BDA | German Employers

Please find below the feedback from the Federation of German Employers’ Associations (BDA). In our view, the following three main adaptations to the AI Act are necessary to ensure better application of the rules for businesses: Article 4 on AI literacy should be worded as follows in order to provide more legal certainty for businesses: Providers and deployers of AI systems +++ should take measures+++ to ensure, to…

Filed in German · English published by the European Commission

Please find enclosed the full position paper. Summary: A coherent approach to the revision of public procurement legislation is essential. This means simplifying the procedure while avoiding overlapping, vague or disproportionate criteria. Unclear EU rules on scope and coverage lead to risk-averse, box-ticking behaviour and uncertainty.

BDA is the umbrella organisation representing the social and economic policy interests of the German business sector, encompassing one million companies with around 30.5 million employees. Public procurement is already socially responsible under the existing framework (cf. directive on public procurement 2014/24/EU: art. 18(2), 20(1), 43(1), 67(2a), 70).

Please find enclosed the full opinion. Summary: Company law is fragmented across the EU with 27 national legal frameworks. The planned 28th The EU regulatory framework offers an opportunity to strengthen the European single market in a targeted way through a simple, legally secure and digitally usable form of business, with real added value in particular for young, innovative and cross-border businesses.

Filed in German · English published by the European Commission

Omnibus I Requires Greater Simplification: The Commissions Draft ESRS Revision Still Falls Short on Social Standards The Omnibus I legislative package establishes a clear political mandate to simplify EU sustainability regulation and strengthen European competitiveness. The ESRS delegated act must now translate this mandate into tangible and measurable simplification.

Rückmeldung zum Verordnungsvorschlag über ein europäisches Konzept für künstliche Intelligenz Wir begrüßen den risikobasierten Ansatz der Kommission, der im Verordnungsvorschlag über künstliche Intelligenz skizziert wird, und teilen das Bestreben, KI sicher, rechtmäßig und im Einklang mit den EU-Grundrechten zu gestalten.

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

Please find our detailed feedback in the paper attached. BDA is the central business association organising the social and economic policy interests of the entire German economy. We pool the interests of one million businesses with around 30,5 million employees. These businesses are associated with BDA through voluntary membership of employer associations.

Strong basic skills are essential for employability, innovation and Europe's competitiveness. Recent international assessments highlight a growing need to improve educational outcomes, particularly in literacy, mathematics, science and digital skills. Employers therefore support a stronger focus on evidence-based school improvement, high-quality teacher education and the effective use of digital technologies.

More talent in the EU through less bureaucracy and more digitalisation This document has been machine-translated from German. The original German version is available here. Position paper on the planned EU Skills Portability Initiative 26 February 2026 Summary Europe needs skilled workers.

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

More talent in the EU through less bureaucracy and more digitalisation This document has been machine-translated from German. The original German version is available here. Position paper on the planned EU Skills Portability Initiative 26 February 2026 Summary Europe needs skilled workers.

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

More talent in the EU through less bureaucracy and more digitalisation This document has been machine-translated from German. The original German version is available here. Position paper on the planned EU Skills Portability Initiative 26 February 2026 Summary Europe needs skilled workers.

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

Quality Jobs through Competitive Enterprises enables BDA | Opinion on the second phase of the European Commission’s social partner consultation on the Quality Jobs Act September 2026. The Quality Jobs Act announced by the Commission must be firmly aligned with the EU’s own simplification and competitiveness agenda. Instead of reducing existing EU burdens, however, it threatens to create new ones.

Filed in German · English published by the European Commission

We welcome the European Commissions initiative to improve EU policies for citizens and to strengthen the Single Market in practice. The decisive criterion for success will be whether the initiative makes it easier for people to live, work and access opportunities across borders. A key principle should guide this work: what is good for citizens and workers is also good for companies.

As the European Commission prepares its next European Vocational Education and Training (VET) strategy, we must set the course for VET systems across the EU that empower learners and businesses alike. VET is not only a powerful launchpad into work its a cornerstone of competitiveness, social inclusion, and democratic resilience.

The objective of competitiveness and cutting red tape must finally also be pursued consistently in the area of EU labour mobility. The European Commission’s proposals so far are too succinct. A targeted labour market omnibus package is needed to reduce existing burdens and strengthen the framework conditions for cross-border mobility in the Single Market.

Filed in German · English published by the European Commission

Please find below the feedback from BDA, the Confederation of German Employers Associations: A competitive and resilient economy is the precondition for creating quality jobs. Employers play a key role in providing competitive jobs. This perspective is missing so far in the Commissions assessment only if businesses strive, quality jobs can be provided.

BDA is the leading organisation dealing with social policy on behalf of the entire German private sector. It represents the interests of small, medium-sized and large companies in all sectors and all issues linked to social policy and collective negotiations, labour legislation, labour market policy and education.

Before extending the mandate of the European Labour Authority (ELA), its legally existing tasks must be fulfilled: ELA should prioritise tailor-made information on EU labour mobility, as well as real progress on digitalisation, rather than further developing its administrative structures.

Filed in German · English published by the European Commission

We welcome the European Commissions proposal to extend selected SME relief measures to small mid-cap enterprises (SMCs) through the Omnibus IV Regulation. This initiative is a long-overdue and necessary step toward a more proportionate regulatory framework that reflects the operational realities of mid-sized companies in Europe.

The digitalisation of social security coordination is long overdue. For decades, paper-based bureaucracy and fragmented procedures have burdened businesses, unnecessarily hampering cross-border mobility and hampering competitiveness in the Single Market. There is an urgent need to facilitate labour mobility as a fundamental freedom in the internal market.

Filed in German · English published by the European Commission

The Federal Association of German Employers’ Associations (BDA) is the largest German social policy umbrella organisation and represents the interests of more than 1 million companies with around 30,5 million employees. She is committed to ensuring that companies can invest in Germany, drive innovation and create jobs and apprenticeships.

Filed in German · English published by the European Commission

Please find below the feedback from the BDA, the Federal Confederation of German Employers’ Associations: There is no need to further strengthen the Whistleblower Directive. In Germany, the Whistleblower Protection Act (HinSchG) has already transposed the Directive comprehensively and partly beyond the EU requirements. The HinSchG covers reports of infringements of national rules on penalties and fines.

Filed in German · English published by the European Commission

The Confederation of German Employers' Associations (BDA) welcomes the evaluation of Council Recommendation 2012/C 398/01 on the validation of non-formal and informal learning. This should be based on expert knowledge provided by Member States, social partners, chambers, education and training providers, and other stakeholders of non-formal and informal education.