Position papers
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EAPB comments on the proposed temporary framework- Iran crisis
State aid 17 April 2026The EAPB highly welcomes the EC proposal for a temporary State aid framework in the context of the war on Iran and the resulting surge in energy and fertiliser prices. However, we feel the measures proposed are too limited in scope and time. Recent developments indicate that the current crisis is not limited to a short-term shock but reflects a structural disruption of global energy markets. According to the International Energy Agency (IEA)1, the current geopolitical situation has led to one of the most significant disruptions in global oil supply in recent history, affecting a substantial share of global energy flows and contributing to sustained price volatility.
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EAPB comments on the proposed draft for a new General Block Exemption Regulation (GBER)
State aid 15 April 2026National and regional promotional banks implement targeted support measures on behalf of their owners. To this end, national, regional and often also European funding resources are used. European State aid rules are of essential importance in this context. While the draft revision of the General Block Exemption Regulation (GBER) contains welcome simplifications for practical application, important elements remain unclear or difficult to operationalise in practice.
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EAPB comments on the EC Guarantee Notice
State aid 30 March 2026The Guarantee Notice of 2008 (‘the Notice’) aims to give Member States more detailed guidance about the principles on which the Commission intends to base its interpretation of Articles 87 and 88 and their application to State guarantees. In order to facilitate the assessment of whether the market economy principle is fulfilled, Section 3.2 of the Notice sets out four cumulative conditions, the fulfilment of which will be sufficient to rule out the presence of State aid.
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Consultation on the Affordable Housing Act
Development, State aid 30 March 2026EAPB considers that supply-side measures must be the primary policy response to a housing stress designation. In that sense, we would like to highlight that blended finance is the condition for scale. Europes affordable housing challenge will not be solved by grants alone. Across the Member States in which our members operate, the same pattern repeats: where programmes rely exclusively on grants, delivery is constrained and generates no leverage on private investment.
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Joint Statement AECM-EAPB-ELTI / Shared priorities for accelerating efficient investment under the next Multiannual Financial Framework 2028-2034
State aid 11 March 20264 associations joining forces for a smarter EU budget to unlock EU competitiveness - The European Association of Public Banks (EAPB), together with AECM - European Association of Guarantee Institutions, the European Association of Long-Term Investors (ELTI), and NEFI, has issued a joint statement on the next Multiannual Financial Framework (2028–2034) proposed by the European Commission.
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