European Association of Public Banks

The European Association of Public Banks and Funding Agencies (EAPB) would like to highlight that National and Regional Promotional Banks and Institutions (NPBIs) are the place-based instrument the strategy is looking for. National and regional promotional banks combine a public-policy mandate, deep territorial knowledge and the capacity to assemble EU resources, national grants and private capital.

The European Association of Public Banks and Funding Agencies (EAPB) represents national and regional promotional banks across the EU. Our members design and deliver concessional lending for affordable housing, channel EU and national grants, and bring together public and private capital. This response is based on the direct operational experience of members active in the financing of affordable housing.

We strongly support the objective of ATAD of combatting tax evasion and international tax planning. However, the negative impact the directive has on strategic investments and the one-size-fits-all character of certain exemptions may have led to a situation where the disadvantages of the directive outweigh the advantages for certain categories of entities that were never its intended target.

The EAPB welcomes the opportunity to offer evidence on the current programming period, followed by considerations for the post-2027 debate. Please find attached, as a good collection of examples of best practices delivered by EAPB members on the ground, our EAPB Compendium of Financial Instruments. I. Evidence from the 20212027 period 1. NPBIs are the logical delivery channel of cohesion investment.

European promotional banks carry out targeted promotional measures on behalf of their owners central and regional governments and municipalities. National, regional, and often additional European funding is used for this purpose. European state aid rules are of essential importance in this context.

The European Association of Public Banks (EAPB) would like to highlight the importance of adapting performance monitoring frameworks to better reflect the specific role and mission of public promotional banks. In that sense, evaluations should not be limited to financial absorption or return, but also consider developmental impact, social value, and the sustainability of investments.

The initiative is well-timed and addresses a real need in the market. For venture and growth capital to play their proper role in supporting European competitiveness, the regulatory framework must enable fund managers to grow and operate at European scale without facing disproportionate burdens or structural obstacles.

Please find attached, and also linked below, the EAPB's position paper on Housing Simplification and Finance. It identifies the EU legislation that National Promotional Banks and Institutions (NPBIs), the leading public financiers of social and affordable housing in Europe, consider most relevant, and sets out a number of proposals for improvement. https://eapb.eu/component/attachments/attachments.html?id=3829

We suggest that national promotional banks be considered as eligible implementing partners for EU-supported investments in resilience, preparedness and civil protection infrastructure at national and regional levels.

The Guarantee Notice is an important legal basis for the activities of national and regional promotional banks and funding agencies, represented by EAPB. We would like to share several proposals to prevent divergent interpretations across Member States and reduce unnecessary administrative workload for beneficiaries.