Position papers

2024

March 2024
AECM position on ensuring affordable access to finance for SMEs through EU guarantees
PDF
March 2024
AECM position on the Framework for Financial Data Access (FiDA)
PDF

2023

December 2023
Priorities for the legislative period 2024-2029
LINK
October 2023
AECM request on the reporting requirements to the de minimis aid
PDF
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
PDF
September 2023
Final evaluation of the Programme for the Competitiveness of Enterprises and Small and Medium-sized Enterprises (COSME) (2014 – 2020)
PDF
July 2023
AECM position on the Strategic Technologies Europe Platform
PDF
July 2023
AECM position on the first set of European Sustainability Reporting Standards (ESRS)
PDF
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
PDF
June 2023
AECM contribution to the Commissions second draft text on the de minimis regulation
PDF
May 2023
AECM on the InvestEU Interim Evaluation
PDF
April 2023
AECM contribution to the public consultation questionnaire for the Recovery and Resilience Facility mid-term evaluation
PDF
April 2023
AECM contribution to the public consultation on the ex post evaluation of the European Regional Development Fund & the Cohesion Fund 2014-2020
PDF
April 2023
AECM on the COSME evaluation
PDF
March 2023
AECM, EAPB, ELTI and NEFI Joint Position on the Draft Parliament Report regarding the EU Financial Regulation Recast
PDF
March 2023
AECM position on the harmonisation of certain aspects of insolvency law
PDF
February 2023
AECM response to Commission’s consultation on the Temporary Crisis and Transition Framework (TCTF)
PDF
February 2023
AECM input to the SME Relief Package
PDF

2022

December 2022
AECM contribution to the Commission’s public consultation on State aid – exemptions for small amounts of aid (de minimis aid) (update)
PDF
December 2022
Leveraging the EU budget for investments
PDF
December 2022
EABP-AECM-NEFI joint position on the Financial Regulation Recast
PDF
November 2022
AECM comments to Commission’s evaluation of the Guarantee Notice
PDF
November 2022
DG COMP reply to the joint AECM-NEFI letter on the thresholds applicable to NPBIs under the InvestEU Fund
PDF
October 2022
AECM comments on the Commission’s draft proposal to prolong and adjust the State aid Temporary Crisis Framework (TCF)
PDF
September 2022
AECM NEFI letter on the thresholds applicable to National Promotional Banks and Institutions under the InvestEU Fund
PDF
September 2022
AECM updated comments on the AML package
PDF
August 2022
AECM reply to the public consultation on the EFSI evaluation
PDF
August 2022
AECM comments to the second consultation on the revision of the General Block Exemption Regulation (GBER) in light of the Green Deal
PDF
July 2022
AECM and NEFI contribution to the Commission’s call for evidence: ”State aid – exemptions for small amounts of aid (de minimis aid)”
PDF
July 2022
AECM position on the Basel Package – update July 2022
PDF
April 2022
Update of the AECM position on the AMLR proposal and the draft PARL report
PDF
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
PDF
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
PDF
February 2022
AECM request to increase the ceiling of the de minimis Regulation
PDF
February 2022
AECM Position on the Basel Package
PDF
February 2022
AECM’s contribution to Commission’s call for evidence for an evaluation of the European Regional Development Fund & Cohesion Fund 2014-2020
PDF
January 2022
AECM Letter: The InvestEU Fund – Request to enter operational phase as soon as possible
PDF

2021

December 2021
AECM EAPB ELTI NEFI contribution to the consultation on the targeted review of the GBER
PDF
September 2021
AECM contribution to the consultation on a targeted review of the Financial Regulation
PDF
September 2021
AECM position on the AML legislative package
PDF
September 2021
AECM contribution on the public consultation on the Debt equity bias reduction allowance
PDF
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
PDF
July 2021
Joint SME Financing Statement July 2021
PDF
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
PDF
July 2021
Commission reply to AECM EAPB ELTI NEFI SMEunited joint letter to EU SME Envoy
PDF
July 2021
Call for Dialogue: Assessment of SMEs’ Post-COVID Financial Health
PDF
July 2021
AECM feedback on the Guidelines on State aid to promote risk finance investments
PDF
June 2021
AECM EAPB ELTI NEFI SMEunited joint letter to EU SME Envoy
PDF
May 2021
AECM input for the CRR/CRD review
PDF
May 2021
AECM Position on the CSRD
PDF
May 2021
AECM Position on the BRRD review
PDF
May 2021
DG Competition reply to AECM EAPB ELTI NEFI SMEunited position on the prolongation of the EGF State aid Scheme
PDF
April 2021
AECM consulation reply on a review of VAT for financial services
PDF
April 2021
AECM consulation reply on an SME referral scheme
PDF
April 2021
AECM comments to the public consultation on the draft revised Communication on important projects of common European interest (IPCEI) 
PDF
April 2021
AECM EAPB ELTI NEFI SMEunited position on the prolongation of the EGF State aid Scheme
PDF
March 2021
AECM position on the need to keep up enhanced guarantee support
PDF
March 2021
AECM Reply to the Commission Consultation on the convergence of insolvency schemes
PDF
March 2021
DG Competition’s reply to AECM letter concerning the Pan-European Guarantee Fund
PDF
March 2021
AECM letter to DG Competition calling for improvement of state aid provisions applicable to the Pan-European Guarantee Fund
PDF
January 2021
Contribution to public consultation ‘EU farm policy — evaluation of its impact on knowledge exchange and advisory activities
PDF

2020

October 2020
AECM-EAPB-ELTI letter to the institutions on InvestEU
PDF
October 2020
AECM comments on the latest version of the InvestEU Investment Guidelines
PDF
September 2020
AECM request for extension of the Temporary Framework for State aid measures to support the economy in the current COVID-19 outbreak
PDF
August 2020
AECM, NEFI and SMEunited position paper on the inter-institutional negotiations on MFF and Next Generation EU
PDF
July 2020
AECM Comments on the second GBER consultation
PDF
June 2020
AECM Comments on the NFRD Revision
PDF
June 2020
AECM’s and SMEunited’s questions on the updated InvestEU proposal
PDF
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
PDF
May 2020
AECM’s first reaction to the updated MFF
PDF
May 2020
AECM input to the OECD report on trade finance in the digital era
PDF
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
PDF
April 2020
AECM on CRR amendments following the covid outbreak
PDF
April 2020
Letter to Commissioner Hahn calling for an ambitious InvestEU budget
PDF
April 2020
Press release on the top-ups for COSME and InnovFin in response to the COVID-19 pandemic
PDF
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 16 June 09:30H
PDF
March 2020
AECM comments on the SME Strategy
PDF
March 2020
Press release on AECM members’ action to fight economic consequences of the COVID-19 outbreak
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