Position papers

  • EAPB position on consultation on rescue and restructuring guidelines

    State aid 13 November 2025

    European promotional banks carry out targeted promotional measures on behalf of their owners – central and regional governments and municipalities. National, regional, and often additional European funding is used for this purpose. European state aid rules are of essential importance in this context. Against this background, we would like to make a few suggestions and point out some significant shortcomings in the context of the consultation on the revision of the rescue and restructuring guidelines for companies in difficulty. Our primary concern is the definition of undertakings in difficulty (UiD), which should reflect economic reality and be simplified.

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  • EAPB Comment Letter on SGEI Draft Decision

    State aid 4 November 2025

    EAPB highly welcomes the draft for a revised Decision of Services of General Economic Interest (SGEI) which would provide deeply needed clarity and legal certainty to schemes to support affordable housing.  Generally, the proposed amendments provide legal clarity on the possibility to support affordable housing and would help EAPB members to increase their support activities to households in need of housing at affordable conditions.

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  • Joint Letter on Omnibus Taxonomy Delegated Act

    Capital markets, Sustainable finance 4 November 2025

    Clarity is essential to realise the simplification objectives of the Omnibus I initiative on Sustainability and support the competitiveness of financial institutions in the EU. The lack of legal certainty on which Taxonomy reporting rules can be applied is presently undermining the Commission’s simplification and burden relief aims in practice.

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  • EAPB Contribution to the Feedback Period on the MFF

    State aid 15 October 2025
    EAPB welcomes the opportunity to contribute to the European Commission’s feedback period on the proposal for the future Multiannual Financial Framework (MFF). As key implementing partners of EU funds, EAPB members are committed to ensuring that the next MFF delivers on its ambitions and achieves greater efficiency in its funding. 
     
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  • EAPB position paper on simplification

    Banking supervision, Sustainable finance 25 July 2025

    We welcome the European Commission’s simplification agenda, including the recent Omnibus initiatives that aim to reduce administrative burdens across key EU policy areas such as sustainability reporting, due diligence requirements, investment procedures, and the regulatory environment for mid-sized companies. These initiatives are an important first step toward a more coherent, proportionate, and investment-friendly regulatory framework.

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