Position papers
2025
| July 2025 AECM response to the Single Market Strategy |
| June 2025 AECM response to the EBA Consultation on draft RTS under Article 28(1) of the AMLR on Customer Due Diligence |
| June 2025 AECM contribution to Commission’s call for evidence for the European Affordable Housing Plan |
| June 2025 Proposals of the Ideas Powered for Business Network – Intellectual Property Driving European Competitiveness |
| May 2025 AECM reflections on a simplified SME definition under InvestEU |
| May 2025 AECM contribution to MFF consultation – EU funding for the single market, and cooperation between national authorities |
| May 2025 AECM contribution to MFF consultation – Implementing EU funding with Member States and regions |
| May 2025 AECM contribution to MFF consultation – EU funding for competitiveness |
| May 2025 AECM contribution to MFF consultation – Performance of the EU budget |
| April 2025 AECM contribution to Commission’s consultation on the draft new State aid Framework to support the Clean Industrial Deal |
| April 2025 10 Suggestions to Support Business Transfers in the EU – Co-signed by AECM |
| April 2025 AECM-NEFI-SMEunited Joint Position Paper on the Second Omnibus package |
| March 2025 AECM considerations for the Second Omnibus package on InvestEU |
| March 2025 AECM response to Commission’s call for evidence on EU Start-up and Scale-up Strategy |
| March 2025 Unlock private capital – The Savings and Investment Union – ELTI-EVFIN-AECM-NEFI Joint Position Paper |
| March 2025 AECM response to the consultation on a European Savings and Investments Union |
| February 2025 AECM considerations for the upcoming First Omnibus package on sustainability |
2024
| December 2024 AECM requests for future funding / financing instruments: Considerations for the Multiannual Financial Framework 2028-2034 |
| November 2024 AECM EAPB ELTI NEFI Common Position Paper on the Future of Cohesion Policy with a Focus on Ensuring Regional Flexibility and Promoting Simplification |
| November 2024 AECM request for a limited prolongation of the State aid Temporary Crisis and Transition Framework (TCTF) after 31 December 2024 to further support the agricultural sector |
| September 2024 AECM reflections on the future of the Cohesion Policy |
| July 2024 AECM comments to the Commission’s proposal for the amendment of the Regulation 1408/2013 on the application of Articles 107 and 108 of the Treaty on the Functioning of the European Union to the de minimis aid in the agriculture sector |
| April 2024 AECM response to EBA consultation on draft Guidelines on the management of ESG risks |
| March 2024 AECM position on ensuring affordable access to finance for SMEs through EU guarantees |
| March 2024 AECM position on the Framework for Financial Data Access (FiDA) |
2023
| December 2023 AECM priorities for the legislative period 2024-2029 English | Français |
| October 2023 AECM request on the reporting requirements to the de minimis aid |
| October 2023 AECM contribution to the Commission’s call for evidence for a mid-term evaluation of the European Regional Development Fund, the Cohesion Fund, and the Just Transition Fund for 2021-2027 |
| September 2023 Final evaluation of the Programme for the Competitiveness of Enterprises and Small and Medium-sized Enterprises (COSME) (2014 – 2020) |
| July 2023 AECM position on the Strategic Technologies Europe Platform |
| July 2023 AECM position on the first set of European Sustainability Reporting Standards (ESRS) |
| June 2023 Statement by Platform Members and Knowledge Partners on the occasion of the Meeting of OECD Committee on SMEs and Entrepreneurship (CSMEE) at Ministerial Level |
| June 2023 AECM contribution to the Commissions second draft text on the de minimis regulation |
| May 2023 AECM on the InvestEU Interim Evaluation |
| April 2023 AECM contribution to the public consultation questionnaire for the Recovery and Resilience Facility mid-term evaluation |
| April 2023 AECM contribution to the public consultation on the ex post evaluation of the European Regional Development Fund & the Cohesion Fund 2014-2020 |
| April 2023 AECM on the COSME evaluation |
| March 2023 AECM, EAPB, ELTI and NEFI Joint Position on the Draft Parliament Report regarding the EU Financial Regulation Recast |
| March 2023 AECM position on the harmonisation of certain aspects of insolvency law |
| February 2023 AECM response to Commission’s consultation on the Temporary Crisis and Transition Framework (TCTF) |
| February 2023 AECM input to the SME Relief Package |
2022
| December 2022 AECM contribution to the Commission’s public consultation on State aid – exemptions for small amounts of aid (de minimis aid) (update) |
| December 2022 Leveraging the EU budget for investments |
| December 2022 EABP-AECM-NEFI joint position on the Financial Regulation Recast |
| November 2022 AECM comments to Commission’s evaluation of the Guarantee Notice |
| November 2022 DG COMP reply to the joint AECM-NEFI letter on the thresholds applicable to NPBIs under the InvestEU Fund |
| October 2022 AECM comments on the Commission’s draft proposal to prolong and adjust the State aid Temporary Crisis Framework (TCF) |
| September 2022 AECM NEFI letter on the thresholds applicable to National Promotional Banks and Institutions under the InvestEU Fund |
| September 2022 AECM updated comments on the AML package |
| August 2022 AECM reply to the public consultation on the EFSI evaluation |
| August 2022 AECM comments to the second consultation on the revision of the General Block Exemption Regulation (GBER) in light of the Green Deal |
| July 2022 AECM and NEFI contribution to the Commission’s call for evidence: ”State aid – exemptions for small amounts of aid (de minimis aid)” |
| July 2022 AECM position on the Basel Package – update July 2022 |
| April 2022 Update of the AECM position on the AMLR proposal and the draft PARL report |
| April 2022 AECM request to prolong the application of the TF for EGF schemes under Section 3.1 and 3.2 until 31 December 2022 |
| March 2022 AECM contribution to the Commission’s public consultation on revised State aid rules for the agricultural and forestry sectors and in rural areas |
| February 2022 AECM request to increase the ceiling of the de minimis Regulation |
| February 2022 AECM Position on the Basel Package |
| February 2022 AECM’s contribution to Commission’s call for evidence for an evaluation of the European Regional Development Fund & Cohesion Fund 2014-2020 |
| January 2022 AECM Letter: The InvestEU Fund – Request to enter operational phase as soon as possible |
2021
| December 2021 AECM EAPB ELTI NEFI contribution to the consultation on the targeted review of the GBER |
| September 2021 AECM contribution to the consultation on a targeted review of the Financial Regulation |
| September 2021 AECM position on the AML legislative package |
| September 2021 AECM contribution on the public consultation on the Debt equity bias reduction allowance |
| August 2021 Commission’s reply to AECM request to extend the Temporary Framework for State aid measures to support the economy in the current COVID-19 outbreak until 31 December 2022 |
| July 2021 Joint SME Financing Statement July 2021 |
| July 2021 AECM request to extend the Temporary Framework for State aid measures to support the economy in the current COVID-19 outbreak until 31 December 2022 |
| July 2021 Commission reply to AECM EAPB ELTI NEFI SMEunited joint letter to EU SME Envoy |
| July 2021 Call for Dialogue: Assessment of SMEs’ Post-COVID Financial Health |
| July 2021 AECM feedback on the Guidelines on State aid to promote risk finance investments |
| June 2021 AECM EAPB ELTI NEFI SMEunited joint letter to EU SME Envoy |
| May 2021 AECM input for the CRR/CRD review |
| May 2021 AECM Position on the CSRD |
| May 2021 AECM Position on the BRRD review |
| May 2021 DG Competition reply to AECM EAPB ELTI NEFI SMEunited position on the prolongation of the EGF State aid Scheme |
| April 2021 AECM consulation reply on a review of VAT for financial services |
| April 2021 AECM consulation reply on an SME referral scheme |
| April 2021 AECM comments to the public consultation on the draft revised Communication on important projects of common European interest (IPCEI) |
| April 2021 AECM EAPB ELTI NEFI SMEunited position on the prolongation of the EGF State aid Scheme |
| March 2021 AECM position on the need to keep up enhanced guarantee support |
| March 2021 AECM Reply to the Commission Consultation on the convergence of insolvency schemes |
| March 2021 DG Competition’s reply to AECM letter concerning the Pan-European Guarantee Fund |
| March 2021 AECM letter to DG Competition calling for improvement of state aid provisions applicable to the Pan-European Guarantee Fund |
| January 2021 Contribution to public consultation ‘EU farm policy — evaluation of its impact on knowledge exchange and advisory activities |
2020
| October 2020 AECM-EAPB-ELTI letter to the institutions on InvestEU |
| October 2020 AECM comments on the latest version of the InvestEU Investment Guidelines |
| September 2020 AECM request for extension of the Temporary Framework for State aid measures to support the economy in the current COVID-19 outbreak |
| August 2020 AECM, NEFI and SMEunited position paper on the inter-institutional negotiations on MFF and Next Generation EU |
| July 2020 AECM Comments on the second GBER consultation |
| June 2020 AECM Comments on the NFRD Revision |
| June 2020 AECM’s and SMEunited’s questions on the updated InvestEU proposal Reply letter from DG ECFIN and DG GROW |
| June 2020 AECM’s reaction to the elements regarding Structural funds of the European Commission Proposal for the 2021-2027 MFF |
| May 2020 AECM’s first reaction to the updated MFF |
| May 2020 AECM input to the OECD report on trade finance in the digital era |
| May 2020 Letter to Commissioner Ferreira calling for an ambitious cohesion policy budget to respond to the economic consequences of COVID-19 for SMEs fostering the use of counter-guarantee |
| April 2020 AECM on CRR amendments following the covid outbreak |
| April 2020 Letter to Commissioner Hahn calling for an ambitious InvestEU budget |
| April 2020 Press release on the top-ups for COSME and InnovFin in response to the COVID-19 pandemic |
| March 2020 AECM NEFI comments on the TF to enable Member States to further support the economy in the COVID-19 outbreak |
| March 2020 AECM ELTI NEFI members actions to mitigate economic effects of the corona outbreak 16 June 09:30H |
| March 2020 AECM comments on the SME Strategy |
| March 2020 Press release on AECM members’ action to fight economic consequences of the COVID-19 outbreak |
| March 2020 AECM comments on mitigating economic effects of the corona outbreak |
| March 2020 AECM Position on Anti-Money-Laundering |
| March 2020 AECM Position on the Sustainable Europe Investment Plan |
| March 2020 AECM Position on the Just Transition Fund |
| January 2020 AECM Position on the transposition of the finalised Basel III rules into EU law |
2019
| December 2019
AECM Sustainability Memorandum |
| October 2019
AECM, Eurochambres and SMEuntited joint comments for the upcoming trilogue on the taxonomy proposal |
| September 2019
AECM comments on the EBA Draft Guidelines on loan origination and monitoring |
| September 2019
AECM comments to the targeted review of the GBER |
| September 2019
Joint comments of AECM, EAPB, ELTI and NEFI on the State of Play regarding InvestEU |
| August 2019
AECM comments on the InvestEU draft Investment Guidelines including Annex |
| July 2019
AECM comments on 2012 State aid modernization package, railways guidelines and short-term export credit insurance – fitness check |
| July 2019
AECM comments as to the de minimis Regulation |
| July 2019
AECM comments as to State aid instruments for agriculture, forestry and rural areas |
| June 2019
AECM comments on the application of state aid rules |
| 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 joint 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 |
| June 2018
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
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) |
| 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 thepublic 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
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| 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 |
