Position papers

  • Joint Statement AECM-EAPB-ELTI-NEFI / Preserving the simplification gains in the European Parliament’s draft report on the NRP Plans Regulation

    3 June 2026

    The European Association of Guarantee Institutions (AECM), the European Association of Public Banks (EAPB), the European Association of Long-Term Investors (ELTI) and the Network of European Financial Institutions for SMEs (NEFI) welcome the joint BUDG-REGI-AGRI draft report on the proposal for the National and Regional Partnership Plans (NRPP) Regulation, prepared by the co-rapporteurs Karlo Ressler, Andrey Novakov and Elsi Katainen.

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  • EAPB Views on the Markets Infrastructure Package

    Capital markets 7 May 2026

    EAPB welcomes the opportunity to comment on the Markets Infrastructure Package (MIP) tabled by the European Commission under the Savings and Investments Union agenda. 

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  • EAPB comments on the proposed temporary framework- Iran crisis

    State aid 17 April 2026

    The 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 2026

    National 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 2026

    The 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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