Allied For Startups

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.

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.

Public procurement is one of the EUs most powerful demand-side policy tools. For startups and scaleups, it can determine whether innovative solutions reach deployment and scale within the Single Market or are forced to prioritise non-European markets. Despite successive reforms, public procurement remains difficult to access in practice for many innovative companies, particularly smaller and fast-growing ones.

Allied For Startups (AFS) supports the objectives underlying the European Commissions proposed Digital Networks Act (DNA), notably strengthening Europes competitiveness, accelerating digital transformation, improving connectivity, reducing regulatory fragmentation, and promoting investment in digital infrastructure.

Allied For Startups (AFS) supports making the EU's existing copyright framework work better for both creativity and innovation, rather than introducing new regulatory layers. The CDSM Directive and AI Act already provide the foundations for a balanced approach; the priority should now be legal certainty, harmonised implementation, and reducing fragmentation across Member States.

Allied For Startups (AFS) welcomes the opportunity to contribute to the Call for Evidence on the European Innovation Act (EIA). Startups and scaleups are Europes most dynamic engines of innovation, yet their growth is constrained by fragmentation, burdensome regulation, and barriers to scale. The EIA is a unique chance to build a genuine single market for innovation.

The existing digital infrastructure in Europe has fostered a vibrant and competitive environment for innovation and startups and the current regulatory framework supports a diverse range of digital innovations. Furthermore, the present system has proven effective in creating a level playing field where startups can compete with established players without facing undue barriers.

Women-led startups in Europe receive only 2 to 3% of venture capital, with mixed teams receiving 10 to 15%. This gap widens at growth stages, limiting scale, exits and capital recycling. Evidence suggests structural bias in networks, due diligence and investment committees, rather than performance differences.

Allied for Startups welcomes the opportunity to give feedback on: “Digital Services Act – ex ante regulatory instrument of very large online platforms acting as gatekeepers”. Startups are the ultimate competitors of our economies. They are born out of the very essence of competitive thought - they aim to challenge any established players in any given markets - digital or analog.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Allied for Startups welcomes the opportunity to provide feedback to the Inception Impact Assessment concerning the ex ante regulatory instrument of the Digital Services Act package. Please find attached our feedback and do not hesitate to reach out if you have questions. Allied for Startups is a worldwide network of over 40 advocacy organisations focused on improving the policy environment for startups.

Allied For Startups (AFS) welcomes the opportunity to contribute to the Call for Evidence on the EU Quantum Act and strongly supports the ambition to position Europe as a global leader in quantum technologies. Europe has a rare and time-bound opportunity not merely to participate in the global quantum race, but to set its direction by building companies that define markets, establish standards, and anchor long-term…

The EUs digital framework has grown complex, with multiple laws, such as the AI Act, Data Act, DSA, DMA and NIS2, creating overlapping compliance burdens for startups and scale-ups. The Digital Fitness Check should assess cumulative impacts, legal coherence, and innovation risks, prioritising consolidation over new legislation.

Startups​ ​on​ ​Fairness​ ​in​ ​platform-to-business​ ​relations November​ ​21,​ ​2017 Dear​ ​Commissioner​ ​Gabriel, Startups recognise platforms as the leading solution in the digital economy. Finally startups can spend time doing what they do best without having to be part-accountants, salesmen, IT-experts, web-developers or part-whatever.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Allied for Startups welcomes the evaluation of the Shareholder Rights Directive as a key opportunity to align Europes corporate governance framework with the realities of startups and scale-ups operating across the Single Market.

European startups continue to face structural challenges when raising growth capital within the Union. Compared with competing ecosystems, companies often struggle to secure large domestic funding rounds, face incentives to relocate their holding structures to access capital, and encounter longer and less predictable fundraising timelines.

The revision of the EU Merger Guidelines is a unique chance to align competition policy with Europes innovation and competitiveness agenda. Startups, central to building global tech leaders, depend on predictable M&A pathways to scale, recycle capital, and attract investment. Yet Europes shallow exit markets and unpredictable merger control risk pushing founders abroad, draining jobs and IP.