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European Venture Philanthropy Association

Impact Europe (EVPA)

Based in Brussels, EVPA formed in 2004 as a non-profit, membership association gathering organisations focused on venture philanthropy (VP) and social investment (SI).

Lobbying Activity

Response to EU’s next long-term budget (MFF) – implementing EU funding with Member States and regions

28 Oct 2025

This contribution sets out Impact Europes feedback on the proposal for EUs next MFF 20282034, with a focus on ensuring that EU funding effectively drives social innovation and impact investment across all regions. Impact Europe (formerly EVPA) is the investing for impact network. We gather capital providers along the full continuum of capital (foundations, impact funds, banks and financial institutions, corporate impact actors, public funders) to increase prosperity and social progress for all, fix inequalities and injustices and preserve the planet. Together, we rally people, capital and knowledge to accelerate, scale and safeguard impact. The next MFFs impact will depend greatly on its ability to leverage private capital and on Member States willingness to co-finance blended or joint investment mechanisms. In the absence of strong social conditionalities, it is crucial to establish explicit incentives and performance-based safeguards that ensure funding genuinely advances social and environmental outcomes, preventing the risk of impact washing. While the proposal rightly focuses on flexibility and standardisation, its territorially neutral design risks concentrating resources in already-strong ecosystems and leaving behind less developed regions, particularly in Central and Eastern Europe. Moreover, the high degree of national discretion could lead to uneven implementation of social priorities, compromising the replication of successful innovation across borders. For the impact investment ecosystem, predictability, inclusiveness, and cross-regional collaboration are essential to scale what works. The MFF can play a decisive role by channeling social objectives, linking incentives to measurable results, and mobilising private investment. When paired with enabling conditions and targeted incentives, as demonstrated by successful national examples in Slovakia and Spain, impact ecosystem can mobilise private capital across Europe and nationally to create real impact through finance. Please read our full report attached.
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Response to European Innovation Act

3 Oct 2025

The European Innovation Act marks a pivotal step in strengthening Europes innovation ecosystem and is a key deliverable of the EU Startup & Scaleup Strategy. As a legislative and cross-sectoral framework, the EIA seeks to tackle long-standing structural barriers from fragmented regulation and finance gaps to limited cross-border sandboxing and underused public procurement to bring innovation to market more efficiently and equitably Impact Europe welcomes this ambition. Our contribution addresses the Commissions identified challenges, while highlighting a critical dimension: impact-driven innovation is generating social, environmental, and economic value across Europe. If the EU is to close the innovation gap and boost its competitiveness, innovation policy must not only address barriers to scale, but be guided by purpose, aligned with Europes values, and powered by capital that prioritises measurable impact outcomes. Impact Europe puts forward the following recommendations: 1. Establish a Common EU Definition for Startups, Scaleups, and Innovative Companies: A harmonised definition would reduce fragmentation, enable cross-border scaling, and provide a consistent policy baseline for startups and scaleups including impact-driven and mission-oriented enterprises to operate more easily. Without such a definition, there is a continued risk that innovation policy disproportionately favours deep-tech ventures, overlooking high-impact models addressing social and environmental challenges. The definition must therefore be inclusive of all mission-driven enterprises, ensuring they are recognised as key actors in Europes innovation ecosystem. 2. Mainstream Impact-Driven Innovation: Social and environmental impact are core drivers of innovation and should be recognised as such from the outset not as a secondary consideration. Impact-driven innovation delivers measurable public value alongside market value. The EU should develop indicators for social and environmental innovation and embed it within the European Innovation Acts monitoring framework (e.g. tracking adoption rates, impact outcomes, and public value created). This would strengthen the innovation ecosystem, crowd in more private capital aligned with purpose, and ensure the EU delivers inclusive, sustainable growth across the Single Market. 3. Finance Fit for Purpose: Mobilise Impact Capital: The European Innovation Act should create space for impact investors to co-invest with EU instruments and fuel the growth of impact-driven startups and enterprises. This means growing the impact investor pipeline and ensuring that capital aligned with public interest outcomes is part of the EUs innovation financing architecture. 4. Make Public and Private Procurement Innovation- and Impact-Friendly: Startups and impact enterprises remain largely excluded from procurement markets. The European Innovation Act should set targets for procurement to allocate a share to innovative, impact-driven suppliers, embedding innovation, social, and environmental impact as standard dimensions. Outcome-based criteria should be promoted to avoid favouring incumbents and to better support the scale of impact-driven enterprises. 5. Support the 28th Legal Regime with EU-Wide Regulatory Sandboxes: The roll out of an EU-wide framework for regulatory sandboxes would lower risks for both startups and regulators, allowing for safe testing, the speed up time to market, and the cross-border scaling of innovative and impact-driven enterprises. The success of this framework and a 28th Legal Regime would rely on the adoption of a common EU definition for startups, scaleups, and innovative companies. The European Innovation Act can become a key enabler of Europes growing impact investing ecosystem recognising the essential role of impact investors in scaling startups and enterprises that pursue innovation with purpose (Kindly refer to the attached document).
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Response to The new Action Plan on the implementation of the European Pillar of Social Rights

27 Aug 2025

On behalf of Impact Europe, I am pleased to submit our feedback regarding the new Action Plan to implement the European Pillar of Social Rights (EPSR). The EPSR is a unique blueprint for building a fair, inclusive, and competitive Social Europe. While the 2021 Action Plan laid important foundations, the rapidly evolving geopolitical, economic, and technological context makes it imperative to renew and reinforce its ambition. Our input therefore highlights: 1) the strategic role of social rights as drivers of resilience, innovation, and competitiveness; 2) the need to increase the visibility and ownership of the EPSR beyond policy circles; 3) the importance of social innovation, SMEs, and social entrepreneurs as central actors in Europes competitiveness; 3) the opportunity to mobilise impact investing and complement public budgets to finance social progress; 4) and the urgency of ensuring a balanced approach by embedding social taxonomies alongside environmental objectives. We see this renewed Action Plan not as a parallel social agenda, but as a strategic cornerstone of Europes competitiveness, supporting a workforce and society able to meet the challenges of the green, digital, and industrial transitions. We thank the Commission for the opportunity to contribute, and we stand ready to further engage, share insights from our community of impact investors and social innovators, and help shape a Social Europe that is both fair and future-proof.
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Response to Revision of EU rules on sustainable finance disclosure

28 May 2025

Impact Europe, together with the United4Impact coalition, is pleased to submit the attached paper as part of our contribution to the European Commissions consultation on the revision of the Sustainable Finance Disclosure Regulation (SFDR). The paper sets out a concrete and actionable proposal for the creation of an impact investing product category within the revised SFDR framework. Our aim is to ensure that the future EU sustainable finance architecture explicitly recognises and supports the unique role of impact investorsparticularly in addressing financing gaps for early-stage, innovative, and often unlisted enterprises that drive meaningful environmental and social progress. This submission draws on extensive feedback from members of our networks, national-level impact investing associations, policy experts, and civil society organisations. We hope it will inform the Commissions deliberations and contribute to building a more inclusive, credible, and effective sustainable finance framework. We thank you for the opportunity to provide input and remain at your disposal for any further information or discussion.
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Meeting with Antti Timonen (Cabinet of Executive Vice-President Henna Virkkunen)

24 Apr 2025 · Competitiveness

Response to EU Start-up and Scale-up Strategy

17 Mar 2025

As a network of impact investors, Impact Europe focuses on the challenges impact and social enterprises face from startup to scaleup, particularly regarding access to finance and the reporting burdens imposed by investor data requests under EU regulations. We recognise the challenges outlined in this call for evidence and welcome the initiative to improve framework conditions for startups and scaleups. However, we call the European Commission to ensure alignment between this strategy and previous efforts supporting social enterprises, such as the EUs Social Economy Action Plan and the Council Recommendation on developing social economy framework conditions. Bridging the Financing Gap: A robust ecosystem of impact investors, microfinance institutions, and social and ethical banks is key to fostering inclusive finance, ensuring sustainable and tailored funding for social and impact startups and scaleups, and driving innovative solutions to pressing social and environmental challenges. To sustain the growth of impact investing across the EU, additional funding must be allocated to InvestEU. The next EU Budget (20282034) should also increase its allocation for social impact investments, given the sectors significant funding gap. Additionally, the EIFs mandate for social impact investing must be maintained and expanded, ensuring continued support through future funding programmes. Moreover, EIF financial instruments should encourage cross-border investments, ensuring capital flows to underserved regions and closing the funding gap for high-impact enterprises. The next European Social Fund + (ESF) programme should continue to strengthen the social impact investing market by combining grants with financial instruments. The EU should support National Managing Authorities and Promotional Banks, deploying ESF+ and other funding instruments, to promote alternatives to grantssuch as repayable or blended financeto strengthen social finance ecosystems across national markets. Unlocking Untapped Capital for Impact Investing: Public sector support has been instrumental in developing impact investing in the EU. However, further scaling requires unlocking untapped capital sources, including philanthropic and retail investors, as well as institutional players like insurers, savings institutions, and pension funds. The EIB and EIF can play a key role in catalysing these capital flows. Additionally, revisions to UCITS and EuSEF frameworks could facilitate retail and institutional investments in impact funds and enterprises. By advancing these initiatives, we can ensure that any investor can engage in financing innovative solutions to social and environmental problems. Creating an Impact Category under SFDR: Impact fund managers account for nearly half of the European impact investing market. A key solution to their fundraising challenges is the creation of a distinct impact category under the Sustainable Finance Disclosure Regulation (SFDR). This would enhance their visibility, reduce confusion with other investment strategies (e.g., responsible, sustainable, and transition investing), and provide clear, accessible impact data. It would also help institutional and retail investors identify opportunities aligned with their values and risk-return profile, leading to better-informed investment decisions. An impact category under SFDR would also alleviate the disproportionate sustainability reporting burdens faced by impact and social enterprises (mostly non-listed SMEs). By ensuring that impact funds report on relevant indicators, data requests to portfolio companies would be more targeted and meaningful. Aligning this approach with the European Commissions goal of reducing administrative burdens would create a regulatory environment that supports the growth of startups and scaleups while maintaining transparency and accountability. For more in-depth analysis and recommendations, please refer to the full contribution document.
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Response to Evaluation of the Public Procurement Directives

7 Mar 2025

Public procurement accounts for 14% of the EUs GDP, representing 2 trillion annually. However, it remains underutilised as a tool to drive social and environmental progress. Social enterprises, SMEs, and start-ups face significant barriers in accessing procurement opportunities due to complex financing structures, a lack of public support, and inconsistencies in procurement policies across Member States. Despite their crucial role in the economy, SMEs secure only 45% of public contracts above EU thresholds, highlighting the need for stronger policies that facilitate their participation in public tenders. The Directive 2014/24/EU provides an important framework for integrating social and environmental considerations into procurement. It promotes fair competition, better SME access to contracts, and more efficient public spending, while also recognising the role of social businesses in fostering inclusion, employment, and sustainability. However, implementation remains inconsistent. The lack of mandatory legal obligations, limited data tracking, and the absence of standardised procurement criteria across Member States showed to be hindering public procurements full potential. Additionally, high administrative burdens, limited funding streams, and risk-averse public spending further discourage the adoption of procurement strategies that prioritise social and environmental impact. To ensure public procurement fulfils its potential as a driver of positive change, Impact Europe proposes a set of key recommendations, which include: o Stronger political ownership, ensuring procurement is recognised as a tool for achieving EU sustainability and social objectives. o Clearer legal and policy frameworks, including standardised criteria and mandatory targets for social and environmentally responsible procurement. o Improved market access for social enterprises, reducing administrative barriers and encouraging joint procurement and contract division into smaller lots. o Enhanced monitoring and data collection, requiring public buyers to report annually on procurement practices that incorporate social and environmental criteria. o Capacity building for public buyers, equipping them with the knowledge and skills to implement and evaluate social and environmental considerations effectively. Public procurement can be a powerful mechanism for fostering inclusive economic growth, promoting sustainability, and supporting the development of social enterprises. For further details on Impact Europe's recommendations for unlocking the full potential of public procurement, please refer to the annexed document. We welcome the European Commissions ongoing efforts to revise public procurement directives and remain available to collaborate for the development of a more socially and environmentally responsible procurement framework that supports social impact, innovation, and sustainability, benefiting both social businesses and society at large.
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Response to Savings and Investments Union

7 Mar 2025

Impact investors including funds, foundations, banks, corporate actors, pension funds, and insurers mobilise capital to finance solutions that generate measurable social and environmental impact alongside financial returns. Despite growing interest, raising funds remains a challenge due to limited awareness of the distinct business model and the perceived risks of investing in ventures that pursue both impact and financial performance. To scale impact investing, it is essential to unlock retail capital and attract more institutional investors, particularly insurers, savings institutions, and pension funds. The European Commissions Savings and Investments Union presents an opportunity to harness private savings for Europe's broader economic and sustainability goals. Creating a more integrated capital market in Europe through a 28th regime would help reduce regulatory burdens on investors and businesses alike. However, to fully support impact investing and channel more capital into innovative and transformative solutions, we recommend the following actions: Financial literacy must be strengthened to enable citizens to better participate in capital markets, generate long-term savings returns, and contribute to positive impact through their investments. At the same time, the availability of social and impact investment products remains limited, restricting retail investors' ability to engage. The EU should expand these offerings and scale proven solutions such as the 90/10 Solidarity Funds, which direct a portion of employee savings into social enterprises while ensuring risk diversification. However, regulatory barriers hinder their expansion across Europe. Adapting the EuSEF Regulation and the UCITS Directive would allow greater retail investor access, enable UCITS funds to allocate a share of assets to social enterprises and funds, and enable cross-border scaling of 90/10 funds. Unlocking pension capital for impact requires regulatory adjustments. Modernising the IORP II Directive would allow pension funds to consider beneficiaries sustainability and impact preferences alongside financial returns. Additionally, establishing a distinct impact category under the Sustainable Finance Disclosure Regulation (SFDR) would enhance transparency, improve impact data comparability, and strengthen credibility, enabling institutional and retail investors to allocate capital to impact more effectively. Philanthropic organisations represent another largely untapped source of impact capital, but legal barriers often prevent them from engaging in impact investing. It is essential that policies allow them to invest through programme activities while preserving their public-benefit and tax-exempt status, or via endowments that align with their mission. Finally, a key solution to unlocking institutional and philanthropic impact investments lies in leveraging the EU budget to de-risk investments. It is essential to increase the InvestEU budget for its continuation, as well as to allocate a higher budget for social impact investments in the next Multiannual Financial Framework (2028-2034), to prevent funding gaps and ensure a twin and just transition. Equally important is strengthening the role of the EIB, particularly the EIF, in developing flexible and innovative financing schemes and co-investment facilities that can better address their impact-risk-return profiles. By implementing these measures, the EU can mobilise significantly more capital for impact investing, aligning private, philanthropic, retail, and institutional investments with Europes sustainability, innovation, and competitiveness goals while fostering a resilient and inclusive economy. For a more in-depth analysis, please refer to the uploaded document.
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Meeting with Mario Nava (Director-General Employment, Social Affairs and Inclusion) and

17 Feb 2025 · Discussion on the future Multiannual Financial Framework

Meeting with Andras Inotai (Acting Principal Adviser Research and Innovation) and NASDAQ and

20 Jan 2025 · Exchange of views on the advancement of the Capital Markets Union in the EU, Discussion on the experiences from the Nordic capital markets

Meeting with Nicolas Schmit (Commissioner) and

12 Jul 2022 · Social Economy Action Plan and impact investment.

Response to Social Economy Action Plan

26 Apr 2021

EVPA welcomes the actions proposed for the Roadmap, emphasising the important role and effects of the following priorities (details in the attached paper): 1. Improving the capacity to access different kinds of resources, including tailored funding and non-financial support to reduce the funding gap for repayable finance for social economy stakeholders EVPA highlights the importance of financial intermediaries’ support for small organisations and entrepreneurs in accessing EU funding and deploying this funding through different financial instruments. It was suggested to the EU institutions to focus more on the role of financial intermediaries and to offer them additional support. The EU funding can be channelled through intermediaries such as social investment funds and foundations who have the capacity to access EU funding and can then support social enterprises. Also, payment by results were suggested by all the interviewees, rather than upfront administration efforts,as a mean to incentivize results and social innovation. Enhanced EU public-private collaboration might be achieved through further clarity and simplification brought to official communication, rather than through the regulation itself. EVPA supports the interaction between EU financial institutions and social investors and finds it highly important for the development of the social investment ecosystem. 2. Facilitate the creation, scaling-up and replication of social innovative projects As innovation is the core of the social sector,EVPA would like to actively enforce this priority and deliver in the future on developing a better framework of sharing best practices and institutionalise their learnings. However, the further development of this framework needs the harmonisations of regulations at national level. Indeed, the regulatory and fiscal environment is still fragmented among MS, hindering cross-geography scale up. 2 other key factors for success might be: strengthening the transnational cooperation on the experiences of European social innovation clusters and improving the relationship between the academic world and the social economy actors that stimulates the transfer of knowledge and technology. 3. Improving the degree of visibility and recognition of social economy organisations EVPA highlights that the development of social economy cannot be built on fragmented measures but requires an ecosystem perspective. Also, clearer communication efforts should be put forward between the EC and national public institutions,and between the national authorities and social investors. EVPA supports the SBI recommendation on promoting a consistent use of concepts and definitions, as there is a need for a common understanding and an overall framework of terms related to the social economy used in European countries. 4. Strengthening social economy in non-EU countries, in particular in enlargement and EaP’s countries A common platform of discussion on social economy set-up across the world, including all the relevant international stakeholders is highly encouraged and supported by EVPA. By collaborating with network organisations active within social economy ecosystem and having subsidiaries outside the EU, the EC can easier operationalise the proposed plans for 2021 onwards, unlocking the access to finance and collaborative work on IMM at the international level. 5. Harmonising social investment principles at the EU level and extending the Taxonomy Regulation to social matters Recently the EC took further steps on sustainable finance and EU taxonomy, adopting an ambitious and comprehensive package of measures to re-orient investments towards more sustainable technologies and business. EVPA believes that more steps are needed to integrate the social values and principles. Starting to create a generally accepted framework for Impact Measurement and Management is crucial and it could pave the way to further development of social impact investment ecosystem.
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Meeting with Michel Servoz (Director-General Employment, Social Affairs and Inclusion)

2 May 2017 · 4th year of EVPA Partnership Agreement under the Commission’s Programme for Employment and Social Innovation (EaSI)