Regulatory Communication
Education about and mediation of relationships within the financial sector, i.e.
ID: 785976617848-15
Lobbying Activity
Meeting with Emiliano Tornese (Head of Unit Financial Stability, Financial Services and Capital Markets Union)
17 Oct 2025 · Non-Bank Financial Intermediation (NBFI)
Response to 28th regime – a single harmonized set of rules for innovative companies throughout the EU
22 Sept 2025
Within the current debate around the European economys competitiveness, an important element is missing: how to encourage long-term ownership within the current economic and social reality. On top of the start-ups and scale-ups seeking continuity, an unprecedented change of ownership is about to put the European economy up for sale, with a silver tsunami of European baby boomer business owners retiring in the coming decade. With US private equity giants persuading European entrepreneurs to sell off their valuable businesses for irresistible amounts of money, and American venture capital funds cleverly poaching EU startups and scaleups with the most innovative potential, we continue to lose assets, taxes, jobs, autonomy and intellectual property to Wall Street and Silicon Valley. European businesses run the risk of effectively falling into the hands of owners driven solely by short-term financial profits. This short-termism is fundamentally incompatible with the EUs long-term competitiveness agenda, which calls for patient capital and future orientation. But the legal framework for the (transition to) these ownership forms is underdeveloped compared to the one for listed corporations. 450.000 businesses change ownership annually, with continuity being threatened in roughly 35% of cases when owners lacking viable options such as family succession. In Austria 30% of business owners are without a succession plan and in Germany, around 100.000 jobs are threatened annually due to lack of suitable succession options for closely held businesses. In Slovenia, almost 25% of all jobs in the private sector in Slovenia are threatened due to the lack of a succession plan. In order to facilitate an industrial transition that provides quality jobs and is beneficial for local development and community resilience, the EU can be inspired by growing trends in this domain. By giving more choices to exiting business owners, and making them choices easily available and attractive, all of Europe will benefit. Legal provisions in the 28th regime should be based on shared principles and present a comprehensive plan for changes in national corporate law: - a legal form for steward-ownership (SO) and employee-ownership (EO), listing the features of each for recognition as - an SO company, incl. o asset locks, o restrictions on transfer of controlling rights (cannot be sold freely), o separation of control vs profit rights, o rules about how surplus profits are reinvested or used for the mission rather than for dividends, o limits on what can be extracted from the firm as rewards/income for owners/investors; OR an EO company, incl. o use of a separate legal entity (SPV) through which employees can gain ownership, o use of financial leverage to overcome capital barriers, o inclusive of all employees, o participation of employees in equity, profit, and governance proportionally to the percentage owned by the SPV; - with a legally recognized and tax-neutral mechanism for an SO or EO business transition, both based around common European design principles but adjusted to the legal realities present in the member states; The EU currently lacks the capacity to nurture its own ecosystem of innovative companies, largely due to insufficient support for ownership retention and to the absence of credible, future-proof succession options in its legislative framework. As part of the 28th regime, the design of a European company should prioritise ownership structures that genuinely enable the growth of innovative and competitive industries across Europe. By doing so, the EU would catalyse a shift away from short-termism towards more forward-looking business models, anchoring capital within the single market and driving innovation through Europes existing competitive advantage. Rather than setting out aspirations for the EU to be more like the US, the former has the chance to chart its own path, building upon its own strengths and history.
Read full responseMeeting with Vincent Hurkens (Cabinet of Executive Vice-President Stéphane Séjourné) and Triodos Bank and European Microfinance Platform
18 Feb 2025 · Omnibus sustainability simplification, Savings and Investments Union
Meeting with René Repasi (Member of the European Parliament)
16 Jan 2025 · Sustainable Company Ownership
Response to Alternative Investment Fund Managers – review of EU rules
25 Jan 2022
This pack will exclude retail investors and unlisted investees from the impact investing market, when those meet in retail-funds that invest in (smaller) private or microfinance loans that are not provided by banks. I’m also concerned that the proposal increases the risk faced by citizens investing in AIFs and limits the choice of impact investing products that banks can offer to their retail clients. The proposal steers citizens towards riskier listed securities, equity or the much riskier crowd-funding market. As such, the proposal will induce retail markets to move away from the EU’s most important CMU and Sustainable Finance objectives: connecting citizens to companies that appeal to their purpose, and engaging citizens in their economies’ transitions towards sustainability. It will make the EU a riskier place for citizens to save and invest long-term through investment funds, not safer, and an exclusive market for the richest individuals only.
Article 16(2a) of the proposal requires an AIF to be closed-ended if the value of its originated loans exceeds 60 % of its net asset value. If retail-AIFs that invest in originated loans are closed-end, this implies a major loss of diversity and resilience of the EU’s financial markets:
1. No liquidity for retail investors until the "end" of the fund, while existing funds have shown adequate liquidity for over 20 years including during several shocks.
2. Limited access for citizens: Banks will choose to no longer distribute them, since their retail systems are organized for open end funds, for which retail clients can count on liquidity when they need it; so these AIFs are then only available for high net worth individuals; the recent successful growth in banks offering impact funds (for renewable energy, micro-finance, and innovations) in their private banking menu will be nullified;
3. Higher risk for retail investors: if funds decrease the amount of loans in the fund in order to stay below 60%, and increase the amount of equity, this will increase the risk profile of the fund; moreover, banks will not want to distribute “combi-funds” for their complexity, so the proposal will in practice only allow equity-only retail-AIFs;
4. Less investment in social and environmental impact: if funds cannot be distributed widely, less fund managers will choose to invest in those SMEs that are so crucial for the transition, both high impact innovative environmental entrepreneurs and social enterprises that ensure the supporting fabric of communities and increase resilience;
5. Only two choices left for retail investors: invest in (volatile) listed securities or engage in (very high risk) crowd-funding. Major parts of the retail market will be left without a safe investment option;
6. Marginalization of the potential market for eco-labelled retail-funds, leaving investors wanting to invest in ESG activities close to home & heart without this option.
7. Many smaller, innovative, non-traditional or micro- companies left without access to funding, when they don’t fit mainstream banks’ standards.
I agree that available liquidity is a crucial requirement for retail investment in general, but I see that many retail AIFs across the Union manage the liquidity of their funds with revolving finance, i.e. incoming and outgoing pipelines of granted and repaid loans, while always keeping part of the fund in liquid securities. A solution that does justice to both the necessary safety for retail investors and the diversity of the investment products with which citizens can engage in themes and undertakings that appeal to them, would be in the liquidity management requirements, so expand Article 16(2a) AIFMD with requirements for small, open-end LOFs like holding at least 10% of its qualified investments in high quality liquid assets, offering at least one redemption opportunity per month, etcetera.
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