ARP TFI S.A.

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…

Europe faces a 350-800 billion annual investment gap that cannot be addressed through grants and subsidies. The European Innovation Act can strengthen competitiveness by fundamentally reforming how Europe mobilizes and deploys capital for innovation. These recommendations align with Capital Markets Union objectives and address systemic barriers to innovation financing. Eight Key Recommendations: 1.

Poland's grid infrastructure faces challenges requiring targeted EU policy reforms and support: 40% of infrastructure exceeds 40 years, 40 bln EUR is needed by 2040 for modernization with approx. 875,861 kilometers of power lines while integrating 82 GW of renewable capacity by 2030a dual transformation creating compound investment needs that current EU mechanisms inadequately address eg.

Recommendations for EU Electrification Action Plan Accelerating cost-effective electrification in coal-dependent regions such as those in Poland requires coordinated infrastructure development. Poland's electrification faces barriers requiring targeted EU policy reforms: aging grid infrastructure (40% exceeds 40 years), 40 billion modernization needs by 2040, and integration of 82 GW renewable capacity by 2030.

Drawing primarily on the necessity of efficiency in spending and the critical need to avoid disrupting market mechanisms, we submit the following feedback regarding the performance structure of the post-2027 MFF, specifically emphasizing the role of the budget in boosting competitiveness. I.