This position paper focuses on the AI-related aspects of the Digital Omnibus initiative. It outlines VBO-FEBs key concerns and recommendations regarding the interaction between the Digital Omnibus and the existing and forthcoming EU framework on artificial intelligence.
VF
VBO FEB
Industry association · Belgium · EU Transparency Register 47676761061-93
17
positions filed
in the 665 files tracked
13
legislative files
of 665 tracked
14
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1518 trade and business associations on this site, they rank #253 by legislative files engaged, a count of participation, not a measure of influence.
3.5
declared lobbying FTE
self-declared
€400K+
declared costs / yr (floor)
0
EP accreditations
as declared to the register
2009
in the register since
Declares membership of
- Lid van o.a. Businesseurope en van Business at OECD.
- Membre e.a. de Businesseurope et du Business at OECD.
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
- Register category
- Trade and business associations
- Registered as
- VERBOND VAN BELGISCHE ONDERNEMINGEN / FEDERATION DES ENTREPRISES DE BELGIQUE (VBO / FEB)
- Head office
- BRUSSEL / BRUXELLES, Belgium
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
VBO FEB filed 17 positions between 12 Mar 2020 and 3 Jun 2026, across 13 of the 665 legislative files tracked here, attaching a full position paper 14 times.
2020 · 8 filed2021 · 3 filed2022 · 2 filed2026 · 4 filed
What they argued
This position paper sets out VBO-FEBs views on the European Commissions Digital Omnibus initiative. It assesses the proposed approach from a business perspective, with a particular focus on regulatory coherence, simplification and legal certainty.
— For the IFR, reducing greenhouse gas emissions should be the first and main objective of climate policy. Increasing production and use of renewable energy is one of the ways to contribute to this. The VBO therefore calls for the renewable energy target to be formulated as an indicative target. — Annex II of the proposal sets out a formula for calculating the renewable energy target per Member State.
Filed in Dutch · English published by the European Commission
Following the impact assessment in preparation for the revision of Directive (EU) 2018/2001, the Belgian Confederation of Belgian Enterprises (FEB) would like to highlight the following issues: — The European Commission has indicated that achieving the current 32 % target for renewable energy would lead to a GHG reduction of 45 % or 5 % higher than the 40 % target.
Filed in Dutch · English published by the European Commission
POSITION PAPER ESRS Draft Delegated Act Public Consultation– FEB Answer Rodolphe Mouriau Deputy Adviser Competence centre [Sustainability & Circular Economy] [email removed] Publication date / 03 June 2026 The Federation of Entreprises in Belgium (FEB) welcomes the European Commission’s efforts to revise the European Sustainability Reporting Standards (ESRS) and recognises the improvements made compared to earlier…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
EXTERNAL NOTE Comments on the EU Proposal for a Directive on Corporate Sustainability Due Diligence Arie Van Hoe Executive Manager Competence Centre Law & Business T [phone removed] [email removed] Introduction On 23 February 2022, the European Commission published its Proposal for a Directive on Corporate Sustainability Due Diligence (the Proposal).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
EXTERNAL NOTE Carbon Border adjustment mechanism Our reference / 202003271629SEM Publication date / 27 March 2020 [name removed] Advisor [name removed] Deputy Advisor Competence centres Climate, Energy & Mobility Europe & International sem@vbo-feb [email removed] Summary FEB questions for the impact assessment about the carbon border adjustment mechanism.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
— For the IFR, reducing greenhouse gas emissions should be the first and main objective of climate policy. Improving energy efficiency is one of the ways to contribute to this. Therefore, the VBO calls for the energy efficiency target to be formulated as a genuine indicative target.
Filed in Dutch · English published by the European Commission
In the light of the impact assessment that the European Commission will organise in preparation for a possible revision of the Energy Efficiency Directive 2012/27/EU (EED), the Belgian Association of Belgian Enterprises (FEB) would like to emphasise the following issues: — The IFR calls for the energy efficiency target to be an indicative target in a possible revised Directive.
Filed in Dutch · English published by the European Commission
In preparation for a possible revision of the EU Emission Trading System, the VBO would like to highlight the following points: — The impact assessment of the 2030 climate and energy targets leads the VBO to conclude that, if the reduction target is raised to 50 % or 55 %, the European Commission assumes a disproportionate additional effort for the ETS sectors.
Filed in Dutch · English published by the European Commission
— The VBO fully supports the European Commission’s choice to use energy content as the basis for the tax rather than the volume of energy carrier consumed when revising the ETD. This adjustment is in line with the objective of the Green Deal to improve energy efficiency.
Filed in Dutch · English published by the European Commission
The Belgian Federation of Enterprises (VNO FEB) supports the stated objectives of the revision of the ETD (Directive 2003/96/EC) and calls on the Commission to ensure competitive energy prices (including taxes, surcharges, etc.) for our companies, especially those intensive in energy subject to international competition. These are both international prices (outside Europe) and prices in the European market.
Filed in French · English published by the European Commission
Following the Commission’s assessment impact on the Industrial Emissions Directive, the Belgian Confederation of Belgian Enterprises (FEB) would like to further focus on the following issues: The FBO considers that it would not be appropriate to take into account the impact of the circular economy or the reduction of greenhouse gas emissions through the Industrial Emissions Directive.
Filed in Dutch · English published by the European Commission
Road transport in the EU is subject to agreed standards in terms of dimensions and weights. The current rules ensure inefficient transport and unfair competition. Absurd situations arise because the wording in the Directive leads to a strict interpretation of border crossing points. The current regime causes significant environmental damage and unnecessary congestion.
Filed in Dutch · English published by the European Commission
NOTE EXTERNE Omnibus Environnement : Premiers éléments d’analyse Date de publication / 7 mai 2026 Résumé Ce document reprend les positions de la FEB et ses membres relatifs aux début des discussions liées à l’Omnibus ‘Environnement’. La FEB soutient cet Omnibus et salue une initiative qui va dans la bonne direction, notamment en termes de simplification réglementaire.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Federation of Enterprises (VBO FEB) welcomes the review of the Directive for Alternative Fuels Infrastructure (DAFI), which should consider the following priorities: 1. Cornerstone of the European Green Deal The European Union has set and clear objectives to reduce emissions of greenhouse gas emissions from road transport.
Filed in French · English published by the European Commission
La FEB (Fédération des Entreprises de Belgique) a pris acte de la communication de la Commission européenne relative au plan d’investissement pour une Europe durable COM(2020) 21. La FEB souhaite faire part des remarques ci-dessous relatives à la Communication de la Commission.
Filed in French · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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