018
AECM’s answer to The De minimis Regulation Questionnaire
PDF
8 March 2018
AECM’s additional comments on the public consultation on EU funds in the area of investment, research & innovation, SMEs and single market
PDF
March 2018
Public consultation on EU funds in the area of investment, research & innovation, SMEs and single market
PDF
March 2018
AECM’s Suggestions to Finding a Solution for Guarantee Institutions to the Double-Monitoring Obligations Under the 4th AML Directive
PDF
January 2018
Evaluation and Impact Assessment of Recommendation 2003/361/EC – the ‘SME Definition’
PDF

2017

23 November 2017
Joint  Position Paper on the Future of EU Finances-AECM-EAPB- NEFI 
PDF
10 October 2017
AECM’s Suggestions on the ‘Small Banking Box’
PDF
25 October 2017
AECM, EAPB, ELTI & NEFI Comments on the  Interim Evaluation of the Programme for the Competitiveness of Enterprises and Small and Medium-sized Enterprises (COSME) (2014-2020)
PDF
September 2017
AECM’s contribution to the questionnaire by the High Level Expert Group on sustainable finance interim report
PDF
August 2017
AECM’s comments on the interim evaluation of the programme for the competitiveness of enterprises and small and medium-sized enterprises (COSME) (2014-2020)
PDF
August 2017
AECM’s comments on the inception impact assessment concerning  a possible increase of the thresholds of the agricultural de minimis aid
PDF
June 2017
AECM’s comments on the definition of SME
PDF
June 2017
AECM’s answers to the COSME Evaluation survey
PDF
April 2017
AECM contribution on Modernising and Simplifying the Common Agricultural Policy (CAP)
PDF
January 2017
Comments of UEAPME and AECM concerning the design and implementation of EU financial instruments
PDF
January 2017
AECM’s position on the ‘Public consultation of the European Central Bank on the exercise of options and discretions by NCAs (national competent authorities) in relation to less significant institutions (LSIs)’
PDF

2016

May 2016
AECM’s comments on the ‘Public consultation on the revision of the Financial Regulation applicable to the general budget of the Union’
PDF
March 2016
AECM’s comments on the Basel Committee on Banking Supervision’s
Second consultative document “Revisions to the Standardised Approach for credit risk”

PDF
January 2016
AECM’s comments on the European Central Bank consultation on the collection of granular credit and credit risk data (“AnaCredit”)
PDF

2015

December 2015
AECM’s comments on the European Central Bank (ECB) “Public Consultation on a draft Regulation and Guide of the ECB on exercises of options and discretions available in Union law”
PDF
October 2015
AECM contribution to the “Discussion Paper and Call for Evidence on SMEs and the SME Supporting Factor” of the European Banking Authority – EBA
PDF
October 2015
AECM’s comments on the DG FISMA “Consultation Paper on the possible impact of the CRR and the CRD IV on bank financing of the economy”
PDF
May 2015
AECM’s contribution to the Public Consultation of the European Commission on the Green Paper “Building a Capital Markets Union”
PDF

2014 and previous years

February 2014
AECM contribution to thepublic consultation of the European Commission on a draft General Block Exemption Regulation (the GBER) on state aid measures
PDF
March 2014
AECM’s contribution to the Public Consultation on the Small Business Act (SBA)
PDF
March 2014
AECM contribution to the public consultation of the European Commission on the draft Commission notice on the notion of state aid
PDF
AECM position on draft General Block Exemption Regulation (the GBER) on state aid measures
PDF
June 2013
AECM position regarding the European Commission’s Draft for the General Block Exemption Regulation (GBER)
PDF
May 2013
AECM position regarding the European Commission’s Draft for De Minimis Regulation
PDF
March 2013
Position on review of Regional State Aid guidelines
PDF
March 2013
AECM position on review of De minimis for agriculture
PDF
October 2012
AECM position on review of De minimis Regulation
PDF
October 2012
AECM position on Risk Capital – Commission Consultation SAM
PDF
September 2012
AECM position on Commission consultation on Entrepreneurship 2020 Action Plan
PDF
September 2012
AECM position on review of the General Block Exemption Regulation (GBER)
PDF
May 2012
AECM position regarding the European Commission’s review process for EU State Aid rules
PDF
November 2011
AECM issues position paper on CRD IV
PDF
May 2011
AECM position on Commission Green Paper on Innovation – Continued call for a strong follow-up programme to the CIP
PDF
February 2011
AECM position on CIP successor programme
PDF
October 2010
AECM position on prolongation of Temporary State Aid Framework
PDF
September 2009
AECM position on Temporary State Aid Framework
PDF