Confederation of Family Organisations in the European Union

COFACE

COFACE Families Europe promotes the well-being and security of families in a changing society.

Lobbying Activity

COFACE Families Europe urges funding for family-led cyberbullying support

29 Sept 2025
Message — The organization calls for adequate funding to provide parents with resources for handling cyberbullying. They also recommend a flexible definition that covers threats made through artificial intelligence technologies.12
Why — Securing dedicated EU funding would allow these groups to maintain and expand their support operations.3
Impact — Online platforms would face new costs for mandatory safety features and content moderation tools.4

Response to The new Action Plan on the implementation of the European Pillar of Social Rights

9 Sept 2025

COFACE Families Europe welcomes the European Commissions efforts to renew the Action Plan for implementing the European Pillar of Social Rights and highlights the urgent need to strengthen the family dimension of EU social and employment policies. Families are at the core of Europes social fabric, yet policies often overlook their realities, particularly those of carers, single parents, and families in vulnerable situations. COFACE calls for an ambitious, family-centred approach across 6 key areas: 1. Strengthening the Family Dimension of the Union of Skills Education and training policies frequently fail to address family realities, creating barriers for parents and carersespecially single mothers, families with disabilities, and low-income households. COFACE proposes a Family Test to ensure EU-funded programmes are accessible to all. Inclusive education must be prioritised, including full participation of children with disabilities and stronger anti-discrimination measures in schools. Digital inequalities persist, with 5.4% of children digitally deprived; bridging this divide requires investment in digital upskilling for disadvantaged groups and inclusive workplaces. 2. A Strong Gender Equality Strategy Post-2025 Despite progress, the gender care and employment gaps remain wide. Women still do most unpaid care work, face discrimination in hiring, and remain underrepresented in leadership. COFACE urges a post-2025 strategy that: Expands accessible care services to reduce the gender care gap. Strengthens corporate reporting on pay gaps, leadership representation, and parental leave uptake by fathers. Applies a multi-generational and intersectional approach, recognising diverse family forms and overlapping vulnerabilities. Ensures full implementation of anti-discrimination directives to create inclusive labour markets. 3. Effective Implementation of the Work-Life Balance Directive The Directive remains inadequately transposed in most Member States. COFACE calls MS to provide adequately paid, non-transferable leave for both parents and carers, alongside flexible uptake arrangements. The persistent childcare gapwhere families struggle between the end of parental leave and access to formal childcarerequires urgent EU-level action. Additionally, the Action Plan should promote a right to disconnect, fair telework rules, and health-promoting workplaces, particularly to support older workers. 4. Boosting the European Care Strategy and Quality ECEC The needs of informal carers remain insufficiently addressed. COFACE calls for an ambitious long-term care action plan, greater EU support for service providers, and a European platform to strengthen dialogue and transparency. For ECEC, investments are critical to reach 2030 targets: ensuring adequate staff-child ratios, well-trained and fairly paid staff, and strong partnerships with parents. 5. Stepping Up the European Child Guarantee Child poverty and social exclusion remain pressing challenges. The EU should foster cross-sectoral coordination (e.g., family hubs integrating education, housing, health, and transport services), supported by ESF+ and ERDF investments. Family support services must be universally accessible and range from general to highly specialised. COFACE also stresses the need to integrate family perspectives into energy poverty policies, ensuring benefits account for household size and specific family needs. 6. Better Data on Families and Care Relations EU social surveys often fail to capture realities of caregiving both within and beyond households. Improved monitoring tools are essential, including an EU-SILC ad hoc module on Adult Care & Work, and distinctions between family and household types. Better data on unpaid care work will allow evidence-based policymaking and reduce risks of reinforcing inequalities. Families, in all their diversity, are essential to Europes resilience and prosperity; the new Action Plan must fully recognise and support them
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COFACE Families Europe urges tougher EU rules on finance and AI

29 Aug 2025
Message — The organization calls for harmonized EU credit assessments and a total ban on energy disconnections. They also advocate for an AI liability regime and stricter rules against exploitative digital marketing targeting children.12
Why — Vulnerable households would gain financial security through lower risks of debt and disconnection.3
Impact — Lenders and technology firms would lose the ability to avoid legal responsibility.4

Meeting with Lucie Davoine (Acting Head of Unit Justice and Consumers)

2 Jul 2025 · Exchange on all policies related to disability, particularly on current developments in employment policies for persons with disabilities at the French and EU levels.

Meeting with Glenn Micallef (Commissioner) and

26 Jun 2025 · Introductory meeting

Meeting with Roxana Mînzatu (Executive Vice-President) and

17 Mar 2025 · The preservation of children’s rights on the agenda

Meeting with Magnus Brunner (Commissioner) and

26 Feb 2025 · Child participation, protection of children’s rights in migration, protection of children from crime

COFACE urges extension of child sexual abuse detection rules

12 Feb 2024
Message — The organization supports a minimum two-year extension to prevent legal gaps in child protection. They also demand a long-term regulation that mandates safety by design for online platforms.123
Why — Extending these rules allows detection and removal of harmful material to continue uninterrupted.45
Impact — Digital privacy advocates and users lose legal protections against the automated scanning of private messages.6

Response to Establishing the digital euro

6 Sept 2023

-Ensure that cash has the same mandatory legal tender status as the digital euro to avoid skewing the balance between digital payments and use of physical cash (bank notes and coins), as these means of payment remain extremely important for vulnerable groups (elderly, undocumented migrants, homeless etc) -Revise the AML rules to ensure that marginal or excluded groups, especially those having trouble providing all of the required documentation, can access a digital euro account. The upper holding limits and restrictions on the number of transactions should be more than enough to prevent money laundering. -We fully support the necessity for public authorities (regional authorities or postal offices) to also distribute digital euro accounts to natural persons. This point should be reinforced, and these entities should receive adequate support in order to be able to open such accounts without any impediments. -Public authorities should also offer dedicated hardware devices or cards in order to ensure that vulnerable groups who may not have access to a mobile phone, can still access and use their digital euro accounts. -We fully support a digital euro with no cost for the end user. However, costs should be at the very least, lower than the current private means of payments for merchants, otherwise how can regulators justify making the acceptance of the digital euro mandatory. -The digital euro should enable micro-payments and transactions (below 1 cent), as this is a major feature necessary to support industry 4.0 and the decentralized internet. Many services already break down payments into micro-transactions (for instance, artists on Spotify receive a fraction of a cent for each listen). -Holding limits may be a problem: if an end user does not have a linked bank account to his digital euro account, what would happen if the amount of euro he/she holds goes above the limit? Would the transaction fail? Where would the excess money go? Also, what would happen if an end user with no linked bank account wishes to make a digital payment which is higher than the maximum holding limit? The holding limit is also an extra burden in keeping track of transactions for merchants, since many payments might be split between the digital euro account, and the linked bank account, creating unnecessary extra transactions because of the holding limit. The upper holding limit defies the purpose of ensuring that people who are currently unbanked or financially excluded can access the digital euro, since having a linked bank account seems very much like a de facto requirement, given the upper holding limit, even though the draft regulation stipulates that having a linked bank account isnt mandatory. Furthermore, creating an upper holding limit which is tied to the person, and not to the digital euro account further restricts the use of the digital euro. -The digital euro accounts of natural persons should accrue interest at a rate equivalent to the ECB's base rate, thereby ensuring equitable treatment and establishing parity with the advantages that banks enjoy by depositing their funds with the ECB. This would also ensure that private banks adjust the interest rates of their savings accounts in a timely fashion, as opposed to the current situation, where interest rates of savings accounts quickly plunged to 0% as the ECBs base rate went down, but remained low even though the base rate increased over the past year. -The digital euro should prompt a major revision of monetary policy and the functioning of the debt-based financial system. While the digital euro poses systemic risks for banks if users could convert all of their existing funds into digital euro, setting up the digital euro could also break the too big to fail phenomenon in banking, enabling banks to fail, while the funds of existing users are converted into digital euro. It could therefore also foster greater financial stability as well, in case of a major banking crisis.
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Meeting with Milan Brglez (Member of the European Parliament, Shadow rapporteur)

2 Jun 2023 · Staff level meeting on the measures in support of children and their families

Response to Proposal for a Council Recommendation on long-term care

28 Mar 2022

The revision of the Barcelona targets needs to balance the needs of the parents (especially mothers) with the rights of the child. Mother’s participation in the job market is an important aspect of ECEC, but the value of it for all as a tool for child development and social inclusion must be stressed. COFACE welcomes the ambition to focus on affordability, accessibility and quality non segregated and inclusive ECEC as well as the focus on children with disabilities. To make the ECEC Recommendation work for all families: 1. Adopt a whole family, two generation approach ECEC services needs to take into account the situation of the families and of the different members (income, family type, additional support needs e.g. for children with disabilities). The needs of the parents and the children should be assessed together following a two-generation approach balancing the needs for work-life balance with the rights of all children to access quality education and childhood services. In that sense, we recommend that the recommendation references clearly relevant actions under the WLB Directive, the European Strategy for the Rights of Persons with Disabilities, the European Child Guarantee, the European Child Rights Strategy and any other relevant frameworks. 2. Review the perimeter of childcare to include new services Parents often must rely on a range of services to be able to balance work and childcare. Including service such as certified child minders into the definition of ECEC would ensure that quality standards can be applied in this type of services, whether they are formal (providing education) or non-formal (providing free time and leisure activities which are essential for the play and growth of children). It is even more important for parents of children with disabilities who are often struggling to find adapted solutions. 3. Training upskilling and reskilling of the workforce It is important to revalorize the work in formal and non-forma ECEC notably through training upskilling and reskilling the workforce and work on the gender aspect. There is a need to attract a more gender-balanced workforce into the ECEC field. In order to create inclusive and non-segregated ECEC Services it is also important to offer to the staff opportunities to boost their inclusive skills and to access trainings on discrimination and unconscious bias in order to feel confident in their work and not to unconsciously reproduce inequalities and stigmatization and to ensure the legal frameworks and funding models allow for inclusive settings from the outset. This has also to do with the ECEC indicators on quality as there is a need to focus on clear and detailed quality standards eg ratios, qualifications, size and more. 4. Refine the indicators and data collections In the new indicators, COFACE recommends creating 3 categories divided by age: 0-1, 1-3, 3-6. This means complementing the data with additional calculations of formal childcare according to the number of hours, which can then lead to ratios e.g. annual average number of hours of formal care per child aged 1-3. This would give a much more accurate picture of the situation. Particular attention should be paid to children with disabilities who sometimes have a place in ECEC, but only a few hours a week. Data collection should be pay more attention to children and families in vulnerable situation due to several intersecting factors. 5. Consultation and outreach to families in vulnerable situations Families in vulnerable situations must be informed and be consulted in the development of ECEC services and extra efforts should be made to reach out and provided ECEC services adapted to those families in an inclusive, accessible and non-stigmatizing way eg through automatic rights through the calculation of ECEC fees based on income levels. Support for parents and families should also be added to the communication effort to create this continuum of care that is adapted to family’s needs.
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Meeting with Astrid Dentler (Cabinet of Vice-President Dubravka Šuica), Iris Abraham (Cabinet of Vice-President Dubravka Šuica)

17 Feb 2022 · - European Care Strategy, including Early Childhood Education and Care and Long-Term Care. - Demographic change.

Meeting with Brenda Furniere (Cabinet of President Ursula von der Leyen), Maria Luisa Cabral (Cabinet of President Ursula von der Leyen)

3 Feb 2022 · action plan to drive change and support both children and their families

Response to Consumer Credit Agreement – review of EU rules

31 Aug 2020

COFACE-Families Europe represents millions of families as consumer units throughout the European Union, via its membership. It focuses on many topics related to the consumer agenda among which digitalization, financial services, energy poverty and vulnerable consumers. COFACE-Families Europe has followed the review of the consumer credit directive very closely, as millions of families rely on consumer credit in order to amortize their spending, especially for certain key expenditure such as a new car or investing in quality appliances to save on energy/water, renovating their homes for energy efficiency etc. We welcome the roadmap and are pleased that many of the challenges and problems raised by COFACE-Families Europe are featured in the roadmap. Here below, we will focus on the challenges and points which may not have been identified in the roadmap. - Defining “responsible lending” and especially, at which point a consumer can be deemed non-creditworthy is of utmost importance. At which point is lending to a specific risk pool considered “irresponsible lending”? Is it when 5% of the consumers are likely to default on the loan? 10%? 20%? This question can no longer be avoided and has to be addressed directly in the revision of the CCD. It is absolutely key as it is a prerequisite for enabling responsible lending to exist by clearly identifying when “responsible” lending turns into “irresponsible” lending (or in other words, which default rates among a consumer base can be considered irresponsible lending). - As regards the scope of the Directive, while the proposal does identify the emergence of certain new operators like peer-to-peer lending and the necessity to broaden the scope to cover these new operators in the Directive (same risk, same regulation), COFACE-Families Europe would like to point out the recent development and explosion of so called “Decentralized Finance” or DeFi, which enables peer-to-peer lending with no “human” intermediary. The fact that DeFi is decentralized will pose a huge challenge for regulators as it will be impossible to regulate. Indeed, DeFi runs on a public blockchain such as Ethereum, and once such a smart contract is made available, there is no way to alter or stop it. There is also no one to target regulation with as the “nearest person principle” breaks down. COFACE-Families Europe very much supports the Policy option 3: “comprehensive revision of the Directive”. In our view, it is the only way to address the challenges identified in the roadmap and the ones identified in the present consultation response. The current CCD leaves many gaps, notably with regards to the scope of the Directive, does not cover certain recent developments such as decentralized and peer-to-peer finance, and fails to accurately define key terms such as “creditworthiness” and “responsible lending”. COFACE-Families Europe looks forward to further discussing these proposals with the European Commission.
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Response to A New Consumer Agenda

4 Aug 2020

While COFACE-Families Europe supports the Commission’s efforts in protecting consumers in the face of new challenges such as sustainable development and digitalization, COFACE-Families Europe wishes to point to structural or systemic causes at the root of consumer vulnerability. Personal consumption plays a big role (50%) in securing economic growth. But given the stagnation of wages and growing inequalities, where do consumers find the financial means to increase their consumption to help fuel this economic growth? There are only two main options: more credit/debt and tapping into savings . This trend is clearly unsustainable, and will inevitably lead to difficult situations for consumers, most notably, overindebtedness, poverty and social exclusion. The new Consumer Agenda must be aligned on the objectives of the European Pillar of Social Rights and the European Semester, fostering inclusive economic growth. In short, while consumer rights are an important milestone, these rights cannot be made operational so long as key issues such as the role of consumers and consumption within the current economic and financial system, are not addressed. Potential solutions to systemic issues causing vulnerabilities that consumers face include: - Ensuring that wages follow the growth in productivity, or in other words, revalorize the importance of wages vs. capital (where most of the profits made by companies fuel dividends, are hidden in fiscal paradises or trickle up to a handful of extremely well paid executives). - Breaking from a financial system which relies, nearly exclusively, on debt (private and public) to keep the system afloat rather than relying on savings and investment (which is a consequence of the distortions in wages in the first place). - Providing adequate protection for consumers and small businesses which bear nearly all the risk for jump starting the economy, by ensuring a fair and accessible right to insolvency for both consumers and small businesses. - Reflecting on mechanisms allowing to reduce public and private debt as well as considering innovative ideas such as universal basic income to decrease the vulnerability of consumers, especially in troubled economic times. While the European Commission Roadmap does recognize two important factors for a radical change in the future, namely, green consumption and digitalization, the Roadmap falls short in identifying certain emerging trends which might pose unforeseen challenges. Two important future developments are to be taken into account: - The growing use of Artificial intelligence and sophisticated algorithms might call into question the principle of free will and therefore, the responsibility of the consumer for his/her choices. - The emergence of decentralized technologies in the digital space could have even much deeper implications for consumers and consumer protection than just focusing on platforms. While regulating platforms is a challenge to be sure, regulating decentralized platforms which provide an equivalent service to centralized ones will prove an even bigger challenge.
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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

Meeting with Ivo Belet (Cabinet of Vice-President Dubravka Šuica)

8 Apr 2020 · EU child guarantee as well as the demographic challenges

Meeting with Vytenis Andriukaitis (Commissioner) and

11 Sept 2019 · EU Platform for action on Diet, Physical Activity and Health

Meeting with Christoph Nerlich (Cabinet of Commissioner Marianne Thyssen)

14 Nov 2018 · Discussion on gender equality and families in Europe

Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans)

14 Nov 2018 · discussion on gender equality and families in Europe

Response to European Disability Strategy (2010-2020) – evaluation

25 Oct 2018

COFACE Families Europe is a European network of 58 family organisations in 23 member states representing 25 million families across Europe. We welcome the Commission's initiative of evaluating the current European Disability Strategy (EDS) to have solid bases for the next EDS post 2020. We welcome as well that an open public consultation will be accompanied by a targeted consultation to reach a larger number of stakeholders. In order to be compliant with the inclusive approach that is at the core of the UNCRPD we suggest to provide interpretation and full accessibility during targeted consultation in order to reach a larger number of respondents, that might not be able to speak English and French. Coming to the list of stakeholders to be consulted, we noticed that organisation representing families of persons with disabilities are not included. This is worrisome as at local and national level they are among the main drivers for the rights of persons with disabilities, together with organisations of self-advocates. We urge therefore to include organisations representing families of persons with disabilities in list of stakeholders, to have a more complete approach. Organisation representing families of persons with disabilities can bring important feedback not only on the rights of persons with disabilities but on those of family carers, providing the 80% of long-term care to persons with disabilities and to older people. In COFACE's opinion, part of the consultation should be focused on how the UNCRPD can be implemented through other European Initiatives including the next Multiannual Financial Framework, the European Semester, the European Pillar of Social Rights, the Digital Single Market and UN initiatives such as the Sustainable Development Goals.
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Meeting with Baudouin Baudru (Cabinet of Commissioner Marianne Thyssen) and European Association of Service providers for Persons with Disabilities and

24 Apr 2018 · MFF

Response to Quality in Early Childhood Education and Care

12 Apr 2018

COFACE Families Europe welcomes the European Commission’s initiative to put forward a Council Recommendation on Quality Early Childhood Education and Care (ECEC). We find it crucial for the achievement of a prosperous, equal and inclusive European Union, that all children have access to a variety of available, affordable and high-quality child services in the communities, including early childhood education and care. COFACE Families Europe is very much in favour of taking inclusiveness into account in the upcoming Council Recommendation. It is extremely important to provide inclusive ECEC services that will ensure the full participation of children with disabilities, Roma children, children with migrant background, or children from disadvantaged background. Unfortunately, ECEC services are often not inclusive towards children with special needs, or children from disadvantaged backgrounds, thus parents are in an extremely difficult situation when they want to return to the labour market. The Recommendation should include a list of vulnerable groups to provide concrete guidance on the need to include them in high quality ECEC services together with other children. This can be helpful for Member States when they carry out national reforms to reinforce education systems to better promote social inclusion. It is very important to provide all children with access to a variety of available and affordable childcare services in the communities. The standard ECEC must be complemented by occasional and emergency childcare, care and education services for sick children. Drop-in part-time babysitting services, multi-purpose childcare facilities, out-of hour’s childcare, and employer supported childcare can be an enrichment of the child care possibilities for families if they are accessible, affordable and of good quality. Sometimes parents of children with disabilities or disadvantaged families are not convinced ECEC are able to meet their child's needs. Therefore, services must invest in building a strong partnership with parents, who are often experts in their child's needs. Both parents and professionals can learn from one another in order to improve the child's development. An inclusive ECEC opens the path to inclusive primary and secondary school. ECEC services have a dual function, on the one hand, they hold an important educational role, and on the other hand as ‘child placement’ to allow parents to work, or to be in education or training. Childcare arrangements, their availability, affordability, accessibility and quality are a pivotal factor for women’s employment and for gender equality and reconciliation of work and family life. This gender dimension should receive adequate acknowledgment in the Council Recommendation. Nevertheless, ECEC services are also a prerequisite to reduce the risk of child poverty. There is a need to make childcare professions attractive as a career path both to men and women with adequate compensation, and to empower childcare professionals with the necessary skills and support to realise inclusion and non-discrimination of children coming from a disadvantaged background, or those who have special needs. In our experiences, there is a lack of childcare for younger children in most EU Member States, despite ECEC for children aged between 0 and 3 being the most needed for parents (mostly women) trying to re-enter the labour market after the birth of a child. It is also the area where Member States are lagging behind in the achievement of the Barcelona objectives. Therefore, in our assessment of the proposed Work-Life Balance package, COFACE has called on the European Commission and the Member States to revise upward the Education and Training 2020 targets on ECEC by aligning them with the Barcelona objectives: extending the scope to younger children, include the care dimension and set targets higher than the current Barcelona Objectives. (More information at: http://www.coface-eu.org)
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Meeting with Baudouin Baudru (Cabinet of Commissioner Marianne Thyssen) and Naturschutzbund Deutschland e.V.

28 Jan 2018 · Multiannual Financial Framework

Meeting with Monika Ladmanova (Cabinet of Commissioner Věra Jourová)

12 Dec 2017 · Work-life balance

Meeting with Sarah Nelen (Cabinet of First Vice-President Frans Timmermans) and AGE Platform Europe and EUROPEAN NETWORK ON INDEPENDENT LIVING BRUSSELS

24 Mar 2017 · Work-Life Balance

Meeting with Monika Ladmanova (Cabinet of Commissioner Věra Jourová)

12 Nov 2015 · New Start Roadmap on work-life balance and Global goals on gender

Meeting with Sarah Nelen (Cabinet of First Vice-President Frans Timmermans)

12 Nov 2015 · work-life balance and global goals on gender

Meeting with Marianne Thyssen (Commissioner)

20 Apr 2015 · Meeting with Coface delegation

Meeting with Marianne Thyssen (Commissioner)

20 Apr 2015 · Social and employment priorities

Meeting with Monika Ladmanova (Cabinet of Commissioner Věra Jourová)

8 Apr 2015 · Family issues