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ACT | The App Association

The App Association

ACT | The App Association represents small business technology developers and innovators in the global app ecosystem.

Lobbying Activity

App Association urges EU to simplify rules for small businesses

9 Jan 2026
Topic — A review of the EU programme monitoring progress toward 2030 digital targets.
Message — They propose a review of digital laws and easier access to AI sandboxes. They also advocate for an optional European legal framework to reduce administrative complexity.123
Why — Unified rules and simplified procedures would lower operational costs for small tech developers.4
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Meeting with Ana Vasconcelos (Member of the European Parliament, Shadow rapporteur) and DIGITALEUROPE and

20 Nov 2025 · Omnibus IV

Meeting with Andreas Schwab (Member of the European Parliament) and EUROCONSUMERS AISBL

17 Nov 2025 · Digital Markets

App industry urges EU to avoid premature space regulations

7 Nov 2025
Topic — New EU regulation on safety, resilience and sustainability of space activities.
Message — The organization requests the EU prioritize implementation of existing guidelines before introducing new binding rules. They argue new regulations should only be considered after current measures are assessed and proven effective.12
Why — This would reduce regulatory complexity and compliance burdens for small tech companies.34
Impact — Regulators lose the ability to establish comprehensive safety and sustainability standards quickly.5
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App Association urges EU to simplify existing rules instead of new regulation

24 Oct 2025
Topic — EU regulation on digital fairness including dark patterns, addictive design, and subscription traps.
Message — The organization requests that the EU prioritize streamlining and enforcing existing consumer protection laws rather than adopting new legislation. They argue current frameworks like DSA, GDPR, and UCPD already address identified harms, and adding new rules would increase complexity and compliance costs for small businesses.123
Why — This would reduce regulatory complexity and compliance costs that disproportionately burden their small business members.45
Impact — Consumer advocates lose stronger protections against manipulative practices through comprehensive new legislation.
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Meeting with Marion Walsmann (Member of the European Parliament)

20 Oct 2025 · Intellectual Property

App Association urges two-year pause on AI Act implementation

14 Oct 2025
Topic — Simplifying EU digital regulations to reduce compliance burdens on businesses.
Message — The organization requests a two-year pause on AI Act obligations until guidelines and standards are finalized. They want harmonized reporting through a single EU portal covering GDPR, AI Act, and other frameworks. They seek consolidated data legislation eliminating overlaps between GDPR and Data Act.1234
Why — This would reduce overlapping compliance costs and reporting requirements that disproportionately burden their small business members.567
Impact — Consumer protections against AI bias and data breaches could be weakened by delayed implementation and reduced reporting.89
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Meeting with Angelika Niebler (Member of the European Parliament)

6 Oct 2025 · 28 regime

App Association urges EU to cut overlapping regulations for startups

3 Oct 2025
Topic — New EU framework to remove barriers for innovative companies and attract investment.
Message — The organization requests consolidation of overlapping digital regulations and exemption of startups from disproportionate reporting requirements. They advocate for coordinated incident reporting mechanisms and regulatory sandboxes to reduce compliance complexity. Future regulations should address demonstrated harms rather than hypothetical risks.123
Why — This would reduce administrative burden and compliance costs for small tech developers navigating complex EU rules.45
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App Association urges EU regulation for unified startup framework

30 Sept 2025
Topic — Proposal for harmonized corporate legal rules to help innovative companies across EU.
Message — The organization requests the 28th regime be established as an EU Regulation, not a Directive, to create a truly supranational company form with uniform rules across all Member States. They call for a digital incorporation platform enabling 48-hour company registration, harmonized insolvency procedures, and unified rules for employee stock options and startup visas.1234
Why — This would eliminate compliance with 27 different national regimes and significantly reduce administrative costs for small tech companies.567
Impact — Member States lose control over national company registration procedures and insolvency frameworks.89
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App Association urges EU to prioritize SME interests in Digital Markets Act review

23 Sept 2025
Topic — Review of Digital Markets Act rules on contestable and fair markets in the digital sector.
Message — The Association requests that DMA enforcement prioritize SME concerns, maintain security safeguards, and avoid expanding the scope to include AI as a Core Platform Service. They seek a more inclusive consultation process and clearer compliance guidelines that smaller businesses can interpret and implement.123
Why — This would reduce compliance costs and preserve the protective environment that helps small app developers compete against larger brands.45
Impact — Large gatekeepers lose flexibility in platform management and face stricter interoperability requirements.67
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App Association urges EU to protect startup acquisition exit

1 Sept 2025
Topic — The European Commission is revising merger guidelines to reflect evolving digital market realities.
Message — The group urges the Commission to recognize acquisitions as a desirable exit for startups. They demand that merger reviews stay based on rigorous, data-driven economic analysis.12
Why — This ensures small developers can continue using acquisitions as a viable success strategy.3
Impact — Enforcement agencies would find it harder to block mergers without meeting high evidentiary standards.4
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App Association urges EU to prioritize enforcement over new consumer rules

29 Aug 2025
Topic — The Commission is developing its consumer policy strategy for the years 2025 to 2030.
Message — The organization requests simpler compliance requirements and practical tools like standardized templates. They argue for better enforcement of current laws instead of introducing new legislative obligations. They recommend reviewing recent regulations for unintended negative impacts on consumer privacy and security.1234
Why — Reduced administrative complexity would lower costs and help small developers scale across the Single Market.56
Impact — New regulation advocates lose if the EU prioritizes enforcement over drafting additional consumer protection rules.7
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App Association backs regulatory relief for small mid-caps

25 Aug 2025
Topic — This consultation seeks to simplify legal obligations for small mid-cap enterprises across Europe.
Message — The group supports extending SME-specific exemptions for data records and financial prospectuses to mid-cap companies. They also request a uniform mid-cap definition and unique support for startups.123
Why — Lower compliance costs for growing firms will encourage them to scale in Europe.45
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Response to Burden reduction and simplification for competitiveness of small mid-cap enterprises - Omnibus Directive

25 Aug 2025

ACT | The App Association (hereafter App Association) hereby submits comments to the European Commission in response to the public consultation on Burden reduction and simplification for competitiveness of small mid-cap enterprises - Omnibus Directive. The App Association is a policy trade association for the small business technology developer community. Our members are entrepreneurs, innovators, and independent developers within the global app ecosystem who engage with verticals across every industry. We work with and for our members to promote a policy environment that rewards and inspires innovation while providing resources that help them raise capital, create jobs, and continue to build incredible technology. Today, the ecosystem the App Association represents, which we call the app economy, is valued at approximately 95.7 billion globally and is responsible for over 1.4 million jobs in the European Union (EU). Please find our feedback on the call for evaluation outlined in the attached pdf.
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Response to Revision of the Standardisation Regulation

21 Jul 2025

Please see the attached document for our feedback.
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App Association: Digital Networks Act must protect small developers

10 Jul 2025
Topic — The European Commission is consulting on the Digital Networks Act to boost connectivity.
Message — The association requests simplification that specifically supports small business developers. They demand that net neutrality protections remain intact and enforceable. They oppose mandated dispute resolution mechanisms that create network fees.12
Why — This prevents indirect costs from being passed down to small application developers.3
Impact — Large internet service providers lose the ability to charge fees for data traffic.4
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App Association Urges SME-Friendly EU Cybersecurity Rules

20 Jun 2025
Topic — A revision of the Cybersecurity Act to improve certification and digital resilience.
Message — ACT calls for aligning certification with international standards like ISO 27001 to simplify compliance. They advocate for a centralized incident reporting platform to reduce administrative burdens. Additionally, they urge the Commission to avoid mandatory third-party certifications that create high-cost barriers.123
Why — Streamlined rules would reduce compliance costs and administrative burdens for small developers.45
Impact — Third-party certification facilities could lose revenue if self-certification is expanded for SMEs.6
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App Association urges AI Act simplification to support small tech developers

4 Jun 2025
Topic — EU strategy to accelerate AI adoption and strengthen Europe's AI leadership.
Message — The organization requests meaningful revision and simplification of the AI Act, including proportional compliance mechanisms for SMEs, streamlined obligations for low-risk deployments, sector-specific guidelines, clearer definitions of high-risk systems, and exemptions such as delayed timelines and reduced documentation burdens for smaller companies.123
Why — This would reduce legal and financial burdens that small developers lack resources to navigate.45
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Meeting with Paul Moley (Cabinet of Executive Vice-President Roxana Mînzatu)

4 Jun 2025 · Introductory meeting by Jason Culloty-CEO, Skillsvista

App Association calls for open innovation-led EU cloud strategy

1 Jun 2025
Topic — A legislative initiative to triple European cloud capacity and accelerate green AI development.
Message — The association advocates for public-private partnerships and simplified permitting to expand sustainable cloud infrastructure. They argue that digital sovereignty should focus on nurturing innovation rather than building protectionist barriers. They also request alignment with the AI Act to prevent burdensome regulatory overlaps.123
Why — Small businesses benefit from lower compliance costs and continued access to global technology.45
Impact — Protectionist-leaning regulators lose the opportunity to mandate the use of strictly European providers.6
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Response to European strategy on research and technology infrastructures

22 May 2025

ACT | The App Association (hereafter App Association) hereby submits comments to the European Commission in response to the call for evidence on the European strategy on research and technology infrastructures. The App Association is a policy trade association for the small business technology developer community. Our members are entrepreneurs, innovators, and independent developers within the global app ecosystem, engaging with verticals across every industry. We work with and for our members to promote a policy environment that rewards and inspires innovation while providing resources that help them raise capital, create jobs, and continue to build incredible technology. Today, the ecosystem the App Association represents, which we call the app economy, is valued at approximately 830 billion globally and is responsible for over 1.3 million jobs in the European Union (EU). Please find our feedback on the call for evidence outlined in the attached PDF.
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Response to International Digital Strategy

21 May 2025

The App Association is a policy trade association for the small business technology developer community. Our members are entrepreneurs, innovators, and independent developers within the global app ecosystem that engage with verticals across every industry. We work with and for our members to promote a policy environment that rewards and inspires innovation while providing resources that help them raise capital, create jobs, and continue to build incredible technology. Today, the ecosystem the App Association representswhich we call the app economyis valued at approximately 86 billion and is responsible for over 1.3 million jobs in the European Union (EU). Please find the our views on the International Digital Strategy in the attached document below.
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Response to Revision of the EU competition rules on technology transfer agreements (Guidelines)

25 Apr 2025

ACT | The App Association is a policy trade association for the small business technology developer community. Our members are entrepreneurs, innovators, and independent developers within the global app ecosystem that engage with markets across every industry. We work with and for our members to promote a policy environment that rewards and inspires innovation while providing resources that help them raise capital, create jobs, and continue to build incredible technology. Please find attached our comments to the TTBER Revision.
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Meeting with Elena Martines (Cabinet of Commissioner Ekaterina Zaharieva)

26 Mar 2025 · The state of the current regulations and the barriers for App developers and SMEs in Europe

Meeting with Mirzha De Manuel (Cabinet of Commissioner Valdis Dombrovskis)

26 Mar 2025 · EU implementation and simplification agenda and digital innovation in the EU

Meeting with Amaryllis Verhoeven (Acting Director Internal Market, Industry, Entrepreneurship and SMEs)

26 Mar 2025 · ACT came to discuss their views on how the EU should improve the business environment for start- and scale ups

Meeting with Aura Salla (Member of the European Parliament)

26 Mar 2025 · DMA

Meeting with Dimitris Tsiodras (Member of the European Parliament)

26 Mar 2025 · EU digital policies and SMEs

Meeting with Eero Heinäluoma (Member of the European Parliament)

26 Mar 2025 · App economy

Meeting with Maria Grapini (Member of the European Parliament)

26 Mar 2025 · SME START-UP

Meeting with Angelika Winzig (Member of the European Parliament)

25 Mar 2025 · Meeting with representatives of ACT | The App Association

Meeting with Jeannette Baljeu (Member of the European Parliament)

25 Mar 2025 · SMEs in the digital domain

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

25 Mar 2025 · Digital regulation/simplification

Meeting with Mary Veronica Tovsak Pleterski (Director Internal Market, Industry, Entrepreneurship and SMEs)

25 Mar 2025 · Discussion on the scalability of Single Market and the regulatory challenges faced by EU startups

Meeting with Xavier Coget (Cabinet of Executive Vice-President Henna Virkkunen)

25 Mar 2025 · Exchange of views on ACT activities, EU innovation agenda, EU digital rules and the upcoming28th regime.

Meeting with Maria Guzenina (Member of the European Parliament)

25 Mar 2025 · IMCO priorities

Meeting with Henrik Dahl (Member of the European Parliament)

25 Mar 2025 · Simplification

Meeting with Maravillas Abadía Jover (Member of the European Parliament)

25 Mar 2025 · SMEs policies

Meeting with Piotr Müller (Member of the European Parliament)

25 Mar 2025 · Regulating digital markets for SMEs

Meeting with Sergey Lagodinsky (Member of the European Parliament) and Qualcomm France

25 Mar 2025 · Exchange of Views

Meeting with Anna-Maja Henriksson (Member of the European Parliament)

25 Mar 2025 · Digitalization

Response to EU Start-up and Scale-up Strategy

17 Mar 2025

Please see attached comments of ACT | The App Association (Transparency Reg. # 7202951387754) on the European Commissions call for evidence on EU Start-up and Scale-up Strategy.
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App Association urges SME-friendly Single Market reforms

31 Jan 2025
Topic — The European Commission is consulting on strategies to develop the single market for 2025.
Message — The group advocates for simplified rules and harmonised implementation of digital laws to reduce administrative burdens. They request a unified European capital market and fair access to essential patents for small developers.123
Why — Reducing these regulatory complexities would lower compliance costs and improve access to investment for small firms.45
Impact — Large telecom operators lose the ability to charge application providers additional network infrastructure fees.67
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Meeting with Dóra Dávid (Member of the European Parliament, Committee chair)

16 Jan 2025 · Priorities for the 10th legislature

Meeting with Aura Salla (Member of the European Parliament)

15 Jan 2025 · Introductory meeting. AI, DMA, SEP

Meeting with Henrik Dahl (Member of the European Parliament, Shadow rapporteur for opinion)

12 Dec 2024 · AI Liability

Small tech developers urge SME representation on AI expert panel

15 Nov 2024
Topic — EU regulation establishing independent scientific panel for AI Act implementation and enforcement.
Message — The App Association requests that the panel include representatives from SMEs across all industry levels. They argue small businesses face specific compliance challenges requiring expert understanding of their resource constraints.12
Why — This would ensure the panel considers SME operational constraints and compliance challenges.34
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App Association urges flexible minor protection rules for small firms

30 Sept 2024
Topic — The Commission is developing guidelines to protect minors on online platforms.
Message — The group requests flexible rules and easy ways for smaller businesses to comply. They suggest using existing parental controls and international standards to streamline regulations.123
Why — Flexible rules would prevent small developers from facing disproportionate financial hurdles.4
Impact — Children could face increased privacy risks if platforms are forced to collect more data.5
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Meeting with Elena Sancho Murillo (Member of the European Parliament) and Asociación Española para el Tratamiento Medioambiental de los Vehículos Fuera de Uso

24 Sept 2024 · Relevant issues to the ITRE Committee

Response to Interim Evaluation of Digital Europe

18 Sept 2024

ACT | The App Association (hereafter App Association) hereby submits comments to the European Commission in response to the call for an evaluation on the European Digital Program. The App Association is a policy trade association for the small business technology developer community. Our members are entrepreneurs, innovators, and independent developers within the global app ecosystem that engage with verticals across every industry. We work with and for our members to promote a policy environment that rewards and inspires innovation while providing resources that help them raise capital, create jobs, and continue to build incredible technology. Today, the ecosystem the App Association representswhich we call the app economyis valued at approximately 830 billion globally and is responsible for over 1.3 million jobs in the European Union (EU). The App Association strongly supports the ongoing digitalisation efforts, particularly those that prioritise the inclusion of SMEs in the technology landscape. Please find our feedback on the call for evaluation outlined in the attached pdf.
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Meeting with Henrik Dahl (Member of the European Parliament, Shadow rapporteur)

17 Sept 2024 · Internal Market

Response to Report on the first review of the EU-US Data Privacy Framework

6 Sept 2024

ACT | The App Association (App Association) appreciates the opportunity to contribute to the European Commission consultation on the EU-US Data Privacy Framework (DPF). The App Association is a policy trade association for the small business technology developer community. Our members are entrepreneurs, innovators, and independent developers within the global app ecosystem that engage with verticals across every industry. We work with and for our members to promote a policy environment that rewards and inspires innovation while providing resources that help them raise capital, create jobs, and continue to build incredible technology. Today, the ecosystem the App Association representswhich we call the app economyis valued at approximately 830 billion globally and is responsible for over 1.3 million jobs in the European Union (EU). Please find our detailed response to the consultation attached as a PDF document.
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App Association rejects network fees for digital infrastructure rollout

7 Jun 2024
Topic — This consultation explores scenarios for building Europe's future digital connectivity networks.
Message — The association urges the Commission to avoid imposing network fees on content providers. They advocate for a market where telecom operators remain responsible for infrastructure investment.12
Why — Preventing network fees protects small developers from higher operational and cloud costs.3
Impact — Telecom operators would lose the opportunity to shift infrastructure costs to tech companies.4
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App Association seeks simpler GDPR rules for small developers

8 Feb 2024
Topic — This consultation reviews the application of the General Data Protection Regulation six years after entry.
Message — The association requests simpler information obligations for smaller firms and stronger, uniform enforcement. They argue privacy rules must remain flexible enough for emerging artificial intelligence technologies.12
Why — Strict enforcement would prevent compliant small businesses from being disadvantaged by non-compliant competitors.3
Impact — Non-compliant companies would lose the financial advantage gained by avoiding data protection costs.4
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Response to Voluntary cybersecurity certification for ICT products, based on a Common Criteria set of security requirements

31 Oct 2023

ACT | The App Association (hereafter App Association) appreciates the opportunity to respond to the Commission consultation on the European cybersecurity certification scheme (EUCC). The App Association is a policy trade association for the small business technology developer community. Our members are entrepreneurs, innovators, and independent developers within the global app ecosystem that engage with verticals across every industry. We work with and for our members to promote a policy environment that rewards and inspires innovation while providing resources that help them raise capital, create jobs, and continue to build incredible technology. Today, the ecosystem the App Association representswhich we call the app economyis valued at approximately 830 billion globally and is responsible for over 1.3 million jobs in the European Union (EU). We welcome the proposed implementing regulation for the Cybersecurity Act, establishing the cybersecurity certification scheme in alignment with global best practices (specifically, the Common Criteria for Information Technology Security Evaluation, also known as ISO 15408). Small businesses, such as our members, have strong incentives to implement stringent cybersecurity measures and increase their resilience. A cyberattack for a small business can mean loss of reputation and constitute an existential threat. Certification schemes harmonised with established international standards are of great importance to our members, who place a strong emphasis on cybersecurity. We appreciate the value of certification marks in enhancing consumer trust, which helps facilitate market access. This is particularly crucial for small and medium-sized enterprises (SMEs) that may not have the same brand recognition and consumer loyalty as larger enterprises. Across consumer and enterprise verticals, end user confidence through certification programs can provide SMEs with an opportunity to demonstrate their commitment to cybersecurity and EU standards, and therefore provide a competitive edge. Moreover, we welcome the streamlined certification process offered by the EUCC, especially regarding the consistency it creates throughout EU Member States in the cybersecurity certification process. We recognise that this helps reduce administrative burdens and costs associated with following fragmented national certification systems. However, we also have several concerns. We hope that the Commission will continue to consider the effects of the EUCC on SMEs, such as our members, after the implementation of the Regulation. Although the EUCC is voluntary, it will become a marker of safeguarding the availability, authenticity, integrity, and confidentiality of data and functionalities within ICT products. This may have a significant impact on growing industries like the internet of things (IoT) and disproportionately affect small businesses with limited resources. Therefore, we urge the Commission to consider the additional negative impact further requirements could have in terms of costs and implementation efforts for SMEs, such as the certification schemes proposed by the Cyber Resilience Act, and to take concerted efforts to educate and support SMEs. Compliance with cybersecurity requirements is difficult to achieve and maintain and requires proactive monitoring and security management before and after a product is on the market. Cyber resiliency requires dynamic and rapid responses, and developers of new products may quickly find themselves unsure of compliance with static requirements due to future vulnerabilities exploited by hackers. We thank the Commission for considering these comments and remain available for questions, clarifications, and follow-up.
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Meeting with Danuta Maria Hübner (Member of the European Parliament, Rapporteur for opinion) and Ericsson and Nokia

18 Oct 2023 · Standard Essential Patents (COD 2023/0133) (Meeting with APA)

Response to Evaluation of Standardisation Regulation (EU) No 1025/2012

29 Sept 2023

ACT | The App Association (hereafter App Association) hereby submits comments to the Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs (DG-GROW) in response to the call for an evaluation on European standardisation. The App Association is a policy trade association for the small business technology developer community. Our members are entrepreneurs, innovators, and independent developers within the global app ecosystem that engage with verticals across every industry. We work with and for our members to promote a policy environment that rewards and inspires innovation while providing resources that help them raise capital, create jobs, and continue to build incredible technology. Today, the ecosystem the App Association representswhich we call the app economyis valued at approximately 830 billion globally and is responsible for over 1.3 million jobs in the European Union (EU). The App Association supports a standardisation framework that incents innovation, scale-up, and increased distribution of European products while reducing national-level fragmentation. Please find our feedback on the call for evaluation outlined in the attached pdf.
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App Association backs harmonised EU data protection enforcement rules

20 Mar 2023
Topic — The initiative aims to streamline cooperation between national data protection authorities.
Message — The association calls for common deadlines and clearer steps in cross-border investigations. They want to ensure that businesses have a guaranteed right to be heard during proceedings.123
Why — Harmonised rules would reduce the administrative burden and legal uncertainty for small businesses.45
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App Association warns EU proposal threatens digital privacy and encryption

12 Sept 2022
Topic — EU legislation requiring online service providers to detect and report child sexual abuse.
Message — The organization opposes mandatory scanning of private communications, arguing it fundamentally undermines user privacy. They reject age verification requirements that create data theft risks and reduce online anonymity. Instead, they urge the Commission to focus on providing resources for law enforcement investigations.123
Why — Small developers would avoid significant litigation risks and the burden of managing sensitive data.45
Impact — Law enforcement agencies lose mandatory technical powers to identify predators using encrypted messaging services.6
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Response to Enabling factors for digital education

12 Sept 2022

Please see attached the feedback of ACT | The App Association to the European Commission's call for evidence for a Council Recommendation titled ‘Digital Education – Enabling factors for success’. Anna Bosch Senior Policy Associate ACT | The App Association
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Response to Improving the provision of digital skills in education and training

9 Sept 2022

Please see attached the feedback of ACT | The App Association to the European Commission's call for evidence regarding its proposal for a Council Recommendation on improving the provision of digital skills in education and training. Anna Bosch Senior Policy Associate ACT | The App Association
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Meeting with Alejandro Cainzos (Cabinet of Executive Vice-President Margrethe Vestager)

8 Sept 2022 · Digital policies.

Meeting with Alejandro Cainzos (Cabinet of Executive Vice-President Margrethe Vestager), Alina-Stefania Ujupan (Cabinet of Executive Vice-President Margrethe Vestager)

8 Sept 2022 · Regulation for Mobile Phones, Cordless Phones and Tablets

Meeting with Ibán García Del Blanco (Member of the European Parliament, Shadow rapporteur for opinion)

30 Aug 2022 · Exchange of views on the Data Act

App Association warns against burdensome health data certification rules

26 Jul 2022
Topic — The consultation concerns the proposed creation of a secure European Health Data Space.
Message — The association wants the Commission to clearly distinguish between wellness apps and medical devices. They believe mandatory certification is overly burdensome and should be replaced by voluntary schemes. They suggest that standards should leverage leading standardisation efforts already in existence.12
Why — A move to voluntary certification would lower operational costs for small app developers.3
Impact — Conflicting regulatory requirements could harm consumers by causing confusion and limiting innovation.4
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Meeting with Alfred Sant (Member of the European Parliament)

1 Jun 2022 · Standard essential patents

Response to European chips act package – Regulation

5 May 2022

Please see attached the feedback of ACT | The App Association (transparency reg. # 72029513877-54) to the European Commission's proposal for a regulation of the European Parliament and of the Council establishing a framework of measures for strengthening Europe's semiconductor ecosystem (Chips Act).
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Meeting with Kevin Keary (Cabinet of Executive Vice-President Valdis Dombrovskis) and Lighthouse Europe

21 Apr 2022 · WTO Matters

Response to EU Competition law – revision of the market definition notice

16 Feb 2022

Please find attached the feedback of ACT | The App Association (Transparency Reg. # 72029513877-54) to the European Commission on its call for evidence for an initiative without an impact assessment: EU competition law – updating the market definition notice (revision)
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Response to VAT in the Digital Age

14 Feb 2022

Please find attached comments of ACT | The App Association (Transparency Reg. # 7202951387754) on the European Commission’s call for evidence for an impact assessment: Value-added tax in the digital age.
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Response to Policy Program - Digital Decade Compass

22 Nov 2021

Please find attached the feedback of ACT | The App Association (Transparency Reg. # 72029513877-54) to the European Commission’s proposal for decision on the Digital Decade Compass Policy Program. Anna Bosch EU Policy Associate ACT | The App Association (Transparency Reg. # 72029513877-54) Rue de Trèves 45 B-1040 Brussels
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Response to Common chargers for mobile phones and similar devices

17 Nov 2021

Please find attached the feedback of ACT | The App Association (Transparency Reg. # 72029513877-54) to the European Commission’s proposal for a Directive of the European Parliament and of the Council amending Directive 2014/53/EU on the harmonisation of the laws of the Member States relating to the making available on the market of radio equipment. Anna Bosch Policy Associate ACT | The App Association (Transparency Reg. # 72029513877-54) Rue de la Loi 23 B-1000 Brussels
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Response to Smartwatches and connected toys

27 Aug 2021

Please find attached the feedback of ACT | The App Association (Transparency Reg. # 72029513877-54) to the European Commission’s Delegated Act supplementing Directive 2014/53/EU of the European Parliament and the Council. Anna Bosch Policy Associate ACT | The App Association (Transparency Reg. # 72029513877-54) Rue de Trèves 45 B-1040 Brussels
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Response to Standardisation Strategy

9 Aug 2021

Please find attached the feedback of ACT | The App Association (Transparency Reg. # 72029513877-54) to the European Commission’s roadmap for a Standardisation Strategy Communication. Anna Bosch Policy Associate ACT | The App Association (Transparency Reg. # 72029513877-54) Rue de Trèves 45 B-1040 Brussels
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App Association urges EU to ease AI compliance burdens on small businesses

3 Aug 2021
Topic — EU regulation establishing harmonised rules for artificial intelligence systems and their market access.
Message — The organization requests a narrower definition of high-risk AI, exemption of research from requirements, and maximum four-week approval timeframes. They argue current compliance costs of up to €330,000 upfront plus €71,400 yearly are unrealistic for small companies.123
Why — This would reduce massive compliance costs and speed market access for their small business members.45
Impact — Consumer protection may weaken if oversight requirements and risk assessment obligations are reduced.6
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Response to Liability rules for Artificial Intelligence – The Artificial Intelligence Liability Directive (AILD)

27 Jul 2021

Please find attached the feedback of ACT | The App Association (Transparency Reg. # 72029513877-54) to the European Commission’s Inception Impact Assessment for a legislative procedure to adapt liability rules to the digital age and circular economy. Anna Bosch EU Policy Associate ACT | The App Association (Transparency Reg. # 72029513877-54) Rue de Trèves 45 B-1040 Brussels
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Response to Policy Program - Digital Decade Compass

13 Jul 2021

Please find attached the feedback of ACT | The App Association (Transparency Reg. # 72029513877-54) to the European Commission’s roadmap for a Digital Compass Policy Programme. Anna Bosch EU Policy Associate ACT | The App Association (Transparency Reg. # 72029513877-54) Rue de Trèves 45 B-1040 Brussels
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Response to Revision of the EU competition rules on horizontal agreements

5 Jul 2021

Please find attached the feedback of ACT | The App Association (Transparency Reg. # 72029513877-54) to the European Commission’s Inception Impact Assessment for a Revision of the two Block Exemption Regulations for horizontal cooperation agreements and the Horizontal Guidelines Anna Bosch Policy Associate ACT | The App Association (Transparency Reg. # 72029513877-54) Rue de Trèves 45 B-1040 Brussels
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Response to Data Act (including the review of the Directive 96/9/EC on the legal protection of databases)

25 Jun 2021

Please find attached the feedback of ACT | The App Association (Transparency Reg. # 72029513877-54) to the European Commission’s roadmap for a Data Act. Anna Bosch Policy Associate ACT | The App Association (Transparency Reg. # 72029513877-54) Rue de Trèves 45 B-1040 Brussels
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Response to Declaration of Digital Principles

8 Jun 2021

Please find attached the feedback of ACT | The App Association (Transparency Reg. # 72029513877-54) to the European Commission’s Directorate-General for Communications Networks, Content and Technology on its roadmap for the "Declaration of Digital Principles – the ‘European way’ for the digital society". Anna Bosch Policy Associate ACT | The App Association (Transparency Reg. # 72029513877-54) Rue de Trèves 45 B-1040 Brussels
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Response to Digital Services Act package: ex ante regulatory instrument of very large online platforms acting as gatekeepers

4 May 2021

Please find attached the feedback of ACT | The App Association (Transparency Reg. # 72029513877-54) to the European Commission’s adopted "Digital Markets Act" proposal. Anna Bosch Policy Associate ACT | The App Association (Transparency Reg. # 72029513877-54) Rue de Trèves 45 B-1040 Brussels
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Response to Business taxation for the 21st century

31 Mar 2021

Please find attached comments of ACT | The App Association (Transparency Reg. # 72029513877-54) on the European Commission’s roadmap for a communication on business taxation for the 21st century. Anna Bosch Policy Associate ACT | The App Association (Transparency Reg. # 7202951387754) Rue de Trèves 45 B-1040 Brussels
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Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

30 Mar 2021

Please find attached the feedback of ACT | The App Association (Transparency Reg. # 72029513877-54) to the European Commission’s adopted "Digital Services Act" proposal. Anna Bosch Policy Associate ACT | The App Association (Transparency Reg. # 72029513877-54) Rue de Trèves 45 B-1040 Brussels
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Response to Revision of the NIS Directive

16 Mar 2021

Please find attached the feedback of ACT | The App Association (Transparency Reg. # 72029513877-54) to the European Commission’s Directorate-General for Communications Networks, Content and Technology on its proposal for a directive on measures for a high common level of cybersecurity across the Union, repealing Directive (EU) 2016/1148. Anna Bosch Policy Associate ACT | The App Association (Transparency Reg. # 72029513877-54) Rue de Trèves 45 B-1040 Brussels
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Response to Legislative framework for the governance of common European data spaces

13 Jan 2021

Please find attached the feedback of ACT | The App Association (Transparency Reg. # 72029513877-54) to the European Commission’s Directorate-General for Communications Networks, Content and Technology on its proposal for a “Regulation on European Data Governance”. Anna Bosch Policy Associate ACT | The App Association (Transparency Reg. # 72029513877-54) Rue de Trèves 45 B-1040 Brussels
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Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

6 Oct 2020 · To discuss the Digital Markets Act.

Response to Legislative framework for the governance of common European data spaces

27 Jul 2020

Please find attached comments of ACT | The App Association (Transparency Reg. # 72029513877-54) on the European Commission’s Roadmap for a “Legislative Framework for the Governance of Common European Data Spaces” (Ares(2020)3480073) Anna Bosch Policy Associate ACT | The App Association (Transparency Reg. # 72029513877-54) Rue de Trèves 45 1040 Brussels
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Meeting with Filomena Chirico (Cabinet of Commissioner Thierry Breton)

12 Jun 2020 · Digital services Act

Meeting with Axel Voss (Member of the European Parliament)

6 May 2020 · Digital solutions in Covid crisis

Response to Report on the application of the General Data Protection Regulation

28 Apr 2020

Please see the file attached for ACT | The App Association's feedback.
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Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

17 Feb 2020 · Platform policy

Response to Evaluation of EU competition rules on horizontal agreements

3 Oct 2019

Please find attached comments of ACT | The App Association (Transparency Reg. # 7202951387754) on the European Commission’s Roadmap, “Evaluation of the two Block Exemption Regulations for horizontal co-operation Agreements” (Ares(2019)5585183-05/09/2019). Brian Scarpelli Senior Policy Counsel ACT | The App Association (Transparency Reg. # 7202951387754) Avenue Adolphe Lacomblé, 59 B-1030 Brussels
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Response to European Partnership for innovative health

27 Aug 2019

Please find attached comments of ACT | The App Association's Connected Health Initiative (CHI) on the EC's Roadmap Consultation titled "European Partnership for innovative health (Horizon Europe programme)." We are more than happy to assist in any way we can moving forward as well. ACT | The App Association (Transparency Reg. # 7202951387754) Lighthouse Europe Avenue Adolphe Lacomblé, 59 B-1030 Brussels
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Response to European Partnership for innovative small and medium-sized enterprises

26 Aug 2019

Please find attached comments of ACT | The App Association on the European Commission's Roadmap titled "European Partnership for innovative small and medium-sized enterprises (Horizon Europe programme)." We are committed to assisting the EC in any way we can moving forward. ACT | The App Association (Transparency Reg. # 7202951387754) Lighthouse Europe Avenue Adolphe Lacomblé, 59 B-1030 Brussels
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Response to Common chargers for mobile phones and similar devices

30 Jan 2019

Please find attached comments of ACT | The App Association regarding the EC's Inception Impact Assessment regarding common chargers for mobile telephones and other compatible devices. We appreciate the opportunity to provide this input, and stand ready to assist the EC in this matter any way we can moving forward. Brian Scarpelli Senior Global Policy Counsel ACT | The App Association (Transparency Reg. # 7202951387754) Lighthouse Europe Avenue Adolphe Lacomblé, 59 B-1030 Brussels
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Meeting with Maximilian Strotmann (Cabinet of Vice-President Andrus Ansip)

26 Oct 2018 · Standard Essential Patents

Response to Improving cross-border access to electronic evidence in criminal matters

19 Jul 2018

ACT | The App Association (App Association) appreciates the opportunity to provide input to decision-makers considering changes to the Regulation on European Production and Preservation Orders for electronic evidence in criminal matters (E-Evidence Regulation) and the Directive on the appointment of legal representatives for the purpose of gathering evidence in criminal proceedings (E-Evidence Directive). We understand these rules have been proposed to ensure law enforcement and judicial authorities can obtain the electronic evidence needed to investigate and prosecute criminals and terrorists. Please see the attached document for our comprehensive comments.
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Response to Fairness in platform-to-business relations

21 Jun 2018

Please find attached ACT | The App Association's comments.
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Response to Fairness in platform-to-business relations

22 Nov 2017

Please find attached ACT | The App Association's feedback on the EC's Impact Assessment on "fairness in platform-to-business relations"
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Meeting with Fabrice Comptour (Cabinet of Commissioner Elżbieta Bieńkowska)

10 Nov 2017 · Standard Essential Patents

Response to Improving cross-border access to electronic evidence in criminal matters

31 Aug 2017

ACT | The App Association (www.actonline.org) appreciates the opportunity to provide input to the Directorate-General for Justice and Consumers and the Directorate-General for Migration and Home Affairs on its Inception Impact Assessment regarding obstacles to accessing electronic evidence across borders in criminal investigations. The App Association represents thousands of app makers and connected device companies across the EU that use mobile technologies to produce innovative solutions that drive the dynamic global app ecosystem and digital economy. We write to provide general input on the intersection of the global digital economy and governments’ interest in accessing data for criminal investigations, as well as to provide detailed feedback on the various potential paths forward. We urge your review of the attached, which contains our input in whole. Brian Scarpelli Senior Policy Counsel bscarpelli@actonline.org ACT | The App Association (Transparency Reg. # 7202951387754) Lighthouse Europe Avenue Adolphe Lacomblé, 59 B-1030 Brussels
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Response to Communication on Digital transformation of health and care in the context of the DSM

16 Aug 2017

Please see attached for comments of ACT | The App Association’s Connected Health Initiative (CHI) to the Directorate-General for Communications Networks, Content and Technology (DG-CONNECT) in response to its Roadmap Consultation, Communication on Digital transformation of health and care in the context of the DSM. CHI appreciates DGCONNECT’s efforts to address future policy goals and actions in the area of digital health and care. We encourage you to contact the undersigned with any questions or ways that we may be of help moving forward. Brian Scarpelli Senior Policy Counsel Connected Health Initiative (Transparency Reg. # 7202951387754) Lighthouse Europe Avenue Adolphe Lacomblé, 59 B-1030 Brussels +1 517-507-1446 | bscarpelli@actonline.org
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Response to Standard Essential Patents for a European digitalised economy

8 May 2017

Please see attached for the comments of ACT | The App Association (Transparency Reg. # 7202951387754) to the European Commission’s Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs on its Roadmap Consultation, “Communication from the Commission on Standard Essential Patents for a European digitalised economy.” Please contact the undersigned with any questions or comments. Best regards, Brian Scarpelli Senior Policy Counsel 517-507-1446 | bscarpelli@actonline.org ACT | The App Association (Transparency Reg. # 7202951387754) Lighthouse Europe Avenue Adolphe Lacomblé, 59 B-1030 Brussels
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Meeting with Anna Herold (Digital Economy)

25 Feb 2015 · IPR Task Force