Almega

Almega arbetar för att svenska tjänsteföretag att ha bästa möjliga förutsättningar för behålla, driva och utveckla sina verksamheter genom en sund och konkurrenskraftig arbetsmarknad.

Lobbying Activity

Response to Digital package – digital omnibus

14 Oct 2025

Almega is the largest employers' organization in the private service sector in Sweden. We represent 10,000 companies covering 60 service industries, employing more than 500,000 individuals. Almega welcomes the digital omnibus and its aim to simplify existing legislation. The top priority should be to reduce administrative burdens in the AI Act and to eliminate overlaps between the AI Act and other EU legislation. In order to unleash the potential of AI EU must ensure clear and proportionate digital regulation that fosters innovation and growth. To reduce legal overlaps and promote legal certainty, Almega offers the following ten recommendations: 1. Set realistic implementation deadlines for High-Risk AI systems 2. Harmonize EU AI standards with international standards 3. Ensure harmonized guidance and oversight between the AI Act and GDPR 4. Modernize copyright law to meet AI challenges 5. Integrate strong trade secret protections within data sharing requirements 6. Reconcile transparency requirements with copyright in access to training data 7. Coordinate and harmonize the AI Act with the Platform Work Directive, NIS2, and public sector confidentiality rules 8. Apply a risk-based approach to SMEs 9. Streamline legal obligations for the use of algorithms in the workplace 10. Promote innovation and growth for SMEs on digital platforms
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Meeting with Arba Kokalari (Member of the European Parliament)

25 Sept 2025 · Labour market policy

Response to Evaluation of the Public Procurement Directives

6 Mar 2025

Almega is Swedens leading employers organization for companies within the service sector. Almega's member surveys on public procurement (see attached file) show that the following are the most important reasons why service companies refrain from participating in public procurement: Too much focus on the lowest price Too time-consuming formalities Too many and irrelevant requirements to fulfil It is important that these challenges are taken seriously to make possible for service companies to participate in public procurement and thereby contribute to the development and benefit of the public sector. Almega would like to highlight the following aspects to consider in the upcoming review of the EU's procurement directive. * The EU principles of transparency, equal treatment, non-discrimination, proportionality and mutual recognition are vital to safeguard the suppliers interest of fair treatment in public procurement procedures. These principles must be corner stones also in the revised directives. * We believe that all companies should have the right to participate in public procurements of social and other specific services regardless of their organizational form. We suggest this should be clarified in the directives. Otherwise there is a risk for less competition and less contribution to the social purposes at stake. * Almega's surveys show that service companies are experiencing major challenges caused by strong focus on lowest price in procurements. Hard price pressure lead to increasing risks at the expense of seriousness and quality in the execution of the assignments. The price level is of course an important aspect when evaluating tenders in public procurement. In situations where the price level ends up at an unjustifiably low level that does not provide conditions for a serious and qualitative delivery, there is however a need for measures to scrutiny and rejection. The provisions regarding exclusion of abnormally low tender prices have proven difficult to apply in order to put a stop to unscrupulous actors. To remedy the situation, we propose the following measures to be taken: - Floor prices should be explicitly allowed, at least in situations/sectors where there is a problem with low pricing. - The conditions for reviewing and rejecting abnormally low tenders should be analyzed and made more efficient. Service companies appreciate the use of fixed prices with evaluation on qualitative values, provided that the fixed prices are set at appropriate levels. The use of fixed price procurements is however not clearly regulated, which may inhibit their use. We would encourage clarification that fixed-price procurements are permitted. * Procurements that focus on the need to be met within the scope of the assignment create incentives for innovation. Functional requirements can also reduce companies' present challenges regarding extensive and detailed requirements. The new directives would benefit from encouraging contracting organizations to form procurements based on functional requirements. * Negotiation within the procurement processes can create better and mutual understanding of the conditions for assignment. The possibility of negotiation is appreciated by many tenderers. We suggest that negotiation should be allowed without restrictions in all procurement procedures, i.e. including current open and selective procedures. * In order to facilitate the procurement procedures we suggest the directives should solely stipulate how to buy and not what to buy. Issues on environmental, social and labour conditions should be regulated in other legislations, common standards and collective agreements. * We consider the threshold values should not be increased since that would expand the challenges for cross-border tenders within the European Union.
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Response to Single Market Strategy 2025

31 Jan 2025

Almega is the largest employers' organization in the private service sector. We represent 11,500 companies covering 60 service industries, employing more than 600,000 individuals. The Swedish private service sector accounts for more than half of Swedens GDP and employs 2,5 million people. The private service sector accounts a third of Swedens exports and generates four out of five new jobs. Almega warmly welcomes the upcoming Single Market Strategy, Deepening and strengthening the single market is essential to boost long-term competitiveness and productivity in Europe. The main priority for the Commission in their work ahead should be services, where the problem with regulatory burden and red tape is notably extensive. The overall regulatory burden stops service companies from even considering expanding their business to Europe or seconding staff abroad. Most service companies are SME: s and therefore do not work with the legal framework on a day-to-day basis. More uniform implementation and enforcement of legislation is key to facilitating the function of the single market. Hence, the following three proposals would be particularly valuable for the EU-commission to consider as part of the upcoming work: 1. Conduct a comprehensive assessment and create an action plan to complete the implementation of the Services Directive. Despite that the Service Directive came into effect in 2009, no more than 60 percent of the barriers and obstacles that existed 20 years ago still exist today. The Commission should make a comprehensive assessment of the implementation of the Services Directive, with a focus on mobility within the Single Market. Once the assessment is done, the Commission should create an action plan based on the findings to streamline enforcement and conclude the implementation. 2. Apply the principle of mutual recognition as a general rule for services. The principle of mutual recognition, which applies for the free movement of goods, does not apply to services, which creates large trade barriers for services. This should be the general rule also for services. Today, there are over 5,700 regulated professions around the union, and about 140 non-medical professions are regulated in only one EU country. As a first step, the Commission could start working towards reducing the number of regulated professions when regulated only in one or a few member states. by urging Member States to increase mutual recognition of qualifications and skills at the national level. 3. Establish a fast-track procedure to the Court of Justice of the European Union (CJEU) for special cases related national rules infringing to the single market. The uneven and weak enforcement of EU-initiatives around the EU is a major concern, which creates instability, unpredictability, and, the risk of damaging the overall credibility of the single market. To toughen enforcement and speed up the process, we suggest that there should be a fast-track procedure to the CJEU for specific legal cases relating to the single market. Furthermore, it should be possible to suspend national laws that are contrary to the single market from the inception of an infringement proceeding. To conclude, the function of the single market is not only limited to the specific legislation regarding goods and services. For example, the single most important asset of service enterprises is individuals competences, which means that free movement of people and flexible labor mobility is a prerequisite for an overall functioning single market. One must also not separate discussions about digital services from other services. Liberalizing the flow of data and harmonizing digital regulatory frameworks are essential steps to create one single market for data. Finally, a well-functioning trans-European infrastructure needs to be prioritized for the internal market to reach its full potential. Please, read more about our proposals in the attached position paper!
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Meeting with Arba Kokalari (Member of the European Parliament)

3 Dec 2024 · Internal market for services

Meeting with Karin Karlsbro (Member of the European Parliament) and EUROPEAN SERVICES FORUM

24 Sept 2024 · Presentation av tjänstesektorn

Meeting with Jörgen Warborn (Member of the European Parliament) and Pfizer Inc.

17 Jul 2024 · Trade

Meeting with Jakop G. Dalunde (Member of the European Parliament)

30 Jan 2024 · Transport policy

Meeting with Jakop G. Dalunde (Member of the European Parliament)

12 Dec 2023 · Transport policy

Meeting with Werner Stengg (Cabinet of Vice-President Věra Jourová)

8 Nov 2023 · Overview on Vice-President's policy priorities on digital

Meeting with Karin Karlsbro (Member of the European Parliament)

8 Nov 2023 · EOV on Swedish priorities in the EU, trade and EU actualities