Position papers

2019

 

April 2019
AECM priorities for the next legislative period


March 2019
Joint comments on the taxonomy proposal (2018/0178(COD))

March 2019
AECM and SMEunited Joint comments on the Taxonomy Draft Report

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

February 2019
AECM, EAPB, ELTI, NEFI and SMEunited joined position paper: Comments on SME-related aspects of the proposed InvestEU Programme

2018

 

December 2018
Position paper on Commission’s proposal on Common Provisions Regulation (CPR ) European Regional Development Fund (ERDF ) and Cohesion Fund ( CF )

December 2018
AECM and EAPB joint Statement on current developments concerning the InvestEU Programme

 

November 2018
AECM and SMEunited comments on the proposal for a regulation establishing the InvestEU Programme

October 2018
AECM’s suggestions to resolve double documentation within the 5th Anti-Money-Laundering Directive

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

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

Annex – AECM members feedback on Energy Efficiency 

June 2018
AECM’s comments on the financial instruments in the agricultural sector: The CAP After 2020

May 2018
AECM’s contribution to the review of the SME definition

April 2018
AECM’s contribution to Performance of Rural Development Programmes of the 2007-2013 period

April 2018
AECM’s answer to The De minimis Regulation Questionnaire

 

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

 

 

March 2018
AECM’s Suggestions to Finding a Solution for Guarantee Institutions to the Double-Monitoring Obligations Under the 4th AML Directive

January 2018

Evaluation and Impact Assessment of Recommendation 2003/361/EC – the ‘SME Definition’

2017

 

23 November 2017

Joint  Position Paper on the Future of EU Finances-AECM-EAPB- NEFI 

10 October 2017
AECM’s Suggestions on the ‘Small Banking Box’

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) – French version available here

 

September 2017
AECM’s contribution to the questionnaire by the High Level Expert Group on sustainable finance interim report

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)

August 2017
AECM’s comments on the inception impact assessment concerning  a possible increase of the thresholds of the agricultural de minimis aid

June 2017
AECM’s comments on the definition of SME

June 2017
AECM’s answers to the COSME Evaluation survey 

April 2017
AECM contribution on Modernising and Simplifying the Common Agricultural Policy (CAP)

January 2017
Comments of UEAPME and AECM concerning the design and implementation of EU financial instruments

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)’

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’

March 2016

AECM’s comments on the Basel Committee on Banking Supervision’s
Second consultative document “Revisions to the Standardised Approach for credit risk”

 

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

 

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”

 

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

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”

 

May 2015
AECM’s contribution to the Public Consultation of the European Commission on the Green Paper “Building a Capital Markets Union”

  

2014 and previous years

 

February 2014
AECM contribution to the
public consultation of the European Commission on a draft General Block Exemption Regulation (the GBER)
on state aid measures

March 2014
AECM’s contribution to the Public Consultation on the Small Business Act (SBA)

March 2014
AECM contribution to the public consultation of the European Commission on the draft Commission notice on the notion of state aid

AECM position on draft General Block Exemption Regulation (the GBER) on state aid measures

June 2013

AECM position regarding the European Commission’s Draft for the General Block Exemption Regulation (GBER)

 

May 2013

AECM position regarding the European Commission’s Draft for De Minimis Regulation

 

March 2013

Position on review of Regional State Aid guidelines

 

March 2013

AECM position on Review of De minimis for agriculture

 

October 2012

AECM position on review of De minimis Regulation

 

October 2012

AECM position on Risk Capital – Commission Consultation SAM

 

September 2012

AECM position on Commission consultation on Entrepreneurship 2020 Action Plan

 

September 2012

AECM position on review of the General Block Exemption Regulation (GBER)

 

May 2012

AECM position regarding the European Commission’s review process for EU State Aid rules

 

November 2011

AECM issues position paper on CRD IV

 

May 2011

AECM position on Commission Green Paper on Innovation – Continued call for a strong follow-up programme to the CIP

 

February 2011

AECM position on CIP successor programme

 

October 2010

AECM position on prolongation of Temporary State Aid Framework

 

September 2009

AECM position on Temporary State Aid Framework