The Federation of Finnish Enterprises

The Federation of Finnish Enterprises welcomes the Commissions intention to simplify the European Unions digital regulation and improve its suitability for small and medium sized enterprises. It is essential that the reforms lead to a concrete reduction in administrative obligations, especially for micro and small companies whose processing of personal data is generally low risk.

The Federation of Finnish Enterprises emphasizes that the Digital Omnibus should balance simplifying compliance, streamlining obligations, and maintaining competitiveness, with particular attention to SMEs, which often bear indirect regulatory burdens through value chains despite being formally out of scope.

The Federation of Finnish Enterprises (Suomen Yrittäjät) represents approximately 70,000 Finnish micro, small and medium-sized enterprises (SMEs) through local chapters and around 36,000 through trade associations. We welcome the opportunity to comment on the proposed Industrial Decarbonisation Accelerator Act. We support the initiative's objective of removing barriers to industrial decarbonisation investment.

One of the objectives of the reform of the Directive is to simplify the rules, in particular for start-ups and innovative companies, through regulatory simplification and taking into account sectoral legislation. Procurement procedures are generally perceived as burdensome from the perspective of both companies and contracting entities.

Filed in Finnish · English published by the European Commission

The proposal for the Artificial Intelligence Act has admirable objectives but is riddled with issues, which render the regulation problematic. Despite containing some right elements, the proposal is excessively burdensome from the perspective of smaller European enterprises developing, providing, or using AI systems, especially those classified as high-risk systems.

Position Paper 1 (5) 23.5.2022 FFE comments on the European Commission’s proposal for a Directive on Corporate Sustainability Due Diligence European Commission published on 23th February proposal for a Directive on Corporate Sustainability Due Diligence.

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

The Federation of Finnish Enterprises (FFE) supports the reasons and objectives of this proposal to make better informed choices in the ecological transition and to tackle false environmental claims. We also support the aim of the directive proposal to set up equal standards for the companies operating in the EU market. Some of the provisions of the proposed directive are however problematic.

The Federation of Finnish Enterprises welcomes the Commission proposal for a European Innovation Act and supports its overall direction. It addresses two major barriers for innovative SMEs: limited access to public R&D procurement and difficulties in valuing, commercialising and financing intellectual property.

Please find the full feedback of the Federation of Finnish Enterprises attached. Our key messages are: - The proposal is a significant step towards a more competitive and innovative data economy in Europe and, if implemented effectively, improves SMEs’ opportunities to access, share and use data, and to switch data processing services.

We welcome the aim of the Data Act initiative of creating a fairer and more competitive data economy in Europe. To achieve this, it is crucial that especially SMEs have better and more equitable opportunities to access, share and use data.

For the European Digital Single Market to function properly and cohesively, its rules must be aligned with the evolution of technology and the rise of new digital services. Fragmentation of the single market regulation hampers growth and is particularly detrimental to the prospects of small and medium-sized enterprises that provide and use digital services.

Although improving the functioning of Europe’s Digital Single Market is vital, it is worth reminding that regulation will bring the EU and its companies only so far when it comes to achieving increased competitiveness and productivity in the global digital economy. In short, the EU cannot regulate its way to the top.

The Federation of Finnish Enterprises represents almost 70 000 Finnish micro, small and medium-sized enterprises (SMEs) through local chapters and around 36 000 through trade associations. We support enshrining a robust 2040 target in the Climate Law to keep the EU on a credible path to climate neutrality by 2050.

The creation of a harmonized and dynamic digital single market where more data is shared and (re)used between companies, individuals and public bodies to make scientific discoveries and innovative products and services, while respecting the European values, is a precondition for the future economic growth that is both socially and ecologically sustainable.

Non-financial reporting directive – Federation of Finnish Enterprises feedback The Federation of Finnish Enterprises (FFE), representing 115 000 small and medium-sized enterprises of Finland would like to express its views on the initial impact assessment regarding the non-financial information reporting directive (NFRD).

The Federation of Finnish Enterprises welcomes the Commission’s proposal for a Cyber Resiliency Act and subscribes to its main objectives. In our assessment, the Regulation would, if implemented effectively, improve SMEs’ internal cybersecurity by enabling them to acquire and operate safer digital products.

[See our full feedback in the attachment.] The Federation of Finnish Enterprises agrees with the general objectives of the Commission’s initiative concerning the Cyber Resilience Act. The level of cybersecurity of digital products and ancillary services offered in Member States for SMEs needs to be raised and the fragmentation of the internal market with respect to cybersecurity rules prevented.

We agree with the general objectives of the Commission’s proposal for the Digital Markets Act. The proposed regulation will bring clear benefits for the SME users of the gatekeeper platforms who currently lack effective means to address their unfair practices.

Online platforms have become paragons of the digital economy. Unfortunately, Europe and European companies have not been at the forefront of the platform transition. This is due to many reasons, one being the sluggish development of the Single Market for digital services, which has not enabled blitz scaling across national borders for the innovative European startups and SMEs.

The Federation of Finnish Enterprises (FFE) supports the reasons and objectives of this proposal promoting repair of goods, green transition and sustainable consumption. Consumption causes negative environmental and climate effects. These effects should be reduced by supporting various operating models of circular economy and by offering repair services and used goods to consumers.

FFE comments: Sustainable consumption of goods - promoting repair and reuse European Commission has published call for evidence for an impact assessment (Ref. Ares (2022)175084 - 11/01/2022). The initiative promotes a more sustainable use of goods throughout their useful life.

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

The review of the Directive on Security of Network and Information Systems (the NIS Directive), passed in 2016, is in our mind welcome, given the rapid pace of the digital transition which keeps increasing the amount of cyber threats in essential sectors of the European societies and economies.

The Federation of Finnish Enterprises (Suomen Yrittäjät), representing small and medium-sized enterprises and micro enterprises across Finland, considers the objective of the proposed Regulation on European Business Wallets to be fundamentally positive.

To succeed in the ongoing digital and green transitions, Europe needs a thriving data economy based on common values and strong markets to which public bodies and undertakings, including publicly controlled companies, contribute by unleashing their vast data assets for innovation and research.

Federation of Finnish Enterprises (Suomen Yrittäjät) represents approximately 70,000 Finnish SMEs through local chapters and 36,000 through trade associations. We welcome the opportunity to contribute to this impact assessment. We support a coherent post-2030 climate target framework. Long-term regulatory predictability is what unlocks private capital at scale and keeps total transition costs manageable.

The revision, of the Directive on General Product Safety, is at a great importance given the significant market developments, particular the globalization of trade and the increase in online sales. Due to these developments it has become clear that the legal framework of product safety needs to be brought up to date.

Suomen Yrittäjät the Federation of Finnish Enterprises (FFE) is an interest and service organisation for small and medium-sized enterprises (SMEs) for all fields around entire Finland and their owners. As Finlands largest organisation, representing over 100.000 enterprises, we work every day to support free entrepreneurship and an entrepreneur-friendly society.

The Federation of Finnish Enterprises (FFE) is the leading SME organisation in Finland with its more than 105 000 SME members of all sectors and sizes. The FFE is also a member of SMEunited, European organisation for SMEs. The FFE is at opinion that a new sui generis geographical indication right for non-agricultural products (non-agri GI) is not the right approach.

The Federation of Finnish Enterprises supports the Commission’s initiative to lay out clear targets for the EU’s digital decade and to establish a robust monitoring and cooperation mechanism to ensure progress towards these goals in all Member States. It is also welcome the Programme is adopted as a binding decision by the Parliament and the Council, as this highlights the importance of the undertaking.

Suomen Yrittäjät - The Federation of Finnish Enterprises (FFE) does not consider the revision of the ADR directive necessary as the ADR system in Finland is working well. We have our concerns about the proposal and how the proposed changes would affect the Finnish well working ADR system. We thank for the opportunity to express our opinions and views on the given proposal in more detail as per attached.

The division of competences between the EU and the Member States regarding social policy is adequate at the moment and more qualified majority voting should not be introduced. The current areas for unanimity voting are sufficient and justified. The social systems in each Member State have structures and principles of their own.