Annexes to COM(2023)535 - SME Relief Package

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This page contains a limited version of this dossier in the EU Monitor.

dossier COM(2023)535 - SME Relief Package.
document COM(2023)535
date September 12, 2023
agreements with financial intermediaries as of 2025, as the resources allocated to guarantees will have been fully used by then.

The Commission has proposed as part of the Strategic Technologies for Europe Platform (STEP)64 to increase the EU guarantee available by 7.5 billion euro through a dedicated STEP window of InvestEU. Once STEP is approved by the co-legislators, the Commission will strive for quick implementation of additional resources allocated to InvestEU, for the benefit of SMEs.

Member States can play a key role by allocating additional resources to InvestEU from , the Recovery and Resilience Facility (RRF) or from national budgets, as well as to make use of the existing transfer possibilities under shared management funds, to boost investment in their country.

In the context of the STEP proposal, the Commission presented several avenues to make the use of such resources easier for Member States and to increase the amount of InvestEU-backed financing to SMEs, notably through the clarification of State aid aspects with regards to all resource transfers as well as the application of ‘do no significant harm’ aspects65.

Where a Member State decides to allocate resources to the InvestEU Member State compartment to implement an existing InvestEU financial product developed for the EU compartment by an International Financial Institution as an implementing partner, such as the EIB Group or the European Bank for Reconstruction and Development (EBRD), this does not in itself entail State aid, as further explained by the Commission in the STEP proposal66. Such possible resource transfers (from shared management, RRF or national budgets) are therefore a quick, easy and optional mechanism available for Member States to channel much-needed finance to SMEs without reporting burdens beyond those required by InvestEU. To date, a number of Member States have made use of this transfer possibility. Given the high market demand, Member States that have not yet made a contribution are encouraged to do so through the InvestEU Member State compartment, in order to support the implementation of financial products for SMEs in their Member State. The Commission will follow the progress of implementation under the SME window together with the network of SME Envoys.

Furthermore, Member States and regions can establish financial instruments co-funded by EU shared management programmes to channel EU resources into various financial products, including loans, guarantees, equity, and other risk-bearing mechanisms. Such support can directly help SMEs. To facilitate this process, the Commission’s fi-compass67 platform provides resources, including general information, guidance, practical tools, and learning opportunities, guiding managing authorities on utilising financial instruments under each of the EU shared management Funds.

The Commission will:

- Action 11: encourage Member States, through the relevant InvestEU governance structure, to allocate additional resources to InvestEU national compartments and facilitate RRF contributions to InvestEU by providing additional guidance on the application of the ‘do no significant harm’ principle by October 2023.


Export credit agencies (ECAs) play a fundamental role in supporting companies in international trade. A more coordinated approach between EU Member States’ export credits and EU-level financing tools is starting to take place and should be further strengthened. As a result of the Russian war of aggression against Ukraine, the majority of EU ECAs suspended their risk coverage for Ukraine, thereby having a negative impact on the ability of EU companies to export to Ukraine. A pilot facility of roughly 300 million euro in the course of 2024 under the SME window of InvestEU will allow Export Credit Agencies to resume their business with regard to Ukraine. The pilot facility is expected to improve the competitiveness of European SMEs by establishing stronger ties with Ukraine, allowing to support several hundred million euro in new exports.

The Commission will:

- Action 12: work with the EIF towards setting up in the course of 2024 a pilot facility to allow Export Credit Agencies to support SMEs in trading with Ukraine.


As part of the wider Capital Markets Union (CMU) initiative68, the creation of SME growth markets, pan-European venture capital funds and crowdfunding have improved access to finance for SMEs. The recent political agreement on the European Single Access Point will make companies, large and small, more visible to investors, while the revised rules for the European long term investment funds regulation and alternative investment funds will enlarge the pool of funding available to SMEs. The Listing Act proposals69 aim to foster access to finance on public markets for companies, including SMEs, by cutting red tape, streamlining rules and allowing owners to retain decision-making powers after the listing of their companies. A high level of ambition for the Listing Act proposals is key to ensure that high-growth companies continue to develop and create jobs in the EU. In order to give SMEs better access to market-based sources of funding and equity capital, a swift adoption of the legislative proposals under the 2020 CMU Action Plan and further discussions on the future development of the CMU, notably in the Eurogroup, will be important.

Another avenue to support SMEs is the European Innovation Council (EIC) which is the leading EU instrument for providing blended finance (grants and equity or quasi-equity) to fast growing start-ups and SMEs that are pursuing breakthrough innovations. The EIC Fund provides equity funding ranging from 0.5 million to 15 million euro equity funding to such companies, leveraging a budget of 10 billion euro to crowd in 30 to 50 billion euro from private investors. For companies that require follow-on financing rounds or larger investment amounts, the Commission’s STEP proposal foresees an additional budget of 2.63 billion euro to enable the EIC Fund to provide unprecedented equity investments ranging between 15 and 50 million euro in technologies of strategic importance for Europe. By generating additional private investments, this can lead to 13 billion euro of fresh equity support to non-bankable SMEs and small mid-caps.

The Commission will also help SMEs with energy efficiency measures (ranging from energy audits to technologies and trainings), by making available 10 million euro from the Single Market Programme through the Enterprise Europe Network by open calls.



3. Public procurement

Easier access to public procurement markets can help SMEs unlock their potential with a positive impact on growth and on economic recovery. A substantial part of public investment is spent through public procurement, representing 14 % of the EU GDP. Yet, SMEs have difficulties finding access to procurement. The Commission has presented initiatives that facilitate the access of companies including SMEs to public procurement, also cross-border70. The aim is to increase the SME share of public procurement in line with their overall weight in the economy. To improve the participation of SMEs in public procurement, it will be important to promote the use of standardised provisions and clauses in procurement documents, especially for low-risk or low-value contracts, making it easier for SMEs to handle tender documents. Practices that improve SME involvement should be promoted, such as the use of conditions suitable for SMEs (more favourable financial qualifications and payment terms).

The Commission will:

- Action 13: promote the use of standardised procurement provisions and conditions suitable for SMEs to improve the participation of SMEs in public procurement.



4. Making it easier for SMEs to access sustainable finance

SMEs play an important role in helping Europe achieve its climate neutrality goals and other environmental goals71. Raising finance for SMEs’ sustainability transition, while minimising administrative burden is therefore key. To realise their full potential towards the transition to a sustainable economy, SMEs need in particular (1) a simple and standardised framework to report on ESG (Environmental – Social – Governance) issues; and (2) financial institutions that support them in their efforts to transition to a sustainable business.

Despite the measures already put in place to address their needs72, SMEs find it difficult to obtain funding for their green projects. SMEs, with the exception of listed SMEs, are formally not subject to the requirements of the EU sustainable finance framework. However, the Commission is aware that these SMEs face increasing information requests for sustainability information by their financial and value chain partners, often in a non-standardised format. In this light, the Commission recognises concerns from SMEs about trickledown effects of these new rules on sustainability reporting.

The Commission is taking action to address these concerns. First, the Commission has encouraged73 large corporate and financial intermediaries to apply the principle of proportionality when engaging with SMEs and to exercise restraint when requesting information from SME value chain partners. It also puts forward specific guidance, including voluntary tools that SMEs can use to access transition finance.

Simplified reporting standards for listed SMEs are under development by the European Financial Reporting Advisory Group (EFRAG). The Commission will ensure that these standards for listed SMEs are proportionate. The standards will limit the information that listed SMEs in the scope of CSRD are required to report. They will also provide a legal limit to the information that European Sustainability Reporting Standards can require large companies to obtain from SMEs in their value chain, and hence limit the trickledown effects. This is an important safeguard from the CSRD to limit the indirect impact on SMEs of value chain reporting requirements imposed on large business. The Commission will seek to ensure, in the ongoing negotiations on the Corporate Sustainability Due Diligence Directive, that these safeguards are carried over in that context. In addition, EFRAG will develop a voluntary standard for non-listed SMEs. SMEs can use this to standardise the sustainability information they wish to report, creating better opportunities to obtain green financing and thus facilitating the transition to a sustainable economy.

User-friendly tools, information and knowledge-sharing, in cooperation with industry stakeholders, will help SMEs navigate the EU’s sustainable finance framework. In particular, simplified approaches, developed together with the Platform on Sustainable Finance, should allow non-listed SMEs to benefit from the use of the taxonomy.

In addition, financial institutions need to support SMEs in their efforts to transition to a sustainable business. This requires a better integration of green SME finance in the business models of banks. There is a need to define the concept of green loans and to set standards for green loans at EU level to enhance their uptake. The inclusion of such loans to SMEs in the numerator of the Green Asset Ratio of banks should, for example, give more visibility to green SME lending and encourage financial institutions to provide sustainable finance to SMEs.

Based on the results of various on-going Commission studies on SMEs and taxonomy reporting/sustainable finance, the Commission will:

- Action 14: ensure that SMEs have a simple and standardised framework to report on ESG issues, by limiting the risk of disclosure requirements trickling down on non-listed SMEs in the value chain of undertakings in the scope of CSRD, and ensuring the rapid delivery of voluntary standards for non-listed SMEs.
- Action 15: encourage financial institutions to include green SME financing in their business models by:

a. working towards a standard or a definition of green loans notably for SMEs based on upcoming advice by the European Banking Authority74;
b. assessing an SME-friendly adaptation of the Green Asset Ratio to be considered in a future update of the Taxonomy Disclosures Delegated Act.


3. Enabling access to skilled staff

The way SMEs and their workers learn, take part in society, and lead their everyday business is changing with technological developments, global and demographic challenges. SMEs need access to a skilled workforce to deal with these changes and to ensure their resilience while contributing to society, productivity and innovation.

The Commission is building on the European Skills Agenda75 to help Member States ensure that 60% of all working-age adults participate in training programmes each year, in line with the target set by the European Pillar of Social Right action plan76. The European Year of Skills and the unprecedented EU financial resources available for skills development during the MFF 2021-27 programming period, in particular an estimated 65 billion euro from the Recovery and Resilience Facility and the European Social Fund Plus, also presents a unique opportunity to accelerate actions that can benefit SMEs’ access to a deep and diverse pool of skills, such as the proposals on digital education and skills77. In that sense, the pilot on the European Digital Skills Certificate78, in cooperation with Member States and stakeholders, will contribute to enhance transparency and recognition of digital skills, facilitating access by SMEs to the talent they need for the digital transition.

As part of the modernisation of vocational education and training (VET) systems79, the EU is also supporting centres of vocational excellence80 to develop local ‘skills ecosystems’ from advanced manufacturing to artificial intelligence, to water technology and urban greening. They work closely with businesses including SMEs, and contribute to regional development, entrepreneurship, innovation, and smart specialisation strategies. The European Alliance for Apprenticeships supports the promotion of more and better apprenticeships across the EU, as effective learning pathways to get the skilled workers companies, in particular SMEs, need.

Within the EU Pact for Skills81, 18 Large-scale Skills Partnerships (LSPs) covering all industrial ecosystems work towards the identification of skills needs and the roll-out of training in enterprises and their supply chains to up- and reskill 10 million workers by 2030. SMEs are actively involved in all LSPs directly, as individual members and indirectly through sectoral network organisations. The partnering up with other players, such as social partners, and networks under the LSPs gives them access to training programmes, content, and material that otherwise they would often not have given their limited size and resources.

The Enterprise Europe Network plays an important role in providing training to SMEs to help them comply with new requirements, to seize the opportunities of measures like the Net Zero Industrial Act or Critical Raw Materials Act and deal with the implications of Green Deal and sustainability legislation, such as the Directive on corporate sustainability due diligence.

Entrepreneurial skills are key to help existing entrepreneurs grow their business and to encourage more people to take up entrepreneurship as a career. To empower women to become entrepreneurs, the Commission has been pursuing awareness-raising activities coupled with training, mentoring, and coaching and improving women entrepreneurs’ access to finance and business networks. For example, Erasmus for Young Entrepreneurs82 has supported more than 9,000 women entrepreneurs and Women TechEU83 has offered funding for companies founded by women with a budget exceeding 10 million euro. However, further work is necessary to unlock the full entrepreneurial potential of women, young people and groups at risk of exclusion.

Finally, processes also need to become easier for SMEs to attract talent from abroad. The Commission will propose later this year a package on maximising the potential of talent mobility that will include a legislative proposal on establishing an EU Talent Pool and an initiative to work with Member States to facilitate the faster recognition of professional qualifications of third country nationals, including through partnerships with third countries, to improve recruitment and job matching.

The Commission will:

- Action 16: present a proposal to establish an EU Talent Pool and an initiative to improve the recognition of qualifications and skills of third country nationals to help skills gaps in the EU labour market – by Q4 2023.
- Action 17: work with groups whose untapped entrepreneurial potential remains high, such as women, young people and persons with disabilities, through awareness, mentoring and coaching campaigns.


4. Supporting SMEs throughout their entire business life cycle

1. Starting a new business

Since the review of the Small Business Act84, the Commission has been working with Member States to reduce the start-up time for new enterprises. The 2016 Start-up and Scale-up Initiative85 included a range of actions to make it more attractive for entrepreneurs to set up a business and expand it in Europe. The Commission is also encouraging Member States to foster the creation of start-ups by implementing the principles and best practices outlined in the declaration on the EU Startup Nations Standard of Excellence86, such as:

- facilitating the creation of new legal entities for start-ups, both online and offline, within minimal time and at minimal costs, including making it possible to submit online administrative documents for the creation of a start-up or subsidiary in other Member States87

- setting up a start-up fast-lane (including a market access helpdesk) through an online one-stop shop that provides full information about national administrative requirements and funding opportunities, to be linked to the Single Digital Gateway;

- supporting diversity and inclusion, also in line with the action plan for the social economy88.



2. Growing the business

The measures in this communication will allow SMEs to compete and grow. SMEs are currently defined as companies with under 250 employees, combined with an annual turnover up to 50 million euro or a balance sheet total up to 43 million. These thresholds were established in 2003. While twenty years later the vast majority of companies remain covered by the SME definition, some companies outgrow the definition and become so-called mid-cap companies.

In 2021, the Commission evaluated the SME definition and concluded that it remained relevant (with the average turnover of EU SME remaining well below the threshold)89. This evaluation was carried out on the basis of 2018 data and could not reflect the impacts of the pandemic, war in Ukraine and the energy crisis, which have shaken the EU’s economy since then, and in particular have driven a significant surge in inflation that is only gradually coming down. Moreover, in light of current and future economic challenges – from digitalisation to demographic change – it may be appropriate to give greater recognition to the productivity gains over the past two decades, by taking them into account in defining the upper bounds of the SME status.

The 2021 evaluation also recognised the need to “look into the challenges that companies meet once they have ‘outgrown’ the SME-phase”90. For example, there may be threshold effects if the benefits of different measures in favour of SMEs are all lost in the event that a growing company exceeds one of those parameters.

A recent Commission study revealed the essential role of mid-caps in the EU economy91: small (250-499 employees) and large mid-caps (500-1499 employees) together account for more than 13% of overall employment in the European non-financial business sector. The share of mid-cap firms is particularly high in industrial ecosystems that are key to the EU’s competitiveness and technological sovereignty: electronics, aerospace and defence, energy, energy-intensive industries, and health.

Various funding schemes for risk finance and scaling-up approved by the European Commission are available to support their dynamic growth process and to address their funding gap. The Guidelines on State aid to promote risk finance investments contain a definition for small mid-caps and allow support under certain conditions to these companies. The Commission also makes it possible for Member States to support mid-cap companies under the Temporary Crisis and Transition Framework92 and the revised General Block Exemption Regulation93.

Small mid-caps usually grow faster, are more innovative and deal better with digitalisation than SMEs, yet still face certain challenges such as the lack of skilled employees or administrative burden. Statistical data on small mid-caps is limited and a coherent approach to support the growth of small mid-cap companies is missing.

The Commission will:

- Action 18: be attentive to the needs of companies that outgrow the thresholds of the SME definition, as well as the broader range of small mid-cap companies, and will, by the end of 2023:


a. analyse the impact of high inflation and longer-run increases in productivity, as well as the interaction with possible additional measures for mid-caps, to raise - when justified - the financial thresholds of the current SME definition;
b. develop a harmonised definition for small mid-cap companies;
c. thereafter, take actions necessary to reflect a revised SME definition in relevant legislative acts, and
d. build a dataset based on the small mid-cap definition and assess possible measures to support these companies in their growth (including potential application in adapted form of certain measures favouring SMEs).




3. Transferring the business, preventing insolvency and giving entrepreneurs a second chance

Successful business transfers benefit Europe’s economy and its social fabric, avoiding job losses and safeguarding economic activity. The Commission Recommendation on business transfers, addressing key legal, fiscal and administrative aspects of business transfers, remains valid today.94 The Commission has been promoting best practices in business transfers developed either under several EU-funded projects95 or by other stakeholders undertaking work in the area. In 2021 the Commission carried out a study on improving the evidence base on business transfers96. In addition, in its proposal for a Council Recommendation on developing social economy framework conditions97, the Commission recommended Member States to ensure an enabling framework for business transfers to employees to form worker cooperatives. Given the importance of business transfers, the Commission is prepared to take stock of recent developments in Member States.

The Early Warning Europe Mentor Academy98 will develop an online learning programme for mentors, who will be able to better support companies at risk of insolvency and help business owners transfer their business to the next generation.

Finally, since approximately 50% of new businesses fail during their first five years99, the Commission’s insolvency policy supports entrepreneurs who have faced bankruptcy to ensure that they can quickly get a second chance. The Directive on restructuring and insolvency aims to prevent bankruptcy and help insolvent businesses to get back on their feet. By mid-2026, the Commission will report on the application and impact of the Directive’s provisions. Additionally, in 2022, as part of the Capital Markets Union, the Commission proposed a Directive on harmonising certain aspects of insolvency law100. Its most innovative feature concerns the introduction of a simplified, swift, and cost-effective winding-up procedure for microenterprises. The Commission encourages the co-legislator to make urgent progress on this proposal. This is crucial to ensure more efficient insolvency proceedings, and therefore an increasing number of cross-border investments, including for SMEs.

The Commission will:

- Action 19: assess framework conditions for business transfers in Member States together with the network of SME Envoys – by Q2 2024.

4. Conclusions

SMEs continue to navigate a very uncertain economic environment. Declining but stubborn levels of inflation will continue to strain added value and employment, while geopolitical uncertainty will keep many supply chains tight.

Besides funding support, including the massive effort from the Commission with a total of approximately 200 billion euro until 2027, it is therefore necessary to step up policy support for SMEs, building on the actions put forward in this Communication. These actions all revolve around the three main operational challenges for SMEs – administrative burden, finance and skills – with the aim to achieve very concrete goals: providing an enabling regulatory framework, reducing reporting requirements, simplifying taxes, fostering liquidity, improving access to finance, providing SMEs with the right skills and supporting them throughout their life cycle.

As recalled by the Commission’s SME Strategy101, effective relief and support to SMEs depend on a concerted effort and a strong partnership among all actors – EU institutions, national, regional and local authorities, SMEs, large companies, social partners, civil society and investors. In particular, the Commission invites Member States to apply the ‘Think Small First’ principle on a national, regional and local level.

As far as the Commission is concerned, all possible levers that can make the life of SMEs easier and clearer must be activated. Delivering short-term relief, laying the groundwork for their long-term competitiveness and resilience, and fostering a fair and SME-friendly business environment are at the heart of the Commission’s approach.

1 SME Performance Review 2023, https://single-market-economy.ec.europa.eu/smes/sme-strategy/sme-performance-review_en.

2 Flash Eurobarometer 486, SMEs, start-ups, scale-ups and entrepreneurship, September 2020, https://europa.eu/eurobarometer/surveys/detail/2244.

3 Productivity in SMEs and large firms, OECD, 2021, https://www.oecd-ilibrary.org/sites/54337c24-en/index.html?itemId=/content/component/54337c24-en.

4 Flash Eurobarometer 486, SMEs, start-ups, scale-ups and entrepreneurship, September 2020, https://europa.eu/eurobarometer/surveys/detail/2244.

5 Some 89% of SMEs are already taking action to be more resource efficient, Flash Eurobarometer 498, SMEs, resource efficiency and green markets, March 2022, https://europa.eu/eurobarometer/surveys/detail/2287.

6 COM (2020) 103 final.

7 COM (2021) 250 final.

8 https://ec.europa.eu/economy_finance/recovery-and-resilience-scoreboard/smart.html.

9 RRF Scoreboard, pillar tagging methodology, ‘Support to SMEs’ as primary or secondary policy area.

10 This includes 43 billion euro under the 2021-2027 multiannual financial framework and a total of 22 billion euro under Cohesion Policy’s Coronavirus Response Investment Initiatives and REACT-EU.

11 The COVID-19 State aid Temporary Framework; the Commission Temporary Crisis Framework for State Aid measures to support the economy following the aggression against Ukraine by Russia; the amended general block exemption rules (Commission Regulation (EU) 2023/1315 ; the proposed revision of the Regulation on de minimis aid, https://competition-policy.ec.europa.eu/public-consultations/2022-de-minimis_en.

12 Within the Enterprise Europe Network.

13 https://single-market-economy.ec.europa.eu/industry/transition-pathways_en.

14 COM (2023) 148 final. The proposal would allow Member States to apply price controls to SMEs as well as consumers during energy crises.

15 COM (2022) 68 final.

16 The CASSINI investment facility is injecting nearly 700 million euro into venture capital funds investing in space, mobilising at least 1.5 billion euro total risk capital for start-ups and SMEs.

17 SMEs are also benefiting from EUR 1 billion financing under the Single Market Programme, earmarked to support strengthening SMEs’ competitiveness and their internationalisation and channelling support to SMEs via SME intermediaries, for instance through the Enterprise Europe Network and Euroclusters, facilitated by the European Cluster Collaboration Platform.

18 All new EU trade agreements include dedicated SME chapters which include provisions to help SMEs grow their business with and in foreign markets. A dedicated complaint mechanism (https://trade.ec.europa.eu/access-to-markets/en/content/single-entry-point-0) allows SMEs to report barriers when accessing foreign markets.

19 https://commission.europa.eu/strategy-and-policy/priorities-2019-2024/stronger-europe-world/global-gateway_en.

20 COM (2020) 760. The Action Plan helps companies, especially SMEs, to make the most of their inventions and creations.

21 Regulation (EU) 2019/1150 (‘the P2B Regulation’) sets out rules for creating a fair, transparent and predictable business environment in particular for smaller businesses and traders on online platforms.

22 SME Performance Review 2023, https://single-market-economy.ec.europa.eu/smes/sme-strategy/sme-performance-review_en.

23 https://single-market-economy.ec.europa.eu/industry/transition-pathways_en.

24 Flash Eurobarometer 486, SMEs, start-ups, scale-ups and entrepreneurship, September 2020, https://europa.eu/eurobarometer/surveys/detail/2244.

25 Survey on the Access to Finance of Enterprises, SAFE, December 2022, https://single-market-economy.ec.europa.eu/access-finance/data-and-surveys-safe_en.

26 Ibid.

27 Ibid.

28 Flash Eurobarometer 529 on European Year of Skills: Skills shortages, recruitment and retention strategies in small and medium-sized enterprises (published in September 2023).

29 Council Directive (EU) 2020/285.

30 COM (2021) 219 final and https://commission.europa.eu/law/law-making-process/planning-and-proposing-law/better-regulation/better-regulation-guidelines-and-toolbox_en.

31 The Fit for Future Platform is a high-level expert group that helps the Commission in its efforts to simplify EU laws and to reduce related unnecessary costs, https://commission.europa.eu/law/law-making-process/evaluating-and-improving-existing-laws/refit-making-eu-law-simpler-less-costly-and-future-proof/fit-future-platform-f4f_en.

32 This also follows the proposals of the Conference on the Future of Europe in 2022 to boost the competitiveness of SMEs and reinforce the SME test (proposals 12, 17 and 35).

33 https://ec.europa.eu/docsroom/documents/53934.

34 A group of Member States’ high-level experts who advise the Commission on all aspects of SME policy, https://single-market-economy.ec.europa.eu/smes/sme-strategy/sme-envoys-network_en.

35 These include also members of RegWatchEurope, comprising oversight bodies of The Netherlands, Finland, Sweden, Germany, Denmark, Norway, Czech Republic, United Kingdom.

36 The OECD Regulatory Policy Outlook 2021 ranks the European Commission’s better regulation system as the most advanced on stakeholders’ consultations and evaluations and in third place on impact assessments

37 Annual Burden Survey 2022 – The European Union’s efforts to simplify legislation, September 2023.

38 2020/C 447/01.

39 SWD (2023) 277 final.

40 COM (2021) 206 final.

41 COM (2023) 442 final.

42 https://ec.europa.eu/info/law/better-regulation/have-your-say-simplify_en

43 The Think Small First principle was defined in the Small Business Act (SBA) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52008DC0394 and further developed in the SBA review https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A52011DC0078.

44 Other bodies relevant for SMEs such as the European Institute of Innovation and Technology.

45 Good practices include the digital risk assessment tool developed by the European Agency for Safety and Health at Work, the Cybersecurity Maturity Assessment for SMEs Tool of the European Union Agency for Cybersecurity or the portal dedicated to entrepreneurs of the European Union Intellectual Property Office.

46 COM (2018)1724. Accessible through the Your Europe web portal: https://europa.eu/youreurope/.

47 COM (2023) 501 final.

48 COM (2023) 177 final.

49 See the related impact assessment, SWD (2023) 178 final.

50 BRIS connects all national registers and makes information about 20 million of companies and branches publicly available.

51 https://ec.europa.eu/solvit/what-is-solvit/index_en.htm; in March 2023, the Commission proposed a benchmark for SOLVIT to solve a minimum of 90% of the cases within 12 months in each Member State.

52 Decision (EU) 2022/2481 establishing the Digital Decade Policy Programme 2030.

53 https://digital-strategy.ec.europa.eu/en/activities/testing-and-experimentation-facilities.

54 COM(2023) 168 final

55 If well designed, the costs of reporting requirements are largely offset by the benefits they bring for example by monitoring air pollution or supervising the financial sector and maintaining financial stability. Such requirements are not only included in primary legislation, but also in implementing or delegated acts or even operational arrangements.

56 Review of the EU’s bank crisis management and deposit insurance framework; Implementing Technical Standards on reporting and disclosures by insurance and reinsurance undertakings; Proposal for a Regulation of the EP and Council amending Regulation (EC) No 223/2009 on European statistics; Economic Governance Review-simplification of reporting; Proposal for a Regulation of the European Parliament and of the Council on detergents and surfactants; Union Customs Code; General pharmaceutical legal framework; several initiatives either in preparation or proposed in transport area, such as the Directive on combined transport, a harmonised legal framework for railway capacity and traffic management and the abolition of the rail freight corridors as part of the greening freight package, the revisions of the Weights and Dimensions (see greening freight package) as well as of the Port State Control Directives, etc.

57 The first set of European Sustainability Reporting Standards (COM (2023) 5303 final) significantly reduced the reporting burden compared to the technical advice received from EFRAG. The Commission extended the principle of reporting only material information, introduced a number of phase-ins, and made certain disclosure requirements voluntary.

58 Article 8 of Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment and amending Regulation (EU) 2019/2088 (OJ L 198, 22.6.2020, p. 13).

59 For more details see the impact assessment report on late payments, published in parallel to this communication.

60 With these aims in mind, the Commission recently launched several infringement procedures in the area of late payments, https://ec.europa.eu/commission/presscorner/detail/en/inf_23_1808.

61 This would include funding available for SMEs through the following instruments (Commission services estimates): InvestEU (EUR 6.9 billion from the dedicated SME window and an additional EUR 0.82 billion via the Social Investment and Skills policy window, Recovery and Resilience Facility (RRF) (EUR 45.2 billion), EIC (EUR 10 billion), Cassini (EUR 0.7 billion), Single Market Programme SME Pillar (EUR 1 billion), Intellectual property SME fund (EUR 0.08 billion), Digital Europe Programme (EUR 0.7 billion), European Defence Fund (over EUR 0.2 billion), European Space programme (EUR 1 billion), Secure Connectivity - IRIS2 (EUR 0.72 billion), Horizon Europe (EUR 15 billion), Just Transition Fund (EUR 4.8 billion), Creative Europe (EUR 2.3 billion), European Regional Development Fund (EUR 38.71 billion), Cohesion Policy’s Coronavirus Response Investment Initiatives and REACT-EU (EUR 22 billion), European Agricultural Fund for Rural Development (EUR 30 billion), Cohesion Fund (EUR 0.05 billion), European Maritime, Fisheries and Aquaculture Fund (EUR 2.52 billion), Life programme (EUR 0.13 billion), Connecting Europe Facility (EUR 0.2 billion), Innovation Fund (EUR 0.17 billion), European Social Fund Plus (EUR 0.82 billion), New European Innovation Agenda in the area of access to finance (EUR 45 billion) for deep-tech startups, SMEs and small mid-caps.

62 Of the various financial instruments available for SMEs during the previous multiannual financial framework (2014-2020 period), the COSME Loan Guarantee Facility alone triggered EUR 68 billion in financing to nearly 900 000 SMEs, helping to create or maintain more than 4 million jobs.

63 https://single-market-economy.ec.europa.eu/access-finance/investeu/investeu-fund-sme-window_en.

64 COM (2023) 335 final.

65 Through an amendment of the technical guidance on the application of ‘do no significant harm’ under Regulation (EU) 2021/241. This will also facilitate the allocation of resources to InvestEU from the RRF.

66 This is without prejudice to the obligation of EU financial instruments and budgetary guarantees to be consistent with State aid rules pursuant to Article 209(2)(c) of the Financial Regulation.

67 https://www.fi-compass.eu.

68 https://ec.europa.eu/commission/presscorner/detail/en/ip_22_7348.

69 COM (2022) 760 final.

70 COM (2017) 572 final. In 2020 and 2021 the Commission published two studies on SMEs’ participation in public procurement: https://op.europa.eu/en/publication-detail/-/publication/eec8227c-ecc4-11ea-b3c6-01aa75ed71a1 and https://ec.europa.eu/docsroom/documents/46111/attachments/1/translations/en/renditions/native. Two brochures have been published in 2023 to foster the participation of startups in public procurement: https://ec.europa.eu/docsroom/documents/54254, https://ec.europa.eu/docsroom/documents/54276.

71 Activity Report 2023 of the OECD Platform on Financing SMEs for Sustainability (page 6), https://www.oecd.org/cfe/smes/SME%20activity-report-2023.pdf.

72 Most recently through the Commission’s Communication “A sustainable finance framework that works on the ground” of June 2023, COM (2023) 317 final, that notably pleads for the inclusiveness, usability and proportionality of such a framework to enable SMEs to raise finance for their sustainability transition.

73 Commission’s Recommendation (EU) 2023/1425 on facilitating finance for the transition to a sustainable economy.

74 The Commission’s call for advice on green loans and mortgages, issued to the EBA in November 2022.

75 COM (2020) 274 final.

76 European Pillar of Social Rights Action Plan, endorsed by heads of state and government in 2020, https://ec.europa.eu/social/main.jsp?catId=1607&langId=en.

77 COM (2023) 205 final and COM (2023) 206 final.

78 https://education.ec.europa.eu/focus-topics/digital-education/action-plan/action-9?.

79 Council Recommendation 2020/C 417/01.

80 https://ec.europa.eu/social/main.jsp?catId=1501.

81 The Pact also encourages partnerships at regional level to support the up and re-skilling of the workforce, including those in SMEs. According to survey results, since its launch in 2020, Pact members’ concerted efforts have reached an estimate of almost two million individuals. In addition, members have made an aggregated investment of close to EUR 160 million into upskilling and reskilling activities. https://pact-for-skills.ec.europa.eu/index_en.

82 https://www.erasmus-entrepreneurs.eu/.

83 https://eismea.ec.europa.eu/programmes/european-innovation-ecosystems/women-techeu_en.

84 COM (2011) 78 final.

85 COM (2016) 733 final.

86 https://startupnationsstandard.eu/files/SNS-declaration.pdf.

87 In line with Directive (EU) 2019/1151 and the proposal COM (2023) 177 final.

88 COM (2021) 778 final.

89 Latest evaluation COM SWD (2021) 280 final.

90 SWD (2021) 280 final.

91 Study to map, measure and portray the EU mid-cap landscape, 2022, https://op.europa.eu/en/publication- detail/-/publication/ad5fdad5-6a33-11ed-b14f-01aa75ed71a1/language-en/format-PDF/source-277396461.

92 COM (2023) 1711.

93 Commission Regulation (EU) 2023/1315.

94 COM 94/1069/EC. Notably, the Commission proposed targeted tax incentives, such as conditional reduction of inheritance and gift taxes in family successions, conditional tax deferrals or reinvestment tax relief, or specific tax incentives to encourage the transfer of the company to employees – with the objective of ensuring that transfer taxes do not endanger the survival of the business.

95 https://single-market-economy.ec.europa.eu/smes/supporting-entrepreneurship/transfer-businesses_en.

96 https://op.europa.eu/en/publication-detail/-/publication/fdfae129-69bb-11eb-aeb5-01aa75ed71a1/language-en/format-PDF/source-190448642.

97 COM (2023) 316 final.

98 https://www.earlywarningeurope.eu/mentor-academy.

99 COM (2012) 795 final.

100 COM (2022) 702 final.

101 COM (2020) 103 final.

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