NGO · Finland
not in the EU Transparency RegisterThis organization files on consultations without a register number, so its record here is built from its filings alone. Register facts (staff, costs, accreditations) are not available for it.
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
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Association of Finnish Cities and Municipalities filed 12 positions between 5 Mar 2025 and 7 Oct 2026, across 9 of the 665 legislative files tracked here, attaching a full position paper 11 times.
Feedback 10.3.2026 94/03.01.00/2026 Jaana Jormanainen, Niina Erkkilä Feedback to the European Commission’s Proposal on the Data Legislation in the Digital Omnibus package The Association of Finnish Cities and Municipalities (AFCM) is a national organisation with all 308 municipalities and cities in Finland as its members.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Feedback 10.3.2026 93/03.01.00/2026 Niina Erkkilä, Jaana Jormanainen Feedback to the European Commission’s Proposal on the AI Act in the Digital Omnibus package The Association of Finnish Cities and Municipalities (AFCM) is a national organisation with all 308 municipalities and cities in Finland as its members.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
In defining the objectives of simplification, public service providers, such as municipalities and cities, should be more strongly visible. On the whole, public sector is spoken of as a source of data, but it is not recognized in other contexts. The local level should be taken into account when considering, among other things, regulations and their simplification.
The Association of Finnish Cities and Municipalities (AFCM) welcomes the direction set out by the European Commission for the future of European public procurement. The proposal rightly seeks to simplify the regulatory framework while strengthening professionalisation and supporting strategic procurement objectives.
EU Procurement legislation shall leave room for local discretion The Association of Finnish Cities and Municipalities (AFCM) considers that the most important goal in the revision of the Public Procurement Directives shall be to simplify the current procedural rules. We consider that simplification means, in practice, less rules and more flexibility to local authorities. 1.
The Association of Finnish Cities and Municipalities (AFCM) thanks for the opportunity to give feedback for the impact assessment considering the IDAA. The Association of Finnish Cities and Municipalities represents Finnish municipalities. In Finland, municipalities are central actors in implementing the EUs climate and environmental policies.
The Association of Finnish Cities and Municipalities (AFCM) considers that the most important goal in the revision of the Public Procurement Directives shall be to simplify the current procedural rules. Firstly, the rules on the application of the different directives, the procedures and the announcement of procurements shall be made easier for both the con-tracting authorities and tenderers.
The Association of Finnish Cities and Municipalities (AFCM), representing 308 Finnish cities and municipalities, welcomes the opportunity to participate in the call for evidence on Clean Corporate Vehicles initiative. We support the Commissions objective of reducing emissions from road transport as well as greening corporate fleets and appreciate the Commissions efforts in finding solutions at the EU level.
The Association of Municipalities praises the opportunity to comment on the update of the EU Arctic policy. A review and update of the EU’s Arctic policy is timely, as the EU’s communication on Arctic policy dates back to 2021 and the situation in the world has become even more critical.
Filed in Finnish · English published by the European Commission
The Association of Finnish Cities and Municipalities (AFCM) considers the European Business Wallets and the interoperability enabled by them to be generally positive and recognises the significant role of municipalities in enabling their use.
Cities and regions are at the heart of Europe's digital transformation. They link the EU's objectives to citizens' daily lives and help to bridge regional gaps in digitalisation. Association of Finnish Cities and Municipalities emphasises the stronger role of local/regional investments in the Digital Decade policies that are now being updated.
Position Paper 1/9 27.8.2026 482/03.00/2026 Minna Mättö, Eeva-Riitta Högnäs, Martti Setälä, Jaana Jormanainen Version 1.0 European Commission’s Proposal on the AI Cloud and AI Development Act The Association of Finnish Cities and Municipalities (AFCM) is a national organisation with all 308 municipalities and cities in Finland as its members.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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