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FAIR - FINANCER ACCOMPAGNER IMPACTER RASSEMBLER

FAIR

FAIR est née en 2021 de la fusion entre Finansol, acteur historique de la finance solidaire, et l’iiLab, laboratoire d’innovation sur l’impact.

Lobbying Activity

Response to General revision of the General Block Exemption Regulation

6 Oct 2025

FAIR welcomes the European Commissions initiative to revise the General Block Exemption Regulation (GBER) and is very pleased to see that the social economy and social enterprises are explicitly recognised among the priorities of this revision. This marks a long-awaited acknowledgement of their essential contribution to inclusive, sustainable and competitive growth across Europe. As a national network representing over 150 social finance and impact investing actors in France, FAIR strongly supports the Commissions goal of simplifying and clarifying the GBER, reducing administrative burden, and ensuring consistency with EU strategic priorities. We particularly welcome the explicit follow-up to the Social Economy Action Plan and the Union of Skills Communication, which both underline the need to adapt State aid rules to the reality of social economy actors. Social enterprises and organisations play a vital role in achieving EU cohesion, employment and environmental objectives. Yet they face structural market failures that justify a distinct regulatory treatment: their profitability is deliberately limited; they are unlisted and excluded from capital markets; and their governance models restrict profit distribution. These characteristics create a permanent funding gap, estimated by the European Commission at between 500 million and 1.4 billion per year. The partial review has already taken steps in the right direction, reflecting commendable efforts in taking the sectors feedback into account. Despite this, the current GBER still assimilates them to SMEs, subject to conditions that are not adapted to their reality, in particular regarding the seven- or ten-year eligibility limit and the 16,5 million cap on total aid (Article 21). Such thresholds, suitable for high-growth SMEs, are incompatible with the long-term, mission-driven nature of social economy actors, and the structural (and not conjectural) market failure they face. FAIR therefore proposes the following adjustments to the GBER: 1. Recognition of social enterprises and organisations as a distinct category of undertakings, drawing on the definitions already present in ESF+ and EuSEF regulations. 2. Removal of the seven-year age limit, allowing support throughout the life cycle of these entities. 3. Revision of the 15 million aid cap, or introduction of flexible ceilings in particular for sectors requiring high levels of equity, such as social housing, renewable energy or sustainable agriculture. 4. Clarification that such aid does not distort competition, since these organisations operate in under-served markets and pursue objectives of general interest. A specific aid framework for social enterprises and organisations would reduce administrative burden for undertakings, Member States and the Commission. Furthermore, it would strengthen territorial and social cohesion by supporting actors active in disadvantaged areas and align State aid rules with major EU strategies, including the Green Deal, the Social Economy Action Plan and the objective of a just transition. FAIR welcomes the Commissions openness to evidence and stakeholder dialogue. We are ready to share further data, case studies and legal drafting suggestions demonstrating how targeted block exemptions could effectively address market failures while safeguarding competition. This revision represents a unique opportunity to make State aid rules truly consistent with the EUs social and territorial cohesion goals. FAIR looks forward to contributing actively to the next consultation steps and to supporting the emergence of a GBER that fully reflects the diversity and impact of Europes social economy. Please find attached a note containing more detailed information on FAIRs position.
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Response to Review of the State aid rules on the Services of General Economic Interest (“SGEI”)

31 Jul 2025

FAIR is the French network for impact finance, bringing together over 150 members including solidarity-based investment funds, foundations, cooperatives, social enterprises, and local authorities. Among our members are several solidarity real estate companies (foncières solidaires) whose mission is to offer housing solutions that are both deeply social and structurally sustainable. We welcome the Commissions ambition to revise the SGEI framework to support affordable and energy-efficient housing. However, to make the revised framework truly effective, it is essential to recognize and preserve the specificities of actors operating at the intersection of social innovation, urban resilience, and solidarity. The notion of "affordable housing" cannot be reduced to housing simply below market price. It must be defined in relation to the actual capacity of households to pay rent without jeopardizing their ability to meet essential needs (i.e., taking into account disposable income and the reste à vivre this notion and the methodology are detailed in the document attached). A commonly accepted standard is that rent should not exceed 30% of household income, adjusted by consumption units. Any definition of affordability that fails to consider this risks missing its target. Solidarity real estate actors buy properties at market prices but choose to rent them at much lower rates, absorbing the financial difference to protect vulnerable tenants; they also oftentimes offer support to the tenants to accompany them towards more traditional housing situations. This business model requires limiting financial returns and often implies lower margins. As such, these actors are not only delivering a public service but doing so with a high degree of social impact and financial prudence. Currently, access to SGEI recognition remains complex and inconsistent across Member States. In France, for example, some solidarity housing operators struggle to obtain SGEI status due to bureaucratic complexity or unclear guidelines. This significantly limits their ability to scale their impact through public support. We therefore welcome the Commissions willingness to simplify access to SGEI recognition. However, simplification alone is not enough: we urge the Commission to accompany this revision with operational guidance for Member States, in order to clarify: The criteria for defining an activity as SGEI in the context of deeply social housing (e.g., % below market rent, income-based rent ceilings). How to take into account the energy performance requirements without excluding actors operating in older, degraded housing stock who are actively working toward renovation. The specific situation of social economy actors who operate under non-profit constraints. As actors already facing difficulties in accessing SGEI mechanisms, solidarity housing providers fear that the revised framework might unintentionally raise barriers rather than remove them especially if stricter energy or profitability criteria are introduced without nuance. We strongly recommend that the Commission ensure the revised rules explicitly preserve space for socially-driven, not-for-profit housing initiatives. Dedicated technical assistance for Member States and tailored guidance for social economy actors would help secure this ambition.
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Response to Recommendation on savings and investment accounts

7 Jul 2025

FAIR, as part of the French National Partner of the Global Steering Group for Impact Investment (GSG), welcomes the Commissions initiative to create a European framework for Savings and Investment Accounts (SIAs). As the leading French network for social impact finance, FAIR represents 150+ members (banks, asset managers, social enterprises, and NGOs) mobilising citizen capital to support a fair and sustainable transition. We fully support the objective of better linking savings with investment opportunities and making capital markets more accessible to citizens. However, to succeed, SIAs must not only be simple and portablethey must also offer investment products aligned with citizens values. This includes access to credible social investment products, which are currently missing from most capital markets frameworks. To this end, we recommend that the Commission: (1) Reform the EuSEF regulation to enhance its accessibility and impactthrough lower investment thresholds, broader eligible assets, and alignment with UCITS. (2) Include social investment options in the design of SIAs, such as EuSEF funds or equivalent, to reflect citizens sustainability preferences. (3) Enable UCITS funds to invest up to 10% in social assets, using EuSEF as a benchmarkreplicating Frances 90/10 fund model, which has successfully mobilised 30 billion in social finance (75% from retail investors). Such steps would not only improve the attractiveness and legitimacy of SIAs for retail investors, but also contribute to the EUs strategic priorities in social cohesion, sustainable development, and citizen empowerment. We believe SIAs can become a powerful gateway to long-term investing if they are designed to be meaningful, inclusive, and impact-oriented. This will also help counter greenwashing and social-washing by giving retail investors access to verified products. More detailed proposals and data are available in the note attached to this contribution.
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Response to Mid-Term Review: Social Economy Action Plan

7 Jul 2025

This contribution to the mid-term review of the Social Economy Action Plan (SEAP) is submitted by FAIR, who is part of the French national partner of the Global Steering Group for Impact Investment (GSG) and the leading network for social impact finance in France. With over 150 members (including financial institutions, social enterprises, and NGOs) FAIR promotes solidarity in savings and finance and works to channel private capital toward social goals through the social economy. Since the adoption of the SEAP in 2021, significant milestones have been achieved, particularly in the recognition and definition of the social economy. The 20232024 adoption by the United Nations of a universal definitionalready endorsed by the ILO and OECDmarks a major step forward. However, implementation has slowed, and the current shift in focus toward competitiveness and innovation risks sidelining social priorities. Many social economy actors still face critical obstacles in accessing appropriate funding. To address this, FAIR highlights the importance of translating the findings of the April 2024 Study on State aid for access to finance and wage subsidies into concrete regulatory reform. The study clearly demonstrates how current EU rules do not reflect the specific nature of social economy organisations. An ambitious revision of the General Block Exemption Regulation (GBER) is urgently needed to allow for more effective supportparticularly in acknowledging market failures, limited profitability, and specific challenges such as age restrictions. Beyond State aid reform, three additional priorities are key to unlocking the full potential of the social economy: Ensuring the continuity of the social investment window under InvestEU in the next Multiannual Financial Framework; Revising the EuSEF regulation to make the label more accessible and impactful; Lifting regulatory barriers to the cross-border replication of innovative instruments like Frances 90/10 solidarity fund model, which combines ESG-listed assets with unlisted social investments. More information and context can be found in the attached document.
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Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque)

25 Jun 2025 · SFDR revision

Response to Savings and Investments Union

5 Mar 2025

FAIR, as a collective of 150+ actors involved in impact finance, welcomes the Commissions commitment to realizing the full potential of the Savings and Investment Union by focusing particular attention on retail investors and directing investment where it is needed the most, including the just transition. The Union has set ambitious goals for itself regarding its transition, in order to answer the urgency of the climate crisis and the social challenges of an aging population and of rising inequalities. Achieving these goals requires an annual investment of at least 813 billion euros by 2030 : there remains an investment shortfall of 406 billion euros per year (according to the I4CE). The SIU has potential to bridge this gap, and we salute President von der Leyen for including harnessing sustainable finance in Commissioner Albuquerques mission letter. However, while significant progress has been made regarding the environmental dimension, the social dimension of sustainable finance still lacks a robust framework. The absence of a robust social Taxonomy unfortunately impacts other regulations, such as SFDR and CSRD, that lack a clear definition making it easy for investors to identify social investments and ensure they are credible. We would like to urge the Commission to remedy this discrepancy and prioritize the social dimension of sustainable investment. In practice, this would mean resuming work on a social Taxonomy, carving a clear space in SFDR for investment that generates positive social impact in the future review of the text. We deplore that the social dimension doesnt occupy a larger place in this call for evidence either. While we appreciate the mention of the Affordable Housing Plan, this only addresses one aspect of a much larger and systemic issue and promoting the European Pillar of Social Rights requires a cross-sectoral approach which can be found in the social economy, that is made up of mostly locally implanted, socially innovative actors, but also larger scalable enterprises, employing over 6,2% of all European workers and representing 10% of all businesses in the EU. Despite their significant and their contributions to the social system, social economy actors appear to be systematically left behind and struggle to have their specific financing needs acknowledged. Citizens should be presented with demanding financial products that fit their sustainability preferences, while maintaining the appropriate levels of liquidity, risk and transparency to protect them. Such products exist, but are not sufficiently recognized at a European level, which prevents them from joining the Savings and Investments Union. To achieve that end, we propose the review of the EUSEF Regulation as well as the UCITS Directive. Wed like to propose making EuSEF funds more accessible to retail investors, by implementing a review in the same spirit as the recent ELTIF review. This could be achieved by lowering the minimum investment amount, as well as by making EuSEF funds eligible for UCITS funds portfolio. To ensure the liquidity necessary to protect investors as required by the UCITS directive, EuSEFs could be limited to the "trash ratio" - the maximum 10% of assets defined in article 50(2) of the UCITS directive. At the same time, this would allow more capital to be channeled to EuSEF-eligible social enterprises in the form of instruments that reflect the reality of the sector (including securitized and non-securitized debt instruments, collateralized and uncollateralized loans, quasi-equity...). This would allow for the replication and dissemination of "90/10" fund models, that have been thriving in France. In this scenario, UCITS funds could invest up to 10% in social enterprises through EuSEF funds. Youll find attached a note detailing the success of 90/10 funds in involving retail investors and financing strategic goals in France, and proposals to replicate it at European level.
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