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EuropeanIssuers

EuropeanIssuers

EuropeanIssuers represents publicly quoted companies across Europe to EU institutions, aiming to ensure policy creates environments where companies can raise capital and deliver long-term growth.

Lobbying Activity

Meeting with Martin Merlin (Director Financial Stability, Financial Services and Capital Markets Union)

1 Dec 2025 · Debates on the simplification of the sustainable finance framework, the experience from corporates on the first year of CSRD implementation, and the relationship between sustainability and competitiveness.

EuropeanIssuers urges flexible EU-wide rules for all companies

30 Sept 2025
Topic — A consultation on creating a single harmonized legal framework for EU companies.
Message — They advocate for an optional corporate form open to all businesses. The regime should use digital tools to support companies going public.123
Why — This would lower compliance expenses by replacing the current patchwork of national laws.45
Impact — National authorities lose influence as the regime limits references to domestic laws.67
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Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

30 Sept 2025 · Simplification

EuropeanIssuers urges EU to promote tax-favored equity investment accounts

8 Jul 2025
Topic — The Commission is creating a blueprint for national savings and investment accounts.
Message — They propose tax-advantaged accounts to channel more retail savings into securities investments. The blueprint should offer high flexibility while avoiding mandatory advice and payout guarantees.12
Why — Publicly quoted companies would benefit from access to a more diverse investor base.3
Impact — Consumer groups lose protections if the accounts lack mandatory advice and guarantees.4
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Meeting with Sven Gentner (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Confederation of Danish Industry and Eni S.p.A.

23 Jun 2025 · ESRS revision and EFRAG progress report

Response to Savings and Investments Union: Directive fostering EU market integration and efficient supervision

5 Jun 2025

EuropeanIssuers and its members thank the European Commission for the opportunity to respond to this initiative. Please find attached EuropeanIssuers' input to the Call for Evidence.
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EuropeanIssuers demands simplified EU sustainable finance disclosure rules

30 May 2025
Topic — Revision of EU rules to simplify sustainable finance disclosures and prevent greenwashing.
Message — They call for aligning disclosure rules with reporting standards to avoid duplicative requirements. They propose reducing complex indicators and introducing a principle based on relevance. Furthermore, they advocate for making the EU Taxonomy voluntary for all businesses.123
Why — This would significantly lower compliance costs and reduce administrative workloads for listed companies.45
Impact — Environmental objectives may suffer if reduced transparency hinders the flow of sustainable investment.6
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Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

15 Apr 2025 · Omnibus

Meeting with Martin Merlin (Director Financial Stability, Financial Services and Capital Markets Union)

15 Apr 2025 · Speech at the General Assembly of EuropeanIssuers on the EU’s agenda for strengthening capital market, notably the Savings & Investments Union (SIU) & the latest developments on the Omnibus proposal aimed at future simplification efforts

Meeting with Jörgen Warborn (Member of the European Parliament, Rapporteur) and EUROPEAN TRADE UNION CONFEDERATION and European Coalition for Corporate Justice

10 Apr 2025 · Omnibus

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 Maive Rute (Deputy Director-General Internal Market, Industry, Entrepreneurship and SMEs)

17 Mar 2025 · Meeting with European Issuers on the impact of financial regulation on European competitiveness

Response to Savings and Investments Union

6 Mar 2025

Please find attached the feedback from EuropeanIssuers, the pan-European Association representing publicly listed companies to the EU Institutions.
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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 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

EuropeanIssuers urges regulatory pause to strengthen capital markets

31 Jan 2025
Topic — The European Commission is consulting on strategies to improve the EU Single Market.
Message — EuropeanIssuers calls for a regulatory pause and the deletion of burdensome rules that hinder access to funding. They support a mandatory competitiveness check for all new initiatives to prevent disproportionate compliance costs. They also emphasize completing the Capital Markets Union to improve financing for European companies.12
Why — Lowering administrative hurdles would reduce compliance costs and facilitate easier access to funding.34
Impact — Transparency advocates lose corporate oversight as reporting requirements are reduced to protect business secrecy.5
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Meeting with Karola Maxianova (Head of Unit Secretariat-General)

30 Jan 2025 · Simplification omnibus

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament) and Bank of America Corporation and

11 Sept 2024 · Capital Markets Union

Response to Postponement of deadlines within the Accounting Directive for the adoption of certain ESRS

19 Dec 2023

EuropeanIssuers represents the interests of publicly quoted companies across 15 European countries, covers markets worth 7.6 trillion market capitalisation, with approximately 8,000 companies. With this regard, EuropeanIssuers welcomes the Proposal for a decision amending Directive 2013/34/EU, concerning the time limits for the adoption of sector-specific sustainability reporting standards. As a pan-European organisation representing companies across diverse sectors, we have observed a consensus among our members regarding the substantial challenges posed by the simultaneous implementation of ESG reporting requirements arising from the CSRD and the Taxonomy Regulation. Commencing in 2025, large undertakings will be mandated to assess and potentially disclose more than 1000 ESG datapoints, leading to a significant administrative burden and financial costs for companies undergoing such extensive analysis. We therefore believe that companies should receive support in this process. For instance, we welcome initiatives such as the non-authoritative guidance on materiality assessment and value chain, alongside the ESRS Q&A Platform, both developed by EFRAG with the intent of aiding companies throughout this task. Nonetheless, we are of the opinion that amending Directive 2013/34/EU would further contribute to alleviating the reporting burden for companies, allowing for additional time and resources for successful implementation. Additionally, such a measure would align with President Ursula von der Leyens commitment to reducing the reporting burden by 25%, which attempts to cut red tape and reduce compliance costs. Thus, freeing entrepreneurial resources and promoting business development in the European Union. In conclusion, as we welcome the amendment to Directive 2013/34/EU, we are in favour of extending the deadline for the Commission to adopt sector-specific sustainability reporting standards through delegated acts by 30 June 2026. Warmest Regards, Florence Bindelle EuropeanIssuers Secretary General
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

26 Sept 2023 · Listed companies and CMU, ESG

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

29 Aug 2023 · Corporate Sustainability Due Diligence Directive

EuropeanIssuers Advocates for Simplified Corporate Sustainability Reporting Rules

7 Jul 2023
Topic — New European standards for corporate sustainability reporting under the Accounting Directive framework.
Message — The group requests that most sustainability disclosures depend on a company's own materiality assessment. They also seek closer alignment with international standards to reduce the overall reporting burden.12
Why — This would reduce administrative costs and protect companies from potential legal risks of self-incrimination.34
Impact — Investors and financial firms lose access to standardized data required for their own mandatory disclosures.5
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Meeting with Eva-Maria Alexandrova Poptcheva (Member of the European Parliament, Shadow rapporteur)

5 Jul 2023 · Listing Act

Response to Upgrading digital company law

9 Jun 2023

EuropeanIssuers welcomes the European Commissions proposal further expanding and upgrading the use of digital tools and processes in company law. While fully supporting the strengthening of the BRIS interconnection system and the "once-only" principle, EuropeanIssuers strongly opposes the introduction of new disclosure requirements for companies and the extension of the Directive to partnerships. Our members share common agreement on codifying the once-only principle, allowing information from foreign Commercial Registers to be accepted by authorities in other Member States. The EU Company Certificate, serving as conclusive evidence of company incorporation, is appreciated, but its content should be limited to the necessary information outlined in Article 14. Nonetheless, we identified a concern about the short timeframe for filing changes to update registers and we suggest integrating BRIS with other accessible systems without burdening companies. Regarding partnerships, we disagree with the inclusion under the Directive and the imposition of disclosure requirements. Partnerships are distinct from limited liability companies and are sufficiently regulated by national laws. Similarly, we oppose the introduction of additional disclosure requirements for groups of companies, as existing legislation already covers this aspect. Financial statements, anti-money laundering measures, and transparency directives already provide relevant information on ownership structure. We also question the necessity of disclosing the place of central administration or principal place of business when different from the registered office, as current disclosure requirements adequately identify companies. Additionally, we express concerns about the proposed preventive administrative or judicial control and legality checks during company formation, which could impose undue burdens on businesses. We expand our comments and reasoning in the document attached.
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EuropeanIssuers calls for delay in taxonomy reporting rules

3 May 2023
Topic — An EU initiative to classify environmentally sustainable economic activities for investment purposes.
Message — The group requests delaying reporting until 2025 for new environmental objectives. They want to make reporting on operational expenditure voluntary for businesses. They also suggest simplifying chemical criteria and fixing table double counting.123
Why — This would reduce compliance costs and provide more time for data collection.45
Impact — Investors and financial institutions would receive less detailed and timely sustainability data.6
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EuropeanIssuers Urges Delay in EU Green Taxonomy Reporting

3 May 2023
Topic — New EU classification for sustainable investments contributing to water protection and circular economy.
Message — EuropeanIssuers requests that requirements do not apply to the 2023 reporting year. They consider that publication of the operational expenditure metric should not be mandatory.12
Why — This would allow companies more time and significantly reduce the reporting burden.3
Impact — Investors will find it difficult to understand and utilize the taxonomy information.4
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Meeting with Alfred Sant (Member of the European Parliament, Rapporteur)

25 Apr 2023 · Listing Proposal on Multiple Share Structures

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

28 Mar 2023

EuropeanIssuers welcomes the European Commissions proposal on multiple-vote share structures (MVSS) in order to facilitate companies listing (as well as the development of an effective Capital Markets Union). Several studies and reports (Oxera Study on Primary and Secondary Market; TESG Report, HLF on CMU Report) already suggested that one of the main reasons for not listing is the loss of control fear. Currently, companies may be prevented from going public in Member States markets where MVSS are prohibited) and more broadly, as recalled by the Commission, differences in MVSS national regimes create an unlevel playing field and leads to unequal opportunities for companies when it comes to listing. In its past position, EuropeanIssuers suggested that any EU action should be limited to an enabling one, confining itself to acknowledging EU-wide the MVSS principle coupled with more limited safeguards, thus leaving MS maximum flexibility in setting out conditions around MVSS and implementing them according to their specific local circumstances. The present proposal correctly acknowledges MVSS as an effective mechanism to allow companies owners retain decision-making powers in a company while raising funds on public markets. While we agree with the proposed minimum harmonization approach leaving sufficient flexibility to Member States for its implementation, the proposal has some limitations that risk making it ineffective, especially in countries that already allow the use of these instruments. In the attached document, EuropeanIssuers provides for more detailed comments and suggestions on the Proposal for a Directive on Multiple-Vote Share Structures.
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Response to Facilitating small and medium sized enterprises’ access to capital

24 Mar 2023

EuropeanIssuers welcomes the opportunity to comment the European Commissions Proposal for a Regulation of the European Parliament and of the Council amending Regulations (EU) 2017/1129, (EU) No 596/2014 and (EU) No 600/2014. The proposals published in December 2022 represent a great effort of simplification in line with the goals of the Capital Markets Union. The reform of the EU rules on capital markets is of paramount importance as one of the factors that may contribute attracting investments and improving confidence; MAR is one of the most important pieces of legislation in that respect and for which EuropeanIssuers welcomes most of the proposed amendments. Furthermore, the proposed simplification and alleviations of the requirements in the Prospectus Regulation for companies seeking finance through financial markets will contribute to improve the effectiveness of the prospectus framework. In the attached document, EuropeanIssuers provides detailed comments and suggestions on the proposed amendments to MAR and Prospectus Regulation.
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EuropeanIssuers urges retention of intragroup reporting exemptions for companies

16 Mar 2023
Topic — Proposed amendments to the European Market Infrastructure Regulation regarding central counterparties and clearing services.
Message — The group opposes removing reporting exemptions for transactions within the same corporate group. They support allowing bank guarantees as collateral to increase flexibility. They also seek better transparency regarding how costs for clearing trades are calculated.123
Why — This would minimize compliance costs and reduce financial burdens for large industrial groups.4
Impact — EU regulators would have less visibility to assess risks within the financial system.5
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Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

8 Mar 2023 · Corporate Sustainability Due Diligence

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and EUROPEAN TRADE UNION CONFEDERATION and

7 Nov 2022 · Corporate Sustainability Due Diligence

Meeting with Jessica Polfjärd (Member of the European Parliament, Shadow rapporteur for opinion)

13 Oct 2022 · CSDDD

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

12 Oct 2021 · Sustainable Corporate Governance Initiative

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

14 Jul 2021

EuropeanIssuers welcomes the opportunity to present its feedback on the Commission’s proposal for a Corporate Sustainability Reporting Directive, for which you may find a full complete response in attachment. In sum, EuropeanIssuers shares the ideal aim of the proposed Directive 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, EuropeanIssuers is concerned about the approach taken by the proposed Directive on Corporate Sustainability Reporting, as it would define a framework that, on one side, appears too prescriptive and, on the other side, does not consider adequately the competitive issues that EU companies could face on international level, as well as the risks of high financial and administrative costs for companies, in particular in light of the effects of Covid-19 pandemic. EuropeanIssuers underlines some concerns with regards to the scope of the Directive, namely the extension of the provisions to all SMEs listed on regulated market, as well as to all large companies, and the lack of extension to non-listed non-EU companies exceeding a certain threshold of global turnover. In particular, EuropeanIssuers believes that the financial and administrative cost needed to implement the new requirements would represent a significant burden for SMEs, and therefore proposes to exempt them altogether from the discipline of CSRD, or at least suggest an opt-in mechanism allowing SMEs to use simplified reporting regimes. With regards to large companies, as first time preparers, EuropeanIssuers proposes a regime of progressive application. Finally, non-EU companies operating in the EU should be subjected to the CSRD discipline, to avoid unfair competition and social or environmental dumping. Furthermore, EuropeanIssuers believes that companies should be the ones defining what constitutes material information, according to specific activity and sector. In addition, contrary to what envisaged by the proposal, flexibility should be maintained regarding the location of non-financial information, be it in the management report or a separate one dedicate to sustainability. EuropeanIssuers also calls for more flexibility in terms of application and warning about the need of a consistent timetable. Overall, while awaiting the convergence between EU and international standards, which is crucial to avoid cumulative effects of diverging reporting obligations, EuropeanIssuers proposes that companies could decide to report under approved international standards, by justifying their choice. With regards to the digitalisation of sustainability reporting, EuropeanIssuers recommends clarity of requirements to avoid undue burden for preparers. Finally, with regards to assurance of sustainability reporting, in order to avoid a market restriction and to ensure alignment to the freedom of services, EuropeanIssuers suggests that the authorisation be made not only by auditors but also by an independent service provider. Please consult the attachment for a more comprehensive response on behalf of EuropeanIssuers.
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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

7 May 2021 · Sustainable corporate governance

Meeting with Mairead McGuinness (Commissioner) and

20 Apr 2021 · Financial sustainable - Taxonomy.

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

6 Apr 2021 · country by country reporting

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

Meeting with Geneviève Tuts (Cabinet of Commissioner Didier Reynders), Lucrezia Busa (Cabinet of Commissioner Didier Reynders)

20 Nov 2020 · Discussion on the implementation of the shareholders’ directive and other portfolio-related matters.

Response to Sustainable corporate governance

8 Oct 2020

EuropeanIssuers welcomes the opportunity to present its comments on the inception impact assessment (IIA) on sustainable corporate governance, for which you may find a full complete response in the attachment. In sum, EuropeanIssuers expresses its support for the concept of sustainable corporate governance and the link between sustainable corporate governance and long-term value creation, agreeing with the assertion that sustainability practices help reconcile economic growth, social progress and the protection of environment. However, EuropeanIssuers would like to emphasize its concerns in relation to the conclusions of the study on director’s duties on which the IIA is founded. As such, EuropeanIssuers points out methodological issues about the sample, and the problems with various substantial remarks of the study’s conclusions. In relation to the measures to address adverse sustainability impacts through the value chain, EuropeanIssuers underlines main points which should be taken into account, such as the effect of the measures on the competitiveness of European companies, the importance of maintaining legal certainty and proportionality the core of these measures, the respect of the principle of materiality and preservation of commercial secrets, as well as ensuring that EU companies are not liable for damages occurring through the supply chain unless they have directly caused the damage or intentionally contributed to it. Regarding the measures to take into account all stakeholder interests and corporate sustainability risks, impacts and opportunities into the corporate strategy, EuropeanIssuers addressed the company interest, sustainability risks, directors’ remuneration, and liability. In relation to company interest, EuropeanIssuers recommends the better assessment of the overall governance framework, which is not limited to legal provisions but includes also case law and corporate governance codes, which are both able to evolve and adapt over time, taking into consideration also stakeholders’ expectations. As to the sustainability risks, EuropeanIssuers suggests a Commission guidance document for board in order to launch an experimental phase, and mentioned that any attempt to standardise best practices that are currently evolving across companies and investors would not be desirable. Regarding directors’ remuneration, the response emphasizes that it should be up to the company to decide which qualitative or quantitative performance criteria are best suited to its sustainable strategy and to provide investors with relevant explanation on how these criteria have been applied and whether the individual targets have been met. Lastly, in relation to liability measures, EuropeanIssuers suggests to leave any decision in relation to this at the national level, considering the different civil liability regimes among the Member States. Please consult the attachment for a more comprehensive response on behalf of EuropeanIssuers.
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Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur)

29 Sept 2020 · Corporate Due Diligence

Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

8 Sept 2020

Please, find EuropeanIssuers' feedback in the attached PDF File.
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Response to Capital markets – research on small and mid-sized companies and fixed income (updated rules in light of the COVID-19 pandemic)

4 Sept 2020

Please find attached EuropeanIssuers' feedback on the draft delegated directive on research on small and mid-cap issuers and on fixed-income instruments to help the recovery from the COVID-19 pandemic.
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Response to Action Plan on the Capital Markets Union

4 Aug 2020

Please find attached the comments provided by EuropeanIssuers on the CMU Roadmap.
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Response to Delegated act on the minimum information of exemption documents describing a takeover, a merger or a division

14 Jul 2020

EuropeanIssuers welcomes the changes introduced by the Commission in comparison with the technical advice published by ESMA in July 2018 which you can find in the attached document.
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Meeting with Valdis Dombrovskis (Executive Vice-President)

16 Jun 2020 · Recovery plan; Capital Markets Union; Sustainable finance

Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans)

8 Apr 2020 · Sustainable finance, Green Deal and recovery

Meeting with Geneviève Tuts (Cabinet of Commissioner Didier Reynders)

2 Mar 2020 · General presentation of activities of the company

Response to Revision of Non-Financial Reporting Directive

28 Feb 2020

The following points are issues which EuropeanIssuers believes are necessary to address in the upcoming review of the Non-financial Reporting Directive (NFRD): • A harmonised non-financial reporting framework developed under EU leadership is needed to stop the proliferation of various public or private reporting initiatives which are not aligned and make reporting extremely time-consuming and confusing for corporates who are confronted with numerous questionnaires and ratings, based on different methodologies and definitions. • Companies should be put at the heart of the standardisation process. The non-financial reporting framework needs to be elaborated in close collaboration with companies to make sure it is operational and reflects the sustainability policies implemented by companies. • Flexibility should be maintained regarding putting non-financial information management report or a separate report dedicated to sustainability, if the quality of and public access to the information is guaranteed in the same way. For example, in Germany, where the non-financial statement can be published in a separate report, the Supervisory Board must examine the content of the non-financial report prior to its publication according to the implementation act of NFRD. The publication in a separate report has no impact on the verification by independent third parties. • Companies do accept to disclose in non-financial reports how they define materiality and which processes they have put in place to identify their material environmental, social and governance (ESG) issues. However, companies need to remain master of defining what is material information according to their specific activity and sector. The necessary flexibility allowing each company to define its own material issues may be counterbalanced by increased transparency on the methodologies applied by companies to define which environmental or social issuers are considered material. Companies are totally opposed to the introduction of an obligation to produce a negative statement, explaining why certain issues are considered as not material, which would indeed lead to illegible reports and a bureaucratic box-ticking approach of materiality. • NFRD should be extended to non-EU companies operating in the EU if they exceed certain thresholds of global turnover. All companies offering products or services in the EU should be subject to the same reporting obligations on sustainability policies and risks. Otherwise EU companies are likely to be exposed to unfair competition and social or environmental dumping. From a legal point of view, there are numerous EU regulations that already apply to non-EU companies, such as Regulation 679/2016/UE on data protection, or Directive 828/2017/ET on the encouragement of long-term shareholder engagement. Small and medium sized companies should not be included in the scope because it would create too high compliance costs for them. • The verification of non-financial information by independent third parties should provide for a plurality of competent organisations (not only auditors), which have been explicitly accredited for verifying social and/or environmental information published by companies. A rigorous process of accreditation of these independent third parties by one of the signatories of the European Accreditation Multilateral Agreement should be put in place in order to guarantee the quality, legitimacy and credibility of such verifications. It should be made clear that non-financial verification is very different in nature from financial audit as the information to be verified is different in nature, and often qualitative. Financial auditors are therefore not automatically competent in the field of non-financial verification. In the case of Member States where mandatory verification does not yet exist, appropriate transition periods should be provided for in order to allow competent independent parties to emerge.
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Meeting with Geneviève Tuts (Cabinet of Commissioner Didier Reynders), Lucrezia Busa (Cabinet of Commissioner Didier Reynders)

4 Dec 2019 · Presentation of the activities of the association

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

9 Sept 2019 · CMU, Sustainable Finance

Response to European Partnership for innovative small and medium-sized enterprises

27 Aug 2019

EuropeanIssuers is the pan-European organisation which represents the interests of publicly quoted companies from all sectors. Dedicated to serving our members from 15 countries across Europe, including Germany, France, the Netherlands, Italy, Poland and Spain, we aim to ensure that EU policy creates an environment in which companies of all sizes – from large blue-chip companies to small and mid-caps as well as emerging growth companies – can easily raise capital through the public markets and deliver growth over the longer term. EuropeanIssuers supports the efforts undertaken by the European Commission focused on providing access to Innovative and R&D intensive small and medium-sized enterprises. EuropeanIssuers believes that successful firms need to access financing on attractive terms to encourage their production, innovative activities as well as entrepreneurial people and knowledge. The success of these companies as future high-leverage innovators depends on their ability to raise funds to support their R&D activities and scale-up. Empirical evidence shows that small and start-up firms in R&D-intensive industries face a higher cost of capital than their larger competitors or firms in other industries. Three-quarters of scale-ups rely on external finance to support their growth, drawing it from a wide variety of sources. Strong and liquid capital markets support cross-border partnerships, global value-chains, new market opportunities and more overall investment in R&D. Thus, it is correct to say that deeper stock markets and venture capital lead to more innovation in SMEs and start-ups through stronger valuation and liquidity. However, reservations about the use of equity finance remain as regards its unsuitability, fears of having to “give up control” or simple lack of knowledge. Furthermore, European data shows that the growth in investment by EU-based companies is being outpaced by their US and Chinese counterparts. EuropeanIssuers is aware that innovative areas such as artificial intelligence and new materials will need a large amount of capital investment and asserts that Europe should not waste the opportunity to optimise R&D due to a lack of investment capital available to SMEs. Regardless of the policy option chosen by the European Commission, EuropeanIssuers believes lawmakers need to guarantee access to a diversified pool of alternative finance making it easier for smaller companies to get the capital they need. EU and Member States’ programmes should encourage investments in start-ups through e.g. a European Growth Fund supported by the European Investment Bank in cooperation with asset owners and fund managers. Some of the benefits of this fund could be passed to an Equity Awareness Marketing Programme, focused on training for entrepreneurs and students building awareness through, for example, education programmes in universities and advertising the link between alternative sources of finance, R&D and innovation capabilities. On another note, EuropeanIssuers also suggests the European Commission to update the current legal definition of an SME in order to reflect current economic realities (current figures date from 15 years ago). We would recommend that an SME is defined as any company that satisfies any two of the following criteria: staff headcount of under 500, turnover of equal to or less than €500 million, or a balance sheet total equal to or less than €500 million. EuropeanIssuers would also like to suggest a definition for small and mid-caps with an upper market capitalisation threshold of EUR 1 billion which is in line with the US JOBS Act as well as potential solutions such as an "SME Carveout" which may facilitate the work of the Commission and goals of the initiative. To read the specifics on this, please read the attached version of our response which should be treated as the full response of EuropeanIssuers.
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Response to A simplified prospectus for companies and investors in Europe

20 Dec 2018

EuropeanIssuers welcomes the opportunity to provide feedback to the Commission’s draft delegated act to be adopted under the Prospectus Regulation (EU) 2017/1129 as regards the format, content, scrutiny and approval of the prospectus to be published when securities are offered to the public or admitted to trading on a regulated market. EuropeanIssuers members have been closely involved in this topic which is key in facilitating access to financial markets and are strongly supportive of the Capital Markets Union. As regards the draft delegated act published for comments, please find our complete feedback in the attached annex.
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Response to EU small listed companies Act

20 Jul 2018

We welcome the opportunity to provide feedback to the Commission’s proposal on the SME Listing Package. We support the Commission’s intention to adapt existing EU rules to introduce a more proportionate regulatory approach to support listing of smaller companies. We applaud the aim to boost the number of initial public offerings (IPOs), to reduce the administrative burdens and the high compliance costs faced by SME growth market issuers, and to foster the liquidity of publicly-listed SME shares. We also welcome several specific proposals. Nevertheless, overall, we believe that more ambition is needed to achieve a fully proportional environment for smaller companies and healthy and thriving European capital markets. Small and mid-cap companies are fundamentally different from large blue-chip companies, as well as from SMEs (in terms of their growth potential, size, turnover, job creation, percentage shareholding of investors, and types of investors, among other things). As such, they require a different regulatory and market ecosystem, along with appropriate, tailored rules for these companies’ growth needs. Therefore, we strongly believe that the SME listing package should provide a definition of a small and mid-cap company enshrined in EU law. In line with the US JOBS Act, we would propose an upper market capitalisation threshold of €1bn. Compared with the industry small-cap fund definitions which range from €1bn to 7bn, such a threshold is rather modest. To reflect the diversity of EU markets, certain flexibility for Member States could be permitted to adjust this threshold to local market realities. Such an approach would help to achieve a European uniform and proportionate approach towards smaller quoted companies while taking into consideration the diversity of market conditions in Member States. The Commission SME Listing proposals are restricted to companies on SME Growth Markets only. We strongly believe that to revive EU capital markets small and mid-cap companies on the Regulated Markets should be also subject to less stringent regulatory requirements[1]. To ensure that such companies are easily distinguishable from those subject to the full regulatory requirements, a separate market segment for small & mid-caps on the Regulated Markets could be envisaged. Consideration could be also given to setting a timeframe (e.g. five years) during which small and mid-caps on the Regulated Markets could benefit from those alleviations. Furthermore, the package should at least review the criteria used to define SME Growth Markets for equity. While we appreciate the intention to make corporate bond markets more attractive, we fail to understand why some of the regulatory alleviations are restricted to bond issuance/issuers only. That is contrary to the Capital Markets Union principle of attempting to remove the bias against equity finance, which we believe should be addressed in this package. Lastly, we would like to emphasise the importance of ensuring there are workable transitional arrangements in all markets allowing companies to smoothly transfer from the SME Growth Market to the Regulated Market and vice versa. In that respect we regret that the proposals for such transitional rules that the Commission was consulting on, are not reflected in the SME Listing Package. Flexibility must be key in setting the arrangements allowing for companies’ smooth transfer between markets. Rather than introducing EU harmonised rules on voluntary transfer of listing and delisting rules, there should be an overarching principle ensuring that local market operators have appropriate arrangements in place. We have included in the annexed document our detailed comments for your consideration.
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Response to EU small listed companies Act

21 Jun 2018

We welcome the opportunity to provide feedback on the draft Delegated Regulation bringing technical adjustments to MiFID II (Directive 2014/65/EU) aimed at promoting the use of SME growth markets. In the attached paper we share some high-level comments on the Commissions’ proposal for the SME Listing Package overall, as well as we are providing detailed comments on MIFID II level 2 adjustments. We will comment on the Commission proposals for changes under the Prospectus Regulation and under the Market Abuse Regulation at a later stage. COMMENTS ON THE EC PROPOSALS FOR CHANGES UNDER MIFID II 1. New definition of debt-only issuers The Commission proposes that an issuer that has no equity instrument traded on any trading venue shall be deemed an SME Growth Market issuer if the total size of its debt issuances does not exceed EUR 50 million over a period of 12 months on all SME growth markets across the Union. While we very much support this proposal that will believe will contribute to promoting the SME Growth Markets concept and enable corporate bond issuer companies to benefit from a more proportionate regulatory framework, we regret that the criteria used to define SME Growth Markets for equity are not being reviewed. As said above, we believe that the SME listing package should provide a definition of a small and mid-cap company, which is crucial to recognise the diverse nature of companies which are no longer SMEs but also very different from large blue-chip companies, and to enable focussed and proportionate rules for such companies. To facilitate healthy and thriving public capital markets, taking the example of the US JOBS ACT, we would propose an upper market capitalisation threshold of €1bn, although some flexibility with an upper limit might need to be left to individual Member States. All companies below this threshold should be exempted from certain EU disclosure requirements and should be allowed access to the SME Growth Markets. Consideration also should be given to a transitional period exempting the newly listed smaller companies from some of the requirements for five years. 2. Minimum free-float criterion as part of the admission rules for SME Growth Market issuers We believe that no rule on minimum free float should be introduced in the EU legislation. As pointed out by the Commission, when an SME goes public, it is likely that there will be a low level of free float. Imposing free float requirements can make the listing unattractive for the company's owners. As the objective of the Commission’s planned initiative is to make SME Growth Markets attractive and to facilitate SME listings, we believe it is best not to impose any EU rules on minimum free float. Such aspects will be more adequately addressed by the local markets and in discussions between investors and companies. We note that, in the UK, the QCA-RSM Small and Mid-Cap Investors Survey 2017 found that a majority of institutional investors believed there should be no enforced minimum free float – either by value of company or size of shareholding floated – as it would represent an unnecessary and punitive burden on the company in question. Furthermore, after consulting a wide range of UK market participants on whether the AIM Rules for Companies should include a specific numerical or percentage threshold for free float in summer 2017, London Stock Exchange found that there was strong support that the current approach to free float strikes the right balance and that a qualitative approach is of benefit to the market. Respondents also commented that it remains of fundamental importance that a growth market has flexibility and is not hampered by numeric constraints which may result in potentially arbitrary outcomes for smaller companies. Please note that despite providing data at this stage from UK only, this concern is very much shared by all our members representing the interests of smaller issuers.
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Response to Public consultation on minimum requirements in the transmission of information for the exercise of shareholders rights

9 May 2018

We very much welcome the opportunity to provide feedback on draft Commission Implementing Regulation laying down minimum requirements implementing the provisions of Directive 2007/36. We would like to mention though that for the future we would appreciate a longer deadline and less constrained possibility to comment especially while dealing with a technical proposal. Overall, EuropeanIssuers welcomes the Draft Regulation and the goals the Commission intends to achieve with it. The standardisation of message contents and formats will achieve effective straight-through processing (STP) and interoperability of IT systems and all messages necessary to inform end investors, enabling them to exercise their rights and achieve a single market for the exercise of shareholders rights in Europe. Our main comments are: • The standardisation of requests for disclosure of end investor (shareholder) identity and for responses to those requests is essential to achieve the goals of the revised Shareholders Rights Directive. It is necessary to set the minimum requirements regarding the formats as suggested in tables 1 and 2. • We especially support relying on existing end investor (shareholder) identifiers as are LEI for legal and national identifiers for natural persons. Full name and address, electronic address, date of birth and legal form are necessary for data quality and identification of shareholders. • The standardisation of confirmation of entitlement will enable end investors to exercise their rights by following one of the procedures referred to in article 5 and rec. 9 of the Draft Regulation and we welcome that both are placed on an equal footing, depending on local circumstances. We welcome the approach to preserve functioning models which already achieve the goals of the revised SRD and the draft level II text. We also welcome that the draft refers to other corporate events which we understand as “corporate actions” as currently defined by market participants. • In the markets where (1) the notice of participation contains the reliable and confirmed information on the entitled position of the shareholder as of the record date, and (2) is delivered to the issuer respecting the deadlines ensuring that the investor can attend the General Meeting, confirmation of entitlement should not be mandatory. • We agree with the approach which on one hand reflects the flexibility provided by the SRD II to define the shareholder according to the applicable corporate law, while on the other hand makes it clear that all information must be transmitted to the end investor, meaning the person holding shares on his/her own account and behalf. This person should receive the general meeting related information and have the possibility to decide on how to vote shares and exercise other rights. The draft may be improved by using a “client” approach making it clear that intermediaries that do not hold securities on their own account must forward all information to their clients until the person, who is the first person holding the securities on their own account, is reached. Nevertheless, we acknowledge that enforcing such obligations may result in increased costs for specific markets (e.g. the UK or Ireland) and stakeholders where this breaks the status quo. • Regarding the language of transmission of information, art. 2 of the Draft Regulation sets forth that information shall be provided in a language customary in the sphere of international finance as well as in the language in which the issuer publishes its financial information in line with the Transparency Directive. We suggest leaving flexibility to the issuer to choose whether to communicate in a language customary in the sphere of international finance depending on the shareholder base, in line with the current Market Standards for General Meetings. Please see our remaining comments in the attached document.
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Response to Fitness Check of supervisory reporting requirements

3 Nov 2017

We very much welcome the Commission’s fitness check of the EU reporting requirements in the financial sector to analyse the shortfalls associated with supervisory reporting, taking a horizontal approach. We agree it is important to look at whether the requirements are meeting their objectives, to analyse the consistency of regulatory frameworks, and measure the cost and burden of the reporting obligations to see whether they are reasonable and proportionate. Nevertheless, we are concerned that that this fitness check, similarly to the EU cumulative impact assessment on financial services legislation performed in 2015, seems to focus solely on the financial sector (i.e. intermediaries and investment companies). Meanwhile, there is a strong need for a fitness check and / or measure the cumulative impact of financial legislation and other regulation on non-financial companies as users of financial markets. To achieve stronger and more liquid capital markets fuelling growth and jobs in Europe, we need proportionate and consistent regulatory approach which does not overburden companies that otherwise may look for financing elsewhere. Since 2009 we have witnessed a ‘regulatory tsunami’. While this legislation has been primarily targeted at financial companies, a lot of it has spilled over onto non-financial companies. Despite the change of the regulatory approach since 2015, there are many new regulatory obligations on non-financial listed companies, some of them still in the pipeline. While the cumulative impact and fitness check exercises seem to focus at reviewing legislation impacting the financial sector only. Therefore, to promote capital markets and ensure a Better Regulation approach, we call again for a fitness check and /or cumulative impact assessment targeted at non-financial companies using capital markets for financing and risk mitigating purposes. As a starting point, we would very much appreciate if the Commission enlarged the scope of the fitness check of the EU reporting requirements, to ensure that various reporting requirements EU listed companies face, are taken into consideration (including EMIR, MiFID II, MAR, Transparency Directive, Accounting Directive, REMIT, Non-Financial Information Directive, DAC 4 implementing BEPS Action 13 on CBCR, etc.). As a next step, we would like this exercise to be complemented by additional analysis covering company law and corporate governance requirements to have a full picture or regulatory requirements EU listed companies face. As a conclusion, we believe that extending the scope of the fitness check to non-financial companies is necessary to make sure that this exercise delivers a positive impact on the real economy. We are thankful for your consideration and we remain at disposal to discuss further.
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Meeting with Valdis Dombrovskis (Vice-President) and

10 Apr 2017 · CMU midterm review

Meeting with Tatyana Panova (Cabinet of Vice-President Valdis Dombrovskis)

16 Mar 2017 · Prospectus

Meeting with Maria Elena Scoppio (Cabinet of Commissioner Pierre Moscovici) and BUSINESSEUROPE

4 Apr 2016 · VAT rates applied to e-publications

Meeting with Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis) and BUSINESSEUROPE

21 Mar 2016 · public CBCR

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

8 Oct 2015 · Prospectus Directive

Meeting with Valdis Dombrovskis (Vice-President) and

1 Oct 2015 · Corporate Tax Transparency

Meeting with Jonathan Hill (Commissioner)

25 Mar 2015 · Capital Markets Union

Meeting with Sebastian Kuck (Cabinet of Commissioner Jonathan Hill)

23 Jan 2015 · Auditing and financial reporting

Meeting with Sebastian Kuck (Cabinet of Commissioner Jonathan Hill)

23 Jan 2015 · Audit & Accounting