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Associação Portuguesa de Bancos

APB

The APB's object is to promote and perform all acts that may contribute to the technical, economic and social progress of its members' business activity and to the defence of their interests in relation to any public or private, Portuguese or foreign entities' initiatives with relevance for the Portuguese banking system.

Lobbying Activity

Meeting with Maria Luís Albuquerque (Commissioner)

2 May 2025 · Financial activities in Europe

Meeting with Pedro Marques (Member of the European Parliament, Rapporteur)

7 Sept 2023 · CMDI

Response to Revision of the EU SME Definition

5 Jul 2017

The Portuguese Banking Association (APB) welcomes the Inception Impact Assessment published by the European Commission, on 8 June 2017, regarding the Revision of the EU SME Definition. FINANCIAL THRESHOLDS The APB considers that the financial thresholds set for the metrics balance sheet total and, in particular, annual turnover - provided in Recommendation 2003/361/EC should be re-assessed, to simultaneously accommodate the effect of inflation that has occurred since 2003 and business structures, which often vary, both from an economic and operational perspective, by type of industry. LEGAL CERTAINTY In APB’s view, it is essential to strike the right balance between facilitating SME access to public support and finance and preventing the set-up of corporate structures used to circumvent the SME definition. We, therefore, welcome the stated intention to review and clarify concepts and rules, which are difficult to interpret (or apply in concrete cases), with the objective to ensure legal certainty. Some of the concepts and rules needing clarification include: • The SME status in case of mergers and acquisitions; • The rules applicable to partner/linked enterprises which have such a relationship through a natural person or group of natural persons. Furthermore, for SMEs that do not qualify as microenterprises, requirements in terms of (i) corporate governance; (ii) audited financial statements; and (iii) an external certification that the company qualifies as a small and medium-sized enterprise, could be envisaged. We also strongly recommend the European Commission to review the rules applicable to companies owned by venture capital funds. Considering both the importance of qualifying as an SME for eligibility for support under many EU business-financing and support programmes (EU funds, EIB programs, EIF) and the Commissions’ recent measures to support venture capital and equity financing in the EU, we would recommend the European Commission to exclude private equity and venture capital funds from the definition of “linked enterprises”. MIDCAP DEFINITION We would suggest the European Commission to consider including in the revised recommendation the concepts/status of small midcap and midcap, which are increasingly used, namely by the European Investment Bank and the European Investment Fund, in a set of different products and which are also based on the concepts of the European Commission recommendation, namely in terms of headcount calculation. Including those concepts in the recommendation would have the advantage of clarifying the rules and creating a specific (small) mid/cap status, to be used in different EU and national instruments. IMPACT ASSESMENTS Considering the importance of SMEs for European growth and job creation, we consider of utmost importance to conduct previous thorough impact assessments, both at an EU and at a national level, of any proposed changes to the SME definition.
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Meeting with Mette Toftdal Grolleman (Cabinet of Commissioner Jonathan Hill)

10 Feb 2015 · CMU and Banking issues