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Europaudvalget 2024-25
KOM (2025) 0503
Offentligt

A competitive, prosperous and digital Europe

by the Federal Minister for Economic Affairs and Climate Action of Germany, the Minister of the

Economy, Finance and Industry of France, the Minister of Economic Development and Technology

of Poland, The Minister of Industry, Business and Financial Affairs of Denmark and the Minister of

Finance of Cyprus

Europe is finding itself in increasing competition with other major economic powers. The global

level playing field is challenged by the practices of states, whose economic model entails market

distortions, and the domestic industrial policy pursued by others.

We must work to improve Europe's competitiveness while ensuring a successful and fair transition

towards climate neutrality by 2050. To this end, we need to simplify the regulatory environment

where necessary, tackle disproportionate compliance and reporting costs and ensure a level playing

field in the single market in order to unleash the creative forces in business, civil society and

administration, while maintaining a high level of protection for health, safety, environmental

protection and consumer protection.

Achieving a meaningful and appropriate reduction in administrative burdens requires action at both

European and national levels. Our approach is to reduce disproportionate administrative and

regulatory burdens for the economy i.a. in order to speed up the twin transition. We need to invest

more in our green transition if we are to meet our ambitious and legally binding climate targets,

while simultaneously preserving competitiveness of the European economy. We need to make it as

easy as possible for companies to go green and digital, while taking both environmental and

economic impacts into account. It is imperative that we simplify bureaucratic procedures, for

instance those that are relevant for the green transition, to help businesses unlock resources used

unnecessarily on compliance and allow them to move these resources in to green investments

instead, while maintaining high standards in terms of health, safety, the environment and consumer

protection.

This also includes reducing bureaucratic costs and minimising the burden of cross-border regulatory

impacts. In this context, we welcome the work of the European Commission to reduce burdens

associated with reporting requirements by 25 percent for companies resulting from EU legislation,

without undermining the related policy objectives. We also very much welcome the intention to

appoint a dedicated EU SME Envoy to advocate SME’s interests and enable an SME-friendly

regulation.

To deliver on and advance these ambitions, the Minister of the Economy, Finance and Industry of

France, the Federal Minister for Economic Affairs and Climate Action of Germany, the Minister of

Economic Development and Technology of Poland, the Minister of Industry, Business and

Financial Affairs of Denmark and the Minister of Finance of Cyprus welcome the strong focus on

boosting competitiveness, reducing burdens and simplifying implementation as well as the

announcement to appoint a Vice-President to pursue these aims in the Political Guidelines for the

next European Commission and urge the Commission to follow up on the intentions through

adoption of a “Bureaucracy Reduction Plan” in order to simplify existing provisions across the most

impactful texts and consider the following for its new mandate.

kom (2025) 0503 - Endeligt svar på spørgsmål 1: Spm. om non-papers eller positionspapirer vedr. sagerne om forenklingspakke IV

Improve the quality and focus on the execution of EU legislations – simplify legislation and

enforce it

The EU has taken much pride in setting up leading legislation to ensure clear policy goals and

direction for European businesses. This necessitates constant attention being paid to whether rules

and regulations continue to deliver on their policy goals and on whether they are set up as simple as

possible for businesses, administrations and citizens. We advocate for a drastic simplification and

strengthened enforcement of EU legislation in order to effectively deliver on the EU's policy goals

and facilitate a successful and fair twin transition based on European competitiveness and

technological leadership.

We thus call on the Commission to deliver an ambitious simplification programme eliminating

overlapping and conflicting regulation and reducing reporting obligations, primarily for SMEs and

way beyond the Commission target of 25 percent, based on a thorough assessment of the results of

its “call for evidence” concerning the rationalisation of reporting requirements. In order to make it

easier for companies, especially small businesses, to do business we ask the Commission to clarify

rules and simplify or remove rules that are obsolete or irrelevant.

The need for new legislation should be justified in light of the enforcement of already adopted EU

law in the same field. For all upcoming initiatives at the EU level, it is therefore particularly

important to examine the extent to which there is any risk of duplicating reporting obligations. We

therefore encourage the Commission to map the existing reporting requirements to identify possible

duplications and unnecessary obligations.

We support the systematic use of the "SME test" within impact assessments, whereby a panel of

SME-stakeholders assesses proposed new obligations to ensure that they are workable,

proportionate and have a positive cost/benefit balance. We also support that impact assessments

systematically take into account competitiveness, possible effects on EU´s trade relations and cross-

border trade within the EU, environmental and social coherence, territorial cohesion, impacts on

individual Member States, impacts on outermost regions, the Union’s sovereignty and defence and

security challenges, where relevant.

We must also look more closely into whether legislation that has been implemented actually

delivers on European policy goals efficiently, or whether there are unexpected impacts, which

hinder businesses in practice to act as expected. We therefore call on the Commission to launch so

called “reality checks” at European level in predetermined fields to identify unnecessary

administrative burdens in a more targeted way. A reality check aims at identifying obstacles and

possible solutions for individual scenarios and investment projects in close dialogue with

entrepreneurs, administrations and other experts concerned, with the primary focus on the users’

perspective.

Also, we believe that rules could be simplified within the areas of reporting procedures asked from

companies, access to programs and EU funds, State aid notification procedures, etc.

The Commission should also, for instance, work to clarify obligations under the GDPR in order to

harmonise their application with the aim of simplified procedures for companies.

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Moreover, we believe administrative burdens related to corporate sustainability reporting need

special attention and fundamental improvements. Businesses face the various difficulties regarding

digital accessibility and interoperability between systems that complicates collection, sharing, and

use of the data needed for the reporting tasks. We call for increased attention with regard to the

implementation of the Corporate Sustainability Reporting Directive (CSRD), Corporate

Sustainability Due Diligence Directive 3 (CS3D), and the Taxonomy, while we fully encourage the

Commission to facilitate reporting processes, by applying a strict “once only principle” and

developing a comprehensive strategy aimed at providing as much guidance and support as possible

to small-companies while strictly limiting the burden that bigger companies can pass on to their

smaller suppliers.

It is also important that we recognise that the burden of monitoring and enforcing Single Market-

rules is increasing, becoming less sustainable for especially smaller national administrations. But at

the same time, monitoring and enforcement is absolutely essential to ensuring an efficient Single

Market. We should therefore look to how new cutting edge technologies can be used to improve

monitoring and enforcement of Single Market rules, and take great note of Mr Letta's report on

Much more than a Single Market's proposals for "harnessing advanced technologies such as

Artificial Intelligence (AI)" to identify infringements more quickly. We suggest to expand and

strengthen the simplification team within the General Secretariat and to include a specific mandate

for simplification in the mission letter for the Commissioner responsible for competitiveness. We

ask for a stronger commitment of Member States as well as the Commission to the work of the

Single Market Enforcement Taskforce (SMET) and the appointment of a chief enforcement officer

in each Commission DG, as already appointed in DG Trade.

A digital and automated administrative business environment

We believe there is huge potential to be made by automating, digitising and accelerating the way

EU legislation is conceptualised and implemented and to do so, it is essential that effective digital-

readiness checks are conducted consistently ("digital by default"). Additionally, it is necessary to

also consider ecodesigned digital solutions to minimize the environmental impacts of these

technologies.

Some EU Member States have had good experiences with this already at national level. All digital

options should be kept in mind when drafting, implementing and applying legislation.

The common digital standards and components that the EU has already developed should be the

foundation for additional efforts on a European level. The Connecting Europe Facility (CEF) serves

as a cornerstone in this endeavour, offering essential digital building blocks such as eDelivery,

eInvoicing and eID that could serve as critical infrastructure to facilitate and secure more effortless

cross-border interactions for businesses within sectors ranging from economy and finance to energy

and security etc.

The present lack of standardisation creates barriers to digitisation and automation and means that

businesses must often adapt to several different systems with different digital maturity varying from

manual reporting forms to more advanced and automated systems when complying with different

reporting requirements, resulting in burdensome administration.

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Administrative burdens related to corporate sustainability reporting needs special attention. We

must improve and standardize the digital infrastructure for sustainability reporting. If we succeed,

we will not only be able to reduce companies’ administrative burdens but also enhance the

trustworthiness of the companies' sustainability reports as well as improve national authorities'

ability to conduct effective control and audit.

We welcome that the Corporate Sustainability Reporting Directive creates a common framework to

make companies' information on sustainability comparable across Europe. As the trickle-down

effect of this regulation represents a significant challenge for SMEs, we call on the Commission to

establish the Voluntary SME standard (VSME) as a cap for SMEs in the value chain and to fight

against situations in which individual value chain actors put pressure on SMEs to go unnecessarily

beyond this standard.

In addition, we call on the Commission and Member States to reduce burdens from reporting

obligations by:



Implementing standardised, interoperable electronic data formats for easier submission of

required information across EU Member States, taking advantage of the existing digital

commons, based on future ESAP regulation.

Requiring standardised system to system data exchange for reporting with authorities, so that

reports can be sent to all systems.

Aligning reporting requirements with existing international digital standards and frameworks to

facilitate cross-border trade and investment.

Promoting data sharing among Member States and government agencies, enabling businesses to

reuse data across various reporting requirements.

Defining common minimum digital standards for future legislation and using CEF building

blocks more consistently.

Making sure that the Digital Product Passports, as proposed in the Ecodesign for Sustainable

Products Regulation (technology neutral, interoperable, technologically and data sovereign),

serve as the default option for future product legislation that sets out product data sharing

requirements, while ensuring that the standard passport gives sufficient flexibility to take into

account specific sectorial requirements.



Set up the right framework for businesses to prosper

As the framework defining a company in the European legislation is more than 20

years old, we

need to look at whether it is still reflecting today’s economic reality. In particular, as the

Commission suggested, the SME definition needs to be assessed and re-adapted in line with the

latest SME Envoy declaration

, in order to take inflation into account. Similarly, we call for the

European Commission to do more analysis on small mid-caps

and their specific needs and role in

Europe’s economic transition, working towards creating a new company category of small mid-

The SME definition is based on the 2003/ 361 recommendation

Smart, Modern, Empowering – Inspiration for furture SME politicies,

June 13th 2024, 50th meeting of the EU

Network of SME Envoys

To define the financial and employee thresholds for a harmonised definition of Mid-Caps the Commission should

realise an in-depth consultation and impact assessment

kom (2025) 0503 - Endeligt svar på spørgsmål 1: Spm. om non-papers eller positionspapirer vedr. sagerne om forenklingspakke IV

caps, to ensure that existing and future regulations are proportionate for this category of company.

For example, with a logic of progressive implementation where these mid-sized companies could

benefit from relevant exemptions already provided for SMEs in regulations.

It is crucial to support the development of mid-caps, as they represent a significant proportion of

dynamic innovative European companies and highly contribute to territorial development and the

twin transition

In line with our aim to digitalise and automate procedures above, as a solution, we support the

current Europe-wide networking of national transparency registers and of collection bodies related

to the European Single Access Point (ESAP), with the aim of giving digital access to companies'

financial and sustainability-related information, as well as on investment products. This coincides

with the current development of a French digital platform enabling companies to prepare and

submit their sustainability report

. Collecting company financial and sustainability data on a

European register would reduce asymmetrical information, thus improving markets efficiency,

particularly with a view to better target sustainable investments.

Based on the ORBIS database to assess the mid-caps segment, there are around 49,000 mid-caps in the European

Union, from which 31,000 are small midcaps and 18,000 large mid-caps. According to a 2022 Commission report, Mid-

caps account for around 13% of total employment and 17% of total turnover in 2019 in the European Union (see :

https://op.europa.eu/en/publication-detail/-/publication/ad5fdad5-6a33-11ed-b14f-01aa75ed71a1/language-en)

For more information, see website: https://portail-rse.beta.gouv.fr