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Suomen Yrittäjät ry

SY

Suomen Yrittäjät is Finland's largest business confederation representing small and medium-sized enterprises.

Lobbying Activity

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

28 Jan 2026 · Simplification

Meeting with Elsi Katainen (Member of the European Parliament)

20 Nov 2025 · Current EU affairs

Finnish enterprises urge EU to simplify digital and data rules

14 Oct 2025
Topic — The European Commission is proposing measures to simplify digital regulations and provide business relief.
Message — The organization calls for a simplified regulatory framework that reduces administrative burdens on smaller firms processing low-risk data. They advocate for prohibiting contractual clauses that unfairly shift liabilities and establishing helpdesks for integrated support.1234
Why — This would lower administrative costs and prevent smaller firms from bearing unfair legal risks.5
Impact — Large corporations would lose the power to push compliance burdens onto their smaller partners.6
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Meeting with Anniina Iskanius (Cabinet of Executive Vice-President Henna Virkkunen)

14 Oct 2025 · Regulatory simplification

Meeting with Aura Salla (Member of the European Parliament)

24 Sept 2025 · General introduction

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur)

24 Sept 2025 · 28th Regime

Meeting with Fausto Matos (Cabinet of Executive Vice-President Henna Virkkunen)

24 Sept 2025 · Justice and consumers

Finnish SME federation backs 2040 climate target with market-based approach

16 Sept 2025
Topic — Amendment to European Climate Law to establish 2040 emissions reduction target.
Message — The federation requests that the 2040 target rely primarily on EU emissions trading rather than overlapping sectoral mandates. They want systematic SME competitiveness checks and administratively light compliance models for small firms.12
Why — This would minimize transition costs for their members and reduce administrative burden on small businesses.34
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Finnish SME group calls for streamlined EU consumer rules

26 Aug 2025
Topic — The EU is establishing consumer policy priorities and actions for 2025-2030.
Message — The organization requests a simplified consumer protection framework to reduce administrative burdens on smaller businesses. They call for streamlined information requirements and maintaining voluntary participation in dispute resolution. Additionally, they urge stronger enforcement against unfair competition from non-EU platforms.123
Why — Reducing regulatory fragmentation and administrative hurdles would lower compliance costs for small businesses.45
Impact — Non-EU digital platforms would face stricter enforcement and accountability for the products they market.6
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Meeting with Aura Salla (Member of the European Parliament)

28 May 2025 · SMEs

Meeting with Maria Blassar (Head of Representation Communication)

20 May 2025 · Exchange of views on simplification.

Meeting with Aura Salla (Member of the European Parliament)

20 May 2025 · Visit to Suomen Yrittäjät

Meeting with Ville Itala (Director-General European Anti-Fraud Office)

11 Apr 2025 · Introducing OLAF’s work to a group of Finnish municipal and city leaders. The aim is to enhance knowledge of the regulatory framework and decision-making processes at EU level.

Meeting with Elsi Katainen (Member of the European Parliament)

10 Apr 2025 · EU-tason sääntely ja päätöksenteko

Meeting with Maria Guzenina (Member of the European Parliament)

10 Apr 2025 · Current affairs

Meeting with Anna-Maja Henriksson (Member of the European Parliament)

19 Mar 2025 · Entrepreneurship

Meeting with Katri Kulmuni (Member of the European Parliament)

19 Mar 2025 · Eurooppapolitiikka ja sen vaikutus yrittäjiin

Meeting with Anniina Iskanius (Cabinet of Executive Vice-President Henna Virkkunen), Antti Timonen (Cabinet of Executive Vice-President Henna Virkkunen)

18 Mar 2025 · Exchange of views on current EU policies and priorities

Meeting with Henna Virkkunen (Executive Vice-President) and

18 Mar 2025 · Exchange of views regarding the Commission priorities, especially SMEs

Meeting with Jon Nyman (Head of Unit Trade)

18 Mar 2025 · Overview of EU trade policy agenda

Response to EU Start-up and Scale-up Strategy

17 Mar 2025

Access to finance remains a significant challenge due to an underdeveloped venture and growth capital ecosystem. While Finland has strong public funding through institutions like Business Finland, private investment opportunities are limited, and the fragmentation of the European venture capital market exacerbates this issue. Regulatory and bureaucratic burdens pose obstacles as startups must navigate complex legal frameworks and comply with differing regulations across Member States. This fragmentation creates uncertainty and complicates market expansion, especially for Finnish startups that are often global-oriented from the outset. Access to markets is another major barrier, with startups facing difficulties in participating in public procurement processes and leveraging free trade agreements due to resource limitations. The availability of skilled talent is a persistent problem, particularly in technology-intensive fields. Slow and bureaucratic work permit and visa processes for highly skilled workers from outside the EU further aggravate this issue. Access to infrastructure, knowledge, and support services remains uneven, with many startups facing challenges in accessing research infrastructure, technology hubs, business accelerators, and networking opportunities. Addressing these challenges requires coordinated efforts at both the EU and national levels to create a more supportive environment for startups and scaleups to thrive. Beyond these well-documented hurdles, startups and scaleups also face challenges in commercializing their innovations, gaining visibility, securing early customers, and scaling production or service delivery. The funding gap for later-stage investment in Europe compared to other global markets hinders expansion, making it difficult for European startups to compete globally. The lack of coordinated support for small and micro-enterprises often leads to missed opportunities for innovation. Late payments from large corporations create liquidity constraints, making it difficult for startups to maintain stable cash flow. The barriers to hiring the first employee remain a pressing issue due to high administrative and financial burdens. Access to EU-funded research and innovation programs remains uneven, with SMEs facing bureaucratic hurdles that make participation challenging. The slow adoption of AI and digitalization among SMEs is another concern, with many lacking the expertise or resources to integrate AI-driven solutions. Addressing these additional barriers requires a more holistic and coordinated approach from the EU and its Member States. To effectively address these challenges, the EU and its Member States should take comprehensive action across key areas, including enhancing access to finance, simplifying regulatory frameworks, bridging the gap between research and market-ready products, improving access to talent, and strengthening infrastructure and business support services. The EU should also take restartups (business transfers followed by continued operations) into account in its startup and scale-up strategy, as business transfers offer significant opportunities for growth and scalability.
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Suomen Yrittjt Urges Simpler EU Procurement Rules for SMEs

7 Mar 2025
Topic — Evaluation of EU directives governing concessions and public procurement in various sectors.
Message — Automate forms and require one-time documents to be submitted only once. Reevaluate turnover requirements that hinder smaller companies from entering the market. Prioritize competition based on quality and innovation instead of just price.123
Why — Reducing administrative burdens would lower costs and improve market access for smaller firms.45
Impact — Consumers and taxpayers may face higher costs if protectionist choices weaken market competition.6
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Meeting with Terhi Lehtonen (Cabinet of Executive Vice-President Teresa Ribera Rodríguez) and SMEunited aisbl

23 Jan 2025 · To hear interest representatives’ view on SME issues in relation to the just transition.

Meeting with Sebastian Tynkkynen (Member of the European Parliament) and FinMobility ry and Sahateollisuus ry

3 Dec 2024 · Teollisuuteen, yrittäjyyteen ja logistiikkaan liittyvät ajankohtaisasiat

Meeting with Maria Guzenina (Member of the European Parliament) and FinMobility ry and Sahateollisuus ry

3 Dec 2024 · Dinner event

Meeting with Mika Aaltola (Member of the European Parliament) and FinMobility ry

1 Oct 2024 · Entrepreneurship in the EU

Meeting with Mika Aaltola (Member of the European Parliament) and Maa- ja metsätaloustuottajain Keskusliitto – Central Union of Agricultural Producers and Forest Owners and FinMobility ry

25 Sept 2024 · EU Competitiveness

Meeting with Sebastian Tynkkynen (Member of the European Parliament) and Maa- ja metsätaloustuottajain Keskusliitto – Central Union of Agricultural Producers and Forest Owners and FinMobility ry

25 Sept 2024 · Pk-yritysten sekä liikenne-, maatalous- ja metsäsektorien ajankohtaisaiheet

Meeting with Taneli Lahti (Cabinet of Commissioner Jutta Urpilainen)

24 Sept 2024 · current EU issues and upcoming institutional period

Meeting with Elsi Katainen (Member of the European Parliament) and FinMobility ry

3 Sept 2024 · Tuleva kausi, komission työohjelma, liikenne- ja yrittäjyyspolitiikka

Meeting with Pekka Toveri (Member of the European Parliament) and FinMobility ry

24 Jul 2024 · Current Topics in EU Politics

Meeting with Eero Heinäluoma (Member of the European Parliament) and FinMobility ry

24 Jul 2024 · Ajankohtaisaiheet

Meeting with Sebastian Tynkkynen (Member of the European Parliament) and FinMobility ry

24 Jul 2024 · Tutustumistapaaminen ja toimialan ajankohtaiset asiat

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

16 Apr 2024 · Priorities for the next parliamentary term

Meeting with Eero Heinäluoma (Member of the European Parliament)

16 Apr 2024 · Ajankohtaisaiheet

Meeting with Elsi Katainen (Member of the European Parliament)

16 Apr 2024 · General EU affairs

Meeting with Ville Niinistö (Member of the European Parliament)

16 Apr 2024 · EU affairs

Finnish SMEs reject EU limits on package travel payments

12 Jan 2024
Topic — The European Commission is reviewing rules to strengthen consumer package travel protection.
Message — The group opposes limiting upfront payments and wants to stop increasing information requirements. They also reject expanding the right to cancel travel for free.123
Why — This would protect the financial liquidity of small operators and reduce administrative burdens.45
Impact — Consumers lose access to expanded refund rights and more detailed pre-sale information.67
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Response to Advanced alternative dispute resolution for consumers

22 Dec 2023

Suomen Yrittäjät - The Federation of Finnish Enterprises (FFE) does not consider the revision of the ADR directive necessary as the ADR system in Finland is working well. We have our concerns about the proposal and how the proposed changes would affect the Finnish well working ADR system. We thank for the opportunity to express our opinions and views on the given proposal in more detail as per attached.
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Meeting with Henna Virkkunen (Member of the European Parliament)

28 Sept 2023 · SMEs

Finnish small businesses warn green claim rules burden SMEs

10 Jul 2023
Topic — A proposal to require companies to scientifically prove their environmental marketing claims.
Message — The Federation requests mandatory state support and fairer penalties for small businesses. They argue that high costs and strict rules currently threaten firm survival.12
Why — This would reduce administrative costs and prevent small firms from market exclusion.3
Impact — Consumers lose transparency if inspection results are suppressed to protect company reputations.4
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Response to Promoting sustainability in consumer after-sales

19 May 2023

The Federation of Finnish Enterprises (FFE) supports the reasons and objectives of this proposal promoting repair of goods, green transition and sustainable consumption. Consumption causes negative environmental and climate effects. These effects should be reduced by supporting various operating models of circular economy and by offering repair services and used goods to consumers. Some of the provisions of the proposed directive are however problematic. We thank for the opportunity to express our opinions and views on the given proposal as per attached.
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Meeting with Henna Virkkunen (Member of the European Parliament)

3 May 2023 · EU entrepreneurship policy

Meeting with Elsi Katainen (Member of the European Parliament)

16 Nov 2022 · Topical EU-legislation affecting municipalities and small and middle-sized companies

Meeting with Taneli Lahti (Cabinet of Commissioner Jutta Urpilainen) and FinMobility ry

24 Oct 2022 · Global Gateway

Response to Strengthening social dialogue

20 Oct 2022

Suomen Yrittäjät edustaa laajasti eri sektoreiden pk-yrityksiä Suomessa. Suomen Yrittäjät on myös euroopplaisen pk-yritysjärjestön SMEunitedin jäsen. Suomen Yrittäjät pitää tärkeänä, että työelämän osapuolia edustavat järjestöt niin kansallisesti kuin EU:n tasolla voivat osallistua työelämän sääntelyä koskevaan valmisteluun. Mahdollisuuksia tähän tulee edistää ja EU:n on tarpeen huolehtia siitä, että järjestöjä kuullaan kattavasti ja oikea-aikaisesti. Työmarkkinaosapuolten vuoropuhelun edistäminen on myönteinen tavoite. On kuitenkin muistettava, että työmarkkinaosapuolet eivät edusta kaikkia yrityksiä eivätkä työntekijöitä. Komission kannanottopyynnössä ei ole lainkaan huomioitu sitä, että järjestäytymisasteen laskua ei voida kompensoida työmarkkinaosapuolten vaikutusmahdollisuuksia lisäämällä. Järjestäytymisvapauteen kuuluu myös oikeus olla kuulumatta liittoihin tai yhdistyksiin. On tärkeä huomioida, että järjestäytymisasteen lasku tarkoittaa sitä, etteivät kaikki työntekijät tai yritykset tule edustetuksi työehtosopimusneuvotteluissa tai työmarkkinaosapuolten muussa vuoropuhelussa. Työelämän sääntöjen ja työehtojen kehittäminen ei siten voi jäädä vain työmarkkinaosapuolten aktiivisuuden varaan tai niiden vastuulle. Tukeutuminen yksin työmarkkinaosapuolten vuoropuheluun ja työehtosopimustoimintaan ei ole ainoa tapa ratkaista työmarkkinoiden kysymyksiä. Komission tulisi huomioida aloitetta antaessaan, että työmarkkinaosapuolten yhteistoiminta ei ole ainoa toimi, joilla työmarkkinoiden toimintaa ja toimivuutta voidaan edistää. Tärkeä on myös muistaa, ettei työehtosopimustoimintaan voida pakottaa. EU:n tuleekin kunnioittaa työmarkkinaosapuolten ja työelämän järjestöjen vapautta päättää itse toimintansa malleista. Lisäksi on syytä huomioida, että EU:n tasolta ei pidä pyrkiä ratkaisemaan kansallisen tason kysymyksiä. Työmarkkinaosapuolten toimintaan vaikuttavat merkittävästi ne ratkaisut ja toimintaperiaatteet, joita kansallisesti kussakin jäsenvaltiossa on tehty. On myönteistä, että komission tavoitteena on parantaa eri työmarkkinaosapuolten toimintaedellytyksiä. Toimintaedellytysten parantaminen voi tehostaa eri järjestöjen osallistumismahdollisuuksia paitsi lainsäädäntövalmisteluun, myös muuhun työmarkkinatoimintaan. On kuitenkin tarpeen muistaa, että EU-tason ratkaisuilla ei voida vaikuttaa osapuolten haluun osallistua toimintaan.
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Meeting with Miapetra Kumpula-Natri (Member of the European Parliament, Shadow rapporteur)

11 Oct 2022 · Meeting on Data Act

Finnish SME group backs EU cyber rules with caveats

7 Oct 2022
Topic — Consultation on new cybersecurity requirements for manufacturers and vendors of digital products.
Message — The organization seeks clarity on cloud software rules and a flexible system for identifying risky products. They also call for financial support to keep compliance costs low for small firms.123
Why — Uniform rules will help small companies scale up while reducing overall business risks.4
Impact — Smaller manufacturers face significant financial burdens from new compliance and testing requirements.5
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Meeting with Henna Virkkunen (Member of the European Parliament)

3 Oct 2022 · EU Digital Policy

Response to Improving the provision of digital skills in education and training

12 Sept 2022

Digitalisation upends the skills landscape of vocations, businesses and entire industries. Thus, it significantly alters expectations of the education and training systems, which in many ways are still modelled after the requirements of the bygone industrial age. Pre-COVID-19 foresight studies in Finland predict that the demand for digital skills, such as the ability to utilise digital solutions and platforms, will greatly increase in the job market by 2035. The pandemic has only accelerated this development, changing skills requirements in SMEs and other workplaces sooner than anticipated. It is high time to reshape the European education and training systems to better meet the swift digital transition the world is witnessing. Digitalisation provides ample opportunities and assets for this endeavour. The key lesson of the COVID-19 crisis is that digital education should no longer be viewed as an island of its own but considered an integral part of all education and training. First, it allows for online learning done completely remotely or in some combination with face-to-face offline pedagogy. The rapid evolution of virtual and augmented reality, the metaverse for education, is bound to have a significant impact on learning environments. Second, and more importantly, digital education promises to improve the learning experience both in a classroom or at home or workplace by enabling educators to better align the pedagogical choices with the needs and preferences of each learner. Digital solutions, whenever they boost learning results, should therefore be fully integrated into all modes of education and training at all phases of a learner’s life cycle, from the early education to the later stage upskilling and reskilling. By forcing education and training institutions and professionals across the board to adopt digital means of instruction and consequently highlighting both benefits and areas in need of development of these new pedagogical solutions, the COVID-19 crisis has hopefully fast-tracked the shift to more future-ready education and training (eco)systems that blend effortlessly both online and offline forms of learning and make the most of what innovative private education providers and technology developers have to offer. This momentum should not be wasted by public authorities in charge of educational affairs. Although education policy remains rightly a domain of national and local decision making in the Member States, the EU, within its jurisdiction, should actively promote and advance the evolution of digital education and digital skills. The EU, mobilised through the Commission programs (Erasmus, Horizon Europe, Digital Europe, structural funds), should focus on a few strategic areas where the EU can add considerable value to the efforts of the Member States. One such area should be digitally enhanced on-the-job training which takes place in SMEs and touches both younger apprentices and trainees and more experienced individuals, including entrepreneurs. Another ought to be the cross-border co-operation between education and training institutions in the field of joint study programs that blend online and offline learning. Increased student and teacher mobility inside the EU and from the third countries via digital technologies, especially AR/VR, would be a third obvious focus area. Joonas Mikkilä Head of Digital and Educational Affairs The Federation of Finnish Enterprises
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Meeting with Heidi Hautala (Member of the European Parliament, Shadow rapporteur)

24 Aug 2022 · Due Diligence (staff level)

Meeting with Miapetra Kumpula-Natri (Member of the European Parliament, Shadow rapporteur) and Technology Industries of Finland (Teknologiateollisuus ry)

20 Jun 2022 · Data Act

Meeting with Henna Virkkunen (Member of the European Parliament)

30 May 2022 · EU Digital Policy

Response to Cyber Resilience Act

24 May 2022

[See our full feedback in the attachment.] The Federation of Finnish Enterprises agrees with the general objectives of the Commission’s initiative concerning the Cyber Resilience Act. The level of cybersecurity of digital products and ancillary services offered in Member States for SMEs needs to be raised and the fragmentation of the internal market with respect to cybersecurity rules prevented. This justifies EU level joint action. However, these actions should be proportionate to the risks at hand and designed together with the European digital industry and espeially its smaller players in mind. In principle, obligations concerning cybersecurity of products or services ought to be borne by the actor who has the actual ability to prevent cyber-related risk by technical solutions. For example, in a situation where a digital product is created by using a software application, the company providing the application should be responsible for ensuring that the outputs have the required level of cybersecurity. Although retailers serve a key function in assisting SMEs to choose safe and secure digital products and services, they should not be burdened with additional monitoring obligations as they often lack the specific expertise needed for reviewing the cybersecurity requirements of digital products. Cybersecurity must already be ensured by the manufacturer or developer. In addition, clarification regarding the responsibility of enterprises in the event of a cyberattack on companies via supply chains, particularly in terms of compensation, is important and should be addressed in the EU-level legal framework. To this end, we recommend the Commission to pursue a set of policies that combines both soft and hard rules and that does not impose undue burden on digital vendors that are small or micro enterprises. Considering the pace at which cyber threats evolve, the Commission should pay close attention to the ways in which these policies can be swiftly yet reliably amended or supplemented. As for hard measures, there is a need for a risk-based horizontal regulatory intervention that introduces new cybersecurity requirements for tangible digital products and ancillary services and backs these up with conformity assessment procedures that can be conducted by vendors independently or by proficient third parties. Requirements and assessments should always be adjusted to the risk level of the product or service. Any requirement should be technology neutral, prescribing desired ends, not preferred means. With respect to digital products that are non-embedded software, we recommend a step-by-step approach, first starting with soft measures such as guidelines, recommendations, and voluntary certification schemes and later, if necessary, followed by mandatory provisions. Here, too, we recommend a risk-based approach to avoid imposing unreasonable burden on developers of non-high-risk software. For example, third-party conformity assessment should not be required categorically, as this will lead to increased costs. It should be clarified whether cybersecurity risks should be addressed throughout the lifecycle of the product or service, i.e., would the vendor be obliged to address new cybersecurity risks after the product has been placed on the market. As a non-embedded software product is in most cases subject to repeated updates during its lifespan, it might be wise to target requirements and related compliance and quality assessments at the processes through which the software product is developed, maintained, and revised, as opposed to subjecting the product itself to repeated and burdensome assessments, with the possible exception of some high-risk products. Vendors of all types of digital products and related services ought to be able to prove their conformity with soft or hard rules to users with certificates or other reliable and uniform descriptions.
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Federation of Finnish Enterprises demands clearer protections for SMEs

23 May 2022
Topic — New EU rules for companies regarding human rights and environmental impact across value chains.
Message — The organization urges the EU to limit obligations passed to SMEs. They demand the removal of civil liability and directors' duty provisions.12
Why — Clearer rules would protect small businesses from unmanageable administrative burdens and excessive compliance costs.3
Impact — Removing civil liability would reduce legal options for victims of corporate environmental or human rights abuses.4
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Finnish SMEs urge stronger data access rights for smaller firms

11 May 2022
Topic — The Data Act proposal seeks to regulate data access and sharing across the EU.
Message — The federation supports exempting small businesses from data sharing obligations and broadening accessible data definitions. They also demand technical feasibility guarantees before cloud service providers can sell services.123
Why — SMEs would benefit from improved data access and reduced costs when switching providers.45
Impact — Cloud service providers would lose revenue from the withdrawal of customer switching charges.6
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Meeting with Nils Torvalds (Member of the European Parliament)

4 May 2022 · Entrepeneurship

Response to Promoting sustainability in consumer after-sales

5 Apr 2022

The Federation of Finnish Enterprises (Suomen Yrittäjät ry) respectfully submits the attached comments regarding the “Sustainable consumption of goods – promoting repair and reuse” initiative public consultation from the European Commission.
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Response to Recommendation on minimum income

30 Mar 2022

Vähimmäistuloa koskeva suositus on luonnollinen jatko Euroopan sosiaalisen pilarin toimeenpanosuunnitelmalle. Komission tausta-aineistosta ei kuitenkaan vielä saa kunnollista käsitystä siitä, mitä suositus konkreettisesti toisi ja mikä sen lisäarvo jäsenvaltioille olisi. Suositus vaikuttaa varsin laaja-alaiselta ja ympäripyöreältä tässä vaiheessa. Jäsenvaltioiden vähimmäistuloa koskevat järjestelmät ovat erittäin heterogeenisiä, joten suosituksen merkitystä on vaikea arvioida. Lähtökohtana vähimmäistuloa koskevalle suositukselle on oltava selvä EU:n ja jäsenvaltioiden välinen toimivallanjako, joka käy ilmi perussopimuksista. Vähimmäistulojärjestelmien sisältö on jäsenvaltioiden toimivallan piirissä eikä suosituksella pidä välillisestikään pyrkiä määrittämään vähimmäistulojärjestelmien tasoa tai sisältö. Vähimmäistulojärjestelmä on kussakin jäsenvaltiossa tiiviisti yhteydessä sosiaaliturvajärjestelmän kokonaisuuteen ja myös muihin yhteiskunnan toimintoihin (esim. verotus), joten suosituksella ei pidä luoda sellaisia vaikutuksia, jotka hämärtäisivät toimivallanjakoa tai haittaisivat kansallisen järjestelmän toimintaa. Vähimmäistuloa tarkasteltaessa ei voida sivuuttaa kysymystä vähimmäistulojärjestelmän rahoituksesta. Tätä pitäisi arvioida tarkasti myös suositusta valmisteltaessa. Ylipäänsä suosituksen vaikutusarviointi on tehtävä huolella, sillä jäsenvaltioiden ratkaisut vaihtelevat. Vähimmäistulo voi koostua useista eri sosiaalietuuksista. Vähimmäistulojärjestelmän (kuten muunkin sosiaaliturvan) rahoitus on oltava kestävällä pohjalla. Vähimmäistulolla on myös yhteydessä kansalliseen kilpailukykyyn, sillä vähimmäistulojärjestelmällä on yhteys myös työn hintaan, erityisesti jos järjestelmän rahoitus perustuu työnantajilta ja työntekijöiltä perittäviin maksuihin. Kannustinloukkuja on vältettävä ja vähimmäistulon pitää kannustaa aktiivisuuteen ja tulojen hankkimiseen sosiaaliturvajärjestelmän ulkopuolelta. Siten vähimmäistuloa koskevassa suosituksessa on tarpeen huomioida riittävästi myös vähimmäistulon piirissä olevien henkilöiden aktivointitoimet sekä etuuksien saamisedellytysten oikea taso. Vähimmäistuloa koskeva suositus olisi kytkettävä yhteen EU:n ohjausjakson ja sosiaalisen tulostaulun kanssa. Nämä ovat oikeita seuranta- ja mittauskeinoja, joilla jäsenvaltioiden kansallisten toimien vaikutuksia ja vaikuttavuutta voidaan tarkastella.
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Response to Policy Program - Digital Decade Compass

18 Oct 2021

The Federation of Finnish Enterprises supports the Commission’s initiative to lay out clear targets for the EU’s digital decade and to establish a robust monitoring and cooperation mechanism to ensure progress towards these goals in all Member States. It is also welcome the Programme is adopted as a binding decision by the Parliament and the Council, as this highlights the importance of the undertaking. We urge the Parliament and the Council to pass the decision with a high level of ambition appropriate to the mission at hand. Furthermore, we ask the Member States and the Commission to commit adequate resources and supervision to the implementation of the Programme. Digital targets With respect to individual EU-level targets, we recommend the Parliament and the Council adopt the following amendments: - Set out a target for a share of population whose digital skills are above the basic level - Include a target for the 6G development - Establish targets for the roll-out of soft data infrastructure (e.g., data spaces, data intermediaries, data altruism organizations, public sector APIs) - Set out targets for a share of SMEs whose digital intensity is (1) at a medium level and (2) at a high level - Lay out targets for ICT investments of SMEs and larger companies - Include targets for public online services that focus on enterprises and business owners - Add a target for the participation of Member States in multi-country projects, giving weight to the contributions of the more digitally advanced Member States. Monitoring and cooperation mechanism We commend the Commission for proposing a robust monitoring and cooperation mechanism to advance the objectives and targets laid out in the Programme. For the implementation of the Programme to be effective, we ask the Commission to pay close attention to the process of adopting and monitoring country-specific recommendations as these are essential in helping Member States overcome obstacles they may face in the digital decade. The process ought to be constructive and closely linked to other EU programmes geared to advancing the digital transition in Member States. The multi-country projects envisaged by the Programme should also be focused on challenges many Member States have in common. To have a better view of the state of play of the digital transition outside the EU, we would advise the Commission to include in its annual Report on the State of the Digital Decade an assessment of the progress of the EU’s main competitors, especially the US and China, in the relevant digital objectives and targets based. National Digital Decade strategic roadmaps To make real progress on the objectives, it is important for each Member State to establish in its National Digital Decade strategic roadmap a realistic national base level and an ambitious yet attainable trajectory for each EU-level target and to follow them up with measures and policies that best serve to achieve them, including multi-country projects and resources from other EU programmes. In the case of more digitally advanced Member States, such as Finland, we would like to see the Commission to encourage them to raise the national bar on the EU-level targets whenever possible. However, the focus should not be solely on the digitally advanced, as all Member States should be counselled to lay out in their national roadmaps additional country-specific targets that take into consideration the level of digital maturity and special circumstances in each Member State and that serve to complement the EU-wide digital transition. The active participation of stakeholders, especially SMEs and their representative organizations, in the adoption, adjustment and implementation of the national roadmaps is crucial in ensuring the successful and inclusive digital transition in Member States. We therefore ask the Commission to pay close attention in the annual cooperation with Member States to the stakeholder engagement.
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Meeting with Arto Virtanen (Cabinet of Commissioner Jutta Urpilainen) and FinMobility ry and Finnish Transport and Logistics SKAL

13 Oct 2021 · Current issues in transport and logistics sector.

Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans)

7 Oct 2021 · Fit for 55

Response to Requirements for Artificial Intelligence

21 Jun 2021

The proposal for the Artificial Intelligence Act has admirable objectives but is riddled with issues, which render the regulation problematic. Despite containing some right elements, the proposal is excessively burdensome from the perspective of smaller European enterprises developing, providing, or using AI systems, especially those classified as high-risk systems. Furthermore, given the fact that the evolution and deployment of AI solutions are still at early stages, it may not be advisable to pass legislation as detailed as is now proposed. The apparent risk is that a too heavy-handed approach to AI undermines the competitiveness of SMEs and hampers the growth of the European digital economy. Therefore, we encourage the EU legislators to carefully take into consideration the regulation’s impacts on innovation and SMEs that provide and use AI systems. // The definition of AI system The definition which emerges from the proposal is too vague and risks expanding the scope of the regulation to include also non-AI software. As this is surely not the intention of the regulation, a more exact definition is required. // The definition of high-risk AI systems The risk-based approach to regulating AI is well founded and welcome. However, the creation of a parallel legal framework to the EU product legislation in the form of the AI regulation is problematic, as it would increase both complexity and cost of compliance especially for SMEs. To avoid this, we would advise removing Annex II from the AI regulation and regulate the use of AI systems on a sector-specific basis in the existing EU product legislation. When it comes to Annex III, we are skeptical whether the use cases of AI systems outlined in point 4 (Employment, workers management and access to self-employment) meet the high-risk criteria. At the very least, their description would need to be more precise. We urge the legislators to take further steps in ensuring that especially smaller providers of AI systems have the required certainty and understanding of whether their systems are considered high-risk or not. We are concerned about the power given to the Commission to adopt delegated acts to add new types of high-risk AI systems to the regulation. The proposed process does not provide enough predictability and legal certainty and, therefore, needs to be revised. // Requirements for high-risk AI systems and the position of small-scale providers and users Given how extensive and detailed the requirements are, they are likely to overwhelm particularly smaller AI providers. This is unacceptable and goes against the EU’s Think Small First principle. We encourage the legislators to consider whether the requirements of high-risk AI systems could be made less stringent for small-scale providers. The regulation should identify and define a category of ‘small-scale users’. // AI regulatory sandboxes We are in favour of the idea of AI regulatory sandboxes. However, we ask the legislators to form a stronger link between the sandbox scheme and the process through which the AI regulation is amended once it has entered into force. We would also suggest moderating the liabilities of SMEs that choose to take part and experiment in AI regulatory sandboxes. This would encourage them to join sandboxes in greater numbers. // Codes of conduct and voluntary compliance Although codes of conduct are welcome, they must not become barriers to markets for the smaller AI players or put them at a competitive disadvantage. // Implementation and enforcement We are concerned whether the Member States have the resources to implement the regulation competently, consistently, and even-handedly. The proposed sanctions seem unreasonably tough from the perspective of smaller AI players. We are particularly concerned about administrative fines, for there is a danger they may be disproportionately imposed on these smaller players. [For our full position, see the attachment]
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Response to Data Act (including the review of the Directive 96/9/EC on the legal protection of databases)

15 Jun 2021

We welcome the aim of the Data Act initiative of creating a fairer and more competitive data economy in Europe. To achieve this, it is crucial that especially SMEs have better and more equitable opportunities to access, share and use data. Business-to-government data sharing for the public interest We agree with the initiative that it is in the public interest to improve governments’ access to some data sources held by private companies. As a rule, business-to-government data sharing schemes must be voluntary in nature and focus on lowering regulatory, technical, and economic barriers for companies to share their data with governments. This same focus would also contribute to G2B sharing. Mandatory B2G sharing requirements can be established only in cases involving an exceptionally high public interest. Business-to-business data sharing We underline the importance of establishing a fair distribution of usage rights between businesses involved in the creation of data, especially non-personal or industrial data. The more balanced the business-to-business data sharing situations are, the more all parties benefit from innovation and productivity potential that a greater availability and use of data offers. We are in favour of more specific transparency obligations for manufacturers of IoT objects to spell out what data is being gathered and for what purposes when the objects are in professional use. We are also supportive of providing companies with easy-to-use model terms for B2B data sharing contracts. However, these policies together with the proposed “fairness test” do not go far enough in addressing the issue of dysfunctional B2B data sharing relationships where one party unilaterally imposes unfair contractual terms on another. Therefore, we urge the European legislators to lay down, as part of the Data Act, fair, reasonable and clear access and usage rights for non-personal data covering horizontally all sectors and B2B situations. Alternatively, the legislators could allow for a more sector-specific approach by providing a harmonisation of general modalities or principles for access to data, which could apply to data rights established in specific sectoral rules, leaving room to consider specific characteristics of the relevant market and sector. In this approach it is important to ensure that the interests of both data holders, e.g., large providers of IoT equipment, and data users, e.g., SMEs using IoT objects or providing supplemental services for them, are taken into account and that any imbalances favouring the former are actively avoided and rectified. Complementing the portability right under Article 20 of GDPR We are open to the proposal of fostering the ability of individuals to take advantage of their right to port their personal data, as defined in Article 20 of GDPR, between smart devices. This could mean mandating companies that sell smart devices to have in place technical interfaces that allow real-time portability of the data these devices collect during their use. Improving portability for business users of cloud services The Data Act needs to take a comprehensive regulatory approach to lay out binding rights for business users to port their data and applications between cloud services or back to on-premise IT systems without encountering contractual, technical or economic barriers. Business users should be entitled to port all non-personal data that they have a legitimate right over. This should also apply to personal data where it is done in compliance with GDPR. When applicable these same rights to data portability should cover also other core platform services used by SMEs, not just cloud computing services. This approach ought to also specify technical and other relevant conditions for cloud services providers to enable the export of data. [For our full feedback, see the attachment.]
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Response to Declaration of Digital Principles

3 Jun 2021

We welcome the initiative to establish through a solemn joint interinstitutional declaration a set of digital principles based on common European values and EU fundamental rights, as laid out in the Charter of the Fundamental Rights of the EU. The principles can provide a shared reference for European policy makers and digital operators at all levels to shape a more human-centered digital society and inclusive yet dynamic economy. To achieve this, it is important to formulate the principles in a language that is comprehensible and reality-based and addresses main stakeholders, including small and medium-sized enterprises and entrepreneurs and their basic freedoms, such as the right to set up and conduct business online. SMEs and entrepreneurs should also be a key target group for any communication effort aimed at raising awareness of the principles. Although the principles should help people, businesses and other organizations interpret and follow the existing fundamental rights in the digital environment in a more consistent fashion, the declaration should state unequivocally that the principles do not establish new rights. As a matter of legal certainty, the declaration should be clear which rights are behind which principles. Also, when a principle is not derived from an established body of rights but proposed more as an ethical recommendation or a good practice, it should be also expressed explicitly.
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Response to Digital Services Act package: ex ante regulatory instrument of very large online platforms acting as gatekeepers

5 May 2021

We agree with the general objectives of the Commission’s proposal for the Digital Markets Act. The proposed regulation will bring clear benefits for the SME users of the gatekeeper platforms who currently lack effective means to address their unfair practices. This creates a more balanced relationship between business users and gatekeepers, on one hand, and between smaller platforms and bigger gatekeepers, on the other, generating new opportunities for SMEs and more options for consumers. The quantitative requirements that a provider of core platform services needs to satisfy to be designated a gatekeeper are appropriate in terms of scale but not of scope. In our view, in the digital realm, it makes little difference for the power and impact of a gatekeeper where its end users or business users are situated. It would be more in line with the purposes of the regulation to also include users outside the EU in the count. If they are left out, the regulation would give several major third-country platforms an unfair competitive advantage over EU-based platforms. It is also to be noted that the additional criteria of turnover and market capitalisation will further narrow down the regulation to a very small number of very large platform companies. To achieve a more level playing field in all markets where dominant platforms exist, we would advise the Commission to hold accountable platforms that, despite not meeting the numeric criteria, perform as de facto gatekeepers in relation to SMEs in a certain industry or a market. Although the proposition mandates the Commission upon market investigation to identify as a gatekeeper a platform that does not satisfy the quantitative thresholds, it would be advisable, to foster legal certainty of large platforms and their users, to consider drafting a separate set of criteria for the pre-gatekeeper stage where it is foreseeable that a full gatekeeper status is reached in the near term. These criteria could be qualitative or quantitative or a combination of both. Some gatekeeper obligations could be applied during this pre-stage, as is proposed in Article 15. Given the widespread harm caused by inappropriate practices of gatekeeper platforms, we consider the obligations, laid out in Articles 5 and 6, to be well targeted and proportionate to the challenges at hand. The obligations proposed in Article 6 are susceptible of being further specified by the Commission depending on a gatekeeper in question. We urge the final text to clearly outline the procedure through which these obligations are specified for a gatekeeper. This would help business users to better anticipate the application and deployment of the obligations. It is essential that SMEs can offer and promote their products and services through third-party online intermediary services at prices and conditions that are different from those they offer or promote through the gatekeeper. The text should also explicitly state that this also applies to the business user’s own website or other web applications. It is also important that SMEs can conclude contracts and interact with end users through a service of their own choosing. Gatekeepers should be prevented from determining a price for products or services that business users offer through a gatekeeper platform. Article 8 would give the Commission a mandate to exceptionally suspend a specific obligation laid out in Articles 5 and 6, upon on a reasoned request by the gatekeeper. We stress that these suspensions need to be carefully weighed and clearly outlined. We would also recommend taking into consideration whether some obligations ought to be ruled as core obligations that cannot be suspended. Finally, we would like to see the text banning a gatekeeper from engaging in retaliatory measures against a business user who has informed an authority about unwarranted actions taken by a gatekeeper. [See the attachment for our complete position.]
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Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

30 Mar 2021

For the European Digital Single Market to function properly and cohesively, its rules must be aligned with the evolution of technology and the rise of new digital services. Fragmentation of the single market regulation hampers growth and is particularly detrimental to the prospects of small and medium-sized enterprises that provide and use digital services. We support the primary goal of the Commission’s proposal for the Digital Services Act which is to establish a common set of rules on digital services and for their providers. The Europe-wide digital markets need to be more open, more trustworthy, and more just. A more harmonized EU-level regulatory landscape reduces administrative burden, creates new opportunities for smaller providers of digital services and offers SMEs greater room for expansion. Although improving the functioning of the Digital Single Market is vital, it is worth reminding that regulation will bring the EU and European companies only so far when it comes to achieving increased competitiveness and productivity. In short, the EU cannot regulate its way to the top. Therefore, more attention needs to be paid to enhancing the capacity of European businesses, especially SMEs and startups, to not just follow the digital trendsetters elsewhere but to be trailblazers in the emerging digital fields. Keeping this in mind, it is imperative that the EU together with the Member States adopt a more committed stance towards investing in education and training, research, development and innovation (RDI) and deployment of new technology. (Please, find our full view on the subject in the attachment.)
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Response to Collective bargaining agreements for self-employed – scope of application EU competition rules

28 Jan 2021

The Federation of Finnish Enterprises (FFE), represents 115 000 Finnish small and medium-sized enterprises, 56 % of which are self-employed entrepreneurs, i.e. entrepreneurs without employees. The FFE does not consider extension of collective bargaining to self-employed appropriate, as it would have a major impact to the legal acquis and create uncertainties to contractual relations. Labour law and its components shall remain applicable only when employment relationship (which is defined in national legislation) exist. The position of self-employed may and shall be enhanced, but extension of collective bargaining is not a right way to do it. The extension would mean in practice creation of new status (or group of person performing work) on top of the current ones. This would also mean that difficult determination problems will follow. The Inception Impact Assessment raises more questions than it give solutions. All of the policy options set in the Inception Impact Assessment will raise serious consequences to national systems and may jeopardize the entrepreneurial freedoms. The position and arguments of the FFE are presented in detail in the attached position paper.
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Response to Geographical indication protection at EU level for non-agricultural products

9 Dec 2020

The Federation of Finnish Enterprises (FFE) is the leading SME organisation in Finland with its more than 105 000 SME members of all sectors and sizes. The FFE is also a member of SMEunited, European organisation for SMEs. The FFE is at opinion that a new sui generis geographical indication right for non-agricultural products (non-agri GI) is not the right approach. The EU IPR acquis is already somewhat fragmented and the initiative to introduce new sui generis non-agri GI right would make the EU acquis even more fragmented. The manufactures, local producers and crafts may need better protection for their products, but that can be done by enhancing existing EU-wide legislation. Regarding the policy options we support primarily that no intervention will be made. Secondary, we could support reform of the trade mark system. This would be in line with the current EU IPR acquis and it would result more coherent and functional outcome than voluntary measures, which could also be suitable option, so member states could introduce protection systems if they so wish. However, this would cause fragmentation between the EU member states and it may have unfavorable consequences. Anyhow, voluntary measuers or national rules for non-agri GI's already exist in some member states. Harmonization of national non-agri GI systems or creation of single protection system for non-agri GI’s are not supported by the FFE. On the content, we do not support creation of new sui generis IPR-forms, as this kind of fragmentation is not appropriate development for already quite fragmented EU acquis on IPR. The need for protection of non-agri GI’s may be reached by developing trade mark legislation, more specifically legislation on collective or certification trade marks. This option would be easily placed to the current IPR acquis and it would also be cost-effective, as the cost of the usage of such marks would be targeted to those who take advantage of them. Furthermore, the protection of local producers, crafts, etc. could be enhanced by developing the EU legislation on misleading market practices. Also this option would take the current EU system better into account without further fragmentation.
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Response to Review of the general product safety directive

31 Aug 2020

The revision, of the Directive on General Product Safety, is at a great importance given the significant market developments, particular the globalization of trade and the increase in online sales. Due to these developments it has become clear that the legal framework of product safety needs to be brought up to date. The review of GPSD is important for maintaining safety of consumer products, but also essential for ensuring a level playing field for businesses. It is important that, while ensuring a high level of consumer safety, the focus is also on the impact on economic operators. It is essential that the economic operators may operate in a market where infringers do not get an unjustified competitive advantage. Addressing product safety deficiencies and ensuring a level playing field for economic operators are not separate objectives. Effective legislation, enforcement and control measures will contribute the fulfillment of both of these objectives. Having stated this, any changes to product safety legislation should be made without creating unnecessary administrative burden or costs. New obligations for economic operators should be imposed appropriately and be a response to the new market developments that have left regulation partially ineffective. The legal framework should support legal certainty for companies also in the case of new technological innovations. Although many dangerous products come from outside the EU, non-EU online marketplaces avoids the obligations of product safety legislation. Therefore, companies operating in third countries can gain a significant competitive advantage over European companies that must comply with legal requirements of product safety legislation. To address these issues the responsibilities of online platforms should be reassessed. Online platform companies hosting third party sellers should be held responsible for the safety of products on their websites when these products are delivered to European consumers and when the manufacturer, importer or distributor of the product does not operate in the EU. Strengthening the market surveillance plays an important role in this context. In our view it seems that the improved implementation and enforcement of the existing legal framework (option 1) would not be sufficient to remedy existing shortcomings of the GPSD. A more robust approach is required, due to the scope of the challenges at hand. The targeted revision of the Directive (option 2) and the full revision of the Directive (option 3) both contains elements that would address the problems related to online sales by strengthening market surveillance and addressing the question of responsibilities of eCommerce companies hosting third party sellers. We also consider that all measures aimed at promoting the consistent application of product safety legislation are important, because it will help companies, in particular SMEs, to bring products to the internal market.
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Response to Revision of the NIS Directive

13 Aug 2020

The review of the Directive on Security of Network and Information Systems (the NIS Directive), passed in 2016, is in our mind welcome, given the rapid pace of the digital transition which keeps increasing the amount of cyber threats in essential sectors of the European societies and economies. The covid-19 crisis and the resulting growth in demand for internet-based solutions have only exacerbated the risks of cyber attacks, many of which are cross border in nature. These factors underline the need for the EU to take a stock of and, if necessary, to strengthen and harmonize the cybersecurity landscape of the internal market. Ultimately, however, it is upon the Member States to reinforce the resilience of their strategic digital networks and systems against cyber threats. We agree that although the NIS Directive has contributed to improving the cybersecurity capabilities in the Member States, the implementation of the directive appears to have been too inconsistent and fragmented. If this development continues, it risks not only causing ever more serious cybersecurity incidents but also skewing the playing field between NIS-liable companies (operators of essential services + digital service providers) operating in different Member States. Furthermore, as they must comply with diverging regulatory regimes, many companies active in several Member States, particularly SMEs, face an increasing amount of administrative burden. It is, therefore, necessary in our mind to assess whether new EU-level policies are required to achieve a course correction. At this point, a completely new legislative act, repealing and replacing the NIS Directive, (policy option 4) seems unadvised, given that the current directive is still relatively recent. A combination of non-legislative measures (policy option 2) and targeted changes to the NIS Directive (policy option 3) seems a more prudent approach. At this point, however, we would advise against expanding the NIS Directive to new sectors or services, as it would risk exposing them to fragmentation issues like those in the current NIS-bound fields. Instead, when considering non-regulatory and regulatory interventions, we would focus on harmonizing the sectors and services already within the scope of the directive. This approach might offer novel non-regulatory instruments that could then be adopted by other sectors and services. Also, regardless of the policy mix, we call on the Commission to avoid imposing a disproportionate financial and administrative burden on smaller operators of essential services and smaller digital service providers. In the spirit of the ‘Think Small First’ principle, all new requirements should be proportionate to the risk presented by the network and information system concerned. Especially in the case of digital service providers, those requirements should not apply to micro- and small enterprises, as is the case now.
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Response to Achieving the European Education Area

12 Aug 2020

More than ever, skilled individuals together with innovative companies are needed to secure Europe’s economic competitiveness, social fairness and strategic resilience. The fruits of digitalisation and green economy can only be harvested over the coming years if people and businesses, especially SMEs, have the right opportunities and incentives to keep their skills up to date. It is therefore imperative that the EU and the Member States step up investment in education, research and innovation, and the deployment of technology not just through the near-term COVID-19 recovery efforts but also the long term fiscal frameworks, including the EU’s MFF which currently still lacks ambition in these very fields. Upping the skills investment is, however, not enough unless combined with the strong determination to reconfigure the education and training systems to meet the demands and seize the opportunities of the digital age. This means that more emphasis must be placed on later-stage adult learning, especially work-based upskilling and reskilling, while also updating initial stages of education, from early childhood education and primary school through vocational and higher education. We are pleased to see that the initiative for the Communication on Achieving the European Education Area (EAA) is in step with these general objectives. It is also important that the initiative doesn’t propose an extension of EU competences, but instead reaffirms the supplementing and supporting role of the EU in the field of education and training policy. We agree that the best way for the EAA to add value is by focusing education and training cooperation between Member States on common goals, particularly regarding lifelong learning, basic skills and digital competences, and on building the resilience of education and training systems. The EAA can achieve this by circulating best practices, facilitating transnational collaboration and talent mobility, and offering resources and practical tools, benchmarks and guidelines for national and local authorities and other stakeholders. We therefore support the proposal of laying out an enabling European framework, succeeding ET 2020, for cooperation with Member States and engagement with stakeholders across all education and training sectors and levels.
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Response to Implementing act on a list of High-Value Datasets

6 Aug 2020

To succeed in the ongoing digital and green transitions, Europe needs a thriving data economy based on common values and strong markets to which public bodies and undertakings, including publicly controlled companies, contribute by unleashing their vast data assets for innovation and research. With this in mind, we welcome the Commission’s initiative to follow up the new Open Data Directive, whose goal is to increase the availability of public sector digital information, with an implementation act ensuring the accessibility of high-value public datasets (HVDs) in machine-readable formats, via application programming interfaces and primarily free of charge – and, most of all, across Member States within a harmonized legal framework that has the ‘think small first’ principle at its heart. We stress that the initiative should lead to greater re-use of HVDs especially by startups and SMEs that are currently at risk of being left behind in the fast-emerging data economy. The more innovative startups and SMEs can bundle HVDs with data from other domains and sectors into novel solutions, the greater the economic, environmental and social gains. Therefore, the main objective of the implementing act should be to free smaller companies of any unnecessary technical, legal, financial or administrative barriers concerning the access to and re-use of HVDs. We urge the Commission to focus on a set of policies that reflects this goal. The short-term public costs of these policies should be balanced with the immense long-term fiscal benefits and governmental efficiencies they entail. We would also like to remind the Commission that when it comes to opening publicly held data on companies and company ownership to a wider use, it should always be done in a way that doesn’t compromise privacy, trade secrets or intellectual property rights.
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Response to Legislative framework for the governance of common European data spaces

28 Jul 2020

The creation of a harmonized and dynamic digital single market where more data is shared and (re)used between companies, individuals and public bodies to make scientific discoveries and innovative products and services, while respecting the European values, is a precondition for the future economic growth that is both socially and ecologically sustainable. With this in mind, we consider the Commission’s initiative on the legislative framework for the governance of common European data spaces to be timely given the pace at which the digital transition is advancing around the globe. Its general objectives are relatively well aligned with the main issue at hand, namely that Europe needs a more concerted effort to improve access to data, both personal and non-personal, within and across sectors and domains in order to foster competitiveness of European businesses, particularly SMEs who often have insufficient resources to tap into big data. We agree with the presumption that to avoid the undesirable fragmentation of the European single market for data a cross-sectoral framework of governance for common data spaces is required. The governance framework would build on, and wisely not tamper with, the existing EU data legislation and would allow for the formulation of sector-specific norms in each individual data space if necessary. In our view, all new binding rules, horizontal or sectoral, that touch upon data sharing provisions between companies should be assessed carefully and have SMEs in mind (‘think small first’). Although the overall approach to B2B data sharing should be market oriented, we do recognize a need to clarify the rules on how the flows of non-personal data are governed between enterprises. For instance, SMEs need a better and fairer access to data generated by machines and devices they own or lease. This may require prohibiting clauses in the general terms and conditions, which prescribe a unilateral, exclusive use of non-personal data by one of the contracting parties, while, however, maintaining the freedom for parties to agree otherwise, if they so choose. The first policy objective of making more of the publicly held personal and company data, which is not covered by the Open Data Directive, usable for research and innovation is welcome. This, however, and as outlined in the initiative, should only be done in accordance with the rights of the data subjects. To take this approach to its logical conclusion, we would like to see the right to consent-/permission-based data portability to be extended to public bodies as it would encourage data sharing within the public sector and be-tween the public and private domains. When it comes to best practices, Finland has established a noteworthy legal and technical mechanism for the secondary use of health and social data through Findata, a one-stop shop permit authority for researchers and innovators. We support the second policy objective of strengthening the mechanisms for data altruism among individuals and companies if they are voluntary in nature. We regard the third policy objective of lowering technical, legal and practical barriers to data sharing to be of utmost importance when establishing a common governance framework for European data spaces. It is especially in the interest of SMEs to increase the interoperability of data ecosystems and to decrease the transaction costs involved. To achieve this, an EU-wide coordinating body/structure/process facilitating the standardization efforts across data spaces may be in order but given the vague description of their nature provided in the initiative our final opinion remains undecided. We do, however, strongly favour supporting the emergence of novel data intermediaries, or so-called data operators, by clarifying their legal standing in the data economy and, if deemed useful, by introducing appropriate voluntary certification schemes labeling trusted intermediaries.
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Response to Digital Services Act package: ex ante regulatory instrument of very large online platforms acting as gatekeepers

25 Jun 2020

Online platforms have become paragons of the digital economy. Unfortunately, Europe and European companies have not been at the forefront of the platform transition. This is due to many reasons, one being the sluggish development of the Single Market for digital services, which has not enabled blitz scaling across national borders for the innovative European startups and SMEs. This has resulted in a situation where a handful of mostly non-European platforms have become to dominate large sectors of the European digital market, acting in many respects as de facto gatekeepers to these fields, thus suppressing competition and making it doubly hard for other companies to challenge them. As it happens, a growing number of SMEs have also become dependent on these large platforms for conducting their day-to-day business and reaching old and new customers. Although platform ecosystems have brought many benefits to SMEs, trading relationships between large platforms and their small-business users are often excessively asymmetrical, even to the point of being unfair. The new EU-wide P2B regulation, applied as of July 2020, is aimed at fixing these issues. Considering these developments, the EU needs to do more to make platform ecosystems fairer, more competitive and more conducive to innovation. Therefore, we agree with the general objectives of the ex ante regulatory instrument, as part of the Digital Services Act package, that would focus on large online platforms and their wider ecosystems. These dominant platforms need to be regulated at the EU level due to their cross-border nature and in order to avoid fragmenting the Digital Single Market. The fragmentation into several national regulatory regimes would only further hamper the ability of European SMEs to thrive in platform ecosystems, whether as platform providers or platform users. As for the policy option 1, since platform ecosystems keep constantly evolving, it is necessary to address emerging questionable practices that might tilt the playing field. It might also require reinforcing the existing oversight, enforcement and transparency requirements of the horizontal framework set in the P2B Regulation. All new measures that apply to all online intermediation services should, however, be assessed carefully with a view to their impact on smaller platform providers before implementation. New obligations should not place small-er providers at deeper disadvantage against larger operators. The P2B regulation managed to increase transparency in platforms. However, it was less successful in increasing fairness in platform-to-business-relations. To ensure a level playing field for small-business users in platforms, terms and conditions of P2B contracts should include only fair and proportionate clauses. Blacklisting certain unfair trading practices and/or abolishing the use of unfair terms and conditions in P2B contracts, might require legislative intervention as envisaged in policy options 1 and 3a. The policy option 2 is advisable. Clearer insight is needed into large online platforms and their impact on consumers, business users and competitors, in order to empower relevant authorities to supervise the con-duct of large platforms and to enforce the rules in a more efficient fashion. A new and flexible ex ante regulatory framework for large gatekeeper-type online platforms, proposed by the policy option 3 and its two sub-options 3a and 3b, is in principle advisable but does not come without possible downsides. These include hurting the EU’s trade relations with the US and China, where most major platforms targeted by this new framework are headquartered, and inadvertently limiting the possibilities of EU-based platforms to survive the expanding regulatory burden that established non-EU large platforms have the means to bear. It is therefore important to further explore the pros and cons of this policy approach.
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Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

25 Jun 2020

Although improving the functioning of Europe’s Digital Single Market is vital, it is worth reminding that regulation will bring the EU and its companies only so far when it comes to achieving increased competitiveness and productivity in the global digital economy. In short, the EU cannot regulate its way to the top. Therefore, more attention needs to be paid to enhancing the capacity of European companies, especially SMEs and startups, to not just follow the digital trendsetters elsewhere but to blaze a trail into the emerging digital fields. Keeping this in mind, it is imperative that the EU together with the Member States adopt a more committed stance towards investing in education and training, research, development and innovation (RDI) and deployment of new technology – the basics of the socially, environmentally and economically sustainable growth. Having stated this, we do see a need for the Digital Services Act and consider its general objectives well founded. The Digital Single Market requires strengthening in terms of competition and innovation and the economic and social benefits they bring to Europe and the wider world. This can be achieved in part by modernizing and harmonizing the rules that underpin the Digital Single Market. Further regulatory fragmentation should strictly be avoided. In our view, the baseline scenario outlined in the roadmap, where no new regulatory measures would be introduced, is insufficient. A more robust approach is required, due to the scope of the challenges at hand, especially with regard to increasing market barriers to SMEs subject to both fragmented regulatory landscape and market dominance of a few large digital players, and the inability of the outdated regulatory framework based on the e-Commerce Directive to address them. The Single Market rules should apply equally to all digital service providers regardless of their origin or establishment. Since service providers from outside the EU would not be covered by the policy option 1, the scale tips towards the policy option 2. However, all new obligations and sanctions imposed on digital services and online platforms should be proportionate to the scale of potential risks posed by a service and take into account the size and scope of the provider in question, so as not to handicap innovative digital SMEs competing against bigger and more established companies who are better placed to overcome regulatory burden. Similarly, when overhauling the regulatory framework for digital services, it is necessary to dismiss old rules that are no longer relevant. The principle of “One In, Two Out” should be adhered to when drawing up a new set of rules. The updated framework should be not only fit for purpose but also as light and streamlined as possible, not increasing but decreasing the cost of doing business for law-abiding SMEs inside the Single Market. The twin goals of (1) a harmonized and level playing field on one hand and (2) decreased administrative burden on the other also apply to, and in many ways depend on, the effective governance of the revamped regulatory framework, suggested in the policy option 3. The gaps between the Member States in terms of implementation and over-sight of the common Digital Single Market rules are still large and re-quire a more vigilant enforcement from the Commission and closer co-operation between the Member States. The Member States that are less equipped or otherwise less inclined to deploy the desired governance structure need special attention from the Commission and other Member States. This divergence in capacity between the Member States needs to be taken into consideration when setting the goals and ambitions for the new EU legislation for digital services. Although the pace of technological transition might call for a swift and extensive legislative action, it would be advisable to proceed in a moderate and step-by-step fashion, ensuring the cohesion of the Single Market.
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Response to Digital Education Action Plan

22 Jun 2020

Digitalisation upends the skills landscape of vocations, businesses and entire industries. Thus, it significantly alters expectations of the education and training systems, which, in many ways, are still modelled after the requirements of the bygone industrial age. Recent (pre-COVID-19) foresight studies in Finland predict that the demand for digital skills, such as the ability to utilise digital solutions and platforms, will greatly increase in the job market by 2035. The pandemic will only hasten this development, changing skills requirements in SMEs and other workplaces sooner than anticipated. It is high time to reshape the European education and training systems to better meet the swift digital transition the world is witnessing. Digitalisation provides ample opportunities and assets for this endeavour. The key lesson of the COVID-19 crisis is that digital education should no longer be viewed as an island of its own but considered an integral part of all education and training. First, it allows for online learning done completely remotely or in some combination with face-to-face offline pedagogy. Second, and more importantly, digital education promises to improve the learning experience both in a classroom or at home or workplace by enabling educators to better align the pedagogical choices with the needs and preferences of each learner. Digital solutions, whenever they boost learning results, should therefore be fully integrated into all modes of education and training at all phases of a learner’s life cycle, from the early education to the later stage upskilling and reskilling. By forcing education and training institutions and professionals across the board to adopt digital means of instruction and consequently highlighting both benefits and areas in need of development of these new pedagogical solutions, the COVID-19 crisis will hopefully accelerate the shift to more future-ready education and training (eco)systems that blend effortlessly both online and offline forms of learning and make the most of what innovative private education providers and technology developers have to offer. This momentum should not be wasted by public authorities in charge of educational affairs. Although education policy remains rightly a domain of national and local decision making in the Member States, the EU, within its jurisdiction, should actively promote and advance the evolution of digital education. The Digital Education Plan, mobilised through the Commission programs (Erasmus, Horizon, Digital Europe, structural funds), should focus on a few strategic areas where the EU can add considerable value to the efforts of the Member States. One such area should be digitally enhanced on-the-job training which takes place in SMEs and touches both younger apprentices and trainees and more experienced individuals, including entrepreneurs. Another ought to be the cross-border co-operation between education and training institutions in the field of joint study programs that blend online and offline learning. Increased student and teacher mobility inside the EU and from the third countries via digital technologies, especially AR/VR, would be a third obvious focus area, as it is likely the pandemic will undermine the old-fashioned exchange programs.
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Response to Revision of Non-Financial Reporting Directive

26 Feb 2020

Non-financial reporting directive – Federation of Finnish Enterprises feedback The Federation of Finnish Enterprises (FFE), representing 115 000 small and medium-sized enterprises of Finland would like to express its views on the initial impact assessment regarding the non-financial information reporting directive (NFRD). FFE recognizes the growing importance and need for communication related to non-financial information and therefore supports Commission’s endeavour to reassess the current regulatory framework. FFE finds that the Commission’s analysis on the current problems of NFRD to be tackled are somewhat correct. As the IIA establishes, the reporting requirements in the NFRD are not detailed and leave a lot of discretion to reporting companies which makes them difficult to enforce as well. There is also complexity and uncertainty regarding the reporting requirements among companies. The IIA also points out that the information reported under this directive is not comparable nor reliable and it is not often relevant to the public who would need this information. At the same time, the Commission relevantly identifies that companies incur unnecessary and avoidable costs related to reporting of non-financial information. FFE strongly advocates that the defects of the directive should be corrected before considering the enlargement of the scope of companies falling under the directive. NFR-requirements have already been found complex and burdensome in large companies applying them. In Finland, large companies have not been able to fully comply with the reporting and monitoring obligations of the directive. It is therefore indisputable that in their current form, they would be even more burdensome and complicated for SMEs to comply with. They would create additional costs to SMEs who most often do not have the expertise to fulfill these types of reporting obligations within the company itself, but would have to pay for external agents/consultants. As the directive at its current state is not delivering the results that it is intended for, it would be unreasonable to enlarge the scope of a directive that does not work optimally. It would also be against EC’s goal to Think Small First and reduce administrative burdens of SMEs. Federation of Finnish Enterprises considers that the Commission should continue the current approach of non-binding guidelines to ensure proper application and effectiveness of the directive. As a secondary option, drafting voluntary standards could be envisaged. Possible standards should however be affordable and easy to apply in small businesses as well. Only once the current directive is functioning well for large companies, should it be feasible to consider extending the scope. However, instead of solely enlarging the scope of the NFR-directive, it is necessary to evaluate the reporting requirements for SMEs as a separate totality due their limited human, technical and financial resources.
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Meeting with Ana Carla Pereira (Cabinet of Commissioner Nicolas Schmit)

18 Feb 2020 · minimum salary and platform work

Meeting with Kaisa Soro-Pesonen (Cabinet of Commissioner Jutta Urpilainen) and FinMobility ry

23 Jan 2020 · Role of SMEs in European development policy

Meeting with Timo Pesonen (Acting Director-General Internal Market, Industry, Entrepreneurship and SMEs)

3 Dec 2019 · exchange views on future SME strategy

Meeting with Risto Artjoki (Cabinet of Vice-President Jyrki Katainen)

22 Mar 2019 · Commission decision making

Meeting with Marika Lautso-Mousnier (Cabinet of Vice-President Jyrki Katainen)

9 Oct 2018 · Topical EU issues