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Association européenne du cautionnement

AECM

AECM represents 47 guarantee organizations across 32 European countries that provide loan guarantees to SMEs with viable projects but insufficient collateral.

Lobbying Activity

Meeting with Michael Erhart (Director Budget) and Wirtschaftskammer Österreich

12 Dec 2025 · Commission proposals for next MFF

Response to Revision of the Rescue and Restructuring Guidelines

14 Nov 2025

The European Association of Guarantee Institutions (AECM) welcomes the European Commissions call for evidence on the revision of the Guidelines on State aid for rescuing and restructuring non-financial undertakings in difficulty. Drawing on the practical experience of AECM members in applying the current rules, we would like to highlight that the main challenge in the existing framework lies in the definition of an undertaking in difficulty (UiD), which does not fit certain categories of companies. Please find our contribution attached.
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AECM urges ringfenced SME funding in next EU budget

30 Oct 2025
Topic — The EU is consulting on future funding for competitiveness after 2027.
Message — AECM requests ringfenced SME funding through a dedicated window with significant budgetary provisioning. They demand that promotional institutions remain the primary implementers of EU guarantees.12
Why — Streamlined reporting and legal templates would reduce administrative costs and accelerate implementation.3
Impact — Commercial banks lose the opportunity to directly manage EU guarantees for profit.4
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AECM urges EU to ring-fence budget support for SMEs

29 Oct 2025
Topic — The Commission is consulting on the EU's next long-term budget for 2028-2034.
Message — AECM calls for a dedicated €70 billion SME funding window and mandatory involvement of regional authorities. They advocate for promotional institutions, rather than commercial banks, to manage loan guarantees.123
Why — Securing implementation roles for promotional institutions protects their market share and funding access.4
Impact — Commercial banks lose the ability to directly implement guarantees and earn associated profits.5
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AECM urges simpler EU State aid rules for small businesses

6 Oct 2025
Topic — The Commission is revising the regulation that exempts certain State aid from prior approval.
Message — The association suggests restructuring the regulation into modules to simplify navigation. They also request that working capital and business takeovers qualify for support.123
Why — This would reduce compliance costs and clarify rules for financial institutions and small businesses.4
Impact — Public transparency advocates lose oversight if mandatory reporting for smaller aid grants is eliminated.5
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Meeting with Jonathan Denness (Head of Unit Regional and Urban Policy) and European Association of Public Banks and Funding agencies AISBL and

15 Sept 2025 · Structured Dialogue between the EAPB, AECM, ELTI, NEFI and DG Regional Policy Unit B.3

Guarantee association AECM backs EU plan to simplify farm funding

1 Aug 2025
Topic — The consultation covers proposed legislative amendments to simplify the EU's Common Agricultural Policy.
Message — AECM urges rapid adoption of reforms to ease administrative burdens and support. They call for harmonized crisis co-financing to prevent market distortions across Europe.12
Why — Standardizing rules reduces complexity for guarantee institutions and encourages private rural investment.34
Impact — Farmers in fiscally constrained nations may suffer if crisis support depends on national budgets.5
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Response to Review of the State aid rules on the Services of General Economic Interest (“SGEI”)

28 Jul 2025

The European Association of Guarantee Institutions (AECM), representing 48 member organisations across 32 countries, welcomes the European Commissions call for evidence on the State aid rules governing Services of General Economic Interest (SGEI). AECM and its members acknowledge the urgent and widespread housing crisis affecting the EU and strongly support the need to revise the existing State aid rules to provide Member States with a more flexible and effective tool for subsidising affordable housing projects. Please find our contribution enclosed.
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Guarantee institutions urge EU to boost young farmers' financing

14 Jul 2025
Topic — This consultation seeks strategies to attract young people to the agricultural sector.
Message — The AECM requests increasing the young farmer age limit to 48. They also propose raising the aid limit for new entrants to €70,000. Finally, they advocate for expanded use of guarantee-based financial instruments.123
Why — These changes would expand the market for guarantee-based lending products.45
Impact — Land mobility schemes would harm speculators profiting from high agricultural prices.6
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Response to European Affordable Housing Plan

4 Jun 2025

The European Association of Guarantee Institutions (AECM), representing 48 member organisations across 32 countries in Europe, welcomes the European Commissions call for evidence for the European Affordable Housing Plan. AECM and its members recognise the urgent need to address the worsening housing crisis across the EU and wish to contribute concrete recommendations based on the financial expertise and on-the-ground experience of our network. Please find our recommendations enclosed.
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Meeting with Patricia Reilly (Cabinet of President Ursula von der Leyen)

4 Jun 2025 · Exchange of views on financial instruments in agriculture

Meeting with Patricia Reilly (Cabinet of President Ursula von der Leyen)

4 Jun 2025 · to follow

Meeting with Alisa Tiganj (Cabinet of Commissioner Christophe Hansen), Pawel Wisniewski (Cabinet of Commissioner Christophe Hansen)

5 May 2025 · Financing of EU agriculture provided by members of the AECM and the EAFRD

Meeting with Gijs Schilthuis (Director Agriculture and Rural Development) and

29 Apr 2025 · AECM annual conference in Berlin (Germany) and exchange of views on the financing of EU agriculture provided by members of the AECM

Meeting with Jonathan Denness (Head of Unit Regional and Urban Policy) and European Association of Public Banks and Funding agencies AISBL and

19 Mar 2025 · Structured Dialogue Meeting between the associations of NPBIs and the DG for Regional and Urban Policy.

Response to EU Start-up and Scale-up Strategy

12 Mar 2025

Please find the AECM feedback attached
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Response to Savings and Investments Union

7 Mar 2025

Please find enclosed the PDF document
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Meeting with Elisabetta Gualmini (Member of the European Parliament)

5 Feb 2025 · ECON Committee

Meeting with Valentina Schaumburger (Cabinet of Executive Vice-President Stéphane Séjourné)

5 Feb 2025 · Access to finance for SMEs, SME policy, better regulation

Meeting with Patricia Reilly (Cabinet of Commissioner Mairead Mcguinness)

19 Mar 2024 · Introduce AECM and its members

Response to Mid-term evaluation of the ERDF, the CF and the JTF 2021-2027

9 Oct 2023

Dear Commission representatives, The European Association of Guarantee Institutions (AECM) welcomes the Commissions call for evidence for a mid-term evaluation of the European Regional Development Fund (ERDF), the Cohesion Fund (CF), and the Just Transition Fund (JTF) for 2021-2027 and is pleased to provide its feedback enclosed. Thank you.
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Guarantee Institutions Seek Simpler Sustainability Rules for Small Businesses

7 Jul 2023
Topic — This consultation addresses the first set of European sustainability reporting standards.
Message — AECM calls for postponing reporting start dates and reducing requirements for small institutions. They advocate for narrowing value chain definitions to include only direct suppliers.12
Why — These changes would lower administrative costs and prevent small financiers from being overwhelmed.3
Impact — Climate advocates lose transparency regarding how smaller entities contribute to global temperature goals.4
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Response to Interim Evaluation of the InvestEU Programme

9 May 2023

Dear Sir or Madam, please find enclosed a short assessment of InvestEU by AECM and its members. Best, AECM
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Response to Evaluation of the Programme for the Competitiveness of Enterprises and small and medium-sized enterprises (COSME)

14 Apr 2023

Dear Sir or Madam, please find our feedback in the attached document. Best regards, AECM
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Meeting with Julia Lemke (Cabinet of Commissioner Paolo Gentiloni)

2 Feb 2023 · InvestEU

Response to Review of the de minimis aid Regulation

22 Jul 2022

Dear Commission representatives, The European Association of Guarantee Institutions (AECM) and the Network of European Financial Institutions for SMEs (NEFI) would like to send our contribution to Commission’s call for evidence ‘’State aid – exemptions for small amounts of aid (de minimis aid)’’. AECM and NEFI members would very much appreciate if the European Commission could take our requests into its kind consideration and remain at the Commission’s disposal to discuss further if deemed useful. Finally, we would like to thank the European Commission once again for its strong support provided to SMEs during these challenging times which makes a significant and decisive difference to the survival of so many companies facing liquidity shortages.
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Meeting with Valdis Dombrovskis (Executive Vice-President) and

28 May 2020 · COVID-19 relief measures

Meeting with Valdis Dombrovskis (Executive Vice-President) and

28 May 2020 · COVID-19 relief measures

Response to Farm to Fork Strategy

16 Mar 2020

The European Association of Guarantee Institutions (AECM) welcomes the new Farm to Fork Strategy, proposed by the European Commission as part of the European Green Deal. We strongly believe that the Farm to Fork Strategy that addresses the agricultural sector as well as the rural areas, is a key element in addressing the issues of sustainable food value chains. Against this background, the Farm to Fork Strategy should provide for a streamlined EU farming policy and the Common Agriculture Policy (CAP) must be in line with its objectives. Currently, it is unclear how the Farm to Fork Strategy will be incorporated in the CAP, and how it will work on the ground. Therefore, it is of utmost importance to ensure coherence and complementarity between EU farming policies. Further, the future CAP for 2021-2027 should be given sufficient funds to meet sustainability food challenges. Farmers are crucial for the agricultural sector yet, their limited access to finance often combined with liquidity problems, the lack of skilled workers as well as the administrative burden will jeopardize their capacity to better perform in the transition to sustainable agricultural systems. Therefore, an adequate budget to support farmers to implement sustainable business models should be ensured under the future CAP for 2021-2027, while the food industry should make full use of the great potential of the shared management financial instruments (EAFRD) as well as of the financial instruments under the InvestEU Member State compartment, both in form of counter-guarantees.
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Response to Action Plan on anti-money laundering

10 Mar 2020

AECM and its members acknowledge the efforts of the European Commission to further strengthen EU rules on anti-money laundering and counter-terrorist financing. At the same time, AECM members would like to draw attention to a double documentation and double due-diligence barrier its members are facing regarding the monitoring responsibilities of obliged entities under the 5th Anti-Money Laundering Directive (“5AMLD”). Guarantee institutions are a very particular kind of financial institution. They have a promotional mission to support entrepreneurs that have a sound business project but lack necessary collateral for the financing bank. In this situation, the guarantee institution jumps in, providing a guarantee that serves as collateral to the house bank. Guarantee institutions thereby play an important role in overcoming market failure in the area of SME finance. Any guarantee activity is necessarily linked to its underlying debt financing provided by a commercial bank. In the case of so-called portfolio guarantees, the guarantee institution even does not have any contact to the beneficiary entrepreneur. In this case, it leaves discretion to the house bank to decide which projects to finance under the portfolio guarantee. Because both the borrowers’ house bank (which grants the credit/loan) as well as the guarantee institution (which gives the necessary collateral) are “obliged entities”, they have the same legal obligations and the same monitoring and due-diligence responsibilities towards competent authorities for the very same financial transaction. This situation is highly unsatisfactory. It puts unnecessary bureaucratic burden on guarantee institutions detracting them from their promotional mission. SMEs will be affected since they need to deliver the same information twice to two different entities. And finally, supervisory authorities receive the very same information twice, which does not have any clear value added but rather increases the complexity of the data it has to manage. Furthermore, we would emphasise the very low-risk operation model that guarantee institutions represent in the financial industry. We are of the opinion that the current review shall be taken advantage of to solve the double documentation issue. This is necessary in order to avoid needless bureaucratic burden hampering business promotion. That is why AECM suggests either to: 1. Amend Article 2 of 5AMLD in a way that makes sure that only the entity granting the loan is considered to be an “obliged entity” for the due diligence and reporting requirements, but this only in situations where guarantees are granted for a specific loan and where the guarantee cannot exist without the loan or 2. Allow the reliance on third parties – such as notaries or banks - to meet not only the requirements concerning the customer identification/acceptance as given the possibility under Article 25 of 5AMLD, but also the monitoring and documentation obligations. or 3. Amend Annex II of lower risk activities in such way as to include the “accessory guarantee of payment of a loan if there is an obliged entity granting the same loan” as criterion for simplified customer due diligence procedures. Brussels, March 2020
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Response to Targeted modification of the General Block Exemption Regulation in relation to the EU funding programmes

26 Feb 2019

The European Association of Guarantee Institutions (AECM) is pleased to contribute to Commission's roadmaps on targeted modification of the General Block Exemption Regulation (GBER) in relation to the EU funding programmes. Please find enclosed our suggestions. It goes without saying that AECM is happy to contribute further to this intense work and provide the European Commission with additional information that may be required.
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Meeting with Florentine Hopmeier (Cabinet of Vice-President Jyrki Katainen)

24 Sept 2018 · AECM and UEAPME position on InvestEU proposal

Meeting with Florentine Hopmeier (Cabinet of Vice-President Jyrki Katainen) and Bpifrance and

26 Feb 2018 · The role of National Promotional Institutions in the next MFF

Meeting with Ioannis Latoudis (Cabinet of Commissioner Corina Crețu), Jan Mikolaj Dzieciolowski (Cabinet of Commissioner Corina Crețu) and

29 Jan 2018 · Position of the EU Finances

Meeting with Antoine Kasel (Cabinet of President Jean-Claude Juncker) and European Association of Public Banks and Funding agencies AISBL and Network of European Financial Institutions for Small and Medium Sized Enterprises

9 Jan 2018 · Future of EU Financial services

Meeting with Marc Lemaitre (Director-General Regional and Urban Policy) and European Association of Public Banks and Funding agencies AISBL

4 Dec 2017 · EAPB and AECM joint position on the future of EU Financial Instruments and Cohesion Funding as part of the new MFF

Meeting with Florentine Hopmeier (Cabinet of Vice-President Jyrki Katainen)

17 Oct 2017 · AECM’s position paper on the interim evaluation of the COSME programme

Response to Agricultural de minimis aid

10 Aug 2017

The European Association of Guarantee Institutions, AECM, warmly thanks the European Commission for the possibility to provide feedback on the Inception Impact Assessment regarding the possible revision of the thresholds of the agricultural de minimis aid as provided in the Commission Regulation (EU) No 1408/2013. In general, AECM is of the view that the individual farmer limits which are currently fixed at the amount of 15.000,00 EUR, as well as the national cap of at present 1 % of the annual agricultural output require more flexibility in terms of nominal size. More precisely and taking into consideration the options raised in the inception impact assessment, the individual ceiling should be increased at least to 30.000,00 EUR given that such a threshold would still be rather weak compared to those of other markets like, for instance, industry, craft and retail. In other words, the European Commission should set the revised threshold as high as it still complies with the requirement that the granting of such aid does not have a distortive impact on competition and trade. Based on our members’ experience as stakeholders in the application of the Commission Regulation (EU) No 1408/2013, AECM confirms that it is simple and implies little administrative burden to provide guarantees according to this regulation. Thus, it is of utmost importance that any future revision remains in line with a simplification approach. We would like to take this opportunity to kindly request the European Commission to introduce a more detailed definition of what constitutes de minimis aid. In the area of providing guarantees it should be decisive who bears the risk. To illustrate: A guarantee provided by a ministry of agriculture, a public entity, a state agency or a guarantee institution which is 100% public, i.e. in those cases in which the losses are born by the budget of a State, constitutes state aid and needs to comply with the de minimis regulation. The same counts for a guarantee institution which is private but whose commitments are covered to 100% by a member state. On the other hand, a guarantee given by a public entity or by a public-private entity, in both instances backed by financial means provided by private companies does not constitute state aid. AECM is happy to continue contributing to this important discussion which should lead to the best benefit possible of SMEs in the agricultural sector fostering their growth in an optimal way. About AECM’s members: The mission of AECM’s 42 members from 26 countries in Europe consists in fostering SMEs’ growth by providing guarantees to SMEs who have an economically sound project but cannot provide sufficient bankable collateral. At the end of 2016 AECM’s members had over 85 billion of guarantee volume in portfolio thereby granting guarantees to more than 2.8 million SMEs. 5 of AECM’s members are exclusively active in the agricultural sector and further 16 members are providing guarantees also for the agricultural sector. Accordingly, the discussion concerning a potential revision of the thresholds of the agricultural de minimis aid, which would have SMEs as main beneficiaries, is crucial for the activity of half of AECM’s members.
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Response to Revision of the EU SME Definition

6 Jul 2017

The European Association of Guarantee Institutions, AECM, warmly thanks the European Commission for the possibility to provide feedback on the Inception Impact Assessment regarding the possible revision of the EU SME Definition as provided in the Recommendation 2003/361/EC. Generally speaking, AECM is of the opinion that the SME Definition has proven its worth in identifying those enterprises which are confronted with market failures particularly in the area of access to finance. It is and remains essential to strike the right balance between those companies which face specific challenges and are in need of a preferential treatment in contrast to those enterprises for which such a preferential treatment would be very much welcomed without being existential. As a consequence, legal certainty is key and therefore, it is imperative to examine the two judgments of the Court of Justice from 15 September 2016 and, as the case may be, to adapt the wording of the SME Definition in order to avoid any artificial increase of the number of enterprises considered as SME or any circumvention e.g. in form of choosing specific corporate structures. Accordingly, AECM favours option 2 meaning a targeted intervention in order to respect and preserve the spirit of the Recommendation 2003/361/EC. At the same time, next to the necessary legal certainty, it must be ensured that the application remains simple and clear laying down unambiguous eligibility criteria for potential beneficiaries so that it is applied in the same way for all SMEs covered by EU legislation. Moreover, AECM fully agrees that it is appropriate to re-assess the adequacy of the financial thresholds (= annual turnover and balance sheet total). Given that the inflation growth between 2003 and 2016 amounts to 26.75%, there is a strong case for a compensation at least for inflation and productivity growth. Also an increase of the thresholds of the staff headcount should be discussed focussing particularly on unlisted small mid-caps from 250 to 500 employees. It would be useful to undertake a study at EU level on the impact of the EU SME Definition on the development of such businesses. Further adaptations like, for instance, a more flexible handling of the way the criteria are combined (e.g. an enterprise fulfilling the criteria of balance sheet and turnover, but having more than the maximum number of employees could be newly introduced as being an SME) should be very carefully examined always having in mind that a market failure needs to be addressed. In this instance, where the maximum number of employees is above that of the definition but where the other criteria are met, the maximum number should still not exceed 500 employees. AECM is happy to continue contributing to this important discussion which should lead to the best benefit possible of SMEs fostering their growth in an optimal way. About AECM’s members: The mission of AECM’s 42 members from 26 countries in Europe consists in fostering SMEs’ growth by providing guarantees to SMEs who have an economically sound project but cannot provide sufficient bankable collateral. At the end of 2016 AECM’s members had over 85 billion of guarantee volume in portfolio thereby granting guarantees to more than 2.8 million SMEs. Accordingly, the discussion concerning a potential revision of the EU SME Definition is crucial for AECM’s members who apply the EU SME Definition especially in the areas of state aid, of structural funds and as financial intermediaries of the EU financial instruments like, for instance, the Loan Guarantee Facility of COSME, the EU programme for the Competitiveness of Enterprises and Small and Medium-sized Enterprises.
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Meeting with Dermot Ryan (Cabinet of Commissioner Phil Hogan), Dermot Ryan (Cabinet of Commissioner Phil Hogan)

19 Jun 2017 · EU financial instruments in form of guarantees including the respective option of the SME Initiative

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

2 Dec 2016 · financial services agenda

Meeting with Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis) and Verband Deutscher Bürgschaftsbanken e.V. and Austria Wirtschaftsservice Gesellschaft mbH

20 Oct 2015 · Financial regulation overview

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

23 Jan 2015 · Investment Plan