Social Services Europe
SSE
Social Services Europe brings together eight Europe-wide networks of not-for-profit providers of social and health care services – currently comprising Caritas Europa, CEDAG, E.A.N., EASPD, EPR, Eurodiaconia, FEANTSA and the Red Cross EU Office, representing over 200,000 not-for-profit social and health care organisations – who each have a track record in providing value-driven services for persons in need.
ID: 470169313931-02
Lobbying Activity
Response to General revision of the General Block Exemption Regulation
6 Oct 2025
Social Services Europe welcomes the opportunity to provide input to the European Commission in regard to the revision of the General Block Exception Regulation. In its current form, the GBER already regulates block exemptions in the areas of effective support for the recruitment, employment and training of disadvantaged and disabled workers in the form of wage subsidies and for the compensation of the additional costs of employing disabled workers. The exemptions provided by the Regulation so far have encouraged Member States, regions and other public authorities to allocate State Aid to enterprises and organisations employing disadvantaged workers and workers with disabilities, fostering employment and contributing to competitive and inclusive labour markets. The national members of Social Services Europe (SSE) contribute to ensuring that well-functioning, accessible and high-quality social services and the related infrastructure can be guaranteed at the local level across Europe. Drawing on their experience, SSE can highlight both the complexity of state aid rules and the fact that these rules are often not well understood by public authorities in EU Member States or by social services and social economy organisations themselves. As a result, the potential of state aid to support the sector remains underused. At the same time, State Aid and in particular the GBER do not fully respond to the specific characteristics of social services and social economy, specifically recognising their model in re-investing their profits in line with their objectives and missions. This, combined with underdeveloped social economy ecosystems and the absence of dedicated legal frameworks, further restricts the sectors access to funding. Yet the magnitude of the social economy1 in Europe makes these barriers particularly concerning. Across the 27 Member States, the social economy encompasses more than 4.3 million entities. At least 11.5 million people representing 6.3% of the EUs employed population work in the social economy, including 3.3 million in the health and social care sector alone. In 2021, the sector generated revenues amounting to a turnover of at least EUR 912 billion. State aid for social services not only supports inclusion but also contributes directly to growth. It enables the employment of persons with disabilities and other disadvantaged groups, and it encourages companies to recruit more inclusively helping to address persistent staff shortages. Many social services themselves are among the largest and fastest-growing employers. They also contribute significantly to the wider economy, including through work integration social enterprises, sheltered employment etc. With these in mind, SSE provides the following recommendations to the European Commission in light of the upcoming revision of the GBER. These aim to ensure that the specificities of the social economy and non-profit social services are fully recognised, and that the Regulations potential is realised to increase the employment of disadvantaged workers and workers with disabilities, while supporting their transition into the open labour market.
Read full responseResponse to The new Action Plan on the implementation of the European Pillar of Social Rights
28 Aug 2025
Social Services Europe (SSE) is a network of 9 European umbrella organisations currently comprising Caritas Europa, CECOP, CEDAG, E.A.N., EASPD, EPR, Eurodiaconia, FEANTSA and the Red Cross EU Office representing over 200,000 not-for-profit social and health care organisations, in a sector employing in 2018 over 11 million people and with has seen an increase of the workforce of more than 10% between 2013 and 2018. The Position Paper attached contains the proposals by Social Services Europe for the European Pillar of Social Rights Action Plan (EPSR AP) which the EC announced to present before the end of 2025 as the follow-up Action Plan to the one issued on 4 March 2021. We indicate in the Position Paper those actions which have particular priority for SSE. It is divided into two main parts: I) SSE Proposals and Priorities for the European Pillar of Social Rights Action Plan (EPSR AP) 2025 and II) SSE Assessment of the European Pillar of Social Rights Action Plan (EPSR AP) 2021: Selected Aspects. SSE has also worked on and/or reacted to several of the specific initiatives included in the EPSR AP 2021, such as European Care Strategy, the Strategy for the Rights of Persons with Disabilities 2021-2030, including the Disability Employment Package and the Social Economy Action Plan. SSE has used the latter quite a lot to actively address and promote the objectives of the EPSR and its priorities on social services. SSE members have been actively involved in several other specific initiatives of the EPSR AP 2021, such as the European Platform on Combating Homelessness In 2024, SSE elaborated a Social Services Action Plan (last updated: 30 June 2024; cf. here on SSE's webpage: https://www.socialserviceseurope.eu/_files/ugd/9f45fc_e304e129d5ac4053b7dbe0c13feb36de.pdf). This document is an important source for the proposals and priorities for SSE for the ESPR AP 2025 included in this document. SSE has also filled in the questionnaire prepared by the EC for this call for evidence and submitted it on 28 August 2028, together with the SSE Position Paper. We have two comments: a) We have replied to all questions except for Q2.1. "we would like to get your assessment on the possible impact the 2021 Pillar Action Plan and all the initiatives that were launched under it - has had on the social and employment situation in Europe. To what extent do you agree or disagree with the following statements: Between the launch of the first Pillar Action Plan (in 2021) and today" SSE considers that useful answers to the 14 statements cannot be given across the board for the whole EU27, but if at all only for each country and sometimes even for a given region. b) Regarding Q3.5 "In the context of the new Action Plan to implement the European Pillar of Social Rights, how can we balance strong social and labour protection with reduced administrative burden?", SSE opted for "Agree somewhat" the first category "Reducing reporting and monitoring requirements for Member States and stakeholders." SSE would like to underline that the agreement concerns the not-for-profit providers of social services and organisations of the social economy. SSE and its members, however, also support a monitoring of how governments of the EU Member States and the local and regional governments (LRGs) comply with labour and social protections.
Read full responseResponse to Review of the State aid rules on the Services of General Economic Interest (“SGEI”)
31 Jul 2025
The national members of Social Services Europe (SSE) contribute to ensuring that well-functioning, accessible and high-quality social services and the related infrastructure can be guaranteed at the local level across Europe. SSEs reply to the questionnaire covers SSEs take on the use of state aid for affordable housing. The complexity of the SGEI Decision, in particular the rigid rules regarding the act of entrustment (Art. 4), requirements for determining the amount of compensation (Articles 5 and 6), and the citation requirement (Article 4(f)), has meant that in most EU MS it is used far too little in the field of social service provision. In order to make the SGEI Decision easier and more comprehensively applicable for the social services sector, SSE sees the need for the European Commission (EC) to issue specific guidelines on focused on social SGEI. These guidelines should also include a note that the generalised application of the general de minimis Regulation in the field of social services across many EU MS should be avoided, and that in a first step the applicability of the, as a rule, content-wise more appropriate SGEI Decision should be examined by the local, regional or national authorities. Furthermore, it should be clarified that a check and proof of market failure in every single case is not required in the area of social SGEI, in particular in the field of social services. The fulfilment of two other criteria should be sufficient to determine a genuine social SGEI, namely 1) the existence of a social need and 2) subsumption of a social service under the exhaustive list in Art. 2 1. c). Such clarification would strengthen the legal certainty of the provision of social SGEI, reduce unnecessary bureaucratic burdens of assessing the nature, mission and economic impact of a social service as a rule provided locally and thus effectively address the practical obstacles to the applicability of the SGEI Decision in the area of social SGEI. In addition, all investments directly related to the provision of social SGI, in particular social services e.g. to improve their climate protection effect, their energy efficiency or to roll out digitisation projects should be eligible for exemption under the category of social SGEI in line with Article 2 1. c) and with Art. 5 3. d) concerning the compensation for costs linked with investments concerning infrastructure necessary for the operation of the SGEI. In Article 2 1. h) of the SGEI de minimis Regulation, a non-profit entity is defined as an entity which, irrespective of its legal status (organised under public or private law) or way of financing, whose primary purpose is to undertake social tasks, which reinvests any profits gained and which predominantly engages in non-commercial activities. Since non-profit entities or more generally speaking not-for-profit organisations or organisations of the social economy provide social services not only when the SGEI de minimis Regulation applies, this definition of non-profit entity should generally apply for all EU State Aid instruments including within the framework of the SGEI Decision. For SSE it is also important that the absence of the citation requirement should not render the act of entrustment invalid. It would be disproportionate to attach such a legal consequence to the non-compliance with a formal requirement, even more so as there is evidence from the last decade that it prevents the use of the SGEI Decision in practice, not least in the area of social services. Finally, SSE calls for the introduction of a radically simplified entrustment act for the provision of social SGEI by non-profit entities, based on a list of criteria. This would provide an ex-ante clarification and create more legal certainty in the correct use of the SGEI Decision. The attachment contains a more detailed description of the practical problems and SSEs proposed solutions on how to pragmatically address them.
Read full responseResponse to Mid-Term Review: Social Economy Action Plan
16 Jul 2025
Social Services Europe (SSE) is a network of 9 European umbrella organisations currently comprising Caritas Europa, CECOP, CEDAG, E.A.N., EASPD, EPR, Eurodiaconia, FEANTSA and the Red Cross EU Office representing over 200,000 not-for-profit social and health care organisations. They provide care, training, support and guidance to millions of people across Europe such as children, older persons, persons with disabilities, people at risk or experiencing poverty and social exclusion, homeless people, migrants and asylum seekers and other vulnerable groups and this in various stages in life. The national members of the 8 EU-level networks being members of SSE are active in a sector employing over 11 million people in the EU 27, of which about half are employed by social economy organisations. This contribution builds on earlier work of SSE on the topic social economy the Social Economy Action Plan (2021), the Council Recommendation on developing social economy framework conditions (2023) as well as in the context of the EC Expert Group on Social Economy and Social Enterprises (GECES) In this summary feedback SSE focuses on points in relation to question 4) What measures should be prioritised in 2026-2030 to help the social economy achieve its full potential? EU Social Economy Gateway: Adding more thematic areas (Topics in focus), in particular on Socially Responsible Public Procurement and Taxation. Keep a strong and supportive social economy angle/perspective into the debates and revisions of EU legislation on state aid in view of the forthcoming revisions of the General Block Exemption Regulation (GBER) until the end of 2026 and of the SGEI Decision, triggered by the European Affordable Housing Plan and on public procurement (with the ongoing revision of Directive 2014/24/EU). As to public procurement, SSE refers to its contribution to the EC Call for Evidence on the Revision of the Public Procurement Directive (4 March 2025) and the Joint Statements of the Network for Sustainable Development in Public Procurement SSE has signed, the recent Open Letter EP Report Public Procurement Compromise Amendments (3 June 2025) and the Letter of the Civil Society Organisations calling for reforms in public procurement to achieve sustainable development goals (24 January 2025). SSE would like to see changes to the EU State Aid Legislation that fully acknowledge the specificities of not-for-profit/social economy providers of social services and of their users and that provide a simple and supportive and administratively simple EU-level regulatory framework for those providers to be able to get the public (financial) support they need to fulfill their social missions, to provide needs-based, user-oriented and community-based social services and to contribute to the realisation of social, health, employment and housing related policy objectives defined by the national or regional legislators and/or by the competent public authorities. For more details SSE refers to its responses the EC Calls for Evidence on the Revision of the general de-minimis Regulation (20 July 2022) and the SGEI de-minimis Regulation (1 June 2023). Improve the data availability on the social economy for comparative purposes, but also within EU MS, including on the (key) sub-sectors. SSE would like to see a focus on the sector of social services (of general interest). Dedicated support for social economy entities, including those in health and social services - must be safeguarded and strengthened under the MFF 2028-2034. With the EC soon beginning its assessment of the Social Climate Plans of the Social Climate Fund, we strongly urge the Commission to make sure that social economy actors have been meaningfully included in both the design and implementation phases. Foresee information and awareness raising measures, mutual exchange and monitoring in view of the transposition of the Directive on an European Cross-Border Association.
Read full responseResponse to Apply AI Strategy
4 Jun 2025
Social Services Europe (SSE) is a network of 8 European umbrella organisations currently comprising Caritas Europa, CEDAG, E.A.N., EASPD, EPR, Eurodiaconia, FEANTSA and the Red Cross EU Office representing over 200,000 not-for-profit social and health care organisations, in a sector employing in 2018 over 11 million people and with has seen an increase of the workforce of more than 10% between 2013 and 2018. SSE welcomes the creation of an EU Apply AI Strategy and the present consultation that demonstrates the ambition to set global standards for trustworthy AI and to balance technological advancement with ethical considerations and human rights. In the context of global technological transformation, and the European Commissions ambition to make Europe an AI continent, investing in the potential of AI in social services especially through responsible and inclusive AI is not only a social imperative but also a strategic investment in Europes long-term competitiveness. Social services must be recognised as a strategic sector in the Apply AI Strategy not only as a user of AI technologies but as a key stakeholder in shaping inclusive, ethical, and human-centred AI ecosystems further enhancing EUs competitiveness. In social services, AI offers significant potential to improve efficiency, accessibility and personalise care. However, successful implementation hinges on addressing sector-specific challenges. These include, among others, data privacy concerns, fairness and bias in algorithms, lack of digital skills among workers, and ethical concerns like surveillance, human care replacement or absence of transparency regarding the use, decision-making process and training of AI-based tools. The strategy must emphasise basic ethical principles of digitalisation: the need to develop and deploy people-centric technology, ensuring privacy protection, inclusive participation, data security and ethical AI use, warranting that AI augments rather than replaces human care. In a recent SSE report on AI-adoption in social services (https://www.socialserviceseurope.eu/_files/ugd/9f45fc_30064b82e3c8405492861872463225d4.pdf), we highlight key recommendations that the EU should emphasise and support with specific regulation, funding schemes for public and private entities and other initiatives that allows the ethical adoption of AI: 1) Co-develop inclusive AI solutions Engaging from the beginning diverse stakeholders, including service users, to codesign tools tailored to their needs. 2) Invest in digital literacy and skills training Establish comprehensive education programmes to prepare workers in social services for AI integration and management layers to be aware of the legal frame like the AI Act. 3) Implement strong regulatory oversight - Taking into consideration the European AI Act, the EU should enforce principles of transparency, accountability, and fairness, building mechanisms for correcting misinformation and maintaining a human oversight layer. 4) Foster collaborative approaches among policymakers, technologists, researchers and service providers to innovate responsibly. 5) Focus on ethical AI deployment Prioritise human dignity, autonomy, and well-being in AI design and application. Inclusive regulation and funding should safeguard dignity and prevent digital exclusion.
Read full responseResponse to Evaluation of the Public Procurement Directives
6 Mar 2025
SSEs assessment: Overall, Directive 2014/24/EU establishes a broadly appropriate legal framework for public procurement across the broad range of economic sectors and across the EU. There are, however, at least three caveats/limitations to this general statement above which applies when looking at the main purposes and objectives of public procurement markets and procedures. Scope for action and starting points for flexibility in public procurement law: It is positive that Directive 2014/24/EU brings flexibility for public procurement procedures and the design of public contracts. In practice, however, this leeway cannot be realised sufficiently and to satisfactorily level in view of the actual use of the features of socially responsible public procurement (SRPP). Even though Directive 2014/24/EU has opened some doors for the better use of SRPP, this option is much too little used within the EU MS at the different levels of administration and across all types of contracting authorities. There is a serious shortcoming in practice: A chilling effect prevails, an avoidance to exploit the full potential of provisions supportive of socially responsible public procurement on paper, given the risk averseness of contracting authorities fearing mistakes, delays or recourses, and given the control and assessment practice by both supervisory bodies for local governments and/or by court of auditors. The insistence of Art. 76.2 Social and other specific services: Principles of awarding contracts of Directive 2014/24/EU to ensure that contracting authorities take into account the criteria stemming from the organisation, regulation, financing and institutional embeddedness of social services as SGEI is fully justified across the EU if and where national legislation requires the application of public procurement procedures. SSE proposes that the wording of this Art. 76.2 should be adapted from Member States shall ensure that contracting authorities may take into account the need () to Member States shall ensure that contracting authorities take into account the need (). SSEs main proposals for revision: 1) Make the use of the Most Economically Advantageous Tender (MEAT)/Best Price Quality Ratio (BPQR) criteria the standard/default logic for public procurement, at least/in particular in economic sectors where staff costs make up for a big share of the total costs, such as in the sector of social services; 2) Social criteria should remain mandatory and not be seen as discriminatory against economic operators, provided accommodations are made to ensure/facilitate the access to public contracts for SME; 3) Promote SRPP in the area of social services as the standard procedure if and where national legislation prescribes the use of public procurement; 4) Elaborate (e.g.) an interpretative communication by the EC to underpin a full (legal) recognition of alternative models to public procurement e.g., authorisation or licensing procedures, reserved markets, or user-led funding models such as personal budgets which promote cooperation and a partnership culture between public authorities, social care providers, service users and other stakeholders; 5) Accessibility: Encourage the comprehensive use of the provisions of Directive 2014/24/EU in relation to the accessibility of products or services procured, building in particular on articles 42, 62, 67 and 76 and on recitals 99 and 101; 6) Better enforcement of rules on reserved contracts (Art. 20); 7) Include references to the social economy as part of future award criteria (Art. 67), in addition to the MEAT/BPQR criteria; 8) Extend Art. 70 (Contract performance clauses) in a way to facilitate their use to promote the inclusive labour markets, workplaces and jobs and the transition of persons with disabilities and other disadvantaged workers into the open/regular labour market.
Read full responseResponse to Proposal for a Directive on cross-border activities of associations
28 Feb 2024
EC Proposal for a Directive on European Cross-Border Associations (COM(2023) 516 final), Brussels, 05.09.23 Reply by SSE to the EC Call for Evidence (28 February 2024) Social Services Europe (SSE) is a network of eight European umbrella organisations comprising Caritas Europa, CEDAG, E.A.N., EASPD, EPR, Eurodiaconia, FEANTSA and the Red Cross EU Office [N.B.: The Red Cross EU Office is not signing this SSE reply] representing over 200,000 not-for-profit social and health care organisations. We are active in a sector employing over 11 million people, of which about half are employed by social economy organisations. On 10 February 2022 SSE issued the SSE Position and Briefing Note Statute for European Cross-Border Associations and Non-Profit Organisations. On 28 October 2022 SSE submitted a response to the EC Call for Evidence on an EC proposal for a legislative initiative on cross-border activities of associations. On 6 January 2023 SSE has also contributed to the impact assessment study on cross-border activities of associations. SSE co-signed the Joint Civil Society Position Paper on the European Parliament Proposal for a European Association Statute with CSE, PHILEA, CEDAG and the European Center for Not-For-Profit Law (10 February 2022). SSE has co-signed two letters with CEDAG, CSE and PHILEA to Commissioner Breton (4 May 2023 and 20 July 2023). For this call for evidence, SSE has also co-signed a joint reply with AIM, CEDAG, CSE, PHILEA and SEE. The following response refers to the EC Proposal for a Directive on European Cross-Border Associations (COM(2023) 516 final) of 5 September 2023 and contains references to the related EP JURI Committee Report adopted on 13 February 2024. It is presented under three headings: 1) Positive elements 2) Aspects that would need to be amended or clarified 3) Avenues of further work beyond the directive The full SSE reply is attached.
Read full responseResponse to Proposal for a Directive on cross-border activities of associations
28 Oct 2022
Social Services Europe (SSE) is a network of eight European umbrella organisations comprising Caritas Europa, the European Council for Non-Profit Organisations (CEDAG), the European Ageing Network (E.A.N.), the European Association of Service Providers for Persons with Disabilities (EASPD), the European Platform for Rehabilitation (EPR), Eurodiaconia, the European Federation of National Organisations Working with the Homeless (FEANTSA) and the Red Cross EU Office representing over 200,000 not-for-profit social and health care organisations. We are active in a sector employing over 11 million people, of which about half are employed by social economy organisations. More than a third of the (estimated) 13.8 million paid jobs in the social economy is in the social services sector. SSE welcomes the new impetus aiming at adopting common minimum standards for non-profit organisations in the EU and a European Statute for European Associations, supported by the Resolution of the European Parliament (EP) of 17 February 2022 which called for such a statute. SSE also welcomes the European Commissions (EC) commitment to respond to the EP Resolution with a legislative act and the related (EC) call for evidence for an impact assessment launched on 5 August 2022. SSE particularly welcomes a key aspect of the EC legislative proposal in line with the letter sent by the EC to the EP on 11 May 2022, namely the facilitation of cross-border activities of (national) associations by addressing and overcoming barriers which hinder these activities. SSE, however, urges the EC to show more ambition by better recognizing the double function of many associations in the field of social services across Europe as 1) providers of services of general (economic) interest in which they play an important role for the lives and well-being of millions of European residents, for the welfare states and social protection systems in the EU and 2) and promotors, facilitators, key actors and defenders of effective civil dialogue and participatory democracy. They also offer opportunities for volunteering. For SSE, having a statute for European cross-border associations and non-profit organisations would be an important tool to guarantee a level playing field in the internal market. It would also bring about a positive definition of a not-for-profit/non-profit organisation. It would help clarifying one of their key features, the so-called full asset lock, i.e., their obligation to use their financial reserves and any possible profit only in accordance with their specific purpose (as laid down in the statutes). For SSE, a Regulation on a statute for European cross-border associations and non-profit organisations (building both on art. 352 TFEU and art. 114 TFEU as legal bases, to be considered more in detail with legal experts) and a Directive on common minimum standards for non-profit organisations (having as main legal basis art. 114 TFEU) in the EU would fill the legislative gap for an EU-wide regulatory framework supportive of and better facilitating their cross-border activities. SSE does not support a harmonisation of common minimum standards for cross-border operations across the EU MS, but rather the definition on EU level of key principles on which national law should be developed in full respect of fundamental rights and freedoms. The text adopted by the EP on 17 February 2022 includes most of the key points relevant for our members and for social services throughout Europe. SSE on 10 February 2022 issued the SSE Position and Briefing Note Statute for European Cross-Border Associations and Non-Profit Organisations. On the same day SSE co-signed the Joint Civil Society Position Paper on the European Parliament Proposal for a European Association Statute with Civil Society Europe (CSE), PHILEA, CEDAG and the European Center for Not-For-Profit Law.
Read full responseResponse to Developing social economy framework conditions
30 Sept 2022
Social Services Europe (SSE) welcomes the European Commission proposal for a Council Recommendation to be presented in 2023. SSE contributes to this recommendation due to our extensive knowledge of the realities and needs of not-for-profit social services providers within the social economy. SSE also highlights that more than a third of the (estimated) 13.8 million paid jobs in the social economy are provided by social services.
Therefore, SSE recommends the following:
• Promote socially responsible public procurement (SRPP) when public procurement is deemed the right way to proceed for the commissioning of services, e.g., for reserved markets to boost employment for disadvantaged workers. Ideally SRPP should be the approach to guide all procurement of services or goods. Additional training and awareness raising activities should be provided in EU Member States (MS) to ensure commissioning authorities are able to implement SRPP in their calls for tenders and undertakings.
• Promote legal and political recognition for alternative instruments to public procurement (respecting the general principles of EU law). As noted above public procurement is not always the correct funding mechanism through which to finance social service provision.
• Revise State Aid rules to ensure more accessibility to not-for-profit social services within the social economy. In the context of the upcoming revision of EU State Aid rules, SSE calls for a significant increase of the threshold of de minimis aid and of the threshold for services of general interest (SGEI) to reduce bureaucracy and improve legal certainty for more contracts. MS should ensure a clear connection at national level between the necessity to improve access to funding and to improve existing State Aid rules.
• Promote and reinforce structured dialogue in all sectors of the Social Economy, including the social services sector. SSE calls for cooperation at the national level between local and regional authorities and social economy organisations, including not for profit social service providers to be strengthened through regular dialogue, as well as cross-border and transnational cooperation.
• Nominate social economy ambassadors as quickly as possible to support social economy organisations, including social service providers, to facilitate access to EU and national funding and to consult with authorities.
• Ensure investment for the sustainability and impact of not-for-profit social services within the social economy. Multiple options for funding should be developed beyond public procurement including but not limited to grants and favourable financing options through loans and guarantees. The recommendation should also ensure all actors in the social economy sector, and particularly not-for-profit social services providers are able to put in place the necessary digital and green transitions.
• Provide training and awareness raising activities on all relevant areas such as taxation frameworks and State Aid as well mapping and exchange of good practice at all levels.
• Encourage that any future guidance addresses social economy organisations and not-for-profit social services providers, respecting their objectives, service mission and the non-distribution constraint for any profits or surplus their economic activities might produce.
• Address low wages and precarious working conditions in the sector through the proposed national social economy strategies. Due to underfunding and the negative perception of the sector there are serious challenges in recruiting and retaining staff, resulting in significant challenges in having a qualified and a gender-balanced staff. The result is that a shortage of highly skilled staff can hamper the ability to provide quality services for users and all those in need.
Social Services Europe (SSE) is a network of eight European umbrella organisations – Caritas Europa, CEDAG, E.A.N., EASPD, EPR, Eurodiaconia, FEANTSA and the Red Cross EU Office.
Read full responseResponse to Review of the de minimis aid Regulation
20 Jul 2022
SSE Contribution to the EC Consultation on exemptions for small amounts of state aid
Social Services Europe (SSE) is a network of eight European umbrella organisations – comprising Caritas Europa, CEDAG, E.A.N., EASPD, EPR, Eurodiaconia, FEANTSA and the Red Cross EU Office – representing over 200,000 not-for-profit social and health care organisations. We are active in a sector employing over 11 million people, of which about half are employed by social economy organisations. This also means that more than a third of the (estimated) 13.8 million paid jobs in the social economy is in the sector of social services. The COVID-19 pandemic clearly showed its relevance, its resilience, but also exposed challenges and weaknesses. In the last decade, SSE and its members have systematically monitored the impact of EU State Aid Rules on social services.
In order to ensure the effective, transparent and unbureaucratic provision of social services on the one hand and compliance with EU State aid rules on the other, SSE underlines the need for all actors not only to lawfully apply the EU State Aid Rules, but also to simplify their application in practice. This concerns the general de minimis regulation (1407/2013) and the SGEI de minimis regulation (360/2012).
If the conditions laid down in Article 107 TFEU are not met, EU State Aid Law should also not be applied. In addition, the transparency requirements must be formulated as simple as possible to allow for a non-bureaucratic application of the de minimis regulations which can easily be checked at all levels of administration.
SSE calls for a significant increase of the threshold of de minimis aid of currently standing at 200,000€, as set in Regulation 1407/2013. This amount was fixed 16 years ago by Regulation 1998/2006. This justifies and makes necessary a significant adjustment to cater for price increases and inflation. As the next adaptation of the threshold is not expected to happen in the next years again, future price and inflation developments have to be taken into account when defining the adapted threshold.
If the de minimis threshold is raised under Regulation 1407/2013, the threshold for services of general interest (SGEI) set in Regulation 360/2012 must also be raised. It currently stands at 500,000€ of any period of three fiscal years (Art. 2, Paragraph 2). An increase to 1.5 million € for any period of three fiscal years would ensure a better functioning of the Regulation on the ground. A large majority of providers of SGEI in the social services sector is active at a local or regional level. The European Commission shares the view that where beneficiaries of state aid offer goods and/or services – including social services – operating mainly in a geographically limited area in a EU Member State this will significantly lower the probability of attracting providers from other EU Member State, implying that there is no (important) effect on the trade between Member States (see Commission Notice 2016/C 262/01 of 19 July 2019, Paragraph 196). Not-for profit social service providers do not share profits with any shareholders. They also operate in areas (e.g., rural areas) that are economically not profitable for for-profit providers. This all reduces the likelihood that these services will be offered by competitors from other EU Member States. Not-for profit social service providers often depend on financial support by public authorities. If one juxtaposes the specific social and societal roles and the specific funding needs of SGEI providers to the low “risk” of a significant impact on cross-border competition and trade, the first objective must be given much greater weight and thus lead to a substantial increase of the threshold.
SSE supports further specific demands for the revision of the general and SGIE de minimis regulations contained in a position paper issued in January 2022 by the BAGFW, which is available in English and German (https://bit.ly/3AzHYgU).
Read full responseResponse to Proposal for a Council Recommendation on long-term care
8 Mar 2022
Social Services Europe (SSE) - Contribution for the European Care Strategy
Social Services Europe (SSE) is a network of eight European umbrella organisations – comprising Caritas Europa, CEDAG, E.A.N., EASPD, EPR, Eurodiaconia, FEANTSA and the Red Cross EU Office – representing over 200,000 not-for-profit social and health care organisations. We are active in a sector employing over 11 million people, of which about half are employed by social economy organisations. The sector is also characterised by a strong employment growth dynamic in the last 10 to 15 years (with a workforce increase by more than 10% between 2013 and 2018), also due to growing social needs. The COVID-19 pandemic clearly showed its relevance as essential services, its resilience, but also exposed challenges and weaknesses.
Our national members support millions of people in various stages in life, such as children, the elderly, persons with disabilities, people at risk of or experiencing poverty and social exclusion, people experiencing homelessness, migrants, refugees, and asylum seekers, LGBTIQ+, and other groups in situations of vulnerability. Our members all recognise the many intersectionalities that people who require care face and so they offer care, support, guidance, education, and training services, as well as addressing barriers and situations of discrimination with the aim to empower the people relying on their support. This is often done through integrated approaches in partnership with public authorities and other service providers. Social services are a core part of national social protection systems and are services of general interest.
SSE’s contribution to the European Commission’s Consultation on the Roadmap for a European Care Strategy is structured in three parts:
• Section 2) contains SSE’s reflections and proposal on the directions for developing social care should take. It covers eight aspects: a) Raison d’être of Social Care; b) Evolving Demand; c) Paradigm Shift; d) Social Care in Crisis; e) Detrimental Impact on Gender Equality; f) Detrimental Impact of the Care Drain; g) Strategic Advantage N°1: 100,000 Not-For-Profit Providers; h) Strategic Advantage N°2: 11 million workers
• Section 3) focuses on the facilitating framework conditions. It deals with ten aspects: a) Varying and Often Outdated Framework Conditions; b) New Strategies; c) Quality of Life Indicators; d) Social Innovation; e) Digitalisation; f) Integration of Social and Health Sector; g) Social Infrastructure Development; h) Workforce Challenges: Lack of Attractiveness, Staff Shortages, Upskilling and Re-skilling; i) More Public Funding; j) Promote Effective Funding Methods
• Section 4) concludes with concrete policy recommendations for the EU Care Strategy. It elaborated more in detail on twelve proposals: a) Enabling Framework Conditions; b) EU Care Strategy promotes a modern vision of Social Care in the EU; c) EU Care Guarantee; d) Modern Vision of Care; e) National Action Plans; f) European Care Platform; g) EU Skills for Care Initiative; h) Campaign to improve attractiveness of jobs in the social care sector; i) EaSI: Annual call for proposals for innovative projects in the field of social care; j) Horizon Europe Programme: Targeted calls for research and innovation into social care; k) InvestEU: Boosting investment into social care; l) European Competence Centres for Social Innovation: Priority focus on social care
We do believe that there are opportunities for the development of Social Care in Europe and have identified two specific strategic advantages that can be leveraged as the European Union addresses the care challenge: Strategic Advantage N°1: 100,000 Not-For-Profit Providers & Strategic Advantage N°2: 11 million workers.
For SSE, the EU Care Strategy must affirm the direction and role that social care should take to achieve jointly agreed objectives. The EU Care Strategy should be implemented in complementarity with other EU strategic frameworks.
Read full responseResponse to Social Economy Action Plan
23 Apr 2021
Social Services Europe Feedback on the Roadmap for the Action Plan on Social Economy: “The Social Economy Action Plan: maximizing the potential of not-for-profit social services?”
Social Services Europe (SSE) welcomes this opportunity to submit feedback to the Roadmap. Given the significant size, scope and impact of the social services sector in the social economy, SSE calls on the Commission to develop an Action Plan that: acknowledges social service providers as key actors in the social economy; ensures they are supported legally, politically and financially; and supports and promotes all social economy actors as strategic partners, especially in terms of job creation, social impact, social innovation and social entrepreneurship. The Roadmap highlights the important role that social economy organisations play in each of these areas and this is also the case for social service providers, but they face significant challenges.
Social service providers are one of Europe’s biggest job creators with thousands of new jobs created each year, and this job growth is expected to continue. They provide essential care and support to millions of people in Europe; they contribute to at least 10 principles of the EPSR. Social services have a strong tradition of innovation in developing new strategies to meet existing needs and respond to new ones. Furthermore, the creation of social services is part of the entrepreneurship process where individuals identify needs and develop solutions.
However, many social service providers struggle with staff shortages, recruitment and the retention of the workforce due to underfunding. Some of the main issues include: an over reliance on women; poor wages; difficult working conditions: and insufficient staffing levels and training. This hampers their ability to provide quality services. If services are struggling to operate, they will neither be able to adapt nor innovate to continue to meet social needs and support the fulfilment of rights. The COVID-19 crisis has emphasised the need for social service provision and laid bare the systemic challenges social services face.
Adding to the initiatives in the roadmap, SSE recommends the following for the Social Economy Action Plan:
1. Foster a supportive ecosystem for the growth of all forms of social economy in Europe, with effective legal, political, and financial dimensions. This ecosystem should include stronger models of cooperation between all social economy actors.
2. Improve access to specific EU funding for and sustainable investment in the social services sector through the ESF+, the Recovery and Resilience Facility and InvestEU.
3. Develop an EU Recommendation on the definition of the Social Economy, ensuring specific reference to not-for-profit social services; as well as a series of supportive EU measures.
4. Increase the visibility, recognition and significance of the social economy sector
5. Consolidate and strengthen a permanent and structured dialogue between the EU and social economy actors
6. Launch a Campaign for Jobs in the Social Economy
7. Propose an initiative on social services of excellence (including long-term care) to set a framework for policy reforms
8. Under the EU’s Agenda for Skills, support social economy actors, including social service providers, in their provision of training for staff and volunteers.
9. Ensure that the EU’s taxation policy favours the development of all social economy actors and encourages Member States to take relevant steps.
10. Establish a High Level Group on Social Innovation
11. Promote social dialogue in the social economy, including social services
12. Strengthen the Expert Group on social economy to ensure a stronger role is given to not-for-profit social services
13. Ensure that more EU Funds are made available to support innovation in the social economy
14. Create a short-term European Emergency Fund for Social Services
Read full responseMeeting with Nicolas Schmit (Commissioner) and
5 May 2020 · Videoconference meeting on the role of social services in the recovery and in the implementation of the European Pillar of Social Rights.
Meeting with Stella Kyriakides (Commissioner) and SGI Europe and
29 Apr 2020 · VC meeting on the Impact of COVID-19 on Social Services and the risks for persons in vulnerable situations
Meeting with Dubravka Šuica (Vice-President) and
29 Apr 2020 · Social Services in Europe, Statutory Duties of Public Social Services, Explanation, Impact & challenges of COVID-19, Elderly, Role of the EU, Rights of persons with disabilities, social dialogue & cross-sectoral social dialogue
Meeting with Florentine Hopmeier (Cabinet of Vice-President Jyrki Katainen) and European Association of Service providers for Persons with Disabilities and
22 Oct 2018 · Discussion on addressing social sector needs in the InvestEU Programme