Danske Iværksættere
DKIV
Danske Iværksættere er en non-profit brancheorganisation, der har iværksættere i fokus.
ID: 407172747899-09
Lobbying Activity
Response to Report on the review of the Digital Decade Policy Programme
8 Jan 2026
Danish Entrepreneurs is a national business organisation representing startups and growth companies in Denmark. We work to improve framework conditions for entrepreneurship and innovation at national and European level. Please find our contribution to the consultation on the review of the Digital Decade Policy Programme attached as a PDF.
Read full responseResponse to Digital Fairness Act
24 Oct 2025
Please find attached Danish Entrepreneurs submission to the Call for Evidence on the Digital Fairness Act, where we argue that Europe does not need more rules it needs fewer, better, and simpler ones, particularly regarding targeted advertising, which is already heavily regulated. We appreciate the opportunity to contribute and remain available for any further clarification or dialogue with DG JUST and the relevant services.
Read full responseResponse to Digital package – digital omnibus
14 Oct 2025
The Digital Omnibus should not just be another legislative exercise. It is a once-in-a-century opportunity to correct the regulatory fragmentation of the past and create a truly competitive Digital Single Market. To succeed, the Commission must approach this initiative with ambition and courage. Simplification is not a technical detail but a strategic necessity for Europes future. Implementation must therefore be practical, proportionate, and designed for the real world in which startups and scaleups operate. Otherwise Europe risks repeating the very mistakes this initiative is meant to fix. For startups, simplification is not a question of convenience, it is essential to their ability to grow and compete. Complex, fragmented, and overlapping regulatory frameworks create uncertainty and impose high administrative costs that smaller companies are least equipped to bear. In the case of emerging technologies like artificial intelligence, regulatory complexity can delay adoption and innovation, limiting Europes ability to build globally competitive companies. While startups in other regions benefit from more predictable and agile regulatory environments, European founders often face a patchwork of obligations and unclear guidance, slowing down product development and discouraging cross-border expansion. Simplifying the EUs digital framework is therefore a prerequisite for ensuring competitiveness, innovation, and a thriving Digital Single Market. Startups should be able to navigate EU rules without needing extensive legal or compliance teams. Reducing unnecessary complexity would allow them to focus their time and resources on creating new technologies, serving customers, and scaling internationally. Main recommendations: - Pause the introduction of new digital legislation until the implementation and harmonisation of existing laws are complete. - Introduce clearer cookie choices without turning browsers into gatekeepers. - Ensure a clear, harmonised AI Act implementation so startups can comply and innovate. - Unlock Europes data potential with stronger enforcement, open public data, and startup-friendly access. Europes ability to compete globally in the digital economy depends on its capacity to create a regulatory environment that rewards innovation and empowers entrepreneurs. For startups, simplification is about making rules clearer, more consistent, and more proportionate. By ensuring that existing frameworks are fully implemented before new ones are introduced, and by requiring a systematic evaluation of the innovation impact of new proposals, the Commission can make the Digital Single Market more predictable and startup-friendly. A streamlined, coherent, and future-proof digital framework will help Europes startups scale faster, compete globally, and deliver the next generation of digital solutions for citizens and businesses alike.
Read full responseResponse to European Innovation Act
2 Oct 2025
Europe has world-class research and entrepreneurial talent, but too often we see breakthrough ideas fail to become thriving companies or to deliver sustainable jobs in Europe. This is due to the fragmented rules, disproportionate compliance costs, weak procurement opportunities, uneven access to infrastructures, and barriers to attracting talent that startups and scaleups face. The forthcoming European Innovation Act (EIA) is a chance to fix these structural obstacles and make Europe the best place to start and scale. To succeed, the EIA must deliver a true Single Market for innovation. Main recommendations: - Common EU definitions of startups, scaleups and innovative companies. - An innovation-friendly rulebook with mandatory innovation tests. - EU-wide mutual-recognition sandboxes and a regulatory ladder. - Unlock IPR-backed finance with standardised valuation and guarantees. - Accelerate commercialisation of public R&I with model IP terms and fast-track certification. - Guarantee fair access to research infrastructures with transparent pricing and vouchers. - Make public procurement innovation-ready with first-purchase facilities and playbooks. - Modernise talent tools with an EU baseline for stock options and mobility reforms. - Coordinate innovation policies with a joint EUMember State Innovation Board and scoreboards. - Measure what matters with annual KPIs and transparent evaluations. Startups are the fastest engines of innovation in Europe. They take high-risk research, transform it into products, and scale solutions to global challenges. Startups move with agility, experiment with new business models, and create competition that drives efficiency and growth. Europe excels in science and technology, but too few results make it to market. Startups bridge this gap. They are the actors who test whether research can survive in the real economy and turn ideas into companies, jobs, and global competitiveness. Yet, only a fraction of the worlds scaleups come from Europe. Founders face 27 fragmented markets, heavy compliance burdens, and limited access to finance and talent. These structural barriers push too many promising companies to either scale slowly or relocate outside Europe. The European Innovation Act is a unique chance to reverse this trend. By cutting fragmentation, simplifying rules, unlocking research results, and improving talent and finance conditions, the EIA can empower startups to thrive inside the Single Market. For Danish Entrepreneurs, it is clear that startups are not just beneficiaries of innovation policy. They are its delivery mechanism. If Europe wants to compete globally, it must put startups at the centre of its innovation framework. Danish Entrepreneurs fully supports the Commissions assessment of the structural barriers holding back European innovation. Startups encounter these challenges most acutely, as they lack compliance departments, lobbying power, and the resources to navigate 27 different regimes. The European Innovation Act must therefore be designed explicitly with startups at its centre. These barriers are not abstract challenges. They are the everyday obstacles faced by founders. The European Innovation Act must translate its ambition into practical reforms that remove fragmentation, simplify rules, and create a level playing field for startups across Europe.
Read full responseResponse to 28th regime – a single harmonized set of rules for innovative companies throughout the EU
30 Sept 2025
Startups and scale-ups are Europes most dynamic engines of innovation, jobs, and competitiveness. Yet, their potential is constrained by the legal fragmentation of the Single Market: 27 national company regimes create barriers to incorporation, investment, and cross-border growth. This fragmentation costs the EU economy an estimated 1.3 trillion annually and contributes to the decline in Europes share of global leading firms. Too often, European founders flip abroad to jurisdictions with simpler, unified frameworks, taking talent and value creation with them. The solution is a true 28th regime: a single, optional, EU-wide company form established through a Regulation. Unlike past half-measures such as the Societas Europaea or recent directive-based proposals, only a uniform regime can eliminate duplication and complexity. Under the 28th regime, founders could incorporate online within 48 hours, operate seamlessly across borders, attract pan-European investment, and offer employees equity recognised EU-wide. Its guiding principle must be one company, one registry, one market. Key features and principles for an effective and attractive 28th Regime - Digital-first incorporation and governance with a central EU registry. - Modern, flexible corporate structures (share classes, EU-wide venture instruments, model agreements). - Cross-border employee ownership with standardised ESOP frameworks. - Seamless operations and recognition of company actions across all Member States. - Efficient exit and failure procedures enabling entrepreneurs to try, fail, and start again. Startups and scale-ups are engines of innovation, growth, and job creation in Europe. They drive technological advancement and help address societal challenges, from healthcare to sustainability. Yet Europes startup ecosystem has been hampered by a fragmented Single Market, where 27 different national legal regimes make it difficult to start and grow a business across borders. This fragmentation is estimated to cost the EU economy around 1.3 trillion every year, limiting Europes ability to develop internationally competitive companies. Twenty-five years ago, 40% of the worlds largest firms were European; today that share has fallen to just 10%. In large part, this decline reflects how Europes status quo makes it harder for new high-growth companies to scale up. There are over 35,000 startups and 3,400 scale-ups in Europe whose full potential is held back by legal complexity and national barriers (EC, EU Startup & Scaleup Strategy (COM(2025) Communication, 28 May 2025). Recognising these challenges, the European startup community has been calling for bold reform. The European Commissions own Call for Evidence acknowledges the need to respond to calls from the business community by providing companies, in particular innovative ones, with a single set of rules to invest more easily and operate in the Single Market. In other words, Europe needs a 28th regime an optional, pan-European company legal framework that founders can choose in order to benefit from a unified set of rules across all Member States. By establishing such a regime, the EU can make it easier and faster for entrepreneurs to launch startups, scale their operations, and attract investment anywhere in the Union. Ultimately, a true 28th regime would reduce administrative burdens and costs, enhance cross-border investment, and boost Europes competitiveness by enabling startups to treat the entire Single Market as their home base.
Read full responseResponse to Consumer Agenda 2025-2030 and Action Plan on Consumers in the Single Market
29 Aug 2025
On behalf of the organisation "Danish Entrepreneurs" I hereby submit our response to the EU Consumer Agenda 20252030 Transparency Register number: 924107323782-57 In our consultation response, we highlight that Europe already has strong consumer protection rules (GDPR, CRD, UCPD, etc.). The real issue is not a lack of rules but complexity, inconsistency, and enforcement gaps. Our key messages: No more regulatory inflation: Instead of adding new layers such as the Digital Fairness Act, the EU should focus on simplifying and enforcing existing rules. Targeted advertising matters: A vital tool for startups to reach customers and compete with large players. Restricting it would hurt both entrepreneurs and consumers. Flexibility is key: Rules on digital contracts, free trials, and subscriptions must remain flexible to support innovative business models. Competitiveness and consumer protection go hand in hand: A thriving startup ecosystem means more choice, better prices, and more innovation for consumers. Conclusion: Consumer rights and startup growth are not opposites. With simplification, consistency, and innovation-friendly rules, the EU can strengthen both.
Read full responseResponse to Digital Networks Act
10 Jul 2025
Danish Entrepreneurs representing over 17,000 startups across Denmark strongly support the EUs ambition to modernize digital infrastructure through the Digital Networks Act (DNA). However, we caution that unless designed with innovation at its core, the DNA risks overregulation, reinforcing incumbents, and undermining Europes ability to lead in next-generation technologies such as AI, cloud, IoT, and quantum computing. 1. DNA must be open, proportionate, and innovation-friendly Startups need less bureaucracy and more flexibility to compete and grow. The DNA should lower barriers to market entry, reduce compliance burdens, and foster private-sector-led deployment of digital infrastructure. The Commissions promise to cut regulatory reporting by 50% is welcome, but must be translated into concrete actions that prioritize startups and SMEs as default beneficiaries. Red tape disproportionately affects early-stage companies and diverts resources from innovation. 2. Net neutrality is essential for startup success Maintaining net neutrality the principle that all internet traffic is treated equally is crucial. Proposals to introduce network fees or obligations targeting "large platforms" could create artificial ceilings for scaleups, discourage growth, and reduce investor confidence. While aimed at major players today, such thresholds could expand to cover smaller companies in the future. The South Korean experience shows that such models lead to worse service, higher prices, and lower innovation without increased infrastructure investment. Weakening net neutrality would shift Europe from an open internet to a pay-to-play model, stifling competition and access. 3. DNA must enable not limit the future of AI, cloud, and quantum To be future-proof, the DNA must actively support emerging general-purpose technologies by: Avoiding mandatory EU-only models like Gaia-X, which risk narrowing innovation and deterring investment Enabling flexible spectrum access through secondary leasing and dynamic allocation Embracing technological neutrality in infrastructure choices to ensure openness and interoperability Prescriptive frameworks or pre-approved vendor models contradict the EUs goal of being a competitive global digital leader. 4. Avoid strategic overregulation Europe must not repeat the mistakes that pushed major scaleups like Spotify, Unity, and Klarna abroad. A complex or protectionist DNA could drive talent and capital out of Europe and lock the continent into outdated technologies. The AI Act has shown that overly broad compliance obligations can become existential threats for startups. Europes digital strategy must be built on open infrastructure, open markets, and open competition. Conclusion Europe has the people, capital, and research base to lead in digital infrastructure. What we need is a regulatory environment that nurtures innovation rather than constrains it. The DNA can become the cornerstone of Europes digital future but only if it is designed with entrepreneurship in mind. Attached is our full feedback. Lets make Europe the best place to build and scale digital infrastructure not a place startups have to leave to grow.
Read full responseResponse to Cloud and AI Development Act
3 Jul 2025
Danish Entrepreneurs welcomes the EU's Cloud and AI Development Act as a key step toward strengthening Europes digital infrastructure and startup ecosystem. They emphasize five main recommendations: Open & Flexible Access: Avoid data localisation, prevent vendor lock-in, and promote interoperability in digital markets. Affordable Compute Power: Invest in sustainable data centers, modern grids, and streamline permits to ensure startups can access high-performance computing affordably. Startup-Friendly Public Procurement: Simplify tender processes, apply proportionality, and improve transparency to enable startup participation. AI Sandboxes for Real-World Testing: Support safe experimentation environments under regulatory guidance without increasing compliance complexity. Legal Clarity & Alignment: Harmonize with existing laws (e.g., Data Act), avoid redundant regulation, and provide clear safeguards for sensitive data. Conclusion: To enhance Europe's digital competitiveness, the Act must prioritize openness, global access, and startup-friendly policies that foster innovation and scalability. We hereby attach our full feedback in the PDF below.
Read full responseMeeting with Ann-Sofie Ronnlund (Cabinet of Commissioner Ekaterina Zaharieva), Elena Martines (Cabinet of Commissioner Ekaterina Zaharieva)
27 Jun 2025 · Startup-Centric Innovation Policy Reform in the EU
Response to EU Start-up and Scale-up Strategy
17 Mar 2025
Please find attached the recommendations from Danish Entrepreneurs regarding the planned EU Startup & Scaleup Strategy.
Read full responseMeeting with Werner Stengg (Cabinet of Executive Vice-President Henna Virkkunen)
12 Mar 2025 · GPAI Code of Practice
Response to How to master Europe’s digital infrastructure needs?
28 Jun 2024
See the attached consultation response.
Read full response