OpenLobby.EU
Explore

Accountancy Europe

Accountancy Europe represents 1 million professional accountants, auditors and advisors from 49 organisations across 35 countries, translating their experience to inform European policy debate.

Lobbying Activity

Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque)

16 Jan 2026 · Exchange with Accountancy Europe on a potential initiative to enhance Audit supervision

Meeting with Evelyn Regner (Member of the European Parliament)

16 Dec 2025 · General exchange of views

Accountancy Europe urges simpler EU Taxonomy reporting rules

5 Dec 2025
Topic — The initiative updates technical screening criteria for defining sustainable activities under EU law.
Message — They propose aligning sustainability criteria with existing EU laws to reduce reporting burdens. They also seek clearer guidance on climate risk assessments and the removal of vague terminology.12
Why — Simplified rules would reduce compliance costs and make sustainability data easier to verify.3
Read full response

Meeting with Piotr Serafin (Commissioner) and

10 Nov 2025 · Implementation and Simplification Dialogue on the Review of the EU Anti-Fraud Architecture

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

6 Nov 2025 · EU Omnibus I

Meeting with Raluca Trasca (Head of Unit Taxation and Customs Union) and European Tax Adviser Federation

4 Nov 2025 · Meeting regarding the composition of the VAT Expert Group

Meeting with Martin Merlin (Director Financial Stability, Financial Services and Capital Markets Union) and

21 Oct 2025 · Audit reform, SIU

Accountancy Europe urges targeted digital simplification over broad deregulation

14 Oct 2025
Topic — The Commission's digital omnibus initiative aims to simplify regulations and reduce reporting burdens.
Message — The organization calls for practical simplification that maintains essential rules like the AI Act rather than pursuing point-blank deregulation. They emphasize that transparency and technical standards are necessary to build trust and ensure the legislation's functioning.123
Why — Limiting the scope of existing laws provides their members with greater regulatory certainty.4
Impact — Citizens and businesses lose vital protections if digital markets are left entirely to themselves.56
Read full response

Meeting with Benjamin Angel (Director Taxation and Customs Union)

18 Jul 2025 · Commission welcomed the new CEO of Accountancy Europe – introductory meeting which addressed several topics including their Purpose 2023 project and their wish to offer support to Commission.

Accountancy Europe urges harmonised tax incentives to boost investment

8 Jul 2025
Topic — Creating a European blueprint for savings and investment accounts and products.
Message — The organisation proposes a unified European system for taxing investment funds and pension products to increase market competitiveness. They recommend tax-free status for funds and improved loss-offsetting rules to incentivise riskier investments in small businesses.123
Why — Harmonised rules reduce cross-border complexity for advisors and prevent capital flight to non-EU markets.45
Impact — Lower earners may face increased inequality as tax incentives primarily benefit wealthier investors.67
Read full response

Response to Savings and Investments Union: Directive fostering EU market integration and efficient supervision

4 Jun 2025

Accountancy Europe welcomes the opportunity to respond to the European Commissions Call for Evidence on Regulation fostering EU market integration and efficient supervision, aimed at advancing the development of a Savings and Investments Union (SIU). Please refer to our attached feedback note/pdf for our full recommendations. The European accountancy and audit profession strongly supports the further integration of EU capital markets and the completion of the Banking Union. These initiatives are critical to achieving multiple strategic goals. Europe will require substantial and sustained financing in the coming years to deliver on the green and digital transitions, strengthen defense capabilities, improve competitiveness of companies, pension investments in a time of declining population, expanding SMEs access to finance, and more. Mobilising private capital is essential to complement public funding in meeting these needs. We note that, as part of the SIU initiative, the Commission is exploring different options for more coordinated or harmonised financial market supervision. Each potential approach has its own merits and drawbacks. We therefore urge the Commission to carefully evaluate all options, with a focus on targeted, evidence-based reforms that achieve meaningful improvements without undermining the functioning of capital and financial markets. Please refer to our attached feedback note/pdf for our full recommendations.
Read full response

Meeting with Maria Luís Albuquerque (Commissioner) and

20 May 2025 · CSRD

Meeting with Sven Gentner (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Ernst & Young Core Business Services BV

7 Apr 2025 · Omnibus proposal changes.

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

27 Mar 2025 · Omnibus

Meeting with Bruno Gonçalves (Member of the European Parliament)

27 Mar 2025 · FISC policies

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament)

19 Mar 2025 · Omnibus

Meeting with Pascal Canfin (Member of the European Parliament, Shadow rapporteur) and BlackRock

12 Mar 2025 · Omnibus I

Meeting with Michalis Hadjipantela (Member of the European Parliament)

4 Mar 2025 · Introductory Meeting

Response to Savings and Investments Union

28 Feb 2025

For our full feedback please see the attached document. Accountancy Europe is pleased to provide its contribution to the European Commissions call for evidence on the European Savings and Investment Union (SIU). The reports by Mario Draghi and Enrico Letta clearly identified a mismatch between savings and investments, and businesses struggle to access adequate financing options. As a result, EU citizens risk missing out on potentially higher returns on long-term savings, whilst companies remain dependent on a narrower set of financing options that may not be suitable for their particular needs or profiles. The Commission has already taken concrete steps towards developing the Capital Markets Union (CMU), and achieved significant progress on the Banking Union (BU). Both are essential building blocks for the SIU, with additional development needed in particular on the CMU side. Accountancy Europe fully supports the efforts to create a strong and effective SIU, which is crucially important to help finance Europes strategic priorities and achievement of our sustainability goals. A more integrated SIU will also be key to expanding the financing options available to Europes SMEs and innovative start-ups. Accountancy Europe looks forward to the Commissions upcoming Communication outlining how the EU, Member States, and market participants can work together to advance this initiative. Accountancy Europe looks forward to building on its past and continued commitment to more integrated European capital markets and support the Commissions objectives. As a general principle, further harmonisation, and minimising scope for national adjustments and interpretations of capital market related legislation, is a bare minimum requirement to foster further capital market integration. Some of the initial areas we propose the Commission to investigate include the following: Make use of Regulations rather than Directives for SIU related legislative initiatives. This is necessary to minimise the risk of national divergencies and gold plating. Some national flexibility can be built into Regulations where this is explicitly deemed to be needed Incentivise listing as a viable option for companies looking for financing. Getting listed currently entails significant new administrative burdens for companies, whilst at the same time there is a growing amount of new emerging non-capital market financing options available for innovative start-ups and promising businesses. The Commission should prioritise re-balancing this situation if it is to succeed in creating successful EU capital markets Bolster the capacity of the European Supervisory Authorities (ESAs), by ensuring that they are adequately resourced to enable them to implement and enforce measures in line with their objectives, and engage with stakeholders in a more robust manner Assess where further coordination of supervisory practices might support scaling up pan-European capital markets Consider the need for tax incentives attached to a possible pan-European savings and investment product. Such tangible incentives can significantly foster retail investors and regular citizens interest to invest in their pension savings, thereby also providing a first point of entry into the world of investment for millions and thus contributing to financial education Consider the benefits of a pan-EU credit referral and mediation scheme especially for SMEs whose loan requests have been turned down. This could be, for example, integrated into the ESAP.
Read full response

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

21 Jan 2025 · Simplification

Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque)

20 Jan 2025 · Omnibus package

Meeting with Hanna Anttilainen (Cabinet of Executive Vice-President Stéphane Séjourné), Vincent Hurkens (Cabinet of Executive Vice-President Stéphane Séjourné)

14 Jan 2025 · General presentation of Accountancy Europe and simplification on sustainability reporting

Meeting with Aurore Lalucq (Member of the European Parliament)

18 Dec 2024 · Omnibus/ CSRD-CS3D, Taxation

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament)

10 Dec 2024 · Savings and Investments Union

Meeting with Ilhan Kyuchyuk (Member of the European Parliament) and Video Games Europe

9 Dec 2024 · General presentation on activities and objectives

Meeting with Axel Voss (Member of the European Parliament)

19 Sept 2024 · Corporate Sustainability Due Diligence

Meeting with Martina Dlabajová (Member of the European Parliament)

21 Feb 2024 · Supporting SMEs with sustainability information

Response to Postponement of deadlines within the Accounting Directive for the adoption of certain ESRS

12 Dec 2023

Accountancy Europe strongly supports ECs efforts to transition EUs economy for a sustainable future. Sustainability reporting is one of the many necessary supporting tools to make this ambition a reality. Our suggestions below are intended to reinforce this objective. Equivalence between sustainability reporting frameworks: Article 40a of the Corporate Sustainability Reporting Directive (CSRD) provides the possibility for third-country companies in the CSRD scope to use ESRS equivalent standards to comply with their reporting obligations. The EC should allow these companies (which already adhere to sustainability reporting requirements similar to those outlined in Article 40a, such as TCFD, ISSB, or California bills) to use international standards equivalent to ESRS. We suggest the EC considers the combination of GRI and IFRS sustainability standards as equivalent to the ESRS, for non-EU entities. In doing so, the EC would reciprocate the benefits granted to European companies (e.g., European companies can use IFRS standards for both sustainability and financial reporting in foreign countries). Equivalence of standards facilitates capital and trade flows, a direct benefit for European companies. Failure to reciprocate risks potential retaliation in having these facilitations revoked, which would burden European companies with extensive reporting obligations in the foreign countries they operate in. Sector-specific ESRS: Accountancy Europe welcomes the ECs decision to postpone by 2 years the adoption of the delegated act with sector-specific ESRS as this will allow the necessary time to develop robust standards and for the first batch of twelve standards to settle in. We strongly suggest the EC builds on the experience and knowledge with the first set of ESRS to ensure fit-for purpose sector-specific ESRS, by: following an adequate due process, which underpins the legitimacy of standards developing clear standards that consider stakeholders comments on granularity and complexity building on existing international standards such as GRI and the ISSB (with SASB incorporated). The EC should also clearly instruct EFRAG on these principles as they undertake their work in developing their technical advice with these standards.
Read full response

Accountancy Europe Calls for Simplified EU Reporting Rules

28 Nov 2023
Topic — This consultation targets a 25 percent reduction in EU legislative reporting requirements.
Message — The organization advocates for eliminating redundant national options and harmonizing tax reporting across the EU. They request recognition of international sustainability standards and mandatory international accounting rules for banks.12
Why — Standardized rules would lower compliance costs and remove obstacles for cross-border business operations.3
Impact — National governments would lose the flexibility to maintain specific local reporting requirements and options.4
Read full response

Response to Business in Europe: Framework for Income Taxation (BEFIT)

17 Nov 2023

Accountancy Europe welcomes any initiative to cut administrative burden and encourage SMEs to engage in cross-border trade. HOT will not significantly reduce the requirements for those SMEs looking to set up branches in other Member States, such as the need to appoint a local advisor or accountant to make appropriate registrations, obtain business licenses etc. However, we believe that it will remove some of the tax administration burdens of engaging in cross-border trade. Please see the attached file for our detailed comments and suggestions as to how the current proposal could be made more effective.
Read full response

Meeting with Monika Hohlmeier (Member of the European Parliament, Committee chair)

16 Nov 2023 · Proper allocation and use of all the public financing

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

7 Nov 2023 · Relevant ECON files

Accountancy Europe calls for harmonised liability in tax relief

9 Aug 2023
Topic — A new EU initiative to standardise and simplify withholding tax relief procedures.
Message — The group wants relief at source to be the mandatory default system across Europe. They request that financial intermediaries be protected from liability for incorrect data provided by clients.12
Why — Standardised rules would reduce legal risks and administrative costs for financial professionals.3
Impact — National tax authorities lose the flexibility to maintain their own fragmented refund systems.4
Read full response

Accountancy Europe Urges Alignment of EU and International Sustainability Rules

7 Jul 2023
Topic — Consultation on the first set of European Sustainability Reporting Standards for corporate sustainability reporting.
Message — The organization requests better alignment with international standards to avoid reporting flaws and inconsistencies. They also seek clear legal status for official guidance and better integration with existing finance regulations.12
Why — Alignment reduces the technical complexity and risk for auditors managing multiple conflicting reporting frameworks.3
Impact — Financial market participants face difficulties fulfilling their own disclosure obligations due to reporting data inconsistencies.4
Read full response

Meeting with Beatrice Covassi (Member of the European Parliament) and Fairshare Educational Foundation (ShareAction) and Stichting World Benchmarking Alliance Foundation

5 Jul 2023 · Corporate Sustainability Due Diligence

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

8 Mar 2023 · Corporate Sustainability Due Diligence

Meeting with Luděk Niedermayer (Member of the European Parliament)

25 Jan 2023 · VAT fraud

Meeting with Lucrezia Busa (Cabinet of Commissioner Didier Reynders) and Finance Watch and

17 Jan 2023 · Corporate Sustainability Due Diligence

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Patricia Reilly (Cabinet of Commissioner Mairead Mcguinness)

28 Nov 2022 · CSRD

Response to Sustainable corporate governance

20 May 2022

Accountancy Europe feedback on the EC's Corporate Sustainability Due Diligence proposal: Scope of the supply chain Due diligence should encompass companies posing major risks and not be limited to any specific tier of the supply chain (risk methodology to be determined by EC). Our paper (March 2020) on company categorisation proposes a risk-based approach to categorise companies which better reflects their impacts on the economy, environment and society. While we support the inclusion of third country companies, the scope only represents around 1% of EU companies. The directive should be extended to all publicly listed, and high-risk SMEs (to be defined by EC). To avoid confusion, the scope of similar legislative initiatives would benefit from being coherent. Due Diligence definitions: - Established business relationship (article 1) The EC should more clearly define established business relationship since this new legal concept is unclear for companies who need certainty on how to discharge their due diligence obligations. Logically, these obligations should encompass the entire supply chain. The EC should also consider how civil liability will apply and clarify the extent of companies’ responsibility in the supply chain. - Contractual cascading (article 7) Companies should identify potential adverse impacts in their supply chain and not offload risk via contracts, especially to SMEs. Companies’ code of conducts should clearly state their policies regarding such contractual cascading. To foster compliance and verification, each business partner should comply with the company’s code of conduct, under transparent procedures. Due diligence verification Due diligence verification by independent third parties (statutory auditor or another service provider) is instrumental to strengthen stakeholders’ confidence in the process. Our paper (Jan 2022, attached) shows the supply chain assurance practices by mid-tier accountancy firms. To be credible and effective, such assurance requires high-quality methods, competent professionals following transparent procedures and public supervision. Internal Controls (article 10,11) Companies’ obligation to periodically self-assess their operations is insufficient to ensure compliance. Instead, we propose for companies to establish appropriate internal controls which can support allocation of duties, remediation, and the necessary safeguards. Internal controls should build on existing international frameworks (e.g. COSO framework). Regarding companies’ obligation to publish an annual statement (art 11), the EC should consult with stakeholders, before publishing the delegated acts. Board of Directors: - Companies for combating climate change (article 15) The board should play a central role in deciding on the company’s long-term strategy and impact therefore, depending on national board structures, should be responsible for the design and effective execution of transition plans. Companies need to invest in educating the board on sustainability matters and promote a more diverse members’ background. Variable remuneration should be linked to sustainability matters overall and not just climate (better placed under article 25, directors’ duties). - Directors’ duty of care and overseeing due diligence (article 25,26) The EC needs to clarify the term ‘board’s collective responsibility’ and provide further guidance for implementation. We are in favour of introducing collective responsibility to promote cultural change within the company. However, the EC needs to consider that Member States have different legal interpretations of board responsibility (collective or individual). Civil liability (article 22) We support the proposal introducing civil liability requirements. To ensure clarity when it comes to implementation, Member States should establish additional civil procedural rules, where necessary. The EC should ensure an effective enforcement mechanism to properly implement this provision.
Read full response

Response to Facilitating small and medium sized enterprises’ access to capital

3 Feb 2022

Accountancy Europe welcomes the Commission's efforts to facilitate SME access to capital market financing. We firmly believe that now, even more than before, it is pivotal to ensure a realistic diversity of funding sources for smaller businesses. Even though access to finance may not at the moment be the highest-ranking concern for SMEs, this remains a key success factor for the growth of innovative businesses in Europe. We and our capital market experts are particularly delighted to see in the public consultation and call for evidence on the listing act that the Commission is considering further alleviations to the EU’s SME prospectus framework. As you may know, Accountancy Europe has done extensive work in this area. Already in 2016 we published recommendations for a simplified prospectus for SMEs, which is shorter, cheaper for SMEs to produce using a maximum amount of information already available to them, whilst still providing key information to investors. See our recommendations here: https://www.accountancyeurope.eu/publications/prospectus/ We also published a model prospectus in 2017 based on a real SME. It demonstrates concretely the feasibility of a simplified prospectus format for smaller businesses that want to seek capital market financing. See our model prospectus here: https://www.accountancyeurope.eu/publications/model-simplified-sme-prospectus/ We have also attached the model simplified prospectus to this feedback. In this light, we would like to express our strong support for the Commission's efforts in this area, and call on ambitious and far-reaching reforms to simplify prospectuses for SMEs. In particular, we urge the Commission to carefully consider, item-by-item, what information is genuinely vital for prospectuses, and what could be omitted completely or disclosed elsewhere (for example in ESAP). We remain at your full disposal to support your work to facilitate SMEs’ access to finance. With kindest regards, Johan Barros, Manager, Accountancy Europe
Read full response

Response to Strengthening the quality of corporate reporting and its enforcement

1 Feb 2022

Accountancy Europe commends the European Commission (EC) for this initiative and for adopting a holistic approach to the 3 pillars of corporate reporting: corporate governance & reporting, statutory audit, and their supervision. Our profession is open-minded to change and ready to contribute to the EC’s efforts to enhance the corporate reporting ecosystem. We propose several solutions below, and in more detail in our consultation response. We concur with the EC’s objective to strengthen each pillar, so the ecosystem is better equipped to deal with company failures and minimise their occurrence. The overall framework should become more coherent, ensuring the 3 pillars are complementary and systemically effective in the EU. Any measure taken should aim at providing reliable and timely information to shareholders, investors, and other stakeholders. The EC’s focus on integrating financial and sustainability reporting is paramount. This, supported by the auditor’s involvement in both, provides a more accurate picture of a company. We support developing quality indicators for corporate reporting, statutory audit, and supervision on a multi-stakeholder basis. Corporate governance and reporting Robust corporate governance and reporting should underpin enhancing the auditor’s role in internal controls (including on fraud and going concern) and more informative audit reports. Companies should issue a public statement on the effectiveness of internal controls over financial reporting, focusing on fraud and going concern. All public interest entities (PIEs) should have a separate audit committee and there should be no Member State options on this requirement. The audit committee should have enough members competent in accounting and auditing. In large PIEs, an independent internal audit function and well-established whistleblowing structures should support the audit committee. Audit We would welcome further simplification and harmonisation of the audit rules across Europe, including removing Member State options, for example on prohibited non-audit services. EU legislation and ethical rules already firmly restrict auditors from providing non-audit services to PIE audit clients. To meet stakeholders’ expectations and emerging needs, auditors should continue being allowed to provide services closely linked to financial statements audit and assurance services, for example assurance on sustainability information, to their audit clients. We welcome the EC looking into ways to increase choice and capacity in the PIE audit market. Substantively changing the market structure will take time, as mid-tier audit firms will need to continue investing in the required expertise and capacity to undertake PIE audits. Further evidence is needed on how any potential market opening measure, such as joint audit, would impact audit quality. Supervision of reporting and audit There is merit in harmonising reporting and audit supervisors’ policies and activities to achieve a level playing field embedded in EU legislation. We support robust supervision and enhanced regulators at EU and national level. Any new powers would need to be proportionate, with adequate checks and balances. We believe that supervisors’ work should be more transparent, for example by publishing their inspection reports on individual PIE audit firms. The supervisory framework should build an environment that fosters learning and development for both companies and auditors, rather than focus on sanctioning.
Read full response

Meeting with Mairead McGuinness (Commissioner) and

2 Dec 2021 · CSRD, wirecard

Response to Revision of EU rules on Anti-Money Laundering (recast)

17 Nov 2021

Accountancy Europe welcomes the European Commission’s package of legislative proposals to strengthen the EU’s anti-money laundering and countering the financing of terrorism (AML/CFT) rules. Harmonization of Anti-Money Laundering (AML) rules and supervision will facilitate a more effective response to the challenges in the fight against money laundering. This will also ensure a level playing field in the AML rules implementation among the member states. In our feedback, we underline the need to maintain in the EU AML framework: i) the risk-based approach and ii) the principle of proportionality. Risks can differ from country to country but also amongst obliged entities and thus need tailored mitigation measures. In the AML ecosystem, all actors need to collaborate and improve coordination amongst them. However, each actor has a different role to play and different risks to encounter. And for that, we invite the European Commission (EC) to take into consideration those differences in the proposed legislation, especially when it comes to its implementation. We also refer to a number of differences between the non-financial and financial obliged entities. These differences are linked to their different roles in the market, the ways they operate but also to the risks they encounter. Going ahead, we would like to see AMLA (Anti-Money Laundering Authority) considering these differences in its decisions, while making sure that the respective roles and responsibilities of oversight remain clear and distinct. It will be key to ensure that the EC proposals are workable and can be implemented effectively. To this end, we refer below to some areas that in our view require clarifications. We would like to emphasise that the profession is welcoming the package, acknowledging its importance to achieve the objectives on AML field. Our comments below aim to facilitate the application of the provisions as smoothly as possible. The accountancy profession remains committed to fighting money laundering and Accountancy Europe remains at your disposal for further discussion on any of the following or other points. 6th AML Directive Article 38: Oversight of self-regulatory bodies We welcome this expected provision. We stand ready to work together with the EC on this objective as well as the new bodies. We would like to point out that effective supervision needs to be tailored to the activities and services of the non-financial sector entities. In the same spirit, the supervisory body should be familiar with the characteristics and risk profile of those entities so that appropriate supervision will be ensured.   Article 10: Beneficial ownership registers We would like to strongly encourage free access to the beneficial ownership registers for all the obliged entities across the members states. Most notably, cross border access to beneficial ownership registers is of utmost importance to enhance transparency and effective information sharing.
Read full response

Response to EU Anti-money laundering supervisor

17 Nov 2021

Accountancy Europe welcomes the European Commission’s package of legislative proposals to strengthen the EU’s anti-money laundering and countering the financing of terrorism (AML/CFT) rules. Harmonization of Anti-Money Laundering (AML) rules and supervision will facilitate a more effective response to the challenges in the fight against money laundering. This will also ensure a level playing field in the AML rules implementation among the member states. In our feedback, we underline the need to maintain in the EU AML framework: i) the risk-based approach and ii) the principle of proportionality. Risks can differ from country to country but also amongst obliged entities and thus need tailored mitigation measures. In the AML ecosystem, all actors need to collaborate and improve coordination amongst them. However, each actor has a different role to play and different risks to encounter. And for that, we invite the European Commission (EC) to take into consideration those differences in the proposed legislation, especially when it comes to its implementation. We also refer to a number of differences between the non-financial and financial obliged entities. These differences are linked to their different roles in the market, the ways they operate but also to the risks they encounter. Going ahead, we would like to see AMLA (Anti-Money Laundering Authority) considering these differences in its decisions, while making sure that the respective roles and responsibilities of oversight remain clear and distinct. It will be key to ensure that the EC proposals are workable and can be implemented effectively. To this end, we refer below to some areas that in our view require clarifications. We would like to emphasise that the profession is welcoming the package, acknowledging its importance to achieve the objectives on AML field. Our comments below aim to facilitate the application of the provisions as smoothly as possible. The accountancy profession remains committed to fighting money laundering and Accountancy Europe remains at your disposal for further discussion on any of the following or other points. Regulation on establishing the Authority for AML and CFT We support the establishment of the new EU AML Authority. It will be instrumental to ensure greater effectiveness and cross-border consistency of AML/CFT requirements application. We welcome the so-called ‘hub and spoke’ approach to the supervision which we also recommended in our reply to the EC AML Action Plan. - Coordination and oversight of national AML/CFT supervisors by AMLA: One of the key tasks of the new AML authority will be to coordinate and oversee national AML/CFT supervisors, including self-regulatory bodies (SRBs) in certain Member States for certain non-financial obliged entities. As previously raised in our reply to the consultation on the EC AML Action Plan, we would like to stress the significant differences between the financial and non-financial obliged entities. We expect that AMLA will have staff with relevant experience and expertise to consider the differences in the way obliged entities operate and the risks they encounter. In practice, this will entail the need for dedicated expertise in the different areas of the non-financial sector.
Read full response

Response to Revision of EU rules on Anti-Money Laundering (new instrument)

17 Nov 2021

Accountancy Europe welcomes the European Commission’s package of legislative proposals to strengthen the EU’s anti-money laundering and countering the financing of terrorism (AML/CFT) rules. Harmonization of Anti-Money Laundering (AML) rules and supervision will facilitate a more effective response to the challenges in the fight against money laundering. This will also ensure a level playing field in the AML rules implementation among the member states. In our feedback, we underline the need to maintain in the EU AML framework: i) the risk-based approach and ii) the principle of proportionality. Risks can differ from country to country but also amongst obliged entities and thus need tailored mitigation measures. In the AML ecosystem, all actors need to collaborate and improve coordination amongst them. However, each actor has a different role to play and different risks to encounter. And for that, we invite the European Commission (EC) to take into consideration those differences in the proposed legislation, especially when it comes to its implementation. We also refer to a number of differences between the non-financial and financial obliged entities. These differences are linked to their different roles in the market, the ways they operate but also to the risks they encounter. Going ahead, we would like to see AMLA (Anti-Money Laundering Authority) considering these differences in its decisions, while making sure that the respective roles and responsibilities of oversight remain clear and distinct. It will be key to ensure that the EC proposals are workable and can be implemented effectively. To this end, we refer (see attached document) to some areas that in our view require clarifications. We would like to emphasise that the profession is welcoming the package, acknowledging its importance to achieve the objectives on AML field. Our comments below aim to facilitate the application of the provisions as smoothly as possible. The accountancy profession remains committed to fighting money laundering and Accountancy Europe remains at your disposal for further discussion on any of the following or other points.
Read full response

Meeting with Ondřej Kovařík (Member of the European Parliament)

28 Oct 2021 · Common SME priorities

Response to EU Standard for Green Bond

22 Sept 2021

Our key concern with green bonds regards the risk of greenwashing, especially now that financial markets show strong interest in expanding their portfolio with green assets. We welcome the European Commission’s (EC) proposal for an EU Green Bond Standard (EU GBS) that introduces requirements aiming at reducing uncertainties for issuers and investors and bringing credibility to the green bond market. Firstly, the requirement for the funds raised by the green bond to be allocated fully to the EU Taxonomy-aligned projects will help reduce uncertainty as to what should be considered green. It will also provide clear guidance to issuers on how to structure a green bond issuance. We also welcome detailed reporting requirements to ensure full transparency on how the bond proceeds are allocated. Reporting on green bonds should be done at regular intervals during the life of the bond and projects invested in, at least annually after all funds have been allocated to green projects. Investors and other stakeholders need to be able to trust that the funded projects produce the expected environmental benefits to ensure that green bonds are credible in the long run. Regular reporting will ensure information’s continuity on the portfolio’s size and the related environmental impact to the market. Moreover, we support the EC’s proposal for all European green bonds to be checked by an external reviewer to ensure compliance with the Regulation on European green bonds and Taxonomy alignment of the funded projects. Investors need to be able to trust the information provided by issuers, especially when it comes to the allocation of proceeds and the bond’s environmental impact. Obtaining independent third-party assurance on various aspects, including on the allocation reports, but also on the environmental reports, could help enhance investors’ confidence further and ensure that green bonds deliver on the EC's ambitions. The EC’s proposal includes a requirement for external reviewers providing services to issuers of European green bonds to register with ESMA. It is expected that external reviewers would be supervised by ESMA. We fully agree that a centralised European accreditation system is important to decrease market uncertainty and create a level playing field for the consistency and quality of the services provided. We note that certain EU Member States already have well established accreditation systems for third-party independent assurance providers. A European solution should build upon these. The schemes in place for audit services, taking into account the public interest, already provide a suitable model ensuring that the quality of the review is safeguarded. Service providers should be formally accredited to ensure their independence, competence and create certainty on the delineation of the responsibilities when assessing compliance with the EU GBS. Equally, such a system should ensure that service providers have appropriate quality control mechanisms and processes to ensure ethics and independence in place to provide high quality assurance. We stress the importance of the ethical dimension for the quality of the services provided. Thus, we encourage ESMA to consider ethical principles and rules in the development of the technical standards. All service providers should comply with equivalent professional standards, thus strengthening investors’ confidence in the reliability of the assurance reports they receive. As proposed, there is no consensus as to what procedures or methodologies used by external reviewers should entail. This might result in inconsistent work effort and quality of services if there is no standardised approach for service providers to consistently apply. It is unclear what the terms used in the proposal would entail in practical terms, such as positive/negative opinion or (detailed) assessment. See Accountancy Europe’s position paper (attached) for the profession's views on building a credible green bond market.
Read full response

Response to Revision of Non-Financial Reporting Directive

1 Jul 2021

The climate emergency is clear to all. Transitioning requires fundamental change in policies and business practices. We commend the EC for its ambition to foster this change and for proposing the CSRD. All involved parties will have to play a balancing act between advancing quickly to meet the ambitious timeline and taking up the challenge of reporting credible and quality sustainability information as from 2024. We support the EC’s proposal to extend the scope to all large and listed companies that significantly impact or can be impacted by the environment and society. European common standards for sustainability reporting need to be set quickly by EFRAG. Such European standards will also provide the necessary basis for digitisation and assurance. We support the way forward, while emphasising the need for coordination of the different sustainability reporting initiatives. It is important for the EC to build on globally accepted standards and contribute to international convergence, especially with the IFRS Foundation’s global sustainability reporting standards in development. Ultimately, consolidated global standards would be best to meet investors’ and capital markets’ needs for information comparability whilst minimising duplications and unnecessary costs. Stakeholders, including companies, need to view the incoming legislation and standards as an opportunity and an efficiently driven process, avoiding a multi-layer of reporting or compliance orientated requirements. Voluntary and proportionate reporting standards for SMEs should be designed to help SMEs address information demands at corporate level coming from financial institutions and larger supply chain partners. It should also set the limits for the information that can be reasonably expected from SMEs (see attached). Investors are voicing the need for third-party independent assurance to introduce greater consistency and credibility to sustainability reporting. We support the EC’s proposal to require limited assurance as a first step. We also agree with the EC that the level of assurance should ultimately be at the same level as financial information. Thus, the EU regulatory framework should set reasonable assurance as an end goal, e.g. over 3 to 5 years (see attached). The European accountancy profession is stepping up to make the transition from limited to reasonable assurance happen. To enhance credibility, quality and consistency of the assurance services provided across the EU, all assurance service providers should be required to apply the same professional assurance standards, ethical requirements, including independence, quality framework, and public oversight. The accountancy profession has already such mechanisms in place. Legislation and practice should ensure that all professionals across countries and sectors are subject to the same rules, ensuring a level playing field. Furthermore, the IAASB’s ISAE 3000 standard (or its national equivalent) is widely used across the EU (see attached). The accountancy profession is ready to actively engage with the EC on assurance standards to work towards a solution accommodating the existing standards and the EU needs. Meanwhile, the coordination at EU level between local assurance standard-setters and supervisors will be of utmost importance to ensure consistent work effort and quality by those providing assurance on sustainability reporting. Digitisation of sustainability reporting should be undertaken in a holistic manner with electronic filings envisaged in other legislation and should not unnecessarily conflict with existing electronic fling regimes in member states. There is still room for improvement to harmonise electronic filing in the EU. Finally, for this reform to be a success, it is instrumental to enhance the responsibilities of Boards and Audit Committees. The level of management responsibility should be the same for financial information and sustainability information.
Read full response

Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

We support the EC in requiring enterprises to provide targeted information as per the EU Taxonomy Regulation and its delegated acts. To ensure consistent application of the rules, there is a strong need to clarify the definitions and the specific requirements. Implementation and interpretation guidance is also required immediately. We call on the EC to create a formal mechanism in addition to the EU Platform on Sustainable Finance to deal with such interpretation issues. In particular, it is unclear: - whether an activity must always be revenue-generating in itself to be considered as eligible or also whether an activity within the company, such as certain investments or expenditures (e.g. for solar energy), could count as eligible (for the determination of the CapEx and OpEx KPIs) even if it is not a revenue-generating activity (as an ‘economic activity’ is not defined for the purpose of the taxonomy) - whether all CapEx associated with a revenue-generating activity that is Taxonomy-aligned is necessarily considered as Taxonomy-aligned, regardless of the nature of the CapEx incurred - whether only the principal revenue-generating activities of a given company shall or can be considered as eligible activities or whether entities can identify other eligible activities within customer contracts in line with IFRS 15 - which disclosures are specifically needed in Year 1 and how to address comparative data in Year 1 and subsequent years - whether the ‘share of Taxonomy eligible and non-eligible activities’ regards all 3 KPIs for both eligible and non-eligible activities, whether further breakdowns are required - how to treat the allocation of shared revenue and/or assets such as for the economic activities of joint ventures - whether ‘expenditure’ refers to cost or cash flow and how to treat direct costs Financial undertakings will face important issues due to the unclarity of the text and the set timeline. Requirements for banks are closely related to the EBA open consultation on prudential disclosures on ESG risks. As feedback would also apply for the delegated act, it is important to liaise with EBA. Also, it is unclear whether information required could be presented together with Pilar 3 disclosures. Additionally: - Disclosures will be based on the prudential reporting. This is consistent with Pilar 3 disclosures, but the information may not reconcile between the accounting perimeter and the prudential perimeter. - Financial undertakings need information from corporates to prepare the required KPIs. Companies’ reporting time schedule for providing information will not enable meeting that for financial undertakings. The whole process will be problematic for the flow of information resulting in financial undertakings having to base their reporting on estimations and not yet reported data. We welcome the phased approach granting undertakings a gradual application of the reporting obligations but if estimates will have to be used, the data quality will be a major issue. - Paragraph 1.2.1.4 of Annex V seems particularly flawed. We welcome the EC’s plans to assess exposures and impacts for SMEs in the taxonomy context. SMEs need clear guidance and tools to help them build their “sustainability maturity”, to standardise their processes and be able to deal with data demands from financial institutions, larger supply chain partners etc. (see attached our SMEs sustainability checklist). The EC should also clarify the limits for the information that can reasonably be required from SMEs. Finally, subjective and variable interpretations of reporting obligations do not provide suitable criteria for assurance engagements. A robust reporting framework is necessary to serve as a basis for assurance. Assurance over sustainability information is currently required in 3 Member States, obtained on a voluntary basis in others and will soon be required more broadly.
Read full response

Meeting with Claude Bocqueraz (Cabinet of Commissioner Mairead Mcguinness)

28 May 2021 · Corporate reporting

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

5 May 2021 · audit regulation

Meeting with Salvatore De Meo (Member of the European Parliament)

13 Apr 2021 · Various

Meeting with Mairead McGuinness (Commissioner) and

4 Feb 2021 · non financial reporting directive.

Response to Sustainable corporate governance

8 Oct 2020

Accountancy Europe welcomes the opportunity to provide feedback on the European Commission’s Inception impact assessment on sustainable corporate governance. Environmental risks also entail significant financial risks for businesses, markets, investors, and the economy. To deliver on the goals of the Paris Agreement on climate change as well as the EU Green Deal, it is imperative to instil businesses’ accountability for their impacts on the environment and society. There is strong empirical evidence that voluntary initiatives are, at least, insufficiently effective. Companies need to address their sustainability impacts on environmental and human rights issues. These impacts need to be properly measured, factored in and accounted for by business. Corporate governance mechanisms within the company should properly underpin corporate accountability through appropriate processes and governance arrangements, which should be subject to independent verification. Sustainable finance has a key role to play in the transition. Clear, consistent and evenly enforced legislation across countries is key to ensure that sustainability is truly and fully embedded into corporate decision making. We propose the following key points to be addressed in priority in the sustainable corporate governance agenda: • Integrate sustainable value creation into the duties of the board: Members of the board have a particular responsibility when they define a business strategy and oversee its execution. Sustainable value creation for the company without material harm to environment and society should be at the heart of the undertaking’s purpose and the duties of the board (cf. the French law "loi pacte"). This entails adapting relevant company law legislation i.e. the EU Company Law Directive 2017 or the Shareholders’ Rights Directive. • Set effective mechanisms to verify due diligence disclosures are trustworthy: We support the Commission’s decision to proceed with a legislative proposal on due diligence duty. It is key to rigorously monitor the compliance and ensure the enforcement of the rules, including through penalties and sanctions. The Commission should couple this with a level playing field in the single market to foster change and legal certainty. • Expand the scope to all companies that significantly impact the environment and society: Corporate governance should not be only an issue only for larger corporations. Ultimately, it is not about the size of a business, but about its risks and sustainability impacts. Enterprises operating in high risk sectors can have substantial external impacts regardless of their size. It will be important to ensure that regulatory measures are proportionate to the companies’ size but also to their sustainability impacts and risks. • Align NFI reporting with sustainable corporate governance: Transparency and disclosures on how environmental and social risks and impacts are tackled and integrated in the governance and risk management processes in the short, medium and long-term will be critical to consistently address short-termism in financial markets. The board will play a key role in this by remaining accountable for their company’s disclosure of material impacts on society and environment as detailed in the NFR Directive. The accountancy profession has an important role in advancing effective corporate governance. Auditors can add value by providing assurance services in respect of corporate governance, internal controls, and sustainability reporting. We are committed to engage in the discussion and further contribute our expertise and thought leadership. We are also attaching Accountancy Europe thought-leadership paper From risks to regulation: rethinking company categorisation that is relevant to the corporate governance discussion.
Read full response

Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

8 Sept 2020

To achieve a truly sustainable economy, the entire investment chain has to build sustainable practices, underpinned with appropriate reporting thereon. It is important to ensure that reporting obligations within the EU Taxonomy Regulation are coherent and aligned with related non-financial reporting initiatives and other data requirements at EU level. We support the EC in requiring the participants of the ‘real economy’ to provide targeted information as per the upcoming delegated act. Having relevant information will also allow banks and other financial institutions to direct capital to sustainable projects and businesses. It will take companies some efforts to provide the required information under the EU Taxonomy Regulation. Even though the methodology is yet to be designed, companies will still have to devote high efforts and resources to define whether parts of turnover can be defined as environmentally sustainable. The same applies for OpEx and CapEx, in particular where it relates to products involving complex supply chains. We should not disregard the challenges regarding allocation for general costs (i.e. overhead). Also, companies will have to establish (or strengthen) the systems, processes and controls to ensure reporting consistency against regulatory requirements. It is thus crucial to thoroughly design the methodology, also considering any options that could result in misleading data. The interest in such (financial) products and services will increase and it might put pressure to present the information only in a positive way. This may result in misleading information (or sustainability-related fraud). Comprehensiveness is a key element of reporting. A future non-financial reporting standard could base its environmental matters on the EU Taxonomy’s environmental objectives and should support the application of the technical screening criteria. Non-financial metrics should be consistent with the EU Taxonomy. It should be noted that banks and insurance undertakings have different business models and play a different role in the investment chain than the non-financial companies. It is thus appropriate to define different criteria for such undertakings. Accountancy Europe supports the EC’s efforts to promote the sustainable transition amongst the smaller businesses. We agree that SMEs may face indirect data demands from markets (from banks when applying for funding, from larger supply chain partners etc.). To help SMEs deal with these demands, a voluntary and adapted NFI framework for SMEs would be an appropriate first step. Professional accountants will play an instrumental role in guiding SMEs through the sustainability transition. Accountancy Europe stands ready to help the EC’s work. Companies’ transition to a sustainable economy is and should remain the primary goal of the EU policies. ‘Green’ and ‘brown’ companies can both present many investment opportunities (i.e. innovation to change business models/transition to different operating models). Turning threats into opportunities can also help ensure that ‘brown’ companies are not excluded from finance which can result in losses, bankruptcies etc which would then result in negative economic impacts. Finally, we would like to emphasise that information needs to be comparable and consistent in terms of quality, reliability and relevance. Given the importance of such information, assurance is necessary to enhance the information’s credibility. Even if companies will need time to establish data collection systems and processes, the Commission should consider any future expectations about independent assurance requirements on the reporting resulting from the delegated now. Otherwise, lack of clarity may confuse markets and reduce trust in both the reporting entities and the auditors, as well as the legislation. (We provide further information in the latest Accountancy Europe position paper on achieving high-quality assurance over NFI).
Read full response

Response to A simplified prospectus for companies and investors in Europe

20 Dec 2018

Accountancy Europe, European Contact Group (ECG) and the European Group of International Accounting Networks and Associations (EGIAN) congratulate the European Commission for all its efforts in pushing through a major overhaul of the EU prospectus framework. It has come a long way from the 2015 public consultation and Prospectus Regulation proposal, all the way to this latest Delegated Act on prospectus disclosures. Overall, we are happy that the Prospectus Regulation and this Delegated Act provide for a more alleviated prospectus regime, in particular for smaller issuers. Accountancy Europe, ECG and EGIAN believe that the European Commission and ESMA could have been even more ambitious in alleviations as well as explicit promotion of incorporation by reference – and still remain within the frames of the Level 1 political mandate. However, we recognise that what we have on the table is a compromise that attempts to take a balanced approach to accommodate viewpoints and concerns from all concerned stakeholder groups. Ultimately, this Delegated Act and the broader Prospectus Regulation are merely first steps on a longer journey. The key will be to observe, assess and analyse how the new rules work in practice, and whether tangible and meaningful alleviations will result, in particular for smaller issuers on SME Growth Markets. Accountancy Europe, ECG and EGIAN as well as our numerous constituents working on IPOs on the ground are committed to continue our joint efforts to identify best practices, flag any challenges and propose new, constructive solutions that take stock of technological potential, evolving expectations of investors and the varying capacities of issuers of different sizes.
Read full response

Response to EU Company law upgraded Package:digital solutions and providing efficient rules for cross border operations of companies

10 Jul 2018

Please find attached our comment letter to the European Commission's proposed amendments to the Directive on cross-border conversions, mergers and divisions.
Read full response

Meeting with David Boublil (Cabinet of Commissioner Pierre Moscovici)

18 Oct 2017 · Meeting with Accountancy Europe to exchange views on tax intermediaries and green taxation

Meeting with David Boublil (Cabinet of Commissioner Pierre Moscovici)

4 May 2017 · Meeting to prepare Commissioner Moscovici's intervention at FEE Tax day.

Meeting with Stephen Quest (Director-General Taxation and Customs Union)

24 Oct 2016 · Discussion on Corporate tax proirities

Meeting with Stephen Quest (Director-General Taxation and Customs Union)

9 Jun 2016 · Exchange of views on topical issues

Meeting with Maria Elena Scoppio (Cabinet of Commissioner Pierre Moscovici)

28 Jan 2015 · Preparation of Tax Day Event