Afep

Paris, 6 February 2026 POSITION PAPER Digital Omnibus French large companies strongly support the Commission’s draft digital omnibus proposals covering several digital texts and encourage both colegislators to support the most ambitious approach possible in terms of (i) the scope of the texts to be included in this simplification exercise and (ii) the simplification, rationalisation and coordination of the…

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

October 2025 Public consultation of the European Commission Digital Omnibus The European Commission's work program provides for the forthcoming presentation of an omnibus simplification package covering several digital texts, the list of which has not yet been drawn up.

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

May 2026 POSITION PAPER Industrial Accelerator Act L’Afep (the Association of large French companies) welcomes the proposal for a regulation establishing a framework for measures for the acceleration of industrial capacity and decarbonization in strategic sectors (Industrial Accelerator Act or IAA) presented by the Commission last March.

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

LAfep, the voice of Large French Companie, considers that the Taxonomy should be made voluntary and, as a cross-sectoral association, also insists on the following points : 1. Better support transition It is necessary to develop a framework for recognising contributions to the ecological transition. The European Taxonomy focuses on sustainable activities and not enough on activities in transition.

AFEP, the association of large French companies would like first to thank the European Commission for giving the opportunity to submit comments at the occasion of the public consultation for the impact assessment of a legislative proposal regarding the adoption of a Critical Raw Material Act.

Main points raised by L'Afep (Large French Companies' Association) and MEDEF (French Business Org) Anticipated financial effects: The introduction of reliefs without limiting their use over time is positive with respect to the alignment with the IFRS and given the methodological difficulties regarding several topics.

AFEP shares the European Commission's view that in order to accelerate the decarbonisation of the European vehicle fleet, it is necessary, in addition to supporting the supply of zero-emission vehicles, to support demand for these vehicles.

AFEP, the French Association of Large Companies, welcomes the initiative of the European Commission to launch an inception impact assessment on a possible carbon border adjustment mechanism. Since 2019, AFEP has been strongly advocating for the EU to take concrete actions to tackle carbon leakage and related competitiveness gaps at the expense of EU-based industries.

L'Afep, together with MEDEF and France Industrie, shares the European decarbonisation ambition and recognises the central role of the European Union Emissions Trading System (EU ETS) in the European climate strategy to steer industrial investments towards decarbonisation. This transition cannot take place at the cost of weakening European and French industrial competitiveness.

AFEP (French Association of Large Companies) member companies emphasise their support to the target of the Paris Agreement and are committed to make the European Green Deal a success. In the context of the revision of the EU Emissions Trading Scheme (ETS) Directive, the following enabling factors will be key for companies: - strike the right balance between current and forthcoming GHG emission constraints, and more…

Paris, May 12th 2026 POSITION PAPER Revision of the NIS 2 Directive L’Afep supports the Commission's intention to revise the NIS 2 Directive in order to simplify and harmonize its implementation and its overall aim of strengthening cybersecurity across the European Union (EU).

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

Paris, 12th May 2026 POSITION PAPER Cybersecurity Act 2 L’Afep supports the Commission's intention to revise the 2019 Cybersecurity Act (CSA) and its overall aim of strengthening cybersecurity across the EU. With regard specifically to the issues of cybersecurity in cloud services, L’Afep is concerned about the delays in the presentation and progress of the Cloud and AI Development Act (CAIDA).

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

The French Association of Large Companies (AFEP) supports the process towards a revision of the Energy Taxation Directive which should lead to more consistency with the new EU climate ambition. However, due to COVID-19 pandemic, Europe is facing a global economic collapse.

L'Afep welcomes this opportunity to comment on the Taxonomy Delegated Acts. Despite the changes proposed some technical screening criteria still lacks clarity and risks of interpretation increase the reporting burden for undertakings (e.g.: for activity 3.6, the reference to the EU labelling regulation should be explicitly mentioned as an alternative to demonstrate life-cycle GHG emissions savings).

AFEP, the French Association of Large Companies, welcomes this call for evidence on the Sustainable Finance Disclosure Regulation (SFDR). AFEP Members support the objectives of the SFDR to attract private funding to facilitate the transition towards greater sustainability and help European companies to seize competitive opportunities.

The French Association of Large Companies (AFEP) welcomes the European Commission’s consultation on a combined roadmap/inception impact assessment on the Digital Services Act package and strongly support the Commission’s intention to revise the E-Commerce Directive.

AFEP, the French Association of Large Companies, welcomes the consultation of the European Commission on an Inception Impact Assessment in view of a possible revision of the Industrial Emissions Directive, following a public consultation in the summer of 2019 to which AFEP responded.

AFEP (the French Association of Large Companies) considers that the revision of the current Non-Financial Reporting Directive (NFRD) is necessary in order to harmonise and standardise sustainability reporting and to end the proliferation of frameworks and standards.

French companies have been engaged for many years in putting CSR at the heart of their strategies and are considered world leaders on third-party verified corporate responsibility reporting. They present the highest level of non-financial information and can provide a legitimate and experienced-based contribution to the Commission’s work on the revision of the 2014 Directive.

AFEP welcomes the Commission's initiative to present such a roadmap and to launch this consultation. The association supports the Commission's assertion that nature credits can be a key tool to reward nature-positive action through private investment to the benefit of nature and businesses by highlighting them, and is convinced that the European Union can play a catalytic role in the development of this form of…

LAfep, the Voice of large French companies, brings together 117 companies representing 4 million employees in Europe, 8 million worldwide, and 70% of the market capitalization of the French stock exchange. LAfep Members are committed to transitioning their business models to reduce their emissions and, in the future, will face huge investments to finance their activities, their transitions and remain competitive.

LAfep, the Association of Large French Companies, welcomes this call for evidence, which appears appropriate for reassessing the necessity, consistency, and effectiveness of the provisions set out in these various Directives.

AFEP, the French Association of Large Companies, is happy to contribute to this call for evidence to address issues related to European supervision. The Commission indicates that it will assess ways to achieve more efficient and unified supervision of capital markets, as indicated in the Competitiveness Compass and in the Savings and Investments Union Communication.

AFEP – the French Association of Private Enterprises – represents 113 of the largest private corporations operating in France and takes part in the public debate in order to provide pragmatic solutions to develop a competitive French and European economy.

The French Association of Large Companies (AFEP) welcomes the opportunity to answer this consultation on the Commission's roadmap. This initiative is particularly welcomed by French large companies in a context where Member States are multiplying domestic measures to restrain access to these benefits by introducing very heavy administrative processes.

LAfep (Association of Large French Companies) welcomes the opportunity to respond to the Commissions Consultation on the revision of the Shareholder Rights Directive (SRD). Overall, there is broad agreement among issuers that the facilitation of shareholder rights has generally improved due to SRD II, leading to a significant increase especially in the transmission of voting instructions.

AFEP member companies fully support the ambitions of the European Commission to enforce its personal data protection standards in favour of its European citizens, consumers, or employees. However, this must go hand in hand with smooth flows of data worldwide and no unnecessary and disproportionate companies’ administrative and financial constraints.

AFEP brings together over 110 large companies operating in France and worldwide which are in majority public interest entities and therefore subject to the disclosure requirements of several pieces of EU legislation listed in the Annex of the ESAP Regulation and in particular the Transparency Directive, the Accounting Directive – including the Non-financial Directive as well as the forthcoming Corporate…

AFEP, the French association of large companies, welcomes the adoption of the proposal for a regulation on foreign subsidies distorting the internal market. With a view to contributing to the early stage of the legislative process, AFEP shares a set of preliminary comments on the proposed regulation in the position paper in attachment.

AFEP, the French Association of Large Companies, welcomes the publication of the roadmap for the inception impact assessment for a possible legislative initiative to comprehensively handle foreign subsidies likely to distort general competition as well as competition in tendering procedures on the EU internal market.

LAfep, the Association of Large French Companies, would like to thank the European Commission for this consultation. French businesses fully agree with the European Commissions assessment that an effective and ambitious anti-corruption strategy is needed.

Afep, the French Association of Large Companies, represents the interest of over 110 of the largest corporations operating in France. Afep members welcome the opportunity to provide feedback on the inception impact assessment regarding a potential legislative proposal from the Commission to address the debt-equity bias.

The successive amendments to the Directive on Administrative Cooperation in the field of taxation (DAC) have resulted in an increasingly complex framework, imposing a significant compliance burden on businesses.

AFEP (French association of large companies) thanks the European Commission for giving the opportunity to share public comments on the proposed regulation on the protection of the EU and Member States against economic coercion by third countries. AFEP comments are outlined in the attached position paper.

AFEP, the association of large French companies, welcomes the preparation of a legislative initiative for the adoption of an anti-coercion instrument. The legislative procedure for the adoption of the revised Enforcement Regulation brought forward the need to design an instrument to rapidly react to unilateral and disproportionate trade restrictive measures by third countries outside the framework of WTO or FTA DSM.

Large French companies that have implemented whistleblowing procedures within their entities worldwide are not seeking a comprehensive overhaul of European legislation. However, the following improvements would be welcome: Corporate groups: The Directive's entity-based approach limits pooling mechanisms and rigidifies internal procedures, affecting the quality of internal enquiry.