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Réseau des Chambres de Commerce et d'Industrie Insulaires de l'Union européenne

INSULEUR

1.

Lobbying Activity

Response to Review of the State aid rules on the Services of General Economic Interest (“SGEI”)

30 Jul 2025

INSULEUR - The Network of the Insular Chambers of Commerce and Industry of the EU welcomes the European Commissions initiative to revise the SGEI rules and appreciates the opportunity to contribute insights from the perspective of EU islands. The availability of adequate and affordable housing is a growing concern in insular territories, where geographic constraints, rising tourism pressure, and high construction costs compound social and economic challenges. In this feedback, INSULEUR highlights a set of urgent priorities to ensure that the revised framework adequately reflects the specific needs of island communities. We call for the inclusion of key-worker housing in tourism-heavy areas, the adoption of higher aid intensity thresholds for insular regions, and stronger provisions to support sustainable, energy-efficient housing. We further recommend: - Introducing territorial differentiation in the legal definition of affordable housing; - Exempting island projects from the restrictive 15 million cap; - Simplifying procedures for local authorities through model templates and fast-track review mechanisms; - Explicitly addressing demographic pressure, pricing distortions, and land-use constraints unique to island contexts; - Supporting inter-island cooperation and pooled investment schemes. Our detailed feedback, observations and proposals is included in the attached document.
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Response to Ex post evaluation of the European Regional Development Fund and the Cohesion Fund 2014-2020

3 Feb 2022

Despite specific provisions targeting islands in EU policies, and in particular in Cohesion Policy regulations, INSULEUR has observed that a consistent and particular attention to insularity as enshrined in Article 174, is missing in Cohesion Policy and therefore from its delivery instruments (ERDF, CF). Islands in different Member States receive from Cohesion Policy amounts that vary considerably, depending on their classification, their situation, and specific interstates agreements, deriving from macro-economic considerations rather than territorial matters. As a result, many EU islands (Corsica, Ionian Islands etc) did not receive such extra financing, whereas they also have to face similar territorial and demographics handicaps (no fixed link to mainland, remoteness, ageing population etc.). This lack of consistency shows that the principles laid down in Article 174 TFEU have not been translated into specific budgetary provisions for islands. A consistent approach to insularity should cover all islands, regardless of their status, size or remoteness. - Although all island regions were involved in the process of developing Operational Programmes, the weakness of the provisions guaranteeing the involvement of regions in Cohesion Policy leaves a large margin of manoeuvre for Member States to decide on the degree of influence of Regions in the preparation of the Partnership Agreement and Operational Programmes. Where island regions were given a special treatment in Operational Programmes, it was mostly due to their special status in their own Member State/constitution, and not thanks to the provisions provided under Article 174 TFEU. - There is a strong potential of territorial financing tools for island regions, but improvements should be introduced to simplify their use and to better link them to islands specificities. Indeed, there are currently very few incentives to encourage Member States/regions to implement integrated territorial development strategies focusing strictly on the specific issues faced by islands. - GDP per capita is also the sole criterion for identifying specific conditions of eligibility to the benefit of the structural funds. This criterion does not reveal really the well-being of insular populations. The Cohesion policy framework for the islands could be governed among other by a more complete system of criteria, complementing the use of GDP per capita as indicators for determining regions eligibility and policy intensity for financing by the EU Cohesion Policy. Furthermore the eligibility rules included in the regulations should apply in the case of island territories in such a way that provides full range eligibility of actions. - When screening OP covering specific territories, the Commission should be given the right to deliver recommendations calling for the Member State to ensure a more effective implementation of Article 174 by setting up specific measures/ad hoc programs to address specific natural and demographic handicaps of islands and/or harness their untapped potential. - All island territories should benefit from the same degree of flexibility to the thematic concentration requirements under the ERDF and greater flexibility in the programming should be ensured, thus allowing Member States and regions to accommodate their specific needs within the thematic scope of Cohesion Policy. - Cohesion Policy funding: At European level, provide an additional envelope for Member States with islands and at national level, set up specific redistribution mechanisms in favour of islands. Overall, in order to guarantee that progress is made towards achieving economic, social and territorial cohesion (including the socio-economic situation of regions as well as the integration of EU priorities), INSULEUR argues that all European islands should finally benefit from policies and measures translated in adequate ERDF and Cohesion Funds adopted at EU or national level, based on the “insularity” factor.
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