EUU, Alm.del - 2014-15 (1. samling) - Bilag 197: Regeringens notat og høringssvar vedr. Kommissionens høring om en ny handlingsplan for små og mellemstore virksomheder

Europaudvalget 2014-15 (1. samling)
EUU Alm.del Bilag 197
Offentligt

NOTAT

16. december 2014

Response from the Danish Government to the public consultation on

the revision of the Small Business Act

The Danish Government supports a full implementation of the current

Small Business Act for Europe and finds that this should be the main fo-

cus for the Commission. Denmark however appreciates the opportunity

to set forth our views on the revision of the Small Business Act for Eu-

rope (SBA).

Denmark recognises the SBA as an important part of European SME pol-

icy and is supportive of ensuring a high level of implementation of the ten

principles in the Member States.

It is important that the SBA is updated and geared towards creating better

opportunities for growth in European SMEs. We find that several of the

Commission’s proposals for a revised SBA will contribute to this goal.

In order to strengthen the SBA’s potential for creating growth opportuni-

ties for SMEs it is necessary to make it focused, ambitious and reflecting

needs of SMEs in Europe. On these grounds, Denmark finds that the pro-

posed actions for the SBA 2015-2020 should strive for a focus on the fol-

lowing.

1. Smart regulation

Denmark believes that it is of vital importance to remove unnecessary

bureaucracy through smart regulation efforts. But the efforts should not

stop here. There is also a substantial potential for reducing unnecessary

red tape through digital solutions. It should be ensured that all EU legisla-

tion is digital by default to enable digital interaction between businesses

and between businesses and the public sector. As an example, smart gov-

ernment solutions, entails a substantial potential for relieving SMEs from

their reporting and accounting obligations.

Regarding the “SME Test”, Denmark finds

it important that a certain

amount of flexibility is left to the Member States regarding its implemen-

tation. The legislation processes in the Member States vary, and already

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today the administrative burdens of Danish SME’s are taken into account

when new Danish legislation is produced.

The proposal for an EU regulation on regulatory simplification regarding

entrepreneurs (e.g. a maximum cost of €100 for setting up a company) is

interesting. In Denmark it is already possible to start up different compa-

ny types online with immediate registration. It is possible to form an en-

trepreneurial company, a private limited company and a public limited

company online with immediate registration. There should be a clear Eu-

ropean added value as well as room for manoeuver for the Member States

if this initiative is to be set forward.

It is however vital that the level of protection of workers’ rights, including

health and safety, and environmental standards are kept the same no mat-

ter the size of the SME. Therefore blanket exemptions for SMEs or mi-

croenterprises do not seem to be a good idea. Instead the basic legislation

should be kept as simple as possible.

We strongly support that the consultation of SME’s and their representa-

tives - as well as the consultation of other relevant stakeholders - is

strengthened. Our proposal is that the SBA 2015-2020 announces the

launch of a platform where Member States and Members of the European

Parliament can submit stakeholder generated proposals for smarter regu-

lation. This will ensure that burden-reducing efforts are targeted at legis-

lation with the largest potential for real-world impact for businesses spur-

ring growth and employment. The Commission should be subject to a

‘comply-or-explain’-principle

and i.e. publish its responses, clearly stat-

ing which proposals it intends to pursue, and explaining why some pro-

posals will not be taken further. This would be a very concrete action to

take in reducing unnecessary administrative burdens.

2. Accessing finance

Denmark encourages the Commission to keep a strong focus on ensuring

a speedy and efficient deployment of the new financial instrument. Fur-

thermore, delays in the implementation of the instruments should general-

ly be avoided as this causes great inconvenience for possible financial

intermediaries planning to apply for them, without compromising the

soundness of the financial instruments.

We find it positive that the Commission investigates the possibilities for

developing alternative sources of finance as long as transparency and

consumer protection is ensured, while at the same time keeping in mind

the importance of promoting the use of existing instruments and EU-

programmes.. The venture capital market and the alternative sources of

finance market make up a small part of the capital market. In this context,

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efforts should also be made to ensure that existing instruments work at

their best.

There is great reasoning in strengthening the revival of the securitisation

markets through delegated acts to the Solvency II Directive and the Capi-

tal Requirements Regulation. Such legislation should comprise the intro-

duction of “high quality securitisations” or “qualifying securitisations”. A

suitable approach would be to lean on the modular approach suggested by

the European Banking Authority in their discussion paper (as well as in-

ternational standards from Basel Committee on Banking Supervision and

the International Organization of Securities Commissions to be published

shortly). This approach would ensure common criteria on qualifying secu-

ritisations across sectors and on top of that specific requirements for regu-

latory benefits within each sector.

3. Access to markets

Denmark firmly believes that the best way the European Commission

could facilitate growth of SMEs is by further developing and deepening

the internal market. Denmark therefore looks forward to any forthcoming

initiatives which would improve the functioning of the internal market for

goods and services.

We know that up to 25% of companies trading in the Single Market have

experienced difficulties with exports due to national rules. And we know

that SMEs often lack expertise and resources to overcome these barriers.

Therefore, concrete initiatives are needed to ensuring transparency and a

better application of rules and principles for the Single Market.

In order to make the Single Market work for SMEs it is vital to ensure

that the Single Market contact points work at their best (i.e. Points of Sin-

gle Contact, Product Contact Point and SOLVIT). An enforced govern-

ance framework at EU-level that commits the Member States and the

Commission to co-operate and prioritize single market instruments would

improve functioning and ensure minimum service standards of these in-

struments. The framework should be based upon a legislative act on

strengthened co-operation and enforcement of single market laws.

Furthermore, the European Commission should establish a common and

uniform notification procedure and public database for goods and services

at EU-level. National rules for services are at present not subject to the

same efficient and transparent notification procedure that exists for goods.

Extending the scope of the information procedure directive (98/34/EC) to

cover all relevant requirements for services and service-providers, for

example new authorisation schemes, could amend this.

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Finally, a concrete tool to improve the Single Market for SMEs is stand-

ardization and increased use of standards by companies and in procure-

ments.

Regarding the Enterprise Europe Network, Denmark recognizes the im-

portant role of, and the many possibilities within, a widely established

network. However, we underline that if Enterprise Europe Network is

continuously upgraded there is a strong need to ensure that an appropriate

share of the budgets for Horizon 2020 and COSME is allocated to the

EEN to ensure a high quality of the Networks’ services to SMEs. An in-

crease in the budgets for EEN may not result in an increase in the amount

member states’

co-financing for EEN from non-EU sources in order to

ensure quality in the network’s activities.

Denmark supports the establishment of a European Resource Efficiency

Excellence Centre (EREEC) as green transition in SMEs should continue

to be an EU focus. We find that EREEC should focus on introducing

models such as industrial symbioses, where two or more companies create

a partnership with the purpose of converting unused/leftover resources

like water, heat, wood, sludge, calcium, etc., in one company into a re-

source in another. Furthermore, we recommend that EREEC will be

strongly linked to existing knowledge hubs such as the UK based Ellen

McArthur Foundation and serve as a reference, not only for SMEs, but

also for interested national and regional stakeholders who provide

knowledge and information about resource efficiency to SMEs in their

region/country. A final remark related to EREEC regards the proposal

that the Centre and its partners should cover 80 % of the European econ-

omy. We would prefer a clarification of what is meant by these 80 % as

this is a bit unclear in the consultation document.

Denmark finds that there should be increased focus on how to establish an

integrated effort regarding the internationalisation of, and access to, third

country markets as well as a clear focus on European added value in rela-

tion to the Missions for Growth.

4. Releasing the entrepreneurial and innovation potential for growth

In general we find that focus should be on streamlining and focusing the

existing platforms aimed at accelerating growth of entrepreneurs. Fur-

thermore, focus should be on

general conditions for growth

instead of a

specific focus on certain groups of entrepreneurs.

We are of course very pleased to see that the concept of Early Warning

has been introduced as a proposal for the new SBA. We would like to

take this opportunity to describe a possible way of arranging the Early

Warning system at EU level. As it is important to have a local attachment,

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there should be an Early Warning system in each Member State with ex-

perts who know the national and local business regulations and business

climate. At EU level there should be an opportunity for a structured ex-

change of best practices and the establishment of a network in for exam-

ple an expert group. Furthermore a knowledge centre for research in

bankruptcy patterns and crisis management could be a possibility.

In the context of the current economic circumstances and the need to

make every effort to facilitate business activity and employment, national

action plans and quality standards for transfer of business are positive

steps as this should help to identify the remaining barriers in the relevant

regulatory and administrative environment affecting business transfers for

the SMEs. It is however important that national business conditions are

taken into account, and initiatives in this area should have a clear Europe-

an added value.

5. Reinforcing skills development to overcome shortage of skilled labour

Availability of skilled labour is a challenge for the EU and we thus sup-

port having it as a focus area for the SBA. It is however important to have

a clear European added value when developing new schemes in this area

as national schemes already exist in several Member States.