512 submissions from 470 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission lists 2,518 submissions on this file. Shown here: the 512 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
CommitteeJURIRapporteurRené Repasi (S&D)
Deliberations in Council working party · 23 Jul 2026
Tabling of amendments in the EP committee responsible · 22 Jul 2026
Committee Amendments Tabled · 22 Jul 2026
Deliberations in Coreper · 15 Jul 2026
Committee Opinion Adopted · 15 Jul 2026
Who showed up
363 submissions from industry — companies and their trade associations — against 65 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 5.6 industry submissions for every one from civil society.
Industry 363Civil society 65Public authorities, academia, other 84
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
What the room declares
118 of 470
in the EU Register
514
full-time lobbying staff
€56.3M+
declared costs a year
294
EP accreditations declared
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 25 Jun 2026 — it ran from 30 Apr 2026.
The initiative will respond to the demands of the business community by providing businesses, especially innovative ones, with a single set of rules to operate and invest more easily in the single market. In a nutshell, it will define a new legal framework that will regulate a wide range of key issues for businesses taking into account online procedures and digital tools under EU company law.
Filed in Italian · English published by the European Commission
The Henri Capitant Association and the Foundation for Continental Law welcome the initiative of the European Commission to create an optional regime for a European Company within the Union. While this proposal is a real step forward in completing the single market, it contains a number of regrettable choices borrowed from Delaware law and some shortcomings.
Filed in French · English published by the European Commission
Operating in 13 EU Member States through over 70 corporate entities, Delivery Hero has scaled across several European markets and seen firsthand how corporate and regulatory fragmentation raises the cost of growing in Europe. As one of Europe's leading founder factories, we have a direct stake in whether the 28th Regime delivers a legal form that genuinely supports founders from incorporation through to scale.
The Notarial Chamber of the Czech Republic understands the aims of the proposal, the needs of companies operating cross-border in the internal market and welcomes the possibility to provide feedback in this consultation. In our view, the proposal provides a solution for a part of the barriers existing in the internal market (especially thanks to ESOP and insolvency rules).
Companies need to set up and scale faster across Europe. We applaud the Commission for getting much of the set up part right: fast, digital, and low-cost procedures will help SMEs across the bloc. However, on scaling, much more needs to be done if the EU Inc framework is to be a truly European alternative to Delaware.
Social Economy Europes contribution to the public consultation on the 28th Regime corporate legal framework EU Inc. Social Economy Europe welcomes the European Commissions proposal for a 28th Regime corporate legal framework EU Inc. as an important step towards a simpler, more integrated and more competitive Single Market.
ANIVEC National Association of Clothing, Confection and Mode Industries provides its technical advice on the proposed Regulation of the 28th Optional Legal Regime (“EU Inc.”), in conjunction with the guidance of the Regulatory Scrutiny Board (RSB).
Filed in Portuguese · English published by the European Commission
Philea welcomes the opportunity to provide comments on the European Commission proposal for A single harmonized set of rules for innovative companies throughout the EU 28th regime. The EU inc. scope should cover foundations Philea and others had called for the EU Inc framework to include foundations and not only limited liability companies.
Mr Bpifrance welcomed the lambition of the EU Inc. proposal, while stressing three priorities to make it an effective lever for European innovation. First, it is essential to preserve the link between national State aid and the real economic growth of undertakings in order to ensure that the benefits of such aid benefit the real economy, while respecting the objective of European harmonisation.
Filed in French · English published by the European Commission
The proposal for a Regulation of the European Parliament and of the Council on the legal framework of the 28th regime for businesses was particularly awaited. It responds to major French academic and institutional initiatives, in particular those of the Henri Capitant Association (December 2020) and the Haut Comité Juridique de la Place Financière de Paris (March 2021) in favour of a simplified European company, in…
Filed in French · English published by the European Commission
Cooperatives Europe is the European cross-sectoral organisation representing cooperative enterprises in Europe. We represent 163 million individual entrepreneurs and member cooperators, owning 250,000 cooperative enterprises and providing jobs to 4,7 million European citizens. We welcome the Commissions proposal for the EU INC and the efforts to support innovative startups and scaleups in Europe.
The Association for Competitive Technology (hereafter ACT) hereby submits comments to the European Commission in response to the Public Consultation on A single harmonised set of rules for innovative companies throughout the EU 28th regime. ACT is a policy trade association for the small business technology developer community.
The CCBE welcomes the objective of establishing an optional European corporate framework facilitating cross-border business activity and reducing fragmentation within the Single Market. However, the proposal does not yet provide the certainty required for a genuinely uniform company form. The principal concern relates to the relationship between the Regulation and national law.
Position Paper from the Belgian Centre of Company Law on the EU Inc. Proposal1 Executive summary The Belgian Centre of Company Law (the “BCCL”) welcomes the Commission’s EU Inc. Proposal, in particular the emphasis on online formation and deliberation, the “once-only” principle, the use of a Regulation rather than a Directive, and the introduction of EU-level templates for articles of association.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The draft regulation on the legal framework for the EU Inc represents a useful step forward as it aims to simplify certain procedures, reduce the fragmentation of company law and promote better cross-border circulation of information.
The German Federal Chamber of Notaries (Bundesnotarkammer) supports the objective of strengthening the European Unions competitiveness and improving the framework conditions for growth-oriented companies. However, the Proposal for a Regulation should be substantially revised in order to ensure consistency with the European acquis in company law, legal certainty, effective anti-abuse safeguards, democratic…
The Royal Dutch Association of Notaries endorses the European Union’s aim of strengthening the internal market and European competitiveness. A new European legal form can contribute to this if it is in line with the European model, in which legal certainty and protection are guaranteed ex ante rather than ex post. The current EU Inc. proposal does not provide sufficient safeguards to this end.
Filed in Dutch · English published by the European Commission
Please find attached the opinion of the Combined Companies Law Committee of the Dutch Bar Association (NOvA) and the Royal Notarial Professional Organisation (KNB) on the European Commission’s proposal for a Regulation of the European Parliament and of the Council on the company law framework of the 28th regime EU Inc.
Filed in Dutch · English published by the European Commission
Proposal for an EU Regulation on the 28th Regime “EU Inc.” Comments and Notes Startup Portugal, as an organisation for the promotion of entrepreneurship registered in the European Transparency Register under number 5213929102373-93, hereby sets out its position on the proposal for a Regulation of the European Parliament and of the Council on the 28th company law regime, published by the European Commission on 18…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
AseBio welcomes the European Commission's proposal to develop Regime 28 and create the EU Inc. framework, an initiative that will allow innovative companies to operate under a single, harmonized set of company rules across the European Union.
ENSIE fully supports Social Economy Europes contribution to the public consultation on the 28th Regime corporate legal framework EU Inc. ENSIE joins Social Economy Europe in calling for the future 28th Regime to be an inclusive instrument that reflects the diversity of Europes enterprise models and ensures that social economy entities can benefit from Single Market simplification without being forced to abandon…
The proposal seeks to facilitate company formation and cross-border business activity. While these objectives are to be supported, it is important to ensure that simplification does not come at the expense of transparency and legal certainty.
Fédération du Commerce et de la Distribution (FCD) – Feedback sur la proposition de la Commission européenne pour un 28ème régime La Fédération française du Commerce et de la Distribution (FCD) se réjouit de la proposition de la Commission européenne en faveur d’un « 28ème régime ». Nous appelons à poser les bases d’un droit européen des affaires.
Filed in French · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
CECOP, the European Confederation of Industrial and Service Cooperatives, welcomes the European Commissions consultation on the Commissions proposal for an EU Inc, or 28th regime. As the EU strives for increasing the competitiveness of Europe and creating an enabling environment for innovation, the 28th regime has the opportunity to contribute to these goals.
ETAF Statement Proposal for a Regulation on the 28th regime corporate legal framework The European Tax Adviser Federation (ETAF), representing the interests of more than 280,000 regulated tax advisers across Europe, would like to thank the European Commission for the opportunity to provide feedback on the proposal for a Regulation on the 28th regime corporate legal framework (COM (2026) 321), or the so-called “EU…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Chamber of Tax Consultants and Auditors (KSW) is the statutory representative body for more than 6300 tax Consultants and almost 2000 accountants and more than 4300 trainee employees in Austria. We take this opportunity to express our opinion on the draft Regulation of the European Parliament and of the Council on the company law framework of the 28th Regimes EU Inc.
Filed in German · English published by the European Commission
GLEIF welcomes the initiative and supports its objective of creating a harmonized corporate framework for innovative companies across the European Union. GLEIF recommends that every newly incorporated EU-Inc. company receive both a European Unique Identifier (EUID) and an ISO 17442 Legal Entity Identifier (LEI) as part of the incorporation process.
CENTR is the association of European country code top-level domain registries (hereinafter ccTLDs). All EU Member States and EEA countries ccTLDs (such as .cz for the Czech Republic and .ee for Estonia) are members of CENTR. CENTR members are at the core of the public internet, safeguarding its stability and security.
With reference to earlier proposals, we recommend to extend EU Inc to other relevant legal forms (besides limited liability companies), including social economy entities such as cooperatives, mutual benefit societies, associations, foundations, social enterprises.
Danish construction professions: A 28th regime could increase the problems of labour crime and undermine our national labour market model. The proposal for a 28th regime must not become a shortcut for underpayment and letterbox companies in construction The proposal for a 28th regime (EU Inc.) is deeply problematic and risks undermining the Danish labour market model of collective agreements, conflict law and labour…
Filed in Danish · English published by the European Commission
In principle, the Federal Bar Association (Bundesrechtsanwaltskammer, BRAK) recognises the objective of creating a single, digital form of company for the European single market with EU Inc., in particular to promote start-ups across borders and strengthen the EU’s competitiveness.
Filed in German · English published by the European Commission
Finance Denmark overall supports the objective of the proposal, including the ambition to establish a voluntary, harmonised company law framework that companies may choose as an alternative to navigating multiple national regimes. A well-functioning 28th regime may help facilitate cross-border activity and thereby contribute to realising the full potential of the internal market.
The Commission’s intention to set a 28th target for the entire EU internal area. We firmly reject the idea of creating a company law system. This would allow companies to choose between the lowest legal requirements in the respective Member States, thereby deliberately circumventing labour law provisions as well as national protective rules.
Filed in German · English published by the European Commission
Stellungnahme der Bundessteuerberaterkammer zum Verordnungsvorschlag der Europäischen Kommission über den gesellschaftsrechtlichen Rahmen des 28. Regimes – „EU Inc.“ Die Bundessteuerberaterkammer vertritt als gesetzliche Spitzenorganisation die Gesamtheit der bundesweit über 106.000 Steuerberater, Steuerbevollmächtigten und steuerberatende Berufsausübungsgesellschaften auf nationaler und internationaler Ebene.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Insurance Europe comments on the EC EU Inc proposal Our reference: PAC-SIU-26-016 Referring to: EC consultation on EU Inc proposal Pages: 2 Date: 25-06-2026 Transparency Register ID no.: 33213703459-54 Introduction Insurance Europe welcomes the European Commission (EC)’s recent proposal for a regulation on the 28th regime corporate legal framework – EU Inc - as an important step towards simplifying and accelerating…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Computershare supports the introduction of the harmonised EU Inc corporate structure under the 28th Regime, and the intent to support start-up and scale-up entities with a digital by default entity lifecycle. As a global market leader in share registration, shareholder management, corporate trust, employee equity plan management and a range of other financial and governance services, we have focused on the elements…
The Austrian Chamber of Civil-Law Notaries (Österreichische Notariatskammer) welcomes the opportunity to contribute to the public consultation on the European Commissions proposal for a Regulation of the European Parliament and of the Council on a 28th legal regime for companies (EU Inc.) (COM(2026) 321 final; 2026/0074) of 18 March 2026.
Deutsche Börse Group (DBG) welcomes the creation of a 28th regime in the form of an EU Inc., designed to enable innovative companies to operate under a single and harmonized EU framework for company law. We support this initiative as it holds the potential to reduce fragmentation across the 27 national company laws, lower administrative hurdles, improve financing options, facilitate cross-border business activities…
The Austrian Trade Union Confederation (ÖGB) rejects the proposal for a 28th Regime vigorously opposed. The protection of workers’ interests and rights and orderly competition are essential prerequisites for European integration. The proposal does not meet these fundamental requirements of the European economic order, but does not strike the right balance between innovation and social responsibility.
Filed in German · English published by the European Commission
ACCA support the 28th regime and proposed regulations as a first step towards reducing fragmentation and practical issues inhibiting companies incorporating, operating and scaling across the Single Market. As noted in our previous submission, establishing a trusted EU company brand will take time. We advocate for proportionate regulations applying the Think small first principle.
The EU Inc. is falling short of the goal of what founders really need is a start-up-friendly and clearly structured labour and tax law rather than complex national rules. Online formation and registration of a limited company in the commercial register within 24 hours has long been a reality in Austria without the existing legal certainty (involvement of notaries and the commercial register) and the prevention of…
Filed in German · English published by the European Commission
The European single market deserves a competitive, accessible and legally certain corporate framework. This is a goal the Belgian notariat (as the competent authority for company constitution under Belgian law) fully supports. The transposition of successive EU company law directives, culminating in Directive 2025/25, has already delivered what EU Inc.
As an Austrian legal practitioner, the further integration of the European internal market is in principle to be welcomed. Uniform digital procedures can facilitate cross-border activities and reduce administrative hurdles. At the same time, the European economy relies on legal certainty and trust.
Filed in German · English published by the European Commission
Response of the German Notaries Association (Deutscher Notarverein DNotV) to the Commission proposal for an EU Inc. / 28th company-law regime The DNotV supports the Commissions objective of facilitating company formation, cross-border growth and investment in the European Union. Europe needs fast, digital and reliable procedures, particularly for start-ups and scale-ups. However, the proposed EU Inc.
Euronext strongly supports the European Commissions proposal to establish an EU Inc. corporate form under the 28th Regime. The initiative addresses a long-standing structural gap in the Single Market by providing a simple, scalable and digital framework for cross-border company formation and growth.
The European Commissions initiative to propose an EU Inc. corporate legal framework is a strong structural reform to support competitiveness and innovation in Europe. This proposal to reduce legal and administrative fragmentation is welcome by EFPIA and especially its SME members which experience the difficulty to scale up their business in Europe.
The proposal seeks to enhance the attractiveness of the European business environment by introducing a new company form. While this objective is understandable, it is important to consider whether the proposed framework may unintentionally encourage regulatory arbitrage.
Global Employer of Record industry’s position on EU Inc. proposal May 2026 Key points ● EU Inc. can solve the corporate side of cross-border scaling, Employer of Record (EOR) provides a parallel solution on the employment side. EOR helps companies navigate the 27 employment rulebooks in the EU.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Confapi, the Italian Confederation of Small and Medium Private Industry, represents a wide-ranging system: more than 116,000 industries, up to 1,200,000 employees, 63 local and regional associations, 13 productive sectorial federations, and 2 groups of interest.
Working with entrepreneurs, company creation and further steps in the corporate lifecycle on a day-to-day basis, I would like to point out one aspect of the proposal that deserves careful consideration: the potential for regulatory arbitrage.
In my practice, I regularly accompany business start-ups and company reorganisations. This repeatedly shows that young businesses in particular benefit from simple procedures, but at the same time are particularly dependent on legal stability. The proposal for a regulation clearly assumes that standardised founding documents and largely automated procedures meet the needs of start-ups.
Filed in German · English published by the European Commission
As a preliminary remark, TCO would like to point out that the purpose of a 28th corporate regime is understandable, but also raises a number of legal questions and risks from an employee and trade union perspective. Creating a European legal form that makes it easier for companies to operate across borders can boost innovation, investment and growth for start-ups in the Single Market.
Filed in Swedish · English published by the European Commission
The EU Inc. proposal is a major step forward for the internal market, notably through digital formation, harmonised company law, and potentially the EUESO with taxation deferred to disposal. However, several targeted adjustments are needed to ensure it works for biotech and deeptech scaleups, spin-outs and founder-led companies.
PROPOSAL FOR A REGULATION ON THE 28TH REGIME CORPORATE LEGAL FRAMEWORK - "EU INC." COM (2026) final Position of the General Council of the Spanish Notariat The General Council of the Spanish Notariat supports the European Commission’s objective of strengthening the competitiveness of the European Union, facilitating the creation and growth of companies, reducing unnecessary administrative burdens and promoting fully…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
In addition to the unrestricted provision of tax assistance, tax advisers, in particular for SMEs, are also first contact persons in business consultancy. This applies to business start-ups, operations and in the event of economic failure. Please find attached the opinion of the DStV in DE/EN.
Filed in German · English published by the European Commission
The proposal appears to equate support for competitiveness with deregulation and the abolishment of necessary safeguards in terming them as too bureaucratic. However, these concepts should be clearly distinguished. Austria and other Member States have demonstrated that highly efficient and digital corporate procedures must go together with strong legal safeguards.
E U R O P E A N O F F I C E A N D L E G A L D E PA R T M E N T FEEDBACK Feedback on the Commission proposal for a “EU Inc.” Registration number in the register of interest representatives: 976536291-45 June 2026 Mechanical and plant engineering is a key strategic industry for the EU economy. VDMA represents 3.500 German and European mechanical and plant engineering companies.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
We (two Belgian corporate law professors who are board members of the Belgian Center for Company Law but want to submit separate feedback because we partially dissent from our colleagues) think the EU Inc. proposal has many merits, but think article 4 needs to be fundamentally rewritten, in order to clarify the relationship between regulation, national law and articles of association; in order to make sure that the…
From the perspective of an Austrian notary’s office focused on company law, we support the objective of facilitating cross-border business activity within the European Union. However, it should be borne in mind that the attractiveness of a legal location does not depend solely on the speed of starting a business. Austrian practice shows that rapid start-ups and preventive legal control are not mutually exclusive.
Filed in German · English published by the European Commission
The National Council of Bars and Law Societies welcomes the European Commission’s initiative to create an optional European corporate framework to facilitate the creation, development and cross-border growth of businesses within the internal market.
Filed in French · English published by the European Commission
AMF Italia considers the EU Inc proposal to be an important step towards strengthening European competitiveness and supporting the cross-border growth of innovative companies. In a context characterised by increasing competition among legal systems and persistent regulatory fragmentation, the creation of a genuinely European corporate form should be pursued with a pragmatic approach, also with a view to making the…
The European Commissions proposal to establish a new form of company operating under the so-called 28th regime that is, governed primarily by directly applicable European rules represents a significant step forward in the process of European integration.
The European Commissions proposal to establish a new form of company operating under the so-called 28th regime that is, governed primarily by directly applicable European rules represents a significant step forward in the process of European integration.
We would like to thank you for the opportunity to provide your feedback. The DIHK opinion on the proposal for a regulation on the company law framework of the 28th Regimes EU Inc.(the 28th regime corporate legal framework EU Inc.), COM(2026) 321, please see the Annex.
Filed in German · English published by the European Commission
FPIAR Federația Patronală a Industriașilor și Antreprenorilor din România welcomes the European Commissions initiative regarding the 28th regime for a European company law framework. FPIAR represents the interests of companies that currently generate over 35,000 jobs in Romania, contributing to the countrys industrial, productive and entrepreneurial development, as well as to the strengthening of economic relations…
The trade union vida (member trade union of the Austrian Trade Union Federation/ÖGB) rejects the proposal for a 28th Regime vigorously opposed. The protection of workers’ rights and orderly competition are essential prerequisites for European integration.
Filed in German · English published by the European Commission
Position on the on the proposed EU Inc. / 28th regime Regulation Assogestioni 1 welcomes the objective of strengthening the competitiveness of the EU, supporting company growth and reducing fragmentation in the internal market.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Europe's private equity and venture capital (PE/VC) ecosystem has reached scale, with deep venture, growth and buyout markets operating increasingly across borders. However, following its fundraising and investments peaks, it is now recovering unevenly across stages.
ÖRAK welcomes the objective of creating an optional European business framework with the aim of facilitating cross-border activity and reducing fragmentation within the internal market. At the same time, the current design of the proposal for an EU Inc. raises a number of important legal and practical concerns that require careful consideration.
Filed in German · English published by the European Commission
EFAMA welcomes the opportunity to contribute to the European Commission's initiative to establish a European company. Our views, at this stage, focus on the need to safeguard shareholder rights and to enable effective stewardship policies for all companies accessing public markets. Please find attached our comments.
The United Services Trade Union (ver.di) strongly rejects the European Commission’s proposal to introduce EU Inc. The reason for this rejection is that the current proposal does not bring about meaningful harmonisation of European company law, but opens up new possibilities for circumventing participation rights, labour standards and social protection mechanisms.
Filed in German · English published by the European Commission
The Danish Chamber of Commerce (Dansk Erhverv) welcomes the voluntary EU Inc. initiative, which aims to make it easier for companies, and particularly SMEs and entrepreneurs, to operate and scale across borders. A well-designed and ambitious regime could represent a genuine break-through for the Single Market and strengthen Europes competitiveness.
Legacoop welcomes the Commission's proposal for a 28th EU corporate regime and supports its ambition to create a uniform legal form at European level. To achieves these objectives, however, two issues require attention. 1. Limiting references to national law The proposal's success will depend on the degree to which it establishes uniform, self-standing rules.
The CSIPME supports the objectives and project of the proposal for a Regulation on the legal framework of the 28th regime for companies – “EU Inc.”. However, he pointed to a number of risks in the current proposal, which raised more questions and answers.
Filed in French · English published by the European Commission
ESBG welcomes the Commissions proposal to introduce an optional European company form (EU Inc.) as a 28th regime in company law. We support the objective of facilitating cross-border business activities, reducing fragmentation and strengthening the competitiveness of the Single Market.
One Market One Law (OMOL), an association dedicated to the unification and codification of business law in the European Union, welcomes the proposal for a Regulation establishing the EU Inc. corporate framework.
Ladies and gentlemen, the Commission proposal poses a serious threat to workers and their rights. The proposal for a so-called 28th There is a clear opposition to the regime. It does not strike the right balance between economic innovation and social responsibility and does not address key challenges such as lack of investment or difficult access to finance.
Filed in German · English published by the European Commission
Ladies and gentlemen, after setting up several companies and partnerships, I follow the development of EU Inc. However, I notice essential errors; for example, the question of the balance-sheet obligation, the principle of withholding tax (tax evasion?!), the duplication of accounts, who creates the unified infrastructure at European level (I am very happy to create a company again to undercut), the place of…
Filed in German · English published by the European Commission
While the DTUC support improving the EUs competitiveness, we fear that the proposal paves way for uncertainty that can endanger labour models and workers. The biggest misunderstanding arises from article 4(2) the country of origin-principle. The Commission states that this only applies company law (w/o definition). The Commission only refers to recital 83 as to 4(2) not covering labour law. We propose 2 amendments.
The Italian Confederation of Free Professions expresses its full support for the establishment of EU Inc., an optional corporate form of the 28th Regime. Overcoming fragmentation between the 27 legal systems is a structural reform for the competitiveness of the Union and to close its innovation gap, in line with the Letta and Draghi Reports.
Filed in Italian · English published by the European Commission
Employee stock options. The proposal could mean that a company's risks are transferred to its employees; if a company becomes insolvent or goes bankrupt, employee stock options risk becoming worthless. Employee stock options must not be a way of avoiding social security contributions and other charges, leading to employees losing social security benefits and occupational pensions.
The proposal for a 28th Regime is strongly opposed. The protection of workers’ interests and rights and orderly competition are essential prerequisites for European integration. The proposal does not meet these fundamental requirements of the European economic order, but does not strike the right balance between innovation and social responsibility.
Filed in German · English published by the European Commission
Stellungnahme des VID - Verband Insolvenzverwalter und Sachwalter Deutschlands zum Vorschlag für eine VERORDNUNG DES EUROPÄISCHEN PARLAMENTS UND DES RATES ÜBER DEN GESELLSCHAFTSRECHTLICHEN RAHMEN DES 28. REGIMES – „EU INC.“ 18.03.2026 – COM (2026) 321 final Executive Summary: • Das Konzept eines 28.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
28. režim (EU Inc.) Stanovisko HK ČR Hospodářská komora České republiky (HK ČR) podporuje záměr Evropské komise zjednodušit přeshraniční podnikání, zvýšit atraktivitu evropských společností pro investory a posílit konkurenceschopnost EU prostřednictvím nové právní formy EU Inc.
Filed in Czech · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
We would like to highlight the following concerns regarding the proposal: Recalling the objective of the legislative proposal, we would like to highlight that Europe's competitiveness depends not only on encouraging entrepreneurs but also on attracting investment. In this vein, investors frequently assess jurisdictions based on the reliability of their legal systems.
Advies de dato 19 juni 2026 Advies van de Vereniging Ondernemingsrechtspecialisten Notariaat (hierna VON) inzake het voorstel van de Europese Commissie voor een Verordening van het Europese Parlement en de Raad betreffende het vennootschapsrechtelijke kader van de 28e regeling1 (het Voorstel). 1. De VON maakt hierbij graag van de gelegenheid gebruik om advies uit te brengen met betrekking tot het Voorstel.
Filed in Dutch · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The proposal for a 28th Regime is rejected. The protection of workers’ interests and rights and orderly competition are essential prerequisites for European integration. The proposal does not meet these fundamental requirements of the European economic order, but does not strike the right balance between innovation and social responsibility.
Filed in German · English published by the European Commission
LEIR OÜ (candidate LOU, Local Operating Unit) supports the European Commission's initiative to establish a harmonized corporate legal framework through the proposed 28th regime, EU Inc., particularly as LEI issuance at incorporation would reduce administrative friction and ensure that EU-Inc. companies are globally identifiable from day one.
In my professional practice, I regularly advise founders, family businesses and growth companies during incorporation processes, financing rounds and ownership restructurings. Based on this experience, I strongly support efforts to make Europe a more attractive environment for innovative businesses.
The proposal sometimes gives the impression that there is a tension between digitalisation and preventive control. However, experience in Austria shows that this does not have to be the case. Austrian company law has taken significant steps towards digitalisation in recent years. Electronic procedures, digital communication and modern registry structures have made it much easier to set up and manage businesses.
Filed in German · English published by the European Commission
Thank you for the opportunity to give feedback to the legislative proposal on the EU Inc., which I would like to submit herewith. When assessing future reforms with the aim to support the competitiveness of the European Union, attention should be given to mechanisms that maintain trust in the system, legal certainty and the quality of data, in particular concerning corporate information in this case.
I would like to highlight my practical experience dealing with company law in Austria, where the introduction of digital tools has benefitted entrepreneurs. In this vein, I welcome any proposal supporting competitiveness and digitalisation while keeping legal certainty. In this vein, the support of company creation with digital tools and standard templates may seem interesting to support efficiency and speed.
Lo, TCO and Saco thank for the opportunity to comment on the European Commission’s initiative for a 28th corporate regime (EU Inc.). We see a risk that the proposal may create legal uncertainty and have undesirable consequences for the Swedish and European labour market. Simplifying company structures at EU level can be a legitimate objective.
Filed in Swedish · English published by the European Commission
The proposal is based on the assumption that company law with its allegedly overly bureaucratic processes represents a major obstacle to European competitiveness. While corporate simplification is a worthwhile objective, this diagnosis appears incomplete. Many businesses operating across borders identify other challenges as more significant.
The ETUC submits the following red lines in response to the European Commissions public consultation :Wrong legal basis and unacceptable use of a Regulation:ETUC strongly contests the use of Article 114 TFEU as legal basis for the 28th regime. Article 114 is intended to harmonise existing national laws, not to create a parallel optional company regime.
Accountancy Europe is pleased to provide feedback on the European Commissions proposed Regulation establishing a new 28th regime framework and the EU Inc. legal form. Our members comprise 49 national institutes of accountants, auditors and advisers. Their day-to-day work includes supporting businesses with financial planning, reporting, data reliability, access to finance and governance, among other areas.
The introduction of an EU Inc. will affect social security matters in key areas such as the coordination of social security, the collection and verification of contributions, and the cross-border enforcement of social security rights.
WIRTSCHAFTSKAMMER ÖSTERREICH Bundesministerium für Justiz z.H. LStA Dr. [name removed], LL.M. [address removed] Abteilung für Rechtspolitik Wiedner Hauptstraße 63 | 1045 Wien T 05 90 900 DW E [email removed] W wko.at/rp per E-Mail: [email removed] [email removed] Ihr Zeichen, Ihre Nachricht vom Unser Zeichen, Sachbearbeiter Durchwahl Datum Z10.200 – 2026-0.245.550 - Rp 50.6.12/2026/AS/CG Dr.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The German insurance industry supports the introduction of a harmonised corporate legal framework EU Inc., as part of an optional 28th regime. We welcome the creation of EU Inc. 28th regime company that is easy to set up and available to both young, innovative business-es and established companies.
Consultation EU Inc. Given the bureaucratic obstacles that startups face to truly operate Europe-wide, the Economic Board Zuid-Holland welcomes the proposal for EU Inc. However, we also recognise that it does not go far enough in establishing clear and uniform rules and implementation practices.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Ladies and gentlemen, with the proposal of an EU Inc., the European Commission is ranked 28th. Regime launched an important debate on the future of the European single market. The Federal Association of Liberal Professions (BFB) welcomes the objective of facilitating cross-border entrepreneurship and strengthening Europe’s competitiveness.
Filed in German · English published by the European Commission
The European Federation of Building and Woodworkers (EFBWW) strongly call on EU legislators to ensure that the EU Inc. regime is not applicable to the construction sector. Our position can be found in the attached file. The proposed regulation fails to account for the specific structural risks inherent to construction, thereby creating significant risks for abuse and spread of letterbox companies.
As property developers, we are not convinced by the idea of an EU.Inc and see no need for it. Reputable companies see no problem with the current formalities for setting up a business in Germany or other countries. This ensures that the companies we work with are genuinely owned by the right people.
This submission is made jointly by Allied For Startups (AFS) and the European Startup Network (ESN). It reflects a shared position representing startup associations and ecosystem stakeholders from across Europe. Further detail is available in the attached joint position paper.
The Czech Startup Association welcomes the EU Inc. proposal's adoption as a regulation. This will ensure strong harmonization of legislation across all EU Member States, which could not be achieved to the same extent through a directive. Practical advantages include the proposals fully digital approach and the first truly ambitious steps towards harmonizing ESOPs and startup financing.
A simple, accessible, and proportionate EU Inc. is essential for SMEs, through low administrative burdens and digital-by-default procedures. A fully digital company lifecycle and seamless cross-border activity require interoperable EU systems such as BRIS and eIDAS, as well as improved access to finance and recognition of modern business models.
The so-called 28th Regime, a single harmonised set of rules for innovative companies across the EU, sounds a good idea first. It promises less bureaucracy, faster start-ups, easier scale-up and better conditions for start-ups. On closer inspection, however, this approach is highly problematic.
Filed in German · English published by the European Commission
The problems facing companies lie in areas other than corporate law. As tax advisors, we are seeing more and more attempts at tax evasion and money laundering. The new legal form would make it easier for criminal organizations to create illicit structures. Employee protections would also be undermined. Tax havens would become more attractive. We see the problems that exist with American companies.
This submission is made jointly by the European Startup Network (ESN) and Allied For Startups (AFS). It reflects a shared position representing startup associations and ecosystem stakeholders from across Europe. Further detail is available in the attached joint position paper.
The DGB firmly rejects the European Commission’s proposal for a regulation establishing the EU Inc. The draft does not create meaningful harmonisation of European company law, but opens up new possibilities to circumvent participation rights, labour standards and social protection mechanisms. Instead of addressing Europe’s economic challenges, such as underinvestment or lack of access to finance, the EU Inc.
Filed in German · English published by the European Commission
The DAV sees a practical need for a uniform legal form across Europe to facilitate the cross-border establishment and operation of companies and to strengthen the European internal market. Among other things, the planned full digitalisation of the start-up process, the once-only principle and the openness of the legal form to established companies and group structures are viewed positively.
Filed in German · English published by the European Commission
NFU believes that the proposed EU.Inc framework fundamentally misdiagnoses Europes venture capital challenges. The core problem is not fragmented incorporation procedures or administrative burdens, but the difficulty of transplanting U.S.-style venture capital structures into Europes very different legal and institutional systems.
Comments on the insolvency law section (Chapter X) of the European Commission’s proposal for a regulation on the 28th regime corporate legal framework – ‘EU Inc.’ Lobby Register No R001459 EU Transparency Register No 52646912360-95 Contact: [name removed] Telephone: [phone removed] Telefax: [phone removed] E-mail: [email removed] Berlin, 13 May 2026 The German Banking Industry Committee is the joint committee…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
I am submitting this policy white paper as a contribution that may be useful for the ongoing legislative and policy discussion on the EU Inc. / 28th regime. The white paper could support policymakers in considering how to differentiate innovative companies from a policy formulation perspective.
Memorandum To From Date Re : : : : European Commission, DG Justice and Consumers (Company Law) Prof. Dr. Chr.M. (Christiaan) Stokkermans, Erasmus University Rotterdam 10 May 2026 Feedback on EU Inc. Proposal _______________________________________________________________ This is a response to the European Commission’s request for feedback on the Proposal for a regulation – COM(2026)321, on The 28th Regime Corporate…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Bitkom welcomed the Commission’s draft. The EU.Inc can make this much easier and faster: fully digital, within 48 hours and uniformly across the 27 Member States. The EU.Inc would, for the first time, introduce uniform rules on employee share ownership and taxation. In addition, fast, digital and low-cost processes make it easier for investors to invest in start-ups and scale-ups.
Filed in German · English published by the European Commission
The German Bar Association welcomes in principle the European Commissions initiative to establish a European company form (28th Regime or ESSU1) as part of its internal market strategy within the scope of its European legislative competence.
Why JEDI supports the 28th regime: The Joint European Disruptive Initiative (JEDI) was launched with an ambitious mission: to demonstrate that Europe can deliver major technological breakthroughs, on par with the best global innovation systems.
Purpose Evergreen Capital GmbH & Co. KGaA (PEC) welcomes the consultation on a possible 28th Regime. As a long-term investment company, PEC provides patient, purpose-aligned capital to founders and successors who want to grow resilient, mission-driven companies without forced exits. Our mission is to help innovative European firms remain independent, protect their purpose, and retain ownership in Europe.
Brussels, the 30th of September 2025 IPIFF Position Paper 28th Regime An opportunity to support the scale-up of the EU innovative sector of insect production 1. Introduction The International Platform of Insects for Food and Feed (IPIFF) is the umbrella organisation of the European insect-producing sector towards European institutions.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The EMA is the EU trade body representing electronic money issuers and alternative payment service providers. Our members include leading payments and e-commerce businesses worldwide, providing online payments, card-based products, electronic vouchers, and mobile payment instruments. Most members operate across the EU, most frequently on a cross-border basis.
1. A directive isnt enough. We need a single, uniform regime across all 27 member states no national carve-outs, no extra layers. 2. Incorporation should be fully online, under 500, and completed within two working days. In 2025, founders shouldnt be queuing for notaries. Stripe Atlas does this in the US for $500 Europe can too. 3. Hiring talent across the EU must be frictionless.
We're building trust infrastructure for AI systems in Copenhagen. We are addressing a global problem that requires Europe's best talent, but EU borders hinder our ability to access it efficiently. As an example, we are currently seeking an ML engineer with specialized expertise in content systems, graph ML, and RAG architectures. Perhaps only 50 people in Europe have this profile at the level we need them.
Cooperatives Europe welcomes the efforts to support innovative startups and scaleups in Europe. We, however, wish to highlight the following elements of the 28th regime that deserve particular attention: 1) level playing field and diversity of business 2) innovative governance features 3) access to capital Please find our full feedback in the attachment.
Background: I'm a partner at a venture capital fund at seed stage. We have done ±50 deals over the last 5 years across NL, DE, BE, SE, NO, FI, DK, UK, PL. I've also studied (European and Competition) law at Erasmus University and UCL London. Having dealt with multiple legal regimes/jurisdictions over the years, the only conclusion I can draw is that the corporate law system in EU is rather ineffective.
We would like to thank you for the opportunity to launch the European Commission’s call for evidence and public consultation on the 28th Legal framework for companies to comment on EU legal framework. Please refer to the attached file for the opinion of the Federal Chamber of Tax Advisors.
Filed in German · English published by the European Commission
The 28th-Regime must support broad-based, majority employee ownership (EO) as a business succession solution. As the UKs membership organisation for its rapidly growing EO sector the Employee Ownership Association (eoa) can provide research and evidence from our members to support this request.
Digital Invest Germany welcomes the European Commissions initiative to develop a 28th regime as the logical next step following the EU INC initiative. For Germany, as one of Europes largest innovation and financial hubs, such a regime could provide a major boost in simplifying corporate operations across the Single Market.
Response to EC Call for Evidence on the 28th Regime 30 September 2025 On behalf of Chamber of Progress – a tech industry association supporting public policies to build a more inclusive society in which all people benefit from technological advancements – I write in response to the Call for Evidence “28th regime – a single harmonized set of rules for innovative companies throughout the EU”.1 The Chamber of Progress…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
2ETthe Czech business initiative representing founders, international company owners, and investorssupports a voluntary, EU-level corporate regime (28th regime) adopted by Regulation under Article 352 TFEU. Europes startups and scaleups still navigate 27 company-law systems that fragment fundraising, slow routine actions with paper, notaries and apostilles, and nudge high-potential companies to flip abroad (often…
It is imperative that we get a harmonized regimen in place for starting tech companies in Europe and ensure they have the right circumstances to win here and win big. And the time is now! We have all the ingredients for success, talent, market, strong SMBs and corporates and most of all the willingness of the ecosystems to pull into the same direction.
EU-INC Response to the European Commission call for evidence on the 28th Regime EU corporate legal framework 30 September 2025 Executive summary and respondent profile EU-INC Background: EU-INC is a grassroots initiative led by members of the European startup and venture capital ecosystem signed by more than 18,000 signatories including founders such as Patrick Collison (Stripe), Taavet Hinrikus (Wise, Plural) and…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Circularise is a European technology company enabling secure data exchange, certification, and traceability across complex global supply chains. Our digital infrastructure supports Digital Product Passports (DPPs), certification and verification services, as well as compliance tools that help businesses meet requirements under a wide range of EU regulations, from the ESPR and Battery Regulation, to REACH and due…
BETTER FINANCE welcomes the EC consultation on an optional, digital-by-default 28th Regime framework, including the potential creation of an EU company brand. Properly designed (and as BETTER FINANCE has long advocated for listed issuers) such a regime could bridge corporate and securities law through simplification, reduce arbitrage, overcome (retail) investors home bias, enhance issuer visibility, and ultimately…
If the European Commission chooses to put forward a proposal for a 28th regime for company law rather than prioritising deeper integration of the Capital Markets Union and the Savings and Investment Union, NFU recommends that such an initiative follow the approach taken by the European Parliaments INL draft report.
This contribution proposes to reframe the 28th regime as a regulatory sandbox: a structured, EU-level environment in which firms can test innovative business models and ownership structures under common oversight. The aim is not to replace systemic reforms on energy or raw materials, but to embed evidence-based policymaking by providing credible mechanisms for experimentation.
Latvian Startup Association (Startin.LV) supports creating a single, optional EU company form via Regulation (not a directive) to end legal fragmentation that slows incorporation, complicates fundraising, and hinders cross-border growth. The regime should be digital-first, enabling fully online incorporation and governance, anchored in eIDAS and a central EU registry interoperable with national registers.
The German Notaries’ Association welcomes the European Commission’s initiatives to strengthen the EUs competitiveness and contributes its expertise on company law aspects of a possible 28th regime. However, the main obstacles for businesses lie not in company law but in access to capital, excessive bureaucracy with burdensome reporting and notification obligations, and fragmented systems of tax and insolvency law.
Filed in German · English published by the European Commission
The Philanthropy Europea Association (Philea) Legal Affairs Committee is pleased to share some comments into the EU Call for evidence for an impact Assessment on the 28th regime EU corporate legal framework. Philea fully recognises the strategic importance of technological innovation and R&D for Europes competitiveness and resilience and the importance that a 28th regime will play by enabling different types of…
Responses to the Commission’s proposal for a 28th Regime 3F Fagliglig Det Forbund and Denmark’s largest trade union thank you for the possibility of submitting a response to the consultation. We organise employees across industries, including industry, construction, transport, cleaning, hospitality, agriculture and services.
Filed in Danish · English published by the European Commission
We are a free-held carsharing company established in 2003 (to continue the service after 10 years of voluntary association activity). Since then, we have increased the number of cars tenfold and the number of customers has been more than thirty-fold. It now concerns (1) the succession of the older shareholders and (2) safeguarding the survival and growth (all previous profits have remained in the company).
Filed in German · English published by the European Commission
Index Ventures response to the calls for evidence on the 28th regime and the European Innovation Act 30 September 2025 Executive summary: Index Ventures is a European-founded venture capital firm and one of the largest backers of European startups, having supported Europe’s most ambitious founders and companies for three decades.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The 28th regime rules must recognise employee ownership as a business succession solution. There is a golden opportunity to create a pan-European business succession solution through the 28th regime. This opportunity will be missed unless Commission adoption recognise four key policy points. In summary: 1.
Startup Portugal is a nonprofit organisation, holding Public Utility Status, whose mission is to promote entrepreneurship in Portugal, in close cooperation with both public and private entities. Startup Portugal welcomes this opportunity to respond to the consultation on the creation of a 28th Regime for innovative companies.
Turning European ambition into action Europe’s innovation engine is strong: world-class research, deep entrepreneurial talent and ambitious societal goals. What we need now is a clear route from lab to large-scale deployment. While the US and China are accelerating, Europe can win on execution by simplifying cross-border rules and cutting duplication.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
I founded two startups with entities in Germany, Luxemburg, the United Kingdom and Portugal. I will be brief because I need to keep working on my company. I believe that the 28th is a massive opportunity for Europe, its member states and competitiveness. A harmonized set of rules for companies should achieve: 1. make it easy and fast to create the entity 2.
As a dynamic financial advisory company that is actively expanding and extending its business to several European Union member states, we welcome the European Commission's initiative to introduce the 28th Regime (Alternative Uniform Regime).
CECOP, the European Confederation of Industrial and Service Cooperatives, welcomes the European Commissions consultation on the 28th regime. innovative cooperatives face many challenges specifically in the startup and scaleup phases, such as lack of access to finance due to many financial tools not being adapted to the characteristics of cooperatives, lack of visibility, and small and medium cooperatives also face…
The European Indirect Employee Ownership (ESOP): a necessity and a challenge! Europe is facing, among other issues, a serious business demography problem, as millions of entrepreneurs across all Member States have already retired or will do so soon, and lack family successors to continue their business projects. This situation threatens the continuity of many enterprises.
The model of steward-owned companies separates voting from profit rights, locks in assets, and prevents businesses from being sold to the highest bidder. In doing so, it secures the companys mission for the long term and supports innovations that are not driven by short-term exit pressure.
Social Economy Europe1 (SEE) is the voice of the 4.3 million social economy enterprises and entities operating across the EU with at least 11.5 million people employed, representing 6.3% of total EU employment. Social economy is recognized as a key driver of both economic and social development that generates a turnover of EUR 912.9 billion (2021), while also mobilizing more than 53 million volunteers and over 230…
Please find attached our report for this consultation. Europe and its leadership, have the opportunity of a lifetime to do the most impressive upgrade ever done to its competitiveness. By doing so, it will take the path of growth and innovation back and will set itself to be a World leading headquarters destination.
Assonime Response to the European Commission’s Call for evidence on the 28th regime – a single harmonized set of rules for innovative companies throughout the EU 30 September 2025 Assonime welcomes the European Commission’s call for evidence and consultation on the 28th regime on company law and believes that its adoption would allow companies operating in Europe to benefit from a single, harmonised set of EU-wide…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The complete response can be found in the attached file. ---- The European Crypto Initiative (EUCI) and its members welcome the European Commissions proposal for a 28th Regimean optional, harmonised corporate legal framework aimed at supporting innovative companies, including start-ups and scale-ups, across the Single Market.
EuropeanIssuers, representing listed and capital market oriented companies across Europe, is pleased to respond to the European Commissions Call for Evidence on the 28th regime - a single harmonised set of rules for innovative companies in the EU. Please find our detailed position in the attached paper.
The CNUE is ready to contribute its expertise to improve any legislative initiative aimed at supporting EU businesses throughout their lifecycle as they grow and expand. When assessing the potential for further improvement for the business environment within the EU, it is crucial to be aware of the recent developments in EU company law and their very core.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Bundesnotarkammer welcomes and supports the European Commissions initiatives to strengthen the competitiveness of the European Union. However, with regard to a potential 28th regime, early-stage consultations showed that company law is not the problem child of European businesses.
We are the European DIGITAL SME Alliance, the largest network of ICT small and medium-sized enterprises (SMEs) in Europe representing over 45,000 businesses across the continent. Please find attached our response to the call for evidence on the 28th regime.
EIT Urban Mobility is the leading European transport innovation community, bringing together over 250 cities, startups, universities, and companies to accelerate sustainable urban mobility. As Europes largest early- and growth-stage mobility impact investor, we support startups through funding, pilots with cities, and skills development.
Please find attached the input from Cleantech for Benelux. Cleantech for Benelux is a coalition of leading cleantech startups, scaleups, investors and ecosystem enablers in the Benelux region. Together, we work with policymakers at a national, Benelux Union and EU level to create a clear and convincing path for scaling breakthrough solutions that power a sustainable future.
INESC institutes are Portugal's leading research and technology organisations, bridging academia, industry, and polytechnics. INESC fully endorse the initiative for a 28th Regime. Companies face barriers to quickly set up, comply with expensive regulations, make IP transfer deals, and exit from investments quickly and affordably.
Employee ownership (EO) has proven internationally to be an effective succession tool and ownership model. Evidence from multiple countries shows that EO boosts productivity, lowers staff turnover, strengthens resilience in crises, and contributes to inclusive growth, reduced inequality, and stronger local communities. Economically, EO acts as a counter-cyclical stabiliser and reinforces sovereignty.
Please see attached letter in support of employee stock ownership plans (ESOPs) from The ESOP Association, a non-profit organization based in Washington, DC that advocates on behalf of employee-owned companies, their employees, and professionals who serve them. Thank you.
Stellungnahme des StartupVerbands zum geplanten „28. Regime“ (Referenzmodell „EU-Inc“) Stand: 30. September 2025 Kontakt Bundesverband Deutsche Startups e.V. | Schiffbauerdamm 40 | 10117 Berlin | [email removed] www.startupverband.de | Eintrag im Lobbyregister des Deutschen Bundestages unter der Reg.Nr.: R002111 Stellungnahme des Bundesverbandes Deutsche Startups e. V. zum geplanten „28.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Read attached file for full consultation hearing: FH, The Danish Trade Union Confederation, appreciates the opportunity to give a response to this hearing on the idea of a 28th regime. While FH supports the idea of stronger competitiveness for European companies, it must never happen at the expense of the progressive social agenda, whether this be EU regulation, member state regulation or the work of trade unions.
CFE Tax Advisers Europe welcomes the opportunity to respond to the European Commissions consultation the 28th Regime, an initiative announced by European Commission President Ursula von der Leyen. CFE strongly supports the objective of creating a simplified EU-wide entity structure to facilitate the expansion of start-ups and scale-ups.
As President of the Slovenian Startup and Scaleup Association, I am writing on behalf of our members and the broader ecosystem to express full support for the 28th regime a single harmonized set of rules for innovative companies throughout the EU. We also align ourselves with the EU-INC initiative, which has outlined the need for such a framework clearly and persuasively.
The Bio-based Industries Consortium (BIC) has over 350 industry members, of which 80% are SME (including 50+ start-ups). Our members come from different sectors across the bio-based value chain. BIC has also over 250 association members, including universities and RTOs. The BIC input below follows a consultation from members who would benefit from a the 28th regime.
The EU's planned '28th regime' is Bolkestein revisited In 2004, Frits Bolkestein a Dutch liberal politician and EU commissioner for the internal market introduced a controversial piece of legislation that would forever carry his name. The Bolkestein Directive would allow companies to provide services in other EU countries under the labour conditions of their home country.
Brussels, 30th of September 2025 Consultation Statement by the European AI Forum (EAIF) on: 28th Regime: A Single Harmonized Set of Rules for Innovative Companies Throughout the EU We welcome the opportunity to contribute to the consultation by the European Commission on its upcoming proposal of a 28th Regime.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The 28th Regime is a welcome proposal that could finally give startups the EU-wide legal certainty and operational simplicity they need, much like passporting rights have done for financial services. For fintech, a unified company status could significantly reduce regulatory friction and unlock cross-border growth. One of the main barriers to financial innovation right now is Europes fragmented regulatory landscape.
Please find attached our report for this consultation. Europe and its leadership, have the opportunity of a lifetime to do the most impressive upgrade ever done to its competitiveness. By doing so, it will take the path of growth and innovation back and will set itself to be a World leading headquarters destination.
ACT | The App Association (hereafter App Association) hereby submits comments to the European Commission in response to the call for evidence on the 28th regime a single harmonized set of rules for innovative companies throughout the EU. The App Association is a policy trade association for the small business technology developer community.
The proposed 28th regime for innovative companies represents a timely and strategic initiative. A streamlined EU-wide corporate framework aiming to harmonise key aspects of a company's operations, from taxation and labour law to investment documentation, to a degree that would allow companies to incorporate in 48 hours and operate seamlessly across borders, could be transformative for the EUs innovation landscape.
On behalf of the Dutch Startup Association (DSA), we call for a single, harmonised EU company form established by regulation, not directive. Startups need clarity, speed, and uniformity to scale across the Single Market. Key points (see attachment for details): - One company form, one registry, one market digital-only, simple, and uniform.
Response from Finance Denmark (Finance Denmark is the business association for banks, mortgage institutions, asset management, securities trading and investment funds in Denmark) From a general perspective, Finance Denmark recognises the potential benefits for companies in not having to navigate 27 different national legal frameworks. A harmonised regime could reduce complexity and administrative burdens.
Memorandum To From Date Re : : : : European Commission, DG Justice and Consumers (Company Law) Prof. Dr. Christiaan Stokkermans, Erasmus University Rotterdam 29 September 2025 Call for evidence 28th Regime (EU corporate legal framework) _______________________________________________________________ 1. Introduction This is a response to the European Commission’s Call for evidence under Ref.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Thank you for the opportunity to provide comments to the European Commissions call for evidence for an impact assessment relating to a potential new optional EU-wide 28th regime company form. The Confederation of Swedish Enterprise has 60,000 member companies organized in 49 business and/or employer associations. Our comments to the European Commissions call for evidence are included in the attached letter document.
ERT wishes to contribute with initial views about a new corporate legal framework for innovative companies across the EU (the 28th regime) as a contribution to the European Commission’s public consultation. ERT believes that the creation of a 28th regime may address genuine issues faced by businesses – particularly SMEs and scale-ups – which would like to set up and expand operations across the EU Single Market.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Stanovisko k 28. režimu Hospodářská komora ČR rozumí snaze Evropské komise snížit roztříštěnost a usnadnit přeshraniční činnost podniků v EU. Z pohledu českého podnikatelského prostředí je však myšlenka zavedení dobrovolného tzv. 28. režimu vnímána spíše skepticky. Jakkoli některé dílčí aspekty 28.
Filed in Czech · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
International Personal Finance (IPF) welcomes the European Commissions initiative to introduce a 28th regime designed to streamline business operations within the Single Market. As a global financial services company specializing in consumer finance, IPF understands both the potential and the necessity of incorporating sector-specific considerations into any harmonized legal framework.
The Spanish Confederation of Social Economy Enterprises (CEPES), representing over 74,600 social economy enterprises and 2.5 million jobs in Spain, responds to the European Commissions call for evidence on the 28th Regime. In line with Social Economy Europe, CEPES stresses that the regime must embrace the full diversity of the EU business ecosystem, including social economy.
Enabling start-ups to thrive is essential to our collective European future. If we want to retain our place in the world as a great place to live and work, we need to facilitate the growth of tomorrow's global businesses. The only way to realize this, is by creating a single market for start-ups. The math is simple.
Startups and scale-ups are Europes most dynamic engines of innovation, jobs, and competitiveness. Yet, their potential is constrained by the legal fragmentation of the Single Market: 27 national company regimes create barriers to incorporation, investment, and cross-border growth.
Please find attached EuropaBio's input. (For complementary feedback and recommendations, please also refer to our consultation response to the European Innovation Act.) Biotechnology is one of the most critical technologies to Europe's autonomy, prosperity and ability to compete globally.
Comentarios para la consulta pública: “28th regime – a single harmonized set of rules for innovative companies throughout the EU”. Los objetivos del proyecto que se somete a consulta pública están alineados con las prioridades de la Unión Europea y de las distintas jurisdicciones de sus Estados miembros en el momento presente y tienen una importancia destacada en la medida en que pretenden, por una parte…
Filed in Spanish · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Single Market is one of the EUs greatest strengths, yet the lack of unified corporate law continues to hinder cross-border business activity. Fragmentation across 27 national legal systems creates complexity, limits growth, and undermines Europes global competitiveness.
Euclid Network (EN) is the European network for social enterprise (SE) intermediary organisations. This includes national associations for social entrepreneurship, incubators and accelerators - all of whom are working to support social entrepreneurs to start and scale their SEs to create positive impacts for communities across Europe.
EDFA welcomes the European Commission's initiative to develop a 28th regime as a natural progress of the EU INC initiative that could simplify corporate operations across the Single Market. As representative of approximately 3000 fintech companies from around 18 member states operating in multiple EU jurisdictions, EDFA recognizes both the potential benefits and the need for careful consideration of sector-specific…
This year, we asked 660 founders and investors about their experiences of the impact ecosystem. The results show one in two founders struggle with regulatory differences across Member States... A well-designed 28th regime is a major opportunity to tackle these issues and ensure innovative impact startups choose Europe to scale.
Stellungnahme des VID Verband Insolvenzverwalter und Sachwalter Deutschlands e.V. im Rahmen des Konsultationsverfahrens zur Folgenabschätzung der Initiative 28. Rechtsrahmen – EU-Rechtsrahmen für Unternehmen I. Einleitung Mit der vorgestellten Initiative soll nach der Beschreibung des politischen Kontextes durch die federführende GD Justiz und Verbraucher ein 28.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
ASEBIO's contribution to this consultation directly addresses the identified challenges and opportunities within the biotech sector. Our recommendations are structured around three key pillars, aligned with the broader European industry consensus, to build a resilient, competitive, and globally attractive biotech ecosystem, based on a single regulatory framework: 1) regulatory simplification and agility to…
On behalf of the European Quantum Industry Consortium (QuIC), we welcome the opportunity to provide input to the consultation on the proposed 28th Regime. Please find attached our detailed position paper, The 28th Regime and Quantum Innovation. In summary, we believe that the 28th Regime represents more than administrative simplification.
Two of the greatest threats to a business doing good is the pressure external finance places upon it and the uneven playing field that still permits the socialisation of negative externalities. To maintain a social/ecological purpose against short-term profit maximisation requires avoidance of capture by extractive forms of finance.
DIGITALEUROPE welcomes the European Commissions initiative to establish a 28th regime, a voluntary legal and administrative framework for businesses operating across the EU. As proposed in the Letta report, European startups and scaleups need a simplified and uniform legal framework that allows them to focus on growth rather than paperwork.
Employee Ownership Ireland (EOI) Statement 28th-Regime Consultation EOI supports the EOAs call to ensure the 28th-Regime recognises broad-based, majority employee ownership (EO) as a proven succession solution not merely a stock-option incentive. Why this matters in Northern Ireland NI has grown from 1 employee-ownership-trust-owned company (EOT) in 2022 to 20 EOTs in September 2025.
Our company is registered in Europe and we want to stay this way as we grow. 28th regime should exist. It's a common theme to hear from European founders that VCs want them to flip their companies to US or UK because of how familiar these jurisdictions are to the VCs. If EU Inc.
Introducing an optional 28th regime may lead to increased legal fragmentation rather than simplification. Instead of unifying the internal market, the coexistence of multiple legal regimes could result in businesses operating under different frameworks, making B2B cooperation, mergers, or partnerships even more complex.
Allied For Startups is glad to be given the opportunity to contribute to the European Commissions Call for Evidence on the 28th regime. Startups and scale-ups are Europes most dynamic engines of innovation, jobs, and competitiveness. Yet, their potential is constrained by the legal fragmentation of the Single Market: 27 national company regimes create barriers to incorporation, investment, and cross-border growth.
The challenges facing society today - from child poverty and educational inequality to job market integration and mental health - require innovative, inclusive, and long-term solutions. At Social Entrepreneurship Netzwerk Deutschland (SEND), our members address these challenges and many more every day using entrepreneurial means.
Civil Society Europe underlines how the discussions related to a 28th regime are focused on the for-profit sector, which has a well established jurisprudence and enjoys the four freedoms of the Single Market. On the other hand, the non-profit sector is not recognised at the EU-level, which creates several problems of legal certainty, difference of treatment and stability of the legal framework when non-profit…
EURATEX, representing the European textile and clothing industry, welcomes the initiative to establish a voluntary 28th regime corporate framework. We support its aim to allow companies, including innovative ones, to operate across the Single Market under a single, harmonised set of rules.
1. Employee hiring rules It should be possible to employ talent anywhere within the EU without being forced to create a separate legal entity in each member state. Companies should also not be pushed into relying on external Employer of Record (EOR) providers just to navigate these fragmented rules.
The European Tax Adviser Federation (ETAF) welcomes the reflection on a potential 28th regime as an opportunity to simplify rules and reduce fragmentation, sharing the underlying concerns about EU competitiveness.
The bureaucratic procedures for creating a limited liability company (SL) in Spain are very costly and hinder the agile creation of a start-up. The minimum share capital is 3,000. Additionally, each time I set up a company, the notary and registry procedures (to ensure the chosen company name is not already in use) incur significant extra costs and take a long time, at least a month.
As an association dedicated to driving innovation and digital transformation in the real estate industry by uniting start-ups and corporate leaders across the sector, we at Proptech Lithuania strongly support the European Commission's ambition to establish a truly pan-European 28th regime a single, harmonised legal framework enabling innovative companies, start-ups and scale-ups to incorporate once, operate…
The red tape involved in setting up a SL in Spain is very costly and prevents the creation of a fast start-up. The minimum share capital is 3000. Moreover, every time I set up a company, the notarial and registration formalities (to verify that the name to be given to the company is not in use) have a significant overcharge and take a long time, at least one month.
Filed in Spanish · English published by the European Commission
The 28th regime must address two distinct challenges. First, innovative firms need an EU-wide stock-option regime to attract and retain talent. Second, millions of SMEs need an employee-ownership pathway for succession. Create two tracks: Startup/Options and Succession/EO. Why two tracks? Stock options ownership. Options rely on liquidity (IPO/trade sale). Works mainly for tech-centric firms.
ICISA is pleased to have the opportunity to contribute to discussions on ways to support innovation and growth among Start-ups and Scale-ups. As a sector which facilitates trade and investment through trade credit insurance, credit and political risk insurance, and surety bonds, our members support this important segment in their efforts to grow and trade throughout the EU and beyond.
Response based on an online expert workshop (see annex). We support the proposed modular approach which should consist of a company law 'backbone' open to all firms, with specific modules for areas like insolvency law, labour law, tax law and alternative ownership structures such as steward ownership and ESOPs. Harmonisation in these areas tends to be complex but can be supported by a strong digital foundation.
The Global Legal Entity Identifier Foundation (GLEIF) welcomes the European Commissions initiative to establish a new 28th Regime to support the establishment and growth of businesses operating in the Single market. For context, GLEIF has been set up to manage the ISO 17442 Legal Entity Identifier (LEI) as a publicly available means of identification accessible to all legal entities globally.
Recent developments highlighted how the fragmentation of the Single Market hampers companies growth in the EU. It negatively impacts entrepreneurs ambitions, investors willingness to finance European companies and ultimately EU productivity. The initiative of a 28th Regime, building on former initiative such as the European Company Statute, could bring solutions and ease companies growth cross-border.
We welcome the European Commissions initiative to create a 28th regime to enhance the competitiveness of the European economy. The 28th regime is intended to simplify applicable rules and reduce the cost of failure by addressing specific aspects within relevant areas of law, including insolvency, labour and tax law.
The DCF is now grasping the opportunity to position itself on the draft “28th regime”, announced last January as part of the Commission’s “Competitiveness Compass” roadmap. First of all, at the time, this draft 28th regime concerns only certain subjects of company law, which is reserved for innovative companies only.
Filed in French · English published by the European Commission
1. A directive is a "cute" step forward but let's get real, what we need is one system, standard for all with a new regime that must be implemented uniformly across all 27 member states with no room open to national interpretation. 2. Incorporating a business should require less than 500 EUR and be done completely online with the registration complete in less than 2 business days.
A harmonized 28th Regime for innovative companies is a forward-looking idea and an urgent and necessary step to unlock the full potential of the European Single Market. With a 28th regime Europe strengthens it's way to economic souvereignity and resilience and becomes an attractive headquater for high-tech ventures and capital.
Please find attached Stripe's complete response to the Open Public Consultation on the 28th regime. We have provided a comprehensive position paper that addresses the key aspects of the consultation and outlines our recommendations based on our engagements with European founders and our experience with digital company formation through Stripe Atlas.
eQualitie (eQ) supports the "28th Regime" proposal and welcomes the Commissions initiative to streamline cross-border operations for European Start-Ups and Scale-Ups. The current fragmentation of the EU market creates significant barriers for SMEs, particularly in the tech sector, by increasing legal complexities and costs.
En tant qu'éditeur juridique français et européen, acteur créateur de doctrine juridique européenne et partie prenante dans la fabrique du droit continental, Lefebvre Sarrut est absolument ravi que la préconisation de 28e régime du rapport Letta fasse l'objet d'un projet de directive, et permette ce faisant de faire émerger un Code européen du droit des affaires.
Ladies and gentlemen, on behalf of the National Chamber of Legal Advisers based in Warsaw, I hereby present my position on the initiative under consideration concerning the creation of the so-called The 28th company law regime, i.e.
Filed in Polish · English published by the European Commission
Feedback for the 28th Regime Public Consultation Enabling Steward-Ownership As an entrepreneur working with Keytoe (www.keytoe.nl ), I strongly encourage the European Commission to ensure that the upcoming 28th Regime explicitly enables steward ownership as a viable, reliable, and scalable legal model across the EU.
Summary Consultation on the 28th Regime: Europes startups and scaleups are key to innovation, competitiveness, and job creation, yet too many are forced to flip abroad due to fragmented rules, costly procedures, and limited access to talent and capital. The 28th Regime is a once-in-a-generation opportunity to create one company form, one registry, one market. 1.
We are a small company in the musical instruments industry, we produce and develop our innovative products in Germany and deliver worldwide. As the founder and owner of the company (and intellectual property rights), I would like to see a legal form in which I can transfer the company to my employees in the sense of steward ownership.
Filed in German · English published by the European Commission
Dear all, The draft report by MEP René Repasi sets out recommendations for harmonising EU rules on employee ownership. Yet a key debate is still unresolved: which model Europe should adopt, and what ESOP truly means. ESOPs are not the same as stock options.
Subject: Urgent Call for Tax Exemption on Energy Community Savings Transfers To: The European Commission Re: Tax-Free Power Savings Transfers for Energy Community Members Energy communities are rapidly expanding across Europe, delivering environmental, financial, and social benefits at scale.
European policymakers have long debated about the idea of harmonising private law across the EU to ensure smoother cross-border operations for businesses. Yet, the difficulty with finding common ground on sensitive issues including taxation and labour laws has prevented progress in the past.
Axeptio is a French start-up founded in 2017, specialising in Consent Management Platform interfaces. Since then, the company has been developed in Europe and internationally through several external growth operations. In 2021 and 2022 Axeptio raised EUR 5.1 million. Axeptio welcomed the European Commission’s initiative to develop a 28th regime.
Filed in French · English published by the European Commission
Salaried employment enables employees to become shareholders of their company, making it a strategic tool in succession. In the context of a business transfer, in particular for a manager preparing for departure or for a family SME, it promotes the continuity and stability of the capital of European SMEs.
Filed in French · English published by the European Commission
GÉANT welcomes the European Commissions initiative on the 28th regime for an EU corporate legal framework as a step towards reducing legal fragmentation and simplifying cross-border operations within the Single Market.
BAND advocates and supports a single legal form for startups across the entire European Union. A single legal form would facilitate cross-border investments, make shareholdings more transparent, and strengthen the entire ecosystem. Currently, around 60% of all global scale-ups are based in North America, compared to only 8% in the EU (source: European Commission). We need to make the ecosystem more attractive.
eBay welcomes the opportunity to respond to this consultation on the 28th Regime. As a global online marketplace, we connect millions of buyers and sellers across the world, enabling small and medium-sized enterprises (SMEs) to reach new customers and grow across borders. We believe the 28th Regime can play a critical role in creating a more coherent, predictable and SME-friendly regulatory environment.
Einride welcomes the intent of the 28th Regime to reduce administrative burden for fast-growing companies. However, for this regime to have a meaningful impact, we stress the importance of it to be ambitious. Einride would also like to submit the following specific inputs on the proposal's scope and implications.
The core design should be narrow, digital-first, and focused strictly on company law. Europe needs one company form, one registry, one market: a modern EU company type with harmonized rules on formation, governance, share classes, pre-emption, information rights, and transparent cap tables.
Our research on thousands of Italian venture-capital-backed startups and some of the most important UK VC-financed startups shows that European practice is already strongly shaped by US contractual models. The new Italian "società a responsabilità limitata" has been rather successfully adapted to meet VC needs.
NATIONAL ACADEMY OF LEGAL SCIENCES OF UKRAINE SCIENTIFIC AND RESEARCH INSTITUTE OF PROVIDING LEGAL FRAMEWORK FOR THE INNOVATIVE DEVELOPMENT 80, Chernyshevska str., Kharkiv, 61002, Ukraine e - m a i I : dLpZLr@emAI. .l',lb 1 02 9911 phone: [phone removed] site: np[palqg.Ua of 29.09.2025 Comments and suggestions to the Call for evidence for an impact assessment - Ares(2025)5502931 l.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
ROStartup proposes a set of concrete measures that can strengthen the design and rollout of the 28th regime. These recommendationscovering a one-stop digital portal, capacity building, awareness campaigns, monitoring and feedback mechanisms, and integration with national strategies, including the recognition of startups as a distinct entityare rooted in evidence from Romanias ecosystem and aligned with European best…
EIP c/o PLUTA Rechtsanwalts GmbH [address removed] Feedback of the European insolvency practitioners’ organisations (EIP) on the EU Commission’s call for evidence for an impact assessment regarding the initiative 28th regime – EU corporate legal framework President of EIP c/o PLUTA Rechtsanwalts GmbH [address removed] Deutschland P: [phone removed] M: [phone removed] e-mail: [email removed] [email removed] Riga…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
ARP TFI S.A., as manager of Poland's Green Fund (PZF), strongly supports the EU's 28th regime initiative as a critical step toward addressing Europe's innovation financing gap and capital market fragmentation. The 28th regime represents an essential opportunity to create a unified, digital-first corporate framework that can streamline cross-border investments and reduce administrative barriers for innovative…
As the founder and long-term CEO of an innovative company, we are promoting new business models in the form of steward ownership to improve the legal framework for business succession. We see this as a matter of urgency on the part of the political community. Klippel GmbH was founded in Dresden almost 30 years ago (www.klippel.de).
Filed in German · English published by the European Commission
CPME (French Confederation of SMEs) welcomes the opportunity to respond to the European Commissions public consultation and is pleased to submit its contribution. In essence, CPME supports the proposal to establish an optional 28th regime for companies, provided that several essential conditions are met.
On behalf of the Slovenian Technology Forum (STF) we would like to express our support in simplifying any EU rules that will finally make the EU more competitive and attractive for companies and investors to get incorporated or stay here and do business across Europe. We would like to see a real progress in the area of the EU capital market union.
EBN, facilitating a pan-European network of over 175 quality-certified European Business and Innovation Centres (EU|BICs) and associate Entrepreneurship Support Organisation (ESO) members who support over 30,000 startups and SMEs annually, welcomes the Commission's commitment to the 28th Regime, a proposal driven by the January 2025 Competitiveness Compass and the March 2025 European Council conclusions.
Key Performance Indicators (KPIs) for Scalability of Energy Communities We have monitored two critical Key Performance Indicators (KPIs) to assess the scalability of energy communities where we operated. Energy communities bring environmental, financial and social benefits to a large amount of people and organizations and are the main source of distributed wealth and innovation in Europe from now until at least…
Can we please setup a framework that allows all European domains (.gr, .it, .de, .fr, etc.) to be purchased from each registrar in Europe without having fragmentation and being us forced to have 10 different registrars (those who sell the domain and its ending, e.g. landlele.gr) for 10 different domain endings (landlele.fr, landlele.gr, landlele.de)?
My feedback is based on more than a decade of studying employee ownership (EO) practices around the world. Research consistently shows that EO is a highly successful business ownership model with wide-ranging positive externalities. For businesses, it brings higher productivity, lower employee turnover, and greater resilience in times of crisis.
EIT Culture & Creativity welcomes the Commissions proposal for a 28th regime as an optional, pan-EU legal framework allowing innovative companies to operate seamlessly across Member States under unified corporate, insolvency, labor, and tax rules.
MUST & Partners is pleased to contribute to this consultation on behalf of One Market One Law, an international non-profit association under Belgian law that is currently in the process of being established. The associations purpose is to advance the unification of business law in the EU through codification and the development of a European Business Code, thereby strengthening the Single Market, facilitating…
The 28th Company Law Regime 1. This paper (the “Paper”) presents the feedback of the Belgian Centre of Company Law (“BCCL”)1 on the ideas for a 28th Company Law Regime, as part of the Consultation which the Commission has organized on this topic.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The German Trade Union Confederation (DGB) firmly rejects the proposal for a 28th regime. The new European legal framework would provide companies with additional tools to weaken co-determination structures and circumvent national labor law. As a consequence, it would significantly undermine the autonomy of the social partners and the rights of workers and their representatives.
Catalyst is a Berlin-based SME and higher education institute founded in 2013, employing around 70 staff members. Over the past decade, Catalyst has established itself as a dynamic centre for creative education, bringing together a truly international community of creatives and students from more than 70 countries.
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.