OpenLobby.EU
Explore

Leaseurope

Leaseurope represents European leasing and automotive rental industries, covering finance and operating leases of automotive, equipment, and real estate assets.

Lobbying Activity

Leaseurope demands simpler EU taxonomy rules for vehicle leasing

5 Dec 2025
Topic — The initiative reviews technical screening criteria for the EU sustainable finance taxonomy.
Message — The organization calls for removing difficult tyre noise and resistance standards from environmental criteria. They also want all leasing models, including financial leasing and transition projects for small businesses, to be eligible.123
Why — Simplification would prevent electric vehicle fleets from being excluded from green portfolios.4
Impact — Removing tyre standards could increase noise pollution and reduce fuel efficiency targets.5
Read full response

Meeting with Mohammed Chahim (Member of the European Parliament)

4 Nov 2025 · Social Leasing EV's

Leaseurope urges EU to exempt finance lessors from device rules

1 Oct 2025
Topic — The European Commission is revising rules for medical devices and in vitro diagnostics.
Message — Leaseurope requests a legal clarification to ensure that financial entities are not classified as distributors. They suggest adding a new recital to better define market availability for assets.12
Why — This change prevents increased compliance costs and avoids technical liability for finance firms.34
Impact — Reduced financing options could hinder access to essential equipment for SMEs and hospitals.56
Read full response

Meeting with Beatrice Timgren (Member of the European Parliament)

17 Sept 2025 · Proposal on Corporate fleet

Response to Clean corporate vehicles

8 Sept 2025

At present, corporate vehicle registrations are responsible for up to 60% of new vehicle purchases and mobility service providers recognise their responsibility in helping to reduce overall fleet emissions. The further uptake of BEVs is constrained by a lack of existing enabling conditions linked to customer demand, vehicle utility and pricing, supply and infrastructure challenges paired with regulatory instability and geopolitical fluctuations. Lack of customer demand is equally relevant when it comes to the second-hand market where there is currently an oversupply of BEVs. Despite the fact that BEVs have a significantly higher depreciation compared to hybrid and ICE vehicles, due to their higher purchase prices there is still a considerable discrepancy between what the average consumer is able to spend on a second-hand vehicle and what is on offer. Other issues such as battery state of health and range only exacerbate this. Moreover, to grow both customer confidence and demand, the recharging experience needs to be as seamless as refuelling an ICE vehicle today by ensuring ease of finding public recharging points, reliable service provision at charge-points, more user-friendly payment options and price transparency, all supported by adequate grid capacity. A long-term strategy needs to go well beyond AFIR and address deployment in both urban centres as well as rural areas, at airports and train stations The EU is currently assessing three policy options: Policy Option 1 Setting of national targets Leaseurope opposes setting of national targets which, in turn, would inevitably be paired with targets imposed by Member States for companies, as in practice this would differ little from policy option 3. Instead of mandating such targets, Leaseurope supports well-designed incentive systems paired with heavy investments in enabling conditions to naturally foster demand for BEVs in primary and secondary markets. Policy Option 2 Rules on financial incentives for corporate vehicles these would be designed to reproduce the incentives systems that have been adopted across the fastest BEV uptake markets in Europe. Even in these markets, consumer demand in the second-hand market is low. As such, incentives should support demand for the primary as well as secondary vehicle markets. Policy Option 3 Targets for companies would not address the existing concerns outlined above. Resulting from a lack of enabling conditions, the introduction of company targets could lead to scale-down of rental/leasing offerings and/or increased pricing, which will have a major impact on the competitiveness of SMEs which depend on our services as well as the wider automotive ecosystem. This would not only reduce the competitiveness of European industry, it would also fail to meet the stated environmental objective as business and consumers are likely to turn to outright financing of older more polluting vehicles and continue to drive them longer. From a legal perspective, we consider the Proposal, notably policy options 1 and 3, not to be compliant with EU law as it is likely to violate the Principles of Proportionality and Consistency of legislation, the Principle of Subsidiarity and to directly infringe Fundamental Rights and Freedoms, including the Freedom to Conduct a Business (as per attached memo from Freshfields). In this regard, it is important to acknowledge that leasing and rental companies are not responsible for the choice of vehicles leased and rented by their clients. Rather than arbitrarily setting targets for corporate fleets that fail to take into account real world limitations and risk major market distortions, Leaseurope believes the Commission should focus on investing on charging infrastructure and grid capacity, subsidies as well as fiscal incentives designed to help consumers and businesses bridge the financing gap, for both new as well as used electric vehicles. For a more detailed position, see our attachment.
Read full response

Meeting with Mark Nicklas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

23 Jul 2025 · Greening corporate fleets

Meeting with Apostolos Tzitzikostas (Commissioner) and

17 Jul 2025 · Corporate Fleets strategic dialogue

Meeting with Markus Ferber (Member of the European Parliament)

3 Jul 2025 · Greening Corporate Fleets

Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque)

26 Jun 2025 · Greening of Corporate Fleet Initiative

Meeting with Sanna Laaksonen (Cabinet of Executive Vice-President Henna Virkkunen)

25 Jun 2025 · Greening of Corporate Fleets Leaseurope

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

10 Jun 2025 · Greening Corporate Fleets

Meeting with Wopke Hoekstra (Commissioner) and

12 Feb 2025 · Dialogue on the future of the automotive sector - Thematic Working Group on 'Clean Transition and Decarbonisation'

Meeting with Mark Nicklas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and Fédération Internationale de l'Automobile and

11 Feb 2025 · Action plan for the automotive sector

Meeting with Silvia Bartolini (Cabinet of Executive Vice-President Henna Virkkunen), Xavier Coget (Cabinet of Executive Vice-President Henna Virkkunen) and

14 Jan 2025 · The role of the automotive aftermarket in the EU Industrial Action Plan for the automotive sector

Meeting with Helena Hinto (Cabinet of Commissioner Apostolos Tzitzikostas) and Insurance Europe and

10 Jan 2025 · Introductory meeting

Meeting with Valvanera Ulargui Aparicio (Cabinet of Executive Vice-President Teresa Ribera Rodríguez) and Insurance Europe and

16 Dec 2024 · Exchange with the Independent Service Providers (ISPs) on the upcoming Commission Initiatives that will support the whole sector competitiveness, including the Competitiveness Compass, the Clean Industry Deal and the Automotive Industry Plan

Meeting with Aleksandra Baranska (Cabinet of Vice-President Maroš Šefčovič), Juraj Nociar (Cabinet of Vice-President Maroš Šefčovič) and

12 Jun 2024 · Decarbonization of road transport

Meeting with Esther De Lange (Cabinet of Commissioner Wopke Hoekstra)

8 Mar 2024 · greening corporate fleets + consequences

Response to Guidance to Member States and market actors to unlock private investments in energy efficiency (EED recast)

26 Feb 2024

Leaseurope calls for equal treatment of leasing services compared to other financial products when it comes to policy and financing measures that will support Member States to deliver on the 2030 energy efficiency targets. Leasing is the primary external financing source sought by European SMEs. According to the latest results of the Survey on Access to Finance of Enterprises (SAFE survey 2023, around 48% of all SMEs have made use of leasing which is more than any other individual form of traditional bank lending, and considered using it in the future. Leasing companies with their expertise and administration resources can contribute to the distribution and fair implementation of funds, enabling thereby the digital and green transition. Using leasing as a financing form reduces the risk, incentivises investments and lowers the final cost of leasing of assets. In this light, leasing companies can provide great support particularly considering leasings unique role in making all type of assets (greener and technologically advanced) more widely available to a broader range of customers. This is important as assets are often associated with high upfront and maintenance costs. Leasing companies have the capability to analyse the risk, collect the necessary documents, initiate the interest in the subsidy and monitor the entire process of granting a subsidy. Leasing is a stable and low risk source of finance that support business and households even during economic crisis periods. This is due to the fact that lessors own and manage the leased assets they finance, with this specialist business expertise bringing many benefits. Given the demonstrated importance of leasing for supporting investment, SMEs and sustainable finance in Europe, Leaseurope calls on the European Commission to work on EU investment frameworks that do not discriminate against leasing and to take into account the specificities of leasing transactions by adapting the requirements and criteria to accommodate the differences of the various forms of financing. For more, please see the Leaseurope paper attached.
Read full response

Leaseurope urges broad green criteria in sustainability reporting

7 Jul 2023
Topic — The Commission is establishing mandatory standards for how large companies report sustainability data.
Message — The federation argues against a narrow view of pollution-reducing asset investments to maintain reporting utility. They also request sufficient implementation time and sector-specific standards for leasing companies.123
Why — Leasing firms could claim sustainability credit for a wider range of financed assets.4
Impact — Environmental advocates may lose clarity if less-than-optimal assets are labeled as sustainable.5
Read full response

Meeting with René Repasi (Member of the European Parliament, Rapporteur for opinion)

8 Jun 2023 · Exchange of views on "harmonising certain aspects of insolvency law" / Austausch zur "Harmonisierung bestimmter Aspekte des Insolvenzrechts" - Staff Level

Leaseurope Demands Wider Leasing Inclusion in EU Green Taxonomy

3 May 2023
Topic — The initiative establishes technical screening criteria for four EU environmental taxonomy objectives.
Message — The federation requests that the taxonomy include a wider range of leased assets. They advocate for eligibility for all legal forms of leasing contracts without discrimination.12
Why — Recognition would ensure financial institutions remain willing to provide funding for leasing services.3
Impact — Smaller companies lose affordable options to upgrade equipment if leasing rules are restricted.4
Read full response

Response to Enhancing the convergence of insolvency laws

17 Mar 2023

Leaseurope and EUF welcome the opportunity to provide comments on the Commissions proposal for a Directive harmonising certain aspects of insolvency law. Leaseurope and EUF acknowledge that there are differences in national insolvency regimes of EU Member States. As such, Leaseurope and EUF understand, in principle, the need to increase a level of coherence between more efficient and less efficient insolvency legislative frameworks. Leaseurope and EUF wish to make some general as well as specific remarks on the proposed Directive together with some suggestions for improvement of the proposed Directive. Please refer to the attached joint position paper of Leaseurope and EUF for further details.
Read full response

Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

15 Feb 2023 · In-vehicle data

Meeting with Maria-Manuel Leitão-Marques (Member of the European Parliament, Shadow rapporteur) and Finance Watch

7 Dec 2022 · DMFSD

Response to Distance Marketing of Consumer Financial Services - Review of EU rules

8 Jul 2022

Leaseurope endorses the Commission’s goal to improve consumer protection online and to ensure the free movement of financial services in the single market by harmonising certain rules related to contracts concluded at distance. However, we believe that these objectives would be more appropriately sought through a targeted revision within the existing framework, which fundamentally still remains relevant and functional. The Unfair Commercial Practices Directive , the Unfair terms in Consumer Contracts Directive as well as the upcoming Digital Services Acts and the Digital Markets Act which will soon start to apply, are sufficient to ensure a high-level of consumer protection online. We suggest examining the outcomes of application of these rules and at a later stage examining whether there is an added-value for additional protection as prescribed in the proposed Article 16e. Leaseurope welcomes the clarification in the Commission’s proposal according to which where there is duplication in disclosure requirements between different legal texts, product-specific legislation will take precedence against the general rules provided for under the DMFSD. In particular, regarding the obligation to provide pre-contractual information and the right of withdrawal, Leaseurope supports the provision whereby “where another Union act governing specific financial services contains rules on pre-contractual information or on the exercise of the right of withdrawal, only the respective provisions of those other Union acts should apply to those specific consumer financial services unless provided otherwise in those acts” (Article 16a(6) and Article 16b(6) of proposal). Likewise, regarding the provision on the obligation to provide “adequate information” (Article 16d(4) of the proposal). To achieve the high-level consumer protection and a real single market, legal certainty is key. It is important therefore to avoid any unintended market confusion and to ensure that the overlaps on the disclosures obligations put forward in sector-specific legislation for particular products and those put forward in the new horizontal rules on distance financial services of the new part of Consumer Rights Directive are avoided. In summary, Leaseurope is in favour of the following: - Clear adherence to the principle of lex specialis whereby product-specific legislation takes priority. - Flexibility for the service/product providers on how to facilitate access to the right to withdrawal of consumers. Adding a “button” is not always the obvious solution. - Unfair Commercial Practices Directive , the Unfair terms in Consumer Contracts Directive as well as the upcoming Digital Services Acts and the Digital Markets Act which will soon start to apply, are sufficient to ensure a high-level of consumer protection online. The provision of additional protection offers no added-value at this stage. Leaseurope is willing to engage in a constructive dialogue with the Commission to further explain its perspective. Please see also the Leaseurope response attached with more detailed comments.
Read full response

Meeting with Thierry Breton (Commissioner) and

16 Jun 2022 · Data Act ; in-vehicle data

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and Insurance Europe and

10 Jun 2022 · Prep meeting for meeting with Commissioner Breton on 16/6

Meeting with Sara Cerdas (Member of the European Parliament, Shadow rapporteur)

25 Feb 2022 · Revision of the Regulation on CO2 standards for cars and vans in the context of the Fit for 55 package

Meeting with Thierry Breton (Commissioner) and

27 Oct 2021 · Data

Response to Consumer Credit Agreement – review of EU rules

2 Sept 2021

Please find attached the Leaseurope feedback to Consumer credit agreements- review of EU rules.
Read full response

Response to Data Act (including the review of the Directive 96/9/EC on the legal protection of databases)

25 Jun 2021

Please find attached Leaseurope feedback to the Data Act.
Read full response

Response to Digital Services Act package: ex ante regulatory instrument of very large online platforms acting as gatekeepers

5 May 2021

Please find attached the Leaseurope response to the Digital Markets Act.
Read full response

Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

31 Mar 2021

Please find attached Leaseurope feedback to the Digital Services Act.
Read full response

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

9 Feb 2021 · Transition to zero emission mobility

Response to Legislative framework for the governance of common European data spaces

8 Feb 2021

Please find attached the Leaseurope response to the proposed Data Governance Act.
Read full response

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Leaseurope fully supports the Commission’s goal to harmonize the criteria used to determine whether an economic activity can be deemed sustainable. We also support the Commission’s broader goal of improving sustainability across the EU, and wish to highlight both the key role our industry can play in enabling the green transition and the need for our unique position to be recognised in the delegated act. We believe failing to recognise the role our industry can play in increasing the uptake of green technologies (among industries and businesses who wish to become more sustainable) would be detrimental to the Commission’s ultimate goal of achieving climate neutrality by 2050. The leasing industry is in many respects sustainable by its very nature, and ideally placed to act as a facilitator of the green transition. In the context of making it easier for citizens and corporate entities to act more sustainably, the leasing and automotive rental industries currently play a major role in improving the availability of newer and greener technologies, without the prohibitive prices that would often deter companies and individuals from upgrading their assets (like factory equipment or vehicles for example) to a more sustainable model. In this way, the leasing and automotive rental industries are in a unique position compared to most other financial service providers, since they are able to go beyond investing in green funds and actually play a role in making greener technologies both available and more widely known about by customers. Our industry has the potential to actively contribute to a number of the criteria set out by the Delegated Act on climate change mitigation and climate change adaptation. We are responsible for funding a wide range of assets, ranging from industrial machinery and agricultural equipment to windmills and solar panels. For example, in Italy, nearly a quarter of the overall portfolio of finance leases alone are deployed in sectors which are qualified as sustainable in accordance with the recommendations of the Technical Expert Group on sustainable finance. In the draft delegated act however, the leasing industry’s role is only recognised in the context of automotive assets and property. This is highly problematic, since our industry will ultimately act as a facilitator for the green transition, making it easier for our customers who wish to do so (whether individuals or entities) to use greener assets without the traditional barriers that may prevent them from accessing these (often newer and therefore more expensive) assets. A number of non-automotive assets that are essential for the green transition (and have been identified as such by the first draft delegated act) are commonly leased, and we believe a reference to this in the delegated act would help greatly in making these greener assets more widely available to a broader range of customers. This is particularly important when considering the often high upfront and maintenance costs associated with these newer, greener assets, and the role of our industry in allowing customers who wish to use more sustainable assets to spread out these costs. Leasing and rental companies take the forefront in financing sustainable energy generating assets such as windmills, electricity storage units, photovoltaic equipment, as well as managing complete powerplant turnkey operations. In Belgium for example, it is estimated that over 20% of the overall portfolio consists out of these assets alone. The green facilitating impact of leasing and rental is, however, not limited to only energy generating and/or storage assets. As experts on asset life cycle management and total cost of ownership, leasing and rental companies meet businesses’ and consumers’ needs across the board, helping to finance and manage everything from agricultural and public transport equipment to advanced data centres to energy efficient urban real estate.
Read full response

Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

15 Dec 2020 · Basel III

Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

15 Dec 2020 · Implementation of Basel III in the EU

Response to A New Consumer Agenda

11 Aug 2020

Please find attached the Leaseurope response to the Commission's request for feedback on the EU's new "consumer agenda".
Read full response

Meeting with Valdis Dombrovskis (Executive Vice-President) and

28 May 2020 · COVID-19 relief measures

Response to Union renewable Financing mechanism

25 May 2020

Please find the Leaseurope response attached.
Read full response

Response to Revision of Alternative Fuels Infrastructure Directive

4 May 2020

Leaseurope, the European Federation representing the leasing and automotive rental industries, supports the Commission’s aim to improve the EU’s network of recharging and refuelling stations for alternative fuel vehicles through the Alternative Fuels Infrastructure Directive (AFID). Improving this infrastructure is a vital component in increasing the uptake of alternative fuel vehicles within the EU, alongside a number of other important steps. Currently, the deployment of alternative fuel infrastructure remains patchwork both across the EU and within different Member States. In order to ensure the AFID successfully addresses this issue then, the targets set out in the Directive should be based on a comprehensive methodology that takes into account not only the availability of alternative fuel stations, but also other factors, such as driver behaviour and the parameters of existing and future technology. It is also important that additional factors impacting the widespread availability of public charging stations and alternative fuel stations for all types of vehicles and models are adequately addressed in the proposal. For example, there should be an attempt to homogenise rules on the use of electric vehicles and charging points across the EU, as well as ensuring the public charging stations are future proof, and will be able to be used long-term as the technology used in LEVs develops. Additionally, the charging and alternative fuel stations must be interoperable, and compatible with all/almost all vehicle models, irrespective or the manufacturer, vehicle type etc. Another important element is the ease of use for the average consumer. Factors such as the ability to pay by cash and card at stations, and reducing the amount of time needed to charge an electric LEV will be imperative in making these vehicles more attractive to consumers. The targets included in the proposal should also assess other potential obstacles to the widespread use of LEVs, such as their comparatively high cost, as well as limited availability. The leasing and rental industries could play a key role in scaling up the use of LEVs, since it would make it possible for consumers and SMEs who do not have the financial resources to buy an LEV outright to use one at a reasonable cost. Notably, leasing companies’ ability to offer LEVs on a large scale relates to how lease agreements are regulated in some Member States, as it is not always possible to finance more than one asset under a single lease agreement. This is very problematic in the context of electric vehicles in particular, since the vehicle is regarded as a separate asset from the vehicle’s battery. Moreover, in many cases a customer leasing an electric vehicle would also want to lease an at-home charging station, and this would again require an additional separate lease agreement. Addressing this issue, and allowing for a more streamlined process for the consumer when it comes to leasing/renting a LEV, would be a major step forward in encouraging more customers to use LEVs.
Read full response

Response to Climate Law

30 Apr 2020

Leaseurope, the European federation representing the leasing and automotive rental industries, supports the Commission’s goal to enshrine their commitment to lower greenhouse gas emissions through the European Climate Law. The leasing and rental industries, with their focus on reusing assets until the end of their life cycle, coupled with their role in enabling consumers to upgrade their vehicles and equipment to models that use cleaner technology, will be a key facilitator in the shift towards a greater uptake of green technology. Whilst we support the Commission’s aim to significantly lower carbon emissions by 2030, we do feel a number of factors need to be addressed in order to enable our industries to support the transition to the scale envisaged by the Commission, and to meet their very ambitious timeline. These issues (set out below) will require significant investment from member states, SMEs, consumers, leasing and rental companies, and vehicle and equipment manufacturers. As a result of the scale of the investment, infrastructural, and process-related changes required, a gradual shift towards this increased uptake in lower emission vehicles and more eco-friendly equipment would be by far the most appropriate means of achieving the EU’s climate goals. Infrastructural needs The infrastructure required to enable a larger uptake of lower emissions vehicles (such as charging stations and alternative fuel stations) will need to be available throughout member states. This will take time owing to the major costs associated with this, as well as the need to both physically install the charging and alternative fuel infrastructure, and ensure there is the necessary capacity (in terms of distribution boards, grid reinforcements etc.) in place to support this infrastructure. Supporting consumers and SMEs in the transition Additionally, there will need to be a major shift in consumer preference, to make using and offering low emission vehicles and eco-friendly equipment -at the scale that would be required to meet these goals- financially viable, both for individual consumers and leasing and rental companies. In the context of low emission vehicles specifically, the improvement of charging/alternative fuel infrastructure will undoubtedly help in encouraging this shift, however equally important will be the availability of financial incentives and support for customers who wish to use eco-friendly vehicles or equipment. Crucially, this support should not only be available to consumers and companies who wish to purchase eco-friendly goods, but also for those who opt to benefit from this new technology by leasing or renting assets. Allowing leased and rented environmentally friendly assets to have the same benefits as purchased assets, not only encourages the re-use of assets, it will likely also improve the uptake of these new technologies. Consumers and SMEs in particular will be more inclined to use more eco-friendly assets when they have the safety that leasing and renting provides, such as the ability to change/upgrade their asset at little additional cost, and not being responsible for repairs of the asset. The role of manufacturers As well as the shift needed by consumers and the changes needed to existing infrastructure, to a large extent the ability of the leasing and rental industries to offer these eco-friendly options at a large scale is dependent on the extent to which manufacturers respond to this issue. In the context of vehicles for example, this could take the form of enabling improvements across their entire range of powertrains.
Read full response

Response to Fast-track interservice consultation on the 'SEIP including a JTM and the JTF"

12 Mar 2020

Leaseurope, the European Federation representing the leasing and automotive rental industries, wholeheartedly supports the European Commission’s commitment to tackling climate change, and in ensuring that no industries and regions are “left behind” in the green transition, which will be supported through the Just Transition Fund. Scope The Commission has outlined that the purpose of the Just Transition Fund will be to design a tailored package of measures across the range of available support from the Commission, the EIB and other international organisations in a simple and integrated manner, accessible to both businesses and public sector authorities. Article 4 does not however provide any guidance on how the funds are re-distributed at national level, and which entities are eligible to benefit from the programme. This is a cause for concern for the leasing and rental industries, as based on experience with other support programmes of a similar nature in the past, these industries have often been excluded at national level from the eligibility criteria. This issue has most recently been addressed in re-cast Clean Vehicles Directive which clearly notes that “In order to help ensure that the potential benefits are fully exploited, the Commission should provide guidance to Member States with regard to the different Union funds that might be used, and should facilitate and structure the exchange of knowledge and best practices between Member States in order to promote the purchase, lease, rent or hire-purchase of clean and energy-efficient road transport vehicles by contracting authorities and contracting entities”. The role leasing can play in this context was also referenced in the 2017 GEAR 2030 report. The leasing and rental industries are also instrumental in facilitating the green transition, and have a particularly prominent role in allowing SMEs to upgrade their products/equipment to more sustainable models without the high costs associated with purchasing these products outright. Leasing also helps drive uptake of clean vehicle technology, with pollution from leased car fleets steadily dropping each year. Additionally, leasing can ensure access to capital for sustainable energy production like wind turbines, biofuel processing plants, photovoltaic panels, long lasting battery cells etc. Concrete measures In order to ensure that leasing and rental can continue to play an instrumental role in supporting and financing the green transition, Leaseurope would like to ensure the scope in Article 4 is further defined. In particular, we would support enshrining in legislation that the acquisition of assets and services provided and financed via leasing and rental companies are not excluded from support measures at national level, in a similar vein to what is already set out in the Clean Vehicles Directive.
Read full response

Response to Action Plan on anti-money laundering

11 Mar 2020

Leaseurope, the European federation representing the leasing and automotive rental industries, supports the Commission’s aim of tackling money laundering within the EU, and to improve the implementation of the EU anti-money laundering framework. In response to the Commission’s recent roadmap “Towards a new comprehensive approach to preventing and combatting money laundering and terrorist financing”, we would like to highlight the low risk profile of the leasing and automotive rental industries in this context, as well as the steps these industries are already undertaking to minimise the potential for their services to be used to facilitate money laundering or finance terrorism. In many respects, the very nature of the leasing and automotive rental industries works to make the industry inherently low risk from a money laundering perspective, and this view is shared by the banking industry, supervisory authorities, and law enforcement officials. For example, in a leasing contract no funds are generally transferred to the lessee (the customer), but the customer instead is given the right to use an asset (e.g. a piece of equipment or a vehicle). In this way, the way leasing contracts are set up clearly do not lend themselves to be used in money laundering or terrorist financing, since funds are almost always paid directly into a supplier’s bank account. In addition to the nature of the relationship between the lessor, lessee and supplier, the duration of leasing contracts, as well as the methods of payment used by lessees to make repayments also works to make leasing very low risk from a money laundering perspective. Leasing contracts are generally long term, and usually last for at least one year or more, with an average contract duration between 3 and 4 years. In addition, in the vast majority of cases, repayments to lessors are made via direct debit or standing order from the lessee’s bank account, meaning that the necessary customer due diligence checks will have been carried out by the customer’s financial institution, before undergoing additional checks by the leasing company, as outlined below. As well as the factors that work to make the leasing and automotive rental industries inherently low risk, the industries have adopted numerous practices to ensure the risk of money laundering and terrorist financing remains low. For example, lessors will register a lessor’s title on an asset to avoid an asset being disposed of without authorisation. Additionally, leasing companies research suppliers extensively and visit them to avoid potential issues on the side of the supplier. Whilst we are in full support of the Commission’s aim of tackling money laundering and terrorist financing in the EU, we would like to stress the need to focus on implementing existing EU legislation -which has only been fully in force since January this year- before considering the adoption of any further legislation. This would allow supervisory authorities, and others responsible for implementing the provisions set out in AMLD 5, the opportunity to do so. It would also enable them to evaluate whether additional amendments to the regulatory framework would be required and, if so, what form these should take.
Read full response

Response to A new Circular Economy Action Plan

20 Jan 2020

Leaseurope, the European federation representing the leasing and rental industries, supports the Commission’s aim of improving the circularity of the European economy through the circular economy action plan. We believe the action plan would be more effective if the services offered by the leasing and rental industries, which will be essential in helping the Commission reach its objectives, were given due consideration. A number of key characteristics of the leasing and rental industries make them inherently compatible with the goals of the circular economy action plan. As experts on asset life cycle management and total cost of ownership, leasing and rental companies ensure that the assets they provide remain in good working condition and are able to be reused for as long as possible. This goal is very much in line with the ultimate rationale of the circular economy; to reduce waste and ensure materials are utilised until the end of their life cycle. In leasing and rental contracts, the lessor owns the goods, and is therefore responsible for their repair, maintenance, and disposal. As a result of this, leasing companies are primed to ensure they use materials and components that are easy to repair, maintain, and recycle at the end of their life cycle. In addition to leasing and rental companies ensuring goods are easily repairable and kept in good condition for the duration of their lifecycle, the industries’ focus on usage rather than ownership, and their role in ensuring the latest technologies are made available to consumers and businesses in the most cost effective manner will help facilitate a move away from outright ownership of certain types of goods. The leasing and rental industries facilitate shared use of vehicles and products, encouraging consumers to purchase less frequently, and ultimately ensuring that the same goods can be used for as long as possible. For example, in cases where a customer would traditionally purchase a new piece of equipment when an upgrade becomes available -and the old equipment would ordinarily be disposed of- the leasing industry ensures that the customer is able to upgrade their equipment to the latest model whilst the older equipment is still utilised by a customer with different requirements. In this way, the leasing and rental industries not only play a key role in preventing products from being discarded once a customer has finished using them, but also in encouraging a broader shift in consumer behaviour away from purchasing goods and towards using goods. This shift will be invaluable in facilitating the move towards a circular economy
Read full response

Response to Evaluation of the Motor Vehicle Block Exemption Regulation

19 Mar 2019

Leaseurope welcomes the opportunity to contribute to this evaluation on behalf of the European automotive leasing and rental industries. Leaseurope believes that the exemption has been most beneficial for the consumer and recommends that the regulation and accompanying guidelines should not only be maintained, but future-proofed. The automotive value chain has significantly been affected by the emergence of new connected services and the use of in-vehicle data. It is therefore necessary to consider updating the legal instrument of the MVBER/Guidelines framework to maintain a competitive aftermarket and mobility services market which will encourage innovation whilst at the same time benefit consumers and businesses. Leaseurope believes that shifting some provisions to the general vertical agreement without maintaining the MVBER does not constitute a viable alternative. Should the exemption no longer exist, there is a real risk that:  consumer choice could be limited, and the market become anti-competitive if our members lost the ‘end-user’ status afforded them by the regulation, as their ability to negotiate competitive prices for consumers would be removed  consumers could experience higher repair costs due the competitive imbalances in the dealership network  consumers could experience severe vehicle downtimes as some main dealers have lengthy lead times or are unable to properly service the vehicle  the roll-out of new innovative mobility services will suffer as a consequence thereof Why should it be maintained Lower cost of repairs for consumers The choice provided by the exemption has enabled the consumer to enjoy lower repair costs due to healthy competition between independent and OEM owned dealers. Consumer access to genuine manufacturer parts The exemption allows the consumer to access genuine OEMs parts supplied by dealers to independent garages, which helps to preserve warranties and ensure customer safety. Without the exemption, manufacturers may restrict access to their parts supply, warranty and goodwill if a vehicle is not serviced within their main dealer network. Convenience and quick turnaround for consumers Having the exemption in place has enabled consumers to access quick vehicle repairs. Currently, lead times through the main dealer networks are long due to a lack of capacity. Our members have reported cases of some manufacturers refusing breakdowns but having the c hoice to use independent garage networks has been helpful in reducing downtimes for consumers. What’s not working so well Technological advances make the exemption less powerful Advances in technology have made some vehicles quite complex. Some manufacturers are always adding in further technology as a way of limiting repairs to their own main dealer network, thus making the market anti-competitive. There is also a grey area with Hybrids and EVs in relation to the battery warranty. Some manufacturers do not appear to recognise the servicing completed by independent repairers as being adequate to cover the warranty on these items. Onerous requirements from manufacturers Some manufacturers have made it rather complex for an independent garage to confidently service or repair a vehicle to the exact standards requested by a manufacturer, the result being that any potential saving to the consumer is outweighed by the risk of an invalidated warranty. The requirements from manufacturers seems to be getting more onerous with regards to the proof required in order for a warranty to be honoured (i.e. receipts for oil, service schedules etc. Taking all of the above into account, we strongly recommend that the current regime is both maintained and strengthened. Sincerely, Richard Knubben Deputy-Director General
Read full response

Response to Cooperative, Connected and Automated Mobility (CCAM)

16 Nov 2018

Leaseurope represents as an umbrella body both the leasing and automotive rental industries in Europe, and is composed of 45 Member Associations in 32 countries. Its membership is responsible for purchasing over 40% of all vehicles registered within the European Union annually, representing a value of well over 200 Billion Euros. In the Roadmap the Commission proposes to address the issue of cooperative, connected and automated mobility across three unique strands; a data governance framework, cybersecurity and a holistic approach to connectivity and automation. With regards to the data governance framework the Commission rightly acknowledges that “centralisation of in-vehicle data as currently implemented by some market players, might in itself not be sufficient to ensure fair and undistorted competition between service providers.”. In light of these concerns, Leaseurope disagrees with the notion that an Impact Assessment was not deemed necessary following the conclusion that the economic, environmental and social impacts arising from this initiative are considered to be small. Access to in-vehicle data constitutes the new frontier for the development of not just a new type of vehicle but also current and new mobility services. Connected cars offer significant downstream business development potential for all stakeholders in the automotive value chain in terms of navigation (real-time localisation - traffic information - congestion mitigation), infotainment (access to streaming), fleet management maintenance (remote diagnostics and prognostics - vehicle recovery – utilisation of shared fleets – encouraging appropriate driver behaviour), insurance (pay as you drive), emissions monitoring and safety. Not having access to vehicle data will fundamentally undermine leasing and rental companies’ ability to provide their customers with a wide range of services they expect our industry to deliver. Moreover, as recognised in the 2018 DG MOVE study examining the effects of Extended Vehicle and Onboard Telematics Platform on the automotive aftermarket and mobility services, failure to address these issues properly will inevitably lead to reduced consumer choice, higher prices, hampered innovation and a significantly less competitive automotive value chain. In light of the above, Leaseurope would welcome a full impact assessment, as well as a comprehensive review of all Commission activities in this area already ongoing with DG MOVE, CONNECT, GROW, COMP and RTD, ensuring an integrated approach. Furthermore, any future recommendation and potential legislative follow-up should be based on a comprehensive testing of technical approaches, ensuring a better comprehension of the impact thereof on the entire automotive value chain.
Read full response

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and

9 Mar 2018 · Connected Car