Associazione fra le società italiane per azioni

ASSONIME

Assonime is a business association representing Italian joint-stock companies in industry, finance, and services.

Lobbying Activity

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

16 Jan 2026 · CSRD

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

4 Nov 2025 · European Sustainability Reporting Standards (ESRS)

Meeting with Ugo Bassi (Director Financial Stability, Financial Services and Capital Markets Union)

3 Nov 2025 · Regulatory developments (pensions)

Meeting with Maria Luís Albuquerque (Commissioner) and

22 Oct 2025 · SIU, Omnibus Package, Securitisation, Financial Literacy

Assonime Calls for Uniform EU Regulation for All Companies

30 Sept 2025
Message — Assonime advocates for a regulation creating a uniform corporate form for all companies. They suggest an optional regime offering flexibility and minimal capital requirements. It should allow easy cross-border movement and use of digital tools.123
Why — This would simplify cross-border operations and reduce costs by replacing various national laws.4
Impact — Creditors might lose traditional protections provided by mandatory minimum share capital requirements.5

Meeting with Andreas Schwarz (Cabinet of Commissioner Ekaterina Zaharieva), Elena Martines (Cabinet of Commissioner Ekaterina Zaharieva)

12 May 2025 · Elkann’s net worth is €2,7 bn.Technology is very much in the DNA of the family business and investment strategy.Elkann organises the only Italian event for tech startups.

Meeting with Martin Merlin (Director Financial Stability, Financial Services and Capital Markets Union) and Association Française des Entreprises Privées / French Association of Large Companies and

8 Apr 2025 · Commission Communication on the Savings and Investments Union (SIU) and Commission Omnibus Simplification package proposals concerning the Corporate Sustainability Reporting Directive (CSRD)

Meeting with Jozef Síkela (Commissioner) and

24 Mar 2025 · Global Gateway

Response to Amendment of Article 31 Union Customs Code Implementing Act

10 Mar 2025

Assonime (the Association of Italian joint-stock companies) has, among its statutory purposes, the promotion of economic and legislative development in order to support the competitiveness of national and European companies in international markets, as well as assisting businesses in ensuring a correct compliance with the legal framework. Because of this approach, we aim to contribute to the improvement of system efficiency and to the collective protection of businesses. The AEO program, and the related network of reputable traders, pursues the objectives of facilitating legitimate trade and to enhance supply chain security at a global level. Given the complexity of multinational structure of companies, we strongly support the proposed regulatory intervention on the mandatory consultation procedure between Member States to be provided in Article 31 of Commission Implementing Regulation (EU) 2015/2447. Such an intervention is necessary to provide further certainty to the AEO procedure and to help outline an even more complete and realistic assessment of a company's reliability, giving rise to benefit for both Authorities and commercial partners. The proposed regulatory intervention could also lead to a better coordination in the application of the AEO criteria among Member States. Even in the perspective of a centralized and shared information management system which is one of the goals of the projected reform of the Union Customs Code the new proposed provisions of Article 31 will establish and ensure more effective consultations, a consistent exchange of information between Member States and broader monitoring plans, in a coherent perspective of preparing for the transition to the new EU regulatory system. Since the renewed mandatory consultation procedure between Member States will enhance controlling activities by the Authorities, it would be necessary to revise all the reference documentation for businesses (SAQ, Explanatory Notes, Guidelines, e-books, etc.) in order to allow them: i) to be prepared by adjusting and adapting their internal processes and ii) to be adequately proactive during the application and the subsequent audit process. In addition, in the interest of enhancing transparency for the benefit of the businesses concerned, specific guidelines should be adopted to address national Authorities to specify in detail the subject and scope of the consultation, clarifying the criteria by which the information received will be assessed, evaluated and considered (e.g., level of non-compliance, reasons for denial, corrective measures, supplementary submission, elements to be considered in the mandatory monitoring, etc.). Further clarification should also be provided about the impact of the renewed mandatory consultation procedure on the monitoring activities that are particularly challenging in countries like Italy, where AEO holders are required to conduct annual self-monitoring. In conclusion, we strongly support the proposed regulatory intervention on the mandatory consultation procedure between Member States and we encourage the issuance of appropriate clarifications in order to ensure a coherence application within the UE and to facilitate the AEO applicant in the authorisation management.
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Response to Savings and Investments Union

6 Mar 2025

The underdevelopment of the capital market is one of the main weaknesses of the European Union economy; the fundamental marker of the underdevelopment are the small size of the EU Stock Exchanges and the decline in their liquidity, both due to the persisting fragmentation of the EU market, still based on essentially national market infrastructures, to their low degree of integration and to a complex mosaic of rules and supervisory practices that concretely hampers the establishment of an integrated financial market. CMU failed for two main reasons: no harmonisation could be really achieved with legislative instruments still providing for a wide discretion in the national implementation or, even when harmonised, offer margins of interpretation at national level; differentiated enforcement practices of NCAs. We therefore urge EU policy maker to provide for a timely and bold reform of the capital markets, in light of Draghi and Letta Reports. Our key proposal is moving toward the establishment of ESMA as the Single European Supervisor for capital markets. This means reinforcing ESMA independence, amending the composition of its highest bodies, taking stock from the ECB governance, and enlarging the areas where ESMA is Single Supervisor: ESMAs direct supervision on all CCPs and EU regulated markets and SMEs growth markets and on significant EU and extra-EU investment firms. ESMAs direct supervision on large issuers, those included in the blue-chip index and exceeding a certain threshold of market capitalization. Furthermore, the entire body of EU rules for capital markets should be consolidated into a real Single Rule Book with the following features: self-executing: all new rules set as Regulation and the existing Directives redrafted in the form and the content of Regulations; completeness: covering all the aspects necessary for their implementation, including the enforcement and the sanctioning system and the liability regime; entirety: no implementing options or flexibility left to national level; full mandatory harmonization: precluding gold plating. Meanwhile, a complementary approach could be the creation of a specific EU discipline to be applied on a voluntary base by market actors based on the 28th regime. Possible candidates: takeover rand Prospectus regulations. The European Commission should also stress test the entire legislation on capital markets in order to detect inconsistencies and overlaps, streamline definitions and the scope of application, identify significant areas of simplification, in particular, for listed companies and in the area of sustainability regulation. Another priority is enhancing the better regulation approach for future EU regulation. A set of principles should be incorporated in the mandate or practices of the institutions and technical bodies: i) the objective of fostering competitiveness shall be adopted by all the legislative institutions and technical bodies ii) impact assessment should be performed also by the other co-legislators and on the final act; iii) the implementation of the One in one out principle should be improved making mandatory for the DG leading the proposal to offset the new costs reducing other costs even in the accumulated stock of legislation; iv) think small first principle should assume a leading role, as the legislation should be designed SMEs first, and, if needed, be reinforced for the big ones on specific issues. This calibration for the big shall remain limited, not to deter SMEs from growing; v) establishing that level 1 legislation (including sanctions) is not applicable until a certain time is elapsed from the publication of the level 2.
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Meeting with Marcel Haag (Director Financial Stability, Financial Services and Capital Markets Union) and Association Française des Entreprises Privées / French Association of Large Companies and

6 Feb 2025 · Omnibus Proposal

Meeting with Cristina Dias (Cabinet of Commissioner Maria Luís Albuquerque), Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque), Larisa Dragomir (Cabinet of Commissioner Maria Luís Albuquerque) and

6 Feb 2025 · Introductory meeting to present the organisations and their work

Meeting with Lucilla Sioli (Director Communications Networks, Content and Technology)

15 Jan 2025 · Discussion on the implementation of EU data and AI regulations and challenges faced by Italian companies.

Meeting with Andrea Beltramello (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

15 Jan 2025 · Savings and Investments Union

Meeting with Michele Piergiovanni (Cabinet of Executive Vice-President Margrethe Vestager)

18 Jul 2024 · Recent developments in competition policy

Response to White Paper on Dual-Use Export Controls

29 Apr 2024

Assonime, the Association of Italian Joint-Stock Companies, welcomes the opportunity to feed into the debate regarding the necessary actions to improve the coordination of export controls on dual-use items in the European Union. The White Paper is an important document that highlights the critical issues of the current historical moment and proposes a series of solutions. Assonime considers it essential to provide feedback on every initiative proposed by the Commission, focusing on the topic of this consultation. Feedback is drawing on the results of Assonime's analysis of the Economic Security Strategy package adopted by the European Commission on 24 January 2024, the outcomes of its permanent Working Group and the First Italian Forum on export controls, recently organized by Assonime with the Italian licensing Authority at the Ministry of Foreign Affairs and International Cooperation. Please find the detailed feedback attached.
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Response to Business in Europe: Framework for Income Taxation (BEFIT)

3 Jan 2024

Assonime - Association of italian joint stock companies - welcomes the opportunity to provide comments on the Proposal for a Council Directive on Business in Europe: Framework for Income Taxation (BEFIT) COM(2023)532 final and on the Proposal for a Council Directive on transfer pricing COM(2023)529 final. Assonime recognizes the importance of the introduction of a common corporate tax system within the EU. Nonetheless, the BEFIT package still entails some complexities and issues that need to be addressed. Please find attached our feedback document.
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Meeting with Christian Ehler (Member of the European Parliament) and European Round Table for Industry and RegWatchEurope

6 Dec 2023 · EU-Wettbewerbsfähigkeit, Allgemeiner Austausch

Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson)

19 Sept 2023 · Net Zero Industry Act – Critical Raw Materials Act

Meeting with Kadri Simson (Commissioner) and

6 Sept 2023 · High level dinner before the ENSTO-E grids event – discussion on the challenges for European networks and electrification.

Meeting with Johannes Hahn (Commissioner)

22 Jun 2023 · Meeting with with Massimo Mocio – General Manager, Discussed the performance and latest developments of EU as an issuer.

Meeting with René Repasi (Member of the European Parliament, Shadow rapporteur)

24 Apr 2023 · Binnenmarktnotfallinstrument/ Single Market Emergency Instrument (SMEI) - Staff Level

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

28 Mar 2023

Please find enclosed Assonime comments on the EC proposal amending Directive 2014/65/EU and repealing Directive 2001/34/EC
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Response to Facilitating small and medium sized enterprises’ access to capital

23 Mar 2023

Our feedback to the Consultation on MAR and Prospectus is illustrated in the file attached
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Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

23 Mar 2023 · EU Green Deal

Italian business group urges optional tax framework for SMEs

26 Jan 2023
Message — Assonime recommends allowing smaller corporate groups to join the new system optionally. They suggest calculating the tax base using harmonized accounting rules to simplify compliance.12
Why — This proposal would lower administrative burdens by eliminating complex internal transfer pricing rules.34

Response to Binding Information on Customs Valuation (BVI)

17 Jan 2023

The proposal, laying down procedural rules for decisions relating to binding information in the field of customs valuation in the Implementing Regulation (EU) 2015/2447, and introducing an electronic system for binding origin and valuation information, established by the new article 21, is really welcomed and appreciated. Only the BTI decisions are currently managed through an IT system, so a modern, coherent IT management system for all the binding decisions in the Union is a deeply felt need. We wish its application could be brought forward, instead of waiting for the end of 2025. In terms of simplification and certainty, a pre-definition of the correct treatment of operations with legitimate traders, will give a solid contribution to the overall compliance and uniformity of customs operations throughout the EU. More specifically, an important and conspicuous use of the BVI will allow Customs Authorities to have valuable information in advance, increasing the effectiveness of the risk assessment. To this would thus be added an information flow on changes in the contractual terms that could increase the knowledge about specific situation and circumstances, and the growing phenomenon of complex or unusual commercial situations, including the recent changes in traditional trade patterns. All of that, traced in an IT system, together with a common data requirement for applications, could certainly increase security by countering fraud and errors. The amendment of article 16 of the Implementing Regulation, adding a new paragraph 3-bis, keeps the application of the BVI decision to only one set of circumstances for the determination of the customs value of the goods. This limitation could seem penalising for economic operators, at a first sight, but it is coherent and could instead be very useful as customs value needs as more precision and rigor as possible, and each decision has to precisely specify criteria and method related to a specific situation. The updated and integrated article 17 defines the fundamental contribution of the electronic system, both for the verification of compliance with all the requirements, in the application phase, and the verification of consistency with existing decisions relating to binding information. All the purposes and the procedural steps, like notification and exchange of data, application of rules of surveillance, through the electronic system will be fulfilled in a modern, clear, and certain way. As for the new article 21, we would like to underline the relevance of the paragraph 4 and the notification, through the electronic system, of the eventual period of extended use of a granted decision. In defining the rules underlying the issuance and the mandatory use of a granted BVI, considering the possibility that court rulings, law changes, incompatibility with the WTO Agreement on Customs Valuation or Committee on Customs Valuations decisions could affect and eventually revoke the decision, the possibility that contractual conditions may change should be considered as well. To his end, it is very important, for economic operators and their planning of commercial transactions, the amendment of the first paragraph of Article 22 of the Implementing Regulation, providing that where the customs authorities decide to grant a period of extended use, they shall specify the date on which the period of extended use of the decision concerned expires. Assonime aims to intensify its commitment to promote the broadest and most qualified knowledge of customs legislation, also for a provision of all the necessary information for obtaining a BVI (e.g., all the facts pertinent to the transaction and its consequent effective use, also in terms of commercial and supply chain planning). It would be therefore useful for the BVI database to be public and available, in compliance with a ban on disclosing confidential information.
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Response to Binding Information on Customs Valuation (BVI)

17 Jan 2023

Assonime, the association of Italian Joint-stock companies, has promoted over the years the involvement of its membership from all production sectors (food, chemical, pharmaceutical, mechanical, metallurgical, textile, etc.), with different dimension, receiving and summarising the different points of view, drawing as a conclusion that a BVI would be useful, not to say essential, to every type of company and economic operator. Decisions relating to binding valuation information (BVI decisions), meeting international standards regarding advance rulings for customs purposes, will join the decisions relating to binding tariff classification information (BTI) and to binding origin information (BOI), completing the well-established legal and operational framework. The proposal amending the Delegated Regulation (EU) 2015/2446 is welcomed and appreciated. We wish its application could be brought forward, instead of waiting for the end of 2025. Guidance on customs valuation has always been needed, as there are circumstances causing many problems for a correct determination of the customs value (such as peculiar and complex commercial situations, contracts clauses, doubt in the application of EU legal provisions, involvement of foreign parties etc.). Some provisions are difficult to apply where companies need, for instance, to take into account price reductions and adjustments, transfer pricing policy, royalties and license fees, further payments or other items related to price, or in determining the sale for the purpose of applying the transaction value, that could be difficult under certain circumstances (e.g. the actual sale for export to the EU when two successive assignments are in place).It is also necessary to know in advance criteria, method, and impact of the customs value, in order to plan business activities. A key tool like BVI decisions, established by the new article 18a and managed under the new article 20a, represents an important step forward in getting certainty for operators. There are undoubtful benefits deriving from the establishment in the EU of BVI: legal certainty, consistency in the law application, avoidance of disputes and, for economic operators, the reduction of the risk of paying a higher duty than the amount actually due. Regarding the validity of the BVI decisions, being aware of the three-year period indicated in the proposal, the BVI should have a validity period and an expiry date compatible with the timing of contractual obligations and clauses, which are often with a medium and long term. Considering the debate relating to a fixed and long validity period vs. a variable period, a five years period of validity would be preferable, in order to guarantee certainty and reliability to operators for a period which allows them to have a stable and effective planning of the transnational commercial operations. Moreover, the possibility that the contractual conditions may change should be taken into consideration. The introduction of a new letter e) in Article 10 of the Delegated Regulation (EU) n. 2015/2446, making BVI decisions subject to the same exception to the right to be heard as those applicable to BTI and BOI, is legally correct and coherent. Nonetheless, the right to be heard should have as few exceptions as possible, because operators could give useful and fundamental additional information. Further considerations on the inclusion of the derogation from the right to be heard in the procedure for issuing decisions relating to binding information would be appropriate; applicants should be given the opportunity to express their point of view. That could be particularly useful for Authorities future decisions on similar cases. It is also fundamental, again in terms of simplification and certainty, the cancellation of the third paragraph of article 19 and article 21, as applications should be submitted, and notifications should be sent using means like electronic data-processing techniques only.
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Assonime seeks reward mechanism for forced labour due diligence

29 Nov 2022
Message — Assonime requests the Commission provide guidelines and risk databases before implementation. They propose a reward mechanism for reliable companies that proactively address forced labour.12
Why — Companies would receive legal certainty and avoid economic damage from supply delays.34
Impact — European companies lose competitiveness against international rivals if controls are excessively burdensome.5

Meeting with Kadri Simson (Commissioner) and

26 Oct 2022 · Joint purchasing options.

Response to Fighting the use of shell entities and arrangements for tax purposes

5 Apr 2022

Assonime - Association of italian joint stock companies - welcomes the opportunity to provide comments on the Proposal for a Council directive laying down rules to prevent the misuse of shell entities for tax purposes and amending Directive 2011/16/EU. Assonime believes that the Proposal raises some issues which should be properly addressed in order to fulfill the objective being pursued.
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Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Association Française des Entreprises Privées / French Association of Large Companies and

12 Oct 2021 · Sustainable Corporate Governance Initiative

Response to Revision of Non-Financial Reporting Directive

13 Jul 2021

Assonime welcomes the opportunity to present its feedbacks on the European Commission Proposal on new Sustainability Reporting requirements. We share Commission’s primary goal of having a clearer and more coherent reporting framework within the EU. We agree that the EU needs a well-developed and harmonised reporting model for environmental, social and governance (ESG) information to enhance transparency and promote sustainable investments. Clear ESG reporting standards for companies are necessary to ensure that reliable, comparable and relevant information is disclosed. Nonetheless, we are concerned about the approach taken by the proposed Directive on Corporate Sustainability Reporting. In first instance, we argue that a better availability and comparability of information does not require such a prescriptive and detailed reporting obligation, which could, on the contrary, water down the disclosure of information that are actually material for investors and stakeholders of each individual company. Secondly, while the provision of a clear standard reference for the disclosure of ESG information is useful, we would like to underline that any EU initiative in this field should be firmly aligned with internationally accepted standards: otherwise, EU companies – especially those operating on international scale but also those having international and non-EU investors – would be at a competitive disadvantage toward non-EU companies and could incur additional costs for complying with the different disclosure requests of their stakeholders. Moreover, we urge the EU legislators to carefully consider any extension of the current NFRD scope and to avoid, in particular for SMEs, any unnecessary risk of high financial and administrative costs for companies who are, in particular nowadays, facing relevant recapitalisation issues that are of utmost importance to support their recovery during and after the Covid19 pandemic.
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Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Association Française des Entreprises Privées / French Association of Large Companies and

7 May 2021 · Sustainable corporate governance

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness) and Association Française des Entreprises Privées / French Association of Large Companies and

7 May 2021 · sustainable corporate governance

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Association Française des Entreprises Privées / French Association of Large Companies and

18 Dec 2020 · Sustainable finance

Response to Sustainable corporate governance

8 Oct 2020

Assonime supports the European Commission intention to favour the evolution of the EU company businesses toward a sustainable and resilient corporate growth. However, Assonime believes that the choice of policy tools for implementing such a goal should be carefully considered, as they can have unintended consequences on the incentives of companies to invest and on the effectiveness of capital markets to attract companies and to support them to grow. As a matter of fact, we think that capital markets can play a crucial role also in stimulating and supporting companies’ evolution toward sustainability. Therefore, any policy action by the EU concerning company law should be aimed to enhance such a role and not to frustrate it. On this regard, we observe that compared to its ambitious mandate the EY study appears to be rather lacking and its conclusions unconvincing, as it is based on an ideologically biased conceptual framework and on a methodologically questionable empirical analysis. Our main concerns about the EY study, fully described in the attached note, can be summarized as follows: - The data sample is not transparent and it appears strongly biased in its composition; - Both pay-out and investment findings suffer from estimation problems; - Even accepting EY figures, their interpretation in the report seems inconsistent; - Other concerns can be raised with respect to the consultation with stakeholders and to the cost-benefit analysis realized by EY, where the same problems of opacity and methodological bias are found. Addressing these issues is a preliminary and necessary step before any empirical, let alone policy, conclusion can be drawn. We therefore suggest the EC: - carrying out further analytical activities, based on a stronger transparency of criteria for the selection of the companies’ sample and a deeper investigation of the economic factors affecting corporate behaviours; - complementing it with an in-house impact assessment of possible policy options, with a transparent and comprehensive involvement of relevant stakeholders; - avoiding specific and premature proposals for legislative reform in delicate areas of company law (as the purpose of the companies and directors’ fiduciary duties), as they would be based on an unproven, and we suspect distorted, assessment of the companies attitude toward the time horizon of their strategy. We are available to provide any possible contribution to such activities. For this purpose, the attached note provides general remarks on both the due diligence in the supply chain and the directors' fiduciary duties.
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Meeting with Paolo Gentiloni (Commissioner)

14 May 2020 · Covid19 impact on economy and situation in Italy

Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union) and KfW Bankengruppe and

8 Jul 2019 · Capital Markets Union Working Group

Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis)

24 Jul 2018 · Sustainable Finance

Meeting with Sebastian Kuck (Cabinet of Commissioner Jonathan Hill)

8 Oct 2015 · IFRS