European cross-border associations

The Association Civic Alliance Latvia (CAL) supports the establishment of a common European framework for cross-border associations. The European Union's Social Economy Action Plan identifies non-profit organisations, including associations and foundations, as key players in the social economy.

Ladies and gentlemen, the Bundesrechtsanwaltskammer (Bundesrechtsanwaltskammer – BRAK) is grateful for the possibility of taking a position on the proposal for a legislative initiative on cross-border activities of associations with the attached opinion.

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Since its creation in 1989 and as per its mandate and missions, CEDAG as membership-based organisation has built a longstanding expertise and rationale in favour of legislative initiatives aiming at adopting a statute for European non-profit organisations (NPOs).

As the cross-sector employers’ federation representing non-profit associations (ASBL) in Wallonia and Fédération Wallonia-Bruxelles (French Community), UNIPSO follows with great interest the European Commission’s (EC) proposal for a legislative initiative on the cross-border activities of associations within the European Union (EU).

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Opinion on the European Commissions legislative proposal on European Cross-Border Associations (ECBA) European House Budapest, a pro-European Hungarian civil society organisation welcomes the European Commissions proposal for a Directive on European Cross-Border Associations (ECBA).

Associations are the most common form of social economy entities in Europe, and it is estimated that there are more than 3.8 million of them . The European Fundraising Association (EFA) is a network of national representative organisations, working to strengthen and develop fundraising and philanthropy across 19 European States.

Associations represent the most common form of social economy entities in Europe and their number is estimated at over 3.8 million. Generosity France is the professional union of general interest organisations, which calls on the generosity of the public. It represents 144 organisations among the largest French associations and foundations invested in all areas of general interest.

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We as Philea clearly welcome the proposed Directive for the establishment of a European Cross-Border Association (ECBA) as an important step in the direction of creating a level playing field for the public-benefit sector and for strengthening civil society space in Europe.

While the EC proposal for a Directive on ECBAs may not seem directly applicable to the operations of the Red Cross, the Red Cross EU Office welcomes the proposal, emphasizing that it represents the first formal recognition of non-profit associations within the EU.

ENSIE has been following with great interest the process of the establishment of a European Cross-Border Association directive, as an important step for the creation of the Single Market for the Public Good. In particular, ENSIE is supporting the broad coalition of civil society and non-profit organisations contributing to the legislative process of the approval of the ECBA Directive with the contribution titled EC…

The proposal is considered to fill a gap in European law, which is now not negligible. We therefore hope that this project will be carried out as soon as possible and that the possibility for consumer associations to carry out cross-border activities will in any event be allowed and strengthened.

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We, Effectief Geven and Giving What We Can, are non-profit organisations working in various Member States of the European Union to promote the practice of Effective Giving, roughly defined as donating to charities that have been identified as being the most impactful per marginal euro donated.

The German Tax Consultants’ Association (DStV) welcomes the current Commission proposal for a Directive on European cross-border associations 2023/0315 (COD). On the one hand, the proposed measures strengthen the EU’s internal market by making cross-border associations more involved in social and economic processes.

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AIM, CSE, PHILEA, SEE, SSE and CEDAG welcome the proposed Directive for the establishment of a European Cross-Border Association and consider as it can pave the way for future similar legal initiatives for other non-profit organisations such as foundations and mutual benefit societies.

If the EU introduces a new legal form for transnational associations, why do these have to be registered at the national level and not in a common European register for transnational associations? One single point of contact for all transnational associations across the EU should be created to facilitate the work of such organisations.

EC Proposal for a Directive on European Cross-Border Associations (COM(2023) 516 final), Brussels, 05.09.23 Reply by SSE to the EC Call for Evidence (28 February 2024) Social Services Europe (SSE) is a network of eight European umbrella organisations comprising Caritas Europa, CEDAG, E.A.N., EASPD, EPR, Eurodiaconia, FEANTSA and the Red Cross EU Office [N.B.: The Red Cross EU Office is not signing this SSE reply]…

Opinion ESS FRANCE ON THE PROPOSAL OF DIRECTIVE TO FACILITY THE ACTIVITES OF TRANSFRONTALIERES ASSOCIATIONS in the European Union ESS France or Chambre Française de l’Economie Sociale et Solidaire is the reference voice of the ESS. It represents and bears the interests of ESS companies and organisations.

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Samaritan International is a European network of 21 non-profit civil society organisations from 19 European countries. We are politically and religiously unaffiliated and cooperate across borders within our network, on a regional, bilateral, and multilateral basis.

Recharging Advocacy for Rights in Europe a solidarity alliance of over 50 human rights defenders from 19 EU countries welcomes the European Commissions proposal for a Directive on European Cross-Border Associations. CSOs that operate in multiple EU member states could create one legal organisation across their home and host countries.

Please find attached the German and English version of our Position Paper. The Bundesarbeitsgemeinschaft der Freien Wohlfahrtspflege (BAGFW) is commenting on the European Commission’s draft ECBA Directive of 5 September 2023. Germany has a strong tradition of non-profit social services through the six associations of charitable welfare (FW).

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From Eixo Atlantique, we believe that the proposal is generally a very positive initiative and that, in our view, it will be highly beneficial for the internal market and cross-border activities, and is therefore indirectly a driving force for cross-border territories.

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As an integral part of the European Commission (EC) Social Economy Action Plan and of the Social Economy Package, along with the Council Recommendation on social economy framework conditions, Social Economy Europe (SEE) welcomes the ECs proposal for a Directive on European cross-border associations in its aim to support cross-border activities of non-profit associations and organisations by creating an additional…

(1) We wholeheartedly welcome the initiative. By removing legal and administrative barriers, EU-wide civic engagement will be empowered and a further Europeanisation of civil society will be stimulated. The directive opens the door to a long overdue common European legal framework. (2) Associations, a significant part of civil society, will be able to make use of the four European freedoms.

LO has not had the opportunity to examine the proposal as a whole and confines its comments to the following. The proposal excludes trade unions from the scope of the regulation. Lo agrees with this. The continued existence of the derogation should be closely monitored at the hearing.

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We did not manage to understand what exactly the EC wants to do in relation to NGOs and their cross-border activities. We understand that in 2023, the European political factor came to understand that NGOs play an important role in civil society and that the different legislation in the EU member states prevents these NGOs from carrying out their cross-border activities.

CEDAG - The European Council for Non-profit Organizations (Comité européen des associations dintérêt général) had been established more than 30 years ago as a network to provide a voice for non-profit organisations at a European level.

>>Challenges: GISAD welcomes the EU Commission's initiative to strengthen the cross-border activities of associations. As digitalisation of society is advancing strongly, legislation should be timely and proactive in preserving digital democracy. Democracy is significantly threatened by the current digital concepts depicted in platforms.

The Bucharest Chamber of Commerce and Industry has a direct interest in regards to Proposal for a legislative initiative on cross-border activities of associations: Single Market, as this concerns its very own legal statute and also is whitin the purpose of its activities.

The European Federation of Allergy and Airways Diseases Patients Associations (EFA) is supportive of creating a new legal form for associations allowing for recognition in all Member States, as long as it is developed in close consultation with a diverse community of Non-Profit Organisations (NPOs) across the EU to ensure benefits and avoid unforeseen negative impacts.

European Alternatives welcomes the proposal for a legislative initiative on the cross-border activities of associations. Our practical experience over 15 years of organising activities throughout the European Union has demonstrated how complicated a lack of effective access to all aspects of the single market is for associations.

Lungs Europe, a Brussels-based collaboration between the European Lung Foundation (ELF) and the European Respiratory Society (ERS), welcomes the EU initiative to introduce a legislation on cross-border activities of non-profit organisations (NPOs) and associations.

Contribution of European House Budapest to the public consultation initiated by the European Commission for a legislative initiative on cross-border activities of associations European House, a pro-European Hungarian civil society organisation established in 1990 welcomes this timely initiative of the EC to remove barriers associations face today in carrying out cross-border activities on an equal footing in the…

The National Council of Commercial Court Registrars (CNGTC) welcomes the European Commission’s initiative to enable associations to operate across borders without barriers in the single markets and thus promote fundamental rights, in particular the non-profit sector.

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EFA - European Fundraising Association is a network of national fundraising organisations, working to strengthen and develop fundraising across Europe. Together we represent the European fundraising community with one voice, one collective body and one shared goal of facilitating better fundraising.

Contribution of Giva Sverige to The European Commission consultation Single market proposal for a legislative initiative on cross-border activities for associations Introduction The resolution contains two legislative proposals 1. A regulation to create the legal form of European association and 2. a directive harmonising common minimum standards for NPOs.

Since it was set up in 1992, the Association Movement has brought the voice of the associations, supports them and fosters associative dynamics in the service of general interest. The Association Movement, a member of the European Civic Forum and a member of Social Economy Europe as a member of the ESS-France, represents almost half of the associations in France through its members.

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The SOS Group, a group which is the leader of social entrepreneurship in Europe, brings together 22.000 employees in 650 associations and social enterprises in 40 countries – most of them in the EU, France and Romania. Our institutions and services combat, act and innovate for the benefit of people in vulnerable situations, future generations and territories.

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Polish Donors Forum fully supports the opinion of PHILEA. Societal challenges, that we face, require cross-border actions and solidarity across borders. The flow of funding for Ukraine via Polish NGOs showed clearly that such activities are very complicated, full of administrative and fiscal obstacles. We are very pleased to see that the European Commission is aware of this problem and proposed ambitious solutions.

The Commission’s proposal can be to give the non-profit sector and the social and solidarity economy a strong ambition at European level. This initiative could be the starting point for a truly European philanthropy, based on a shared vision, identity and objective across all Member States.

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Civil society engagement plays an important role in a modern, democratic society. Be it in the field of charitable care, sport and culture or advocacy, as advocacy and watchdog organisations. Associations and foundations can play an important role in addressing current challenges. But to do so, they need a legal framework that strengthens their work and protects them across borders and at national level.

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The European Patients Forum (EPF) is an umbrella organisation of patient organisations across Europe and across disease-areas. Our 78 members include disease-specific patient groups active at EU level and national coalitions of patients.

The TCO, a Swedish trade union union with 12 member federations with approximately 1,2 million members, would like to make the following comments in this consultation on proposals for legislative initiatives on cross-border activities of associations: Similarly to the European Parliament resolution of 17 February 2022 with recommendations to the Commission on a statute for European cross-border associations and…

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The philanthropy sector is pleased to contribute to this consultation and we would like to stress our key ask to work towards a European Single Market for Public Good and an enabling environment for foundations as well as associations with the envisaged legislative approach. The philanthropy sector is part of civil society and a key contributor to a more equitable and sustainable world.

Harmonized legislation concerning NGOs and EU minimum standards are essential to protect civil society from authoritarian threats. The bare existence of laws that can suppress civil society has a serious chilling effect on NGOs, especially smaller ones. EU level protection can safeguard civil society and help the remaining democratic voices in authoritarian regimes, such as Hungary.

ASOCIACIÓN ESPAÑOLA DE FUNDACIONES (AEF) is pleased to contribute to this consultation, in line with the contribution of Philea and other umbrella and individual organisations of the philanthropy sector. This consultation give us the opportunity to stress our key ask to work towards a European Single Market for Public Good and an enabling environment for foundations as well as associations, according to our European…

The Maecenata Foundation is an independent think tank focused on civil society and philanthropy. The Foundation includes the Maecenata Institute of Philanthropy and Civil Society, a non-university research institute, and the Tocqueville Forum, a network, policy and research support agency. The Foundation is also the German partner in the Transnational Giving Europe network.

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BCSDN welcomes this initiative and believes it is vital that all European CSOs, including those from the Enlargement region, have a say in this process. While this will not yet affect CSOs from the Enlargement countries, considering they are expected to eventually join the EU, civil society from the region must already take a more systematic role in the EUs future policy-making processes.

Social Services Europe (SSE) is a network of eight European umbrella organisations comprising Caritas Europa, the European Council for Non-Profit Organisations (CEDAG), the European Ageing Network (E.A.N.), the European Association of Service Providers for Persons with Disabilities (EASPD), the European Platform for Rehabilitation (EPR), Eurodiaconia, the European Federation of National Organisations Working with…

Social Economy Europe (SEE) welcomed the adoption by the European Parliament (EP) of its ambitious Resolution of 17 February 2022 with recommendations to the Commission on a statute for European cross-border associations and non-profit organisations. SEE also welcomes the European Commission (EC) for its commitment to respond to this EP resolution with a legislative act.

AIM, the International Association of Mutual Benefit Societies (AIM,) is an international umbrella organisation of federations of health mutuals and health insurance bodies counting with 52 members from 28 countries around Europe, Latin America and Africa and the Middle East.

FAIR welcomes the Commissions initiative, following the Parliaments legislative initiative resolution. Our association firmly believes that in order to promote the development of an EU non-profit sector (specific objective 4), and in particular when it comes to helping them access adapted financing, cooperation and inter-operability between national frameworks is needed.

Philea is pleased to contribute to this consultation and we would like to stress our key ask to work towards a European Single Market for Public Good and an enabling environment for foundations as well as associations with the envisaged legislative approach. The philanthropy sector is part of civil society and a key contributor to a more equitable and sustainable world.

The Biomedical Alliance in Europe (BioMed Alliance) welcomes the efforts of the European Commission to ensure a full single market freedoms for associations, simplifying their cross-EU activities and promoting their fundamental rights.

Euclid Network (EN) welcomes this call for feedback launched by the Commission. EN brings together national social enterprise support organisations and topic specific associations. EN itself is an association undertaking European activities, interacting with organisations in European countries who possess varied legal forms.

Urgent action is needed on the taxation of donations in kind. In-kind donations are an important lever to provide everyday consumer goods to those in need across the EU, as well as to non-profit organisations with products for their operation.

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The Social Economy Action Plan adopted on 09/12/2022 recognises the potential of the social economy to foster democratic participation and the creation of an economy that works for all. The forthcoming Council recommendations on developing the framework conditions for the social economy should make it possible to harmonise the political and legal frameworks of the various social economy families in which NPOs…

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The Deutscher Steuerberaterverband e.V. (DStV) welcomes the introduction of an appropriate European rulebook that strengthens the legal position of cross-border associations in the EU internal market. As a result, the different legal and administrative requirements in the EU Member States should be adapted and unjustified restrictions removed.

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The Association of Finnish Foundations is pleased to contribute to this important consultation. We would like to emphasize the importance of a European Single Market for Public Good and an enabling environment for foundations as well as associations with the envisaged legislative approach.

GÉANT is a Membership Association, legally headquartered in the Netherlands as a Dutch Association or Vereniging. We have 38 Members and 1 Representative Member. There is one representative per EU Member State plus representatives of States in wider Europe. The association is co-funded by the Membership and the European Commission via project funding.

The adoption of the proposal to facilitate the cross-border activities within the EU is, in principle, welcome, particularly given the failure of many Member States to ratify Council of Europe Convention No. 124.

Kellen is one of the worlds largest providers of management and services to ‎associations and trade organizations. Kellen serves some of the leading ‎global organizations from offices across Asia, Europe and the United States, ‎along with strategic representation in the Middle East and South America.

Full opinion in annex and here: https://bit.ly/3gNw2k4 Germany has a long tradition of non-profit providers of social services. The six associations of charitable welfare services (FW) are the largest providers of non-profit social services in Germany, employing 1.9 million people and around 3 million volunteers.

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Europe is facing an unprecedented amount of crises: war on the European continent, climate change, inflation, the energy transition, the undermining of democracy and the rule of law, increasing inequality, loss of biodiversity, migration and so forth. European institutions and Member States cannot tackle these challenges by themselves.

Wikimedia Deutschland welcomes the proposal of a legislative initiative on cross-border activities of associations. As a part of Wikimedia movement comprising many entities (affiliates) across the EU we have first hand-experience with cross-border cooperation contributing to access to free knowledge and advocating for freedom of expression and access to information.

ESTA, the European Cash Management Companies’ Association is pleased to respond to the consultation on a legislative proposal on cross-border activities of international associations. ESTA would support a European status of associations. The focus of our response is on the difficulties to register locally to VAT for our annual conferences, which take place each year in a different EU Member States.

>>Challenges: GISAD welcomes the EU Commission's initiative to promote the cross-border activities of associations. However, GISAD rejects the principle of limiting the activity to the EU territory. In the context of digital transformations, geographical borders will play an increasingly minor role. What remains are the borders of language areas and values.

Just as some business associations operate across the 27 member states, some operate worldwide. Any legislation introduced must not curtail the operation of bodies which represent organisations that operate beyond and within EU boundaries. It is important that industrial bodies can represent their members inside the EU to legislative and regulatory bodies outside the EU where required.

The Council of Europe has a recommendation containing the conditions that associations should fulfil. That text seems to me to be capable of serving as guidelines. National legislation should not require associations to fulfil obligations similar to those required of companies. It should not be forgotten that we are usually volunteering.

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The Insurance Ombudsman, as a recognised consumer conciliation body, welcomes the proposal for a legislative initiative on cross-border activities of associations. For consumers, the Versicherungsombudsmann e.V.

Filed in German · English published by the European Commission