Position papers and Press releases
2021
April 2021
AECM EAPB ELTI NEFI SMEunited position on the prolongation of the EGF State aid Scheme
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March 2021
AECM position on the need to keep up enhanced guarantee support
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March 2021
AECM Reply to the Commission Consultation on the convergence of insolvency schemes
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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
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June 2020
AECM Comments on the NFRD Revision
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June 2020
AECM’s and SMEunited’s questions on the updated InvestEU proposal
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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
April 2020
AECM on CRR amendments following the covid outbreak
PDF
| 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 |
