VÖWG

Response to the Call for evidence of the European Commission on the digital package and omnibus (simplification) Vienna, 10 October 2025 About the Association of Public Services and Enterprises Austria We are committed to ensuring that essential public services remain accessible, affordable, and of high quality for everyone in Austria – today and in the future.

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

Rückmeldung zur öffentlichen Konsultation der EU-Kommission zum Kreislaufwirtschaftsakt Wien, 05.11.2025 Über den Verband der öffentlichen Wirtschaft und Gemeinwirtschaft Österreichs Unser Ziel ist es, dass Dienstleistungen der Daseinsvorsorge für alle Menschen in Österreich zugänglich, leistbar und von hoher Qualität bleiben – heute und in Zukunft.

Filed in German · English published by the European Commission

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

VÖWG welcomes the revision of the EU public procurement framework as an opportunity to strengthen practicability, competition and legal certainty. The current system remains overly complex, discouraging participation and leading to reduced bidder numbers, particularly in specialised and critical infrastructure markets.

The Association of the Public Economy and Community Economy of Austria (hereinafter ‘VÖWG’) represents the interests of the main stakeholders in the public sector, in particular in the field of services of general interest. The VÖWG therefore represents 120 companies and institutions providing services of general interest in the ownership, participation or on behalf of local authorities.

Filed in German · English published by the European Commission

In response to the European Commissions proposed amending regulation, and based on the input from its members - particularly Austrian public hospital providers - the VÖWG has formulated feedback and amendment proposals. The document is attached below.

As the Austrian Association of Public Economics and Public Sectors (VÖWG) and thus also representatives of public health institutions in Austria, we welcome the initiative to revise the general pharmaceutical legislation in the European Union. In recent years, there have been some shortcomings in the existing rules.

Filed in German · English published by the European Commission

The VÖWG welcomes the aim of the revised European Sustainability Reporting Standards (ESRS). The measures are in principle suitable for reducing the administrative burden on companies and making sustainability reporting more practical. However, the current draft shows that significant challenges remain in terms of clarity, comparability and practicality.

Filed in German · English published by the European Commission

The EU Emissions Trading System (EU ETS) is a key instrument to reduce greenhouse gas emissions and aims to achieve climate neutrality by 2050. Under the Fit for 55 package, review clauses were added to ETS Directive 2003/87/EC. By 2026, consider possible adaptations for stationary installations, aviation and maritime transport, as well as an extension to new sectors such as waste management.

Filed in German · English published by the European Commission

The Austrian Association of Public Economy and Community Economy (VÖWG) welcomes the European Commission’s initiative on Clean Corporate Vehicles (CCV) and shares the objective of effective decarbonisation of the transport sector.

Filed in German · English published by the European Commission

The Association of Public Enterprises and the Public Economy warmly welcomes the European Commission’s recent call for evidence. It is positive to highlight the recognition that, despite progress, the development of renewable energy in the European Union remains insufficiently rapid to ensure key objectives such as energy independence, regional added value and compliance with climate targets.

Filed in German · English published by the European Commission

The Austrian Association of Public Economy and Public Economy (Verband der öffentlichen Wirtschaft und Gemeinwirtschaft Österreichs, VÖWG) welcomes the draft revision of Delegated Regulation 2021/2139 and supports the Commission’s objective of making the EU taxonomy more practical, legally certain and consistent.

Filed in German · English published by the European Commission

The VÖWG supports the objectives of the SEA Directive to reduce single-use plastics and reduce marine litter, but stresses that municipal companies (in particular waste and water management) need stable and predictable framework conditions for practical implementation.

Filed in German · English published by the European Commission

Rückmeldung zur Sondierung und öffentlichen Konsultation zur Skills Portability Initiative Wien, 26.02.2025 Über den Verband der öffentlichen Wirtschaft und Gemeinwirtschaft Österreichs Unser Ziel ist es, dass Dienstleistungen der Daseinsvorsorge für alle Menschen in Österreich zugänglich, leistbar und von hoher Qualität bleiben – heute und in Zukunft.

Filed in German · English published by the European Commission

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

The Association of Public Enterprises and Public Sectors (VÖWG) is grateful for the possibility of an initial assessment by the European Commission of the planned revision of Directive 96/53/EC on weights and dimensions. In principle, an increase in the dimensions of road vehicles and an increase in the maximum permissible weight is critical. Please find further details in the annex.

Filed in German · English published by the European Commission

Against this background, the VÖWG welcomes the initiative as it responds to one of the key challenges of environmental policy: the continued underfunding of nature conservation and ecosystem restoration. However, successful implementation requires a clear guarantee of long-term counter-financing, transparency of the interaction between public and private funds and concrete incentives for companies to purchase nature…

Filed in German · English published by the European Commission

The Austrian Association of Public Economy and Public Economy (VÖWG) welcomes the initiative to improve the framework conditions for affordable housing at European level. In the VÖWG’s view, the legislative act should be designed in such a way as to respect the principle of subsidiarity and take into account existing national systems in the field of social, non-profit and affordable housing.

Filed in German · English published by the European Commission

Simplification at European level must not result in new administrative burdens, particularly for non-profit and municipal housing developers, or limit their room for manoeuvre in housing policy. The main elements that should be taken into account in the Housing Simplification Package include: Permit-granting procedures & digitalisation Projects of particular importance for housing or climate policy for which no…

Filed in German · English published by the European Commission

Since its introduction in December 1991 the Nitrates Directive (91/676/EEC) has been a key instrument for protecting waters from nitrate pollution from agriculture. Despite significant progress, nitrate pollution from agricultural sources remains a serious problem in many EU Member States.

Filed in German · English published by the European Commission

The VÖWG warmly welcomes the initiative as it responds to key challenges for the protection of water resources and the long-term security of public water supply and sanitation. However, successful implementation requires water resilience to be addressed as a cross-sectoral task, problems to be solved at source as a matter of priority, and the polluter pays principle to be consistently applied.

Filed in German · English published by the European Commission

The Late Payment Directive (Directive 2011/7/EU) sets out a common set of rules to combat late payment in business-to-business (B2B) and public sector bodies (G2B) transactions. As set out in recital 12 of the Directive, the objective of the Directive is to promote a ‘strong change towards a culture of prompt payment’ in the economic environment of the Union.

Filed in German · English published by the European Commission

The VÖWG welcomes in principle the use of digital solutions where they make a concrete contribution to the safety, quality assurance, resource efficiency and operational performance of public water and wastewater companies. At the same time, from the point of view of services of general interest, it is crucial that digitalisation is not seen as an end in itself.

Filed in German · English published by the European Commission

The Association of the Public Economy and the Common Economy (Verband der öffentlichen Wirtschaft und Gemeinwirtschaft, VÖWG) warmly welcomes the European Commission’s initiative. A modern and integrated regulatory framework for energy efficiency is crucial for the success of the energy transition, especially in cities and regions with growing demand.

Filed in German · English published by the European Commission

The draft act on end-of-waste criteria for plastic waste, published on 23.12.2025, aims to establish EU-wide end-of-waste criteria for plastic waste. The draft is adopted as an implementing act under Article 6(2) of the Waste Framework Directive (2008/98) and specifies the uniform application of the end-of-waste conditions to certain types of waste.

Filed in German · English published by the European Commission

The Association of Public Economy and Public Economics of Austria (VÖWG) welcomes in principle the objectives pursued by the European Commission in its draft revision of the Electricity Internal Market Regulation (BMVO) and the Electricity Internal Market Directive (BMRL) on EU electricity market design.

Filed in German · English published by the European Commission

As the consultation document is still rather vague, containing mainly broad policy areas and po-tential domains for regulation, the feedback is not fully concrete. In general, adapting working conditions to digitalisation, algorithmic management and AI in the workplace is commendable, as are safeguards for occupational health.

The VÖWG welcomes the initiative to update the minimum training requirements for midwives and specialist doctors. We would like to take this opportunity to express our support for raising the min-imum training requirements for both professions.

The Austrian Association of Public Economics and Public Industries (VÖWG) attaches the opinion on the Proposal for a Regulation of the European Parliament and of the Council amending Regulations (EC) No 261/2004, (EC) No 1107/2006, (EU) No 1177/2010, (EU) No 181/2011 and (EU) 2021/782 as regards the enforcement of passenger rights in the Union and on the proposal for a Regulation of the European Parliament and of…

Filed in German · English published by the European Commission

1. Initial situation: Demographic change and the pressures on Europe’s skilled labour face an unprecedented challenge: A growing need for skilled labour, combined with a shrinking labour supply. Demographic change, the ageing of the population and the consequent reduction in the workforce, as well as the decline in labour supply in and from eastern and south-eastern Europe, are placing massive pressure on services…

Filed in German · English published by the European Commission

The VÖWG expressly thanks for the opportunity to comment on the planned aptitude test. The announced review in the form of a questionnaire is an important step to ensure the adequacy and timeliness of the existing regulatory frameworks in the area of energy security.

Filed in German · English published by the European Commission

The MDMS regulation should create a fair, proportionate and operationally workable framework that strength-ens multimodal travel without undermining integrated public transport systems or shifting excessive control to digital intermediaries.

The Rail Ticketing Regulation must deliver fair competition and better passenger services without creating dis- proportionate risks for transport operators. The inclusion of meta search engines, alignment with Directive 2012/34/EU, sufficient time for commercial negotiations and operator approval of travel chains are essential to ensure legal certainty and a level playing field.

VÖWG welcomes the European Commission's initiative to reduce administrative burdens and enhance regulatory clarity. At the same time, VÖWG stresses the importance of ensuring that these simplification measures also apply to publicly owned enterprises. To create a level playing field, public and municipal companies must be included in the Commission's recommendation on the definition of Small Mid-caps.