Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Directives 2014/65/EU and (EU) 2022/2557 as regards the extension of certain mitigating measures available for small and medium sized enterprises to small mid-cap enterprises and further simplifying measures
Date: 2025-05-21
Institutions: Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, European Commission
Subjects: administrative formalities, critical infrastructure security, financial control, financial legislation, financial market, market access, provision of services, risk management, single market, size of business

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 21.5.2025  COM(2025) 502 final 2025/0131 (COD)  Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Directives 2014/65/EU and (EU) 2022/2557 as regards the extension of certain mitigating measures available for small and medium sized enterprises to small mid-cap enterprises and further simplifying measures {SWD(2025) 501 final}  
 
 
EXPLANATORY MEMORANDUM 

1. 

• 

CONTEXT OF THE PROPOSAL 

Reasons for and objectives of the proposal 

European  businesses  create  employment,  innovation  and  prosperity.  Competitiveness  and 
productivity are essential conditions for businesses to flourish; they have been at the heart of 
EU policy for decades1. To set the EU economy on a sustainable growth path, the EU and its 
Member States need to make structural improvements to the business environment, including 
well focused investment and regulatory measures. 

President  von  der  Leyen  has  set  out  a  plan  for  Europe’s  sustainable  prosperity  and 
competitiveness in the political guidelines for the European Commission’s 2024-2029 term2. 
Making business easier and deepening the Single Market are among the plan’s key priorities. 

The  Commission’s  better  regulation  agenda3  also  supports  the  competitiveness  of  European 
enterprises  by  aiming  to  ensure  that  EU  laws  deliver  on  their  objectives  without  imposing 
unnecessary burden. In 2023, the Commission identified the need to rationalise and simplify 
reporting  requirements  for  enterprises  and  administrations4 
them  by  25%,  without 
undermining  the  policy  objectives  of  the  relevant  legislation.  This  commitment  was 
subsequently  increased  to  25%  reduction  of  all  administrative  costs  and  35%  for  small  and 
medium-sized enterprises (SMEs)5. 
Mario  Draghi  in  his  report  on  ‘The  future  of  European  competitiveness’6,  argues  that  EU 
regulation  imposes  a  proportionally  higher  burden  on  SMEs  and  small  mid-cap  enterprises 
(SMCs)7 than on larger  enterprises. The report suggests that the  Commission  should extend 
the  existing  mitigation  measures,  currently  available  to  SMEs,  to  small  mid-caps  to  extend 
proportionality in EU law to them. The Draghi report also observes that EU lacks a commonly 
agreed definition of small mid-caps and readily available statistical data.  

According to Enrico Letta’s ‘Much more than a market’ report, distinguishing between mid-
caps and large corporations in EU regulations will enable more suitable rules, fostering their 
growth  and  equitable  participation  in  the  Single  Market,  especially  during  crises8.  Mid-cap 
enterprises  can  therefore  contribute  to  completing  the  Single  Market  and  making  it  work 
better.  

1 

2 

3 

4 

5 

6 

7 
8 

Long-term  competitiveness  of  the  EU:  looking  beyond  2030,  COM/2023/168  final,  https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52023DC0168 
https://commission.europa.eu/document/download/e6cd4328-673c-4e7a-8683-
f63ffb2cf648_en?filename=Political%20Guidelines%202024-2029_EN.pdf  
Better  regulation:  Joining  forces  to  make  better  laws,  COM(2021)  219  final,  available  at:  https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=COM:2021:219:FIN  
Long-term  competitiveness  of  the  EU:  looking  beyond  2030,  COM(2023)  168  final,  available  at: 
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52023DC0168  
Mission  letter  to  Stéphane  Séjourné,  Executive  Vice-President-designate  for  Prosperity  and  Industrial 
Strategy,  available  at:  https://commission.europa.eu/document/download/6ef52679-19b9-4a8d-b7b2-
cb99eb384eca_en?filename=Mission%20letter%20-%20S%C3%89JOURN%C3%89.pdf  
M. Draghi, The future of European competitiveness, 2024, available at: 
https://commission.europa.eu/topics/strengthening-european-competitiveness/eu-competitiveness-
looking-ahead_en#paragraph_47059, p. 65  
I.e. companies that have outgrown the SME definition. 
E. Letta, Much more than a market, 2024, available at: 
https://www.consilium.europa.eu/media/ny3j24sm/much-more-than-a-market-report-by-enrico-
letta.pdf, p.107. 

EN 

1 

  EN 

 
 
Back  on  12  September  2023,  the  Commission  published  the  SME  Relief  Package9, 
announcing  its  goal  to  help  small  and  medium  sized  enterprises  to  compete  and  grow,  by  -
amongst others - being attentive to the needs of enterprises that outgrow the thresholds of the 
SME definition10, and the broader range of small mid-cap enterprises (SMCs). Under Action 
18 of the relief package, it was announced that the Commission would ‘develop a harmonised 
definition for small  mid-cap enterprises, build a  dataset  based on such definition and assess 
possible measures to support these enterprises in their growth (including potential application 
in adapted form of certain measures favouring SMEs)’.  
A  study  to  ‘Map,  measure  and  portray  the  EU  mid-cap  landscape’11  shows  mid-cap 
enterprises play a vital role in the EU economy, providing 13% of overall employment. They 
are prominently present in industrial ecosystems that are key to the EU’s competitiveness and 
technological  sovereignty,  such  as  electronics,  aerospace  and  defence,  energy,  energy-
intensive  industries  and  health.  Mid-caps  represent  a  segment  of  the  business  sector  that 
clearly  distinguishes  itself  from  SMEs,  but  also  from  large  firms.  Compared  to  SMEs,  they 
tend to  demonstrate a higher pace of growth  -  around 20% of them were SMEs three years 
earlier,  and  a  higher  level  of  innovation  and  digitisation,  although  they  face  certain  similar 
challenges such as administrative burden and share the need for more proportionality in new 
legislation and for targeted support. To enable the smooth transition of SMEs into small mid-
cap enterprises, it is important to address these challenges in a coherent manner. 

The  objective  of  this  proposal  is  indeed  to  provide  targeted  policy  support  that  can  help 
companies  to  scale,  in  particular  in  relevant  and  important  sectors.  In  the  current  economic 
context and with a view to the sectors with high shares of companies in the bracket 250-749 
employees12, the definition for SMCs therefore covers enterprises that are three times the size 
of SMEs13. This is to better accompany scaling up of enterprises and to cover a larger number 
of  companies.    The  Commission  has  issued  a  recommendation  formalising  such  definition 
(Commission Recommendation of 21.5.2025 on the definition of small mid-cap enterprises -  
C(2025)  3500  final),  as  part  of  a  simplification  package  for  small  mid-caps,  which  also 
includes  this  proposal  for  a  Regulation  that  introduces  into  existing  legislation  mitigating 
measures for SMCs. 

A  definition  of  small  mid-cap  enterprises  is  already  in  use  under  the  General  Block 
Exemption  Regulation14  and  the  Guidance  on  Risk  Finance15,  for  the  purpose  of  identified 
market  failures  susceptible  to  be  addressed  through  targeted  public  financial  support  from 
national resources. The purpose of a general SMC definition is, however, not to replicate the 
definition used in State aid rules per se, but to serve as a basis for targeted policy support that 
can help companies to scale in relevant and important sectors. The definition of SMCs in said 

9 

10 

11 

12 

13 
14 
15 

final, 

available 

at:  https://eur-lex.europa.eu/legal-
SME  Relief  Package,  COM/2023/535 
content/EN/TXT/?uri=COM:2023:535:FIN; See also annex 3A to this report SME relief package policy 
tracker. 
SMEs are currently defined as companies with under 250 employees, combined with an annual turnover 
up  to  50  million  euro  or  a  balance  sheet  total  up  to  43  million  -  Recommendation  2003/361/EC  - 
https://single-market-economy.ec.europa.eu/smes/sme-definition_en  
B. Dachs, I. Siedschlag, W. Yan, M. Yoveska, F. Boeira, S. Ivory, Study to map, measure and portray 
the  EU  mid-cap  landscape,  European  Union,  2022,  available  at:  https://op.europa.eu/en/publication-
detail/-/publication/ad5fdad5-6a33-11ed-b14f-01aa75ed71a1/language-en/format-PDF/source-
277396461  
In terms of percentage shares, the highest shares of small mid-caps with 250-749 employees are found 
in electronics, energy renewables and aerospace and defence 
As defined in Commission Recommendation 2003/361/ EC 
General Block Exemption Regulation 
Guidelines on State aid to promote risk finance investments 

EN 

2 

  EN 

 
 
Recommendation remains, of course, without prejudice to the thresholds deemed appropriate 
in the State aid context.’ 

In  light  of  the  above,  the  present  proposal  aims  to  include  consideration  for  SMCs  and 
proportionality when it comes to administrative burden, following the logic explained above 
to  cover  enterprises  that  are  three  times  the  size  of  SMEs,  in  a  number  of  legal  acts  where 
mitigating  or  supporting  measures  are  already  available  for  SMEs.  Therefore,  where  SMEs 
are defined by their average market capitalisation, such as in Directive 2014/65/EU, a similar 
approach should be applied when defining SMCs. 

The aim is to support SMCs dealing with similar challenges as SMEs. Insofar as they are still 
at their growth stage, they may equally benefit from proportionality in regulation, rather than 
being subject to the same rules as large enterprises which are better equipped and have more 
resources to deal with these rules. 

This  proposal  thus  aims to  extend to  SMCs certain  provisions currently applied to  SMEs in 
the following legislation acts: 

For Directive 2014/65/EU on markets  in  financial  instruments,  this proposal  aims to  extend 
the support currently available for SMEs to access  SME growth markets. In order to extend 
such benefit to SMCs, the proposal adds a definition of an SMC in Article 4(1) and, in Article 
33(3),  allows  the  operator  of  a  multiple  trading  facility  (MTF),  applying  to  have  its  MTF 
registered as an SME growth market, to demonstrate compliance with the minimum threshold 
based on both SME and SMC issuers admitted to trading on SME growth markets. 

Directive (EU) 2022/2557 on the resilience of critical entities requires Member States to adopt 
a strategy for enhancing the resilience of critical entities (Article 4). In this strategy, Member 
States  must  provide  a  description  of  measures  already  in  place  which  aim  to  facilitate  the 
implementation  of  certain  obligations  by  the  SMEs  that  are  identified  as  critical  entities 
(Article 4(2)). This proposal aims at drawing attention to SMCs by extending the obligation 
for Member States to  describe in  their strategy  also  facilitating measures  for SMCs, in  case 
such measures are already in place at national level.  

• 

Consistency with existing policy provisions in the policy area 

This proposal is part of a package of measures aiming at reducing administrative burden for 
SMCs by extending to them certain provisions that SMEs currently benefit from. Its purpose 
is  to  deliver  on  the  commitment  of  the  Commission  to  1)  make  business  easier  and  reduce 
administrative burden by 25% and 35% for SMEs, and 2) extend proportionality in EU law to 
small mid-caps. 

The  rationalisation  introduced  by  these  measures  will  not  affect  the  achievement  of  the 
objectives in  the  concerned policy area nor the  rationale of the legislative acts,  as it merely 
extends  to  SMCs  measures  already  in  place  for  SMEs,  without  any  rick  to  lower  socio-
economic and environmental standards. 

• 

Consistency with other Union policies 

The current proposal intends to mirror the SMCs situation to the one of SMEs in a number of 
legal acts, covering different policy areas. It aims at making the achievement of the objectives 
of  those  legislations  more  efficient  and  less  burdensome  for  enterprises,  organisations  and 
public authorities. 

EN 

3 

  EN 

 
2. 

• 

LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY 

Legal basis 

This proposal is based on Article 53(1) and Article 114 of the Treaty on the Functioning of 
the European Union, which are the legal basis of the acts it amends. 

The legal acts referred to in point 1 and affected by this proposal contain similar provisions 
that are intended to cut red tape for SMEs or help them fulfil the obligations imposed on them 
through the relevant acts, with the aim of making  it easier and less burdensome for them to 
apply such legislation. In order to extend this proportionality where administrative burden is 
concerned, it is considered warranted to extend the provisions towards small mid-caps. 

• 

Subsidiarity (for non-exclusive competence)  

The obligations imposed on enterprises are done so directly and indirectly by Union law and 
can  therefore  only  be  amended  at  Union  level.  Member  States,  enterprises,  and  the 
Commission will benefit from extending to SMCs certain rules currently applicable to SMEs. 

• 

Proportionality 

Extending  to  SMCs  of  certain  provisions  already  applicable  to  SMEs  simplifies  the  legal 
framework by making minimum changes to Member States’ existing obligations.  As a result, 
SMCs should be hereinafter conferred the same treatment as SMEs. The proposal is limited to 
those changes that are necessary to  ensure SMCs benefit from the same legal framework as 
SMEs. 

The targeted amendments only concern aspects applicable to SMEs (defined in various ways, 
depending on the context of the legal act and the choice of the co-legislator) which will now 
be extended to SMCs and which are suitable for inclusion in a single proposal. The definitions 
of SMCs that are to be included in the acts will follow the approach to define SMEs by the co-
legislator for those acts, and cover enterprises that are three times the size of those SMEs. 

• 

Choice of the instrument 

The  Directives  concerned  by  this  proposal  provide  a  different  degree  of  harmonisation  of 
national legislation for the relevant areas. These pieces of legislation contain provisions that 
take  into  account  the  situation  of  SMEs  and  ensure  that  requirements  avoid  imposing  an 
unnecessary burden on SMEs. This proposal aims at ultimately making such legislation less 
burdensome for SMCs, in the same way as it is currently applied to SMEs. 

Therefore,  in  the  interest  of  efficiency,  a  joint  proposal  for  the  extension  of  the  provisions 
applicable to SMEs to SMCs in the form of the present omnibus proposal appears to be the 
most suitable solution. In particular, the choice of a Directive for this proposal is justified by 
the need to use the same legal instrument as the legal acts that are to be amended.  

RESULTS 
CONSULTATIONS AND IMPACT ASSESSMENTS 

EX-POST 

EVALUATIONS, 

OF 

STAKEHOLDER 

Ex-post evaluations/fitness checks of existing legislation 

3. 

• 

N/A 

EN 

4 

  EN 

 
Stakeholder consultations 

• 
In line with the commitment made in the SME Relief Package16 to assess possible measures to 
support  small  mid-cap  enterprises  in  their  growth,  the  Commission  has  analysed  the  acquis 
with a particular focus on initiatives either considered as burdensome or including dedicated 
lighter  regimes  or  mitigating  measures  for  SMEs.  The  screening  has  revealed  a  range  of 
possibilities to ensure better proportionality for small mid-cap enterprises.  

The Commission has also engaged with and listened to the business community to determine 
how  to  use  the  small  mid-cap  enterprise  definition  for  horizontal  policy  purposes,  and  to 
identify  fields  for  proportionate  regulatory,  funding  or  policy  measures.  In  that  respect,  the 
position  papers  sent  by  stakeholders  make  a  number  of  recommendations,  such  as 
‘considering  the  specific  characteristics  of  mid-caps  in  the  better  regulation  context’,  or 
‘ensuring that EU regulation is more sensitive to business size’.  

The Commission consulted European industry representatives for specific ideas on providing 
tailored  support  to  SMCs.  This  was  done  through  bilateral  meetings  and  a  ‘Roundtable  on 
Simplification’ on the necessary policy support for small mid-cap enterprises on 6 February 
2025. The results of all these discussions have contributed to the list of proposals put forward 
in this document. 

• 

Collection and use of expertise 

The  measures  currently  applicable  to  SMEs  to  be  extended  to  SMCs  have  been  identified 
following a process of internal and external scrutiny of existing legislation and are based on 
the experience of implementing of the related legislation. Since this is one step in the process 
of  continuous  assessment  of  the  need  for  mitigating  measures  for  small  enterprises  so  that 
they  can  comply  with  obligations  arising  from  Union  legislation,  the  scrutiny  of  the 
administrative burden and its impact on stakeholders will continue. 

• 

Impact assessment 

The  proposal  concerns  limited  and  targeted  changes  to  legislation  to  extend  to  SMCs  the 
measures currently applicable to SMEs. These changes are based on experience gained from 
legislation.  The  changes  ensure  a  more  efficient  and  effective 
implementing  EU 
implementation. Their targeted nature and the lack of relevant policy options make an impact 
assessment  not  necessary.  However,  the  attached  staff  working  document  looks  at  elements 
on the impact of such measures, including quantification of expected savings. 

• 

Regulatory fitness and simplification 

Under the regulatory fitness and performance programme (REFIT), the Commission ensures 
that  its  legislation  is  fit  for  purpose,  targeted  to  the  needs  of  stakeholders,  and  minimises 
burdens  while  achieving  its  objectives.  This  proposal  is  therefore  part  of  the  REFIT 
programme,  reducing  unnecessary  burdens  for  SMCs,  by  bringing  the  rules  applicable  to 
SMCs into line with those for SMEs. 

This  is  a  REFIT  proposal,  aimed  at  simplifying  legislation  and  cutting  red  tape  for 
stakeholders. 

• 

Fundamental rights 

N/A. 

16 

SME  Relief  Package,  COM 
content/EN/TXT/?uri=COM%3A2023%3A535%3AFIN 

(2023)  535  final,  available  at:  https://eur-lex.europa.eu/legal-

EN 

5 

  EN 

 
 
4. 

BUDGETARY IMPLICATIONS 

N/A. 

5. 

• 

N/A. 

OTHER ELEMENTS 

Implementation plans and monitoring, evaluation and reporting arrangements 

• 

Explanatory documents 

N/A. 

• 

Detailed explanation of the specific provisions of the proposal 

With regard to Directive 2014/65/EU: 

Where Article 4(1) includes a definition of SMEs, a definition of SMCs will now be included. 
It will define SMCs as a category of enterprises, distinct from SMEs. 

Article 33 requires that at least 50 % of the issuers whose financial instruments are admitted 
to trading on the multilateral trading  facility (MTF) are SMEs at the time when the MTF is 
registered as an SME growth  market  and in  any calendar year. This  proposal  will allow the 
operator  of  an  MTF,  applying  to  have  its  MTF  registered  as  an  SME  growth  market,  to 
demonstrate compliance with the threshold based on both SME and SMC issuers admitted to 
trading  on  the  SME  growth  market.  This  will  allow  SMCs  to  better  benefit  from  access  to 
SME growth markets.  

With regard to Directive (EU) 2022/2557: 

Article  4  lays  down  that  each  Member  State  must  adopt  by  17  January  2026  a  strategy  for 
enhancing  the  resilience  of  critical  entities  (the  ‘strategy’).  In  this  strategy,  Member  States 
must  provide  a  description  of  measures  already  in  place  which  aim  to  facilitate  the 
implementation of certain obligations by the SMEs that are identified as critical entities. The 
current  proposal  aims  to  draw  attention  to  SMCs  by  extending  this  obligation  for  Member 
States, so that they also describe such facilitation measures for SMCs, in case they exist. 

A definition of SMCs should be added to the definition of SMEs included under Article 4. 

EN 

6 

  EN 

 
2025/0131 (COD) 

Proposal for a 

DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 

amending Directives 2014/65/EU and (EU) 2022/2557 as regards the extension of certain 
mitigating measures available for small and medium sized enterprises to small mid-cap 
enterprises and further simplifying measures 

THE EUROPEAN PARLIAMENT AND THE COUNCIL OF THE EUROPEAN UNION, 

Having  regard  to  the  Treaty  on  the  Functioning  of  the  European  Union,  and  in  particular 
Article 53(1), Article 114 thereof, 

Having regard to the proposal from the European Commission, 

After transmission of the draft legislative act to the national parliaments, 
Having regard to the opinion of the European Economic and Social Committee,1 
Having regard to the opinion of the Committee of the Regions2,  

Acting in accordance with the ordinary legislative procedure, 

Whereas: 

(1) 

(2) 

(3) 

1 
2 
3 

4 

5 

6 
7 

In the political guidelines for the European Commission’s 2024-2029 term3, President 
von  der  Leyen  set  out  a  plan  for  the  Union’s  sustainable  prosperity  and 
competitiveness. Making business easier and deepening the Single Market are among 
the plan’s key priorities. 
The  Commission’s  better  regulation  agenda4  also  supports  the  competitiveness  of 
Union enterprises by aiming to ensure that Union laws deliver on their objectives at a 
minimum cost. In 2023, the Commission identified the need to rationalize and simplify 
reporting  requirements  for  enterprises  and  administrations5  and  committed  to  reduce 
administrative burdens by 25%.  
On  12  September  2023,  the  Commission  published  the  SME  Relief  Package6, 
announcing its goal to help small and medium sized enterprises (‘SMEs’) compete and 
grow, by being attentive to the needs of enterprises that outgrow the thresholds of the 
SME definition7, and those in the broader range of small mid-cap enterprises. Action 

OJ C , , p.  
OJ C , , p. . 
https://commission.europa.eu/document/download/e6cd4328-673c-4e7a-8683-
f63ffb2cf648_en?filename=Political%20Guidelines%202024-2029_EN.pdf  
Better  regulation:  Joining  forces  to  make  better  laws,  COM(2021)  219  final,  available  at:  https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=COM:2021:219:FIN  
Long-term  competitiveness  of  the  EU:  looking  beyond  2030,  COM(2023)  168  final,  available  at: 
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52023DC0168  
SME Relief Package (europa.eu). See also annex 3A to this report SME relief package policy tracker. 
SMEs are defined as companies with under 250 employees, combined with an annual turnover up to 50 
million euro or a balance sheet total up to 43 million  - Recommendation 2003/361/EC - https://single-
market-economy.ec.europa.eu/smes/sme-definition_en 

EN 

1 

  EN 

 
 
18  of  this  relief  package  announced  that  the  Commission  would  ‘develop  a 
harmonised  definition  for  small  mid-cap  enterprises,  build  a  dataset  based  on  such 
definition  and  assess  possible  measures  to  support  these  enterprises  in  their  growth 
(including  potential  application  in  adapted  form  of  certain  measures  favouring 
SMEs)’. 

Enterprises outgrowing the SME definition – the ‘small mid-cap enterprises’ (‘SMCs’) 
– play a vital role in the Union’s economy.8 They are prominently present in industrial 
ecosystems  that  are  key  to  the  competitiveness  of  the  Union  and  its  technological 
sovereignty,  in  fields  including  electronics,  aerospace  and  defence,  energy,  energy-
intensive  industries  and  health.  Around  20%  of  all  small  mid-cap  enterprises  were 
SMEs three years earlier9.  

Compared to SMEs, SMCs tend to demonstrate a higher pace of growth, and level of 
innovation  and  digitisation.  Nevertheless,  where  administrative  burden  is  concerned, 
they  face  similar  challenges  as  SMEs,  leading  to  a  need  for  proportionality  in 
legislation  and  for  targeted  support.  To  enable  the  smooth  transition  of  SMEs  into 
SMCs,  it is  important  to address in  a  coherent  manner the cliff-effect  that  may arise 
once they outgrow the segment of SMEs and are faced with rules that apply to large 
enterprises. To make business easier for SMCs and reduce their administrative burden, 
a number of existing acts which provide for specific mitigating rules for SMEs should 
be adapted to extend the scope of those provisions and include SMCs. 
Directive  2014/65/EU10  of  the  European  Parliament  and  of  the  Council,  contains 
certain  provisions  that  aim  at  providing  simplification  or  mitigating  measures  to 
SMEs.  More  specifically,  those  provisions  aim  at  alleviating  administrative  burden 
and reducing or eliminating market entry barriers or draw Member States’ attention to 
the  benefits  that  SMEs  derive  from  dedicated  guidance,  support  and  assistance. 
Directive (EU) 2022/2557 11 of the European Parliament and the Council provides that 
Member States should support critical entities, including those that qualify as small or 
medium-sized  enterprises,  in  strengthening  their  resilience.  The  Directive  requires 
Member States to  include  in  their resilience strategies a description of measures that 
are already in place at national level which aim to facilitate the implementation of the 
obligations of SMEs that were identified as critical entities. 

To ensure consistency and legal certainty, a definition of SMCs should be introduced 
in  those  acts.  While  the  definition  of  SMCs  should  in  principle  correspond  to  the 
definition  in  Commission  Recommendation  of  21.5.2025  on  the  definition  of  small 
mid-cap  enterprises  -    C(2025)  3500  final  and  cover  enterprises  that  are  up  to  three 
times the size of SMEs, it should, where appropriate, build on the definitions of SMEs 
that are  already provided in  the acts  that are being amended, which were considered 
fitting by the legislators.  

Study  to  map,  measure  and  portray  the  EU  mid-cap  landscape  -  https://op.europa.eu/en/publication-
detail/-/publication/ad5fdad5-6a33-11ed-b14f-01aa75ed71a1/language-en/format-PDF/source-
277396461 
https://www.esri.ie/system/files/publications/BKMNEXT429.pdf 
Directive  2014/65/EU  of  the European  Parliament  and  of  the  Council  of  15 May  2014 on  markets  in 
financial  instruments  and  amending  Directive  2002/92/EC  and  Directive  2011/61/EU  (recast)  (OJ  L 
173, 12.6.2014, p. 349, ELI: http://data.europa.eu/eli/dir/2014/65/oj.) 
Directive (EU) 2022/2557 of the European Parliament and of the Council of 14 December 2022 on the 
resilience  of  critical  entities  and  repealing  Council  Directive  2008/114/EC  (OJ  L  333,  27.12.2022,  p. 
164, ELI: http://data.europa.eu/eli/dir/2022/2557/oj). 

(4) 

(5) 

(6) 

(7) 

8 

9 
10 

11 

EN 

2 

  EN 

 
 
(8) 

(9) 

Directive  2014/65/EU  identifies  a  subcategory  of  multilateral  trading  facilities 
(‘MTF’)  known  as  SME  growth  markets.  Article  33  (3),  point  (a),  of  that  Directive 
lays  down  specific  conditions  to  ensure  that  those  trading  venues  effectively  benefit 
SMEs by facilitating their access to capital and the further development  of specialist 
markets  that  cater  for  SMEs’  needs.  That  provision  should  be  extended  to  include 
SMCs,  to  also  allow  those  companies  to  access  capital  markets  through  those  SME 
growth markets.  

Directive  (EU)  2022/2557  obliges  the  Member  States  to  support  critical  entities  that 
qualify as  SMEs in  strengthening their resilience.  In doing  so, Member  States  are to 
prevent excessive administrative burdens. To this purpose, Member States are to adopt 
strategies for enhancing the resilience of critical entities. Pursuant to Article 4 of that 
Directive, each strategy is to contain a description of measures that are already in place 
to facilitate the implementation of certain obligations by the SMEs that are identified 
as  critical  entities  by  the  Member  States.  The  scope  of  that  provision  should  be 
extended to include SMCs, so that Member States should include a description of any 
facilitating measures for SMC in their strategies. 

(10) 

Directives 2014/65/EU and (EU) 2022/2557 should therefore be amended accordingly, 

HAVE ADOPTED THIS DIRECTIVE: 

Article 1 
Amendments to Directive 2014/65/EU 

Directive 2014/65/EU is amended as follows: 

(1) 

in Article 4(1), the following point (13a) is inserted: 

‘(13a) ‘small mid-cap enterprises’, for the purposes of this Directive, means  companies that 
had an average market capitalisation equal to or higher than EUR 200 000 000 and lower than 
EUR 1 000 000 000 on the basis of end-year quotes for the previous three calendar years;’; 

(2) 

in Article 33(3), point (a) is replaced by the following: 

‘(a)  at  least  50%  of  the  issuers  whose  financial  instruments  are  admitted  to  trading  on  the 
MTF are SMEs or SMCs or both, at the time when the MTF is registered as an SME growth 
market and in any calendar year thereafter;’. 

Article 2 
Amendment to Directive (EU) 2022/2557 

In Article 4(2) of Directive (EU) 2022/2557, point (h) is replaced by the following: 

‘(h) a description of measures already in place which aim to facilitate the implementation of 
obligations under Chapter III of this Directive by small and medium-sized enterprises within 
the meaning of the Annex to Commission Recommendation 2003/361/EC* and by small mid-
cap enterprises within the meaning of the Annex to Commission Recommendation XX** that 
the Member State in question has identified as critical entities.’. 

________ 

*  Commission  Recommendation  of  6  May  2003  concerning  the  definition  of  micro,  small  and 
medium-sized 
ELI: 
http://data.europa.eu/eli/reco/2003/361/oj).  

enterprises 

20.5.2003, 

124, 

(OJ 

36, 

p. 

L 

**  Commission  Recommendation  of  21.5.2025  on  the  definition  of  small  mid-cap  enterprises  -  
C(2025) 3500 final. 

EN 

3 

  EN 

 
Article 3 
Transposition 

1. 

Member  States  shall  adopt  and  publish,  by [Note  to  PO:  insert  exact  date  – 
[…] 12 months  after  entry  into  force  of  this Directive] at  the  latest,  the  laws, 
regulations  and  administrative  provisions  necessary  to  comply  with  this Directive. 
They shall forthwith communicate to the Commission the text of those provisions. 

They  shall  apply  those  provisions  from [Note  to  PO:  insert  exact  date  –  […]  12 

months and one day after entry into force of this Directive]. 

When  Member  States  adopt  those  provisions,  they  shall  contain  a  reference  to  this 
Directive  or  be  accompanied  by  such  a  reference  on  the  occasion  of  their  official 
publication. Member States shall determine how such reference is to be made. 

2. 

Member States shall communicate to the Commission the text of the main provisions 
of national law which they adopt in the field covered by this Directive. 

Article 4 
Entry into force 

This Directive shall enter into force on the twentieth day following that of its publication in 
the Official Journal of the European Union. 

Article 5 
Addressees 

This Directive is addressed to the Member States. 

Done at Brussels, 

For the European Parliament 

For the Council 

The President 

The President 

EN 

4 

  EN 

 
LEGISLATIVE FINANCIAL AND DIGITAL STATEMENT 

1. 

1.1. 

1.2. 

1.3. 

FRAMEWORK OF THE PROPOSAL/INITIATIVE ................................................. 3 

Title of the proposal/initiative ...................................................................................... 3 

Policy area(s) concerned .............................................................................................. 3 

Objective(s) .................................................................................................................. 3 

1.3.1.  General objective(s) ..................................................................................................... 3 

1.3.2.  Specific objective(s) ..................................................................................................... 3 

1.3.3.  Expected result(s) and impact ...................................................................................... 3 

1.3.4. 

Indicators of performance ............................................................................................ 3 

1.4. 

1.5. 

The proposal/initiative relates to: ................................................................................. 4 

Grounds for the proposal/initiative .............................................................................. 4 

1.5.1.  Requirement(s) to be met in the short or long term including a detailed timeline for 

roll-out of the implementation of the initiative ............................................................ 4 

1.5.2.  Added value of EU involvement (it may result from different factors, e.g. 

coordination gains, legal certainty, greater effectiveness or complementarities). For 
the purposes of this section 'added value of EU involvement' is the value resulting 
from EU action, that is additional to the value that would have been otherwise 
created by Member States alone. ................................................................................. 4 

1.5.3.  Lessons learned from similar experiences in the past .................................................. 4 

1.5.4.  Compatibility with the multiannual financial framework and possible synergies with 
other appropriate instruments ....................................................................................... 5 

1.5.5.  Assessment of the different available financing options, including scope for 

redeployment ................................................................................................................ 5 

1.6. 

1.7. 

2. 

2.1. 

2.2. 

2.2.1. 

2.2.2. 

Duration of the proposal/initiative and of its financial impact .................................... 6 

Method(s) of budget implementation planned ............................................................. 6 

MANAGEMENT MEASURES................................................................................... 8 

Monitoring and reporting rules .................................................................................... 8 

Management and control system(s) ............................................................................. 8 

Justification of the budget implementation method(s), the funding implementation 
mechanism(s), the payment modalities and the control strategy proposed .................. 8 

Information concerning the risks identified and the internal control system(s) set up 
to mitigate them............................................................................................................ 8 

2.2.3.  Estimation and justification of the cost-effectiveness of the controls (ratio between 

the control costs  and the value of the related funds managed), and assessment of the 
expected levels of risk of error (at payment & at closure) ........................................... 8 

2.3. 

3. 

3.1. 

Measures to prevent fraud and irregularities ................................................................ 9 

ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE ............ 10 

Heading(s) of the multiannual financial framework and expenditure budget line(s) 
affected ....................................................................................................................... 10 

EN 

1 

  EN 

 
3.2. 

Estimated financial impact of the proposal on appropriations ................................... 12 

3.2.1.  Summary of estimated impact on operational appropriations.................................... 12 

3.2.1.1.  Appropriations from voted budget ............................................................................. 12 

3.2.1.2.  Appropriations from external assigned revenues ....................................................... 17 

3.2.2.  Estimated output funded from operational appropriations......................................... 22 

3.2.3.  Summary of estimated impact on administrative appropriations ............................... 24 

3.2.3.1. Appropriations from voted budget .............................................................................. 24 

3.2.3.2.  Appropriations from external assigned revenues ....................................................... 24 

3.2.3.3.  Total appropriations ................................................................................................... 24 

3.2.4.  Estimated requirements of human resources.............................................................. 25 

3.2.4.1.  Financed from voted budget....................................................................................... 25 

3.2.4.2.  Financed from external assigned revenues ................................................................ 26 

3.2.4.3.  Total requirements of human resources ..................................................................... 26 

3.2.5.  Overview of estimated impact on digital technology-related investments ................ 28 

3.2.6.  Compatibility with the current multiannual financial framework.............................. 28 

3.2.7.  Third-party contributions ........................................................................................... 28 

3.3. 

4. 

4.1. 

4.2. 

4.3. 

4.4. 

4.5. 

Estimated impact on revenue ..................................................................................... 29 

DIGITAL DIMENSIONS .......................................................................................... 29 

Requirements of digital relevance .............................................................................. 30 

Data ............................................................................................................................ 30 

Digital solutions ......................................................................................................... 31 

Interoperability assessment ........................................................................................ 31 

Measures to support digital implementation .............................................................. 32 

EN 

2 

  EN 

 
1. 

FRAMEWORK OF THE PROPOSAL/INITIATIVE  

1.1. 

Title of the proposal/initiative 

Proposal  for a DIRECTIVE  OF THE EUROPEAN PARLIAMENT  AND OF THE 
COUNCIL,  amending  Directives  2014/65/EU  and  (EU)  2022/2557  as  regards  the 
extension  of  certain  mitigating  measures  available  to  SME  to  small  mid-cap 
enterprises 

1.2. 

Policy area(s) concerned  

Simplification, Competitiveness 

1.3. 

Objective(s) 

1.3.1.  General objective(s) 

To  support  the  growth  and  development  of  small  and  medium-sized  enterprises 
(SMEs) into  small mid-caps, thus  increasing  their competitiveness  and contribution 
to European welfare and prosperity 

To promote a favorable business environment and to reduce administrative burdens 
for  SMEs  and  small  mid-caps,  thereby  enhancing  their  ability  to  innovate,  create 
jobs, and contribute to economic growth. 

1.3.2. 

Specific objective(s) 

Extend some mitigating measures to small mid-caps in order to facilitate their growth 
and development. The proposal aims to extend certain mitigating measures currently 
available  to  SMEs  to  small  mid-caps,  mainly  in  the  area  of  burden  reduction  and 
simplified  or  assisted  reporting,  by  putting  forward  a  proposal  for  an  omnibus  act 
amending Directive 2014/65. 

Extend,  as  regards  SMCs  identified  as  critical  entities,  the  obligation  for  Member 
States  to  describe,  in  their  resilience  strategies,  the  measures  already  in  place  at 
national  level  which  aim  to  facilitate  the  implementation  of  their  obligations  under 
Directive  (EU)  2022/2557  by  putting  forward  a  proposal  for  the  omnibus  act 
amending Directive (EU) 2022/2557. 

1.3.3.  Expected result(s) and impact 

Specify the effects which the proposal/initiative should have on the beneficiaries/groups targeted. 

The  proposal/initiative  is  expected  to  have  the  following  overall  effects  on  the 
beneficiaries/groups targeted: 

- 
Reduced  administrative  burdens:  Small  mid-caps  will  experience  a  reduction 
in  administrative  burdens,  which  will  enable  them  to  focus  on  their  core  business 
activities and improve their competitiveness 

- 
Improved  competitiveness:  Small  mid-caps  will  become  more  competitive, 
both  domestically  and  internationally,  which  will  enable  them  to  increase  their 
market share and contribute to European economic growth  

EN 

3 

  EN 

 
 
 
 
- 
Job creation: The growth and development of small mid-caps will lead to the 
creation  of  new  and  quality  jobs,  which  will  contribute  to  reducing  unemployment 
and promoting social cohesion  

- 
Increased  innovation:  Small  mid-caps  will  be  encouraged  to  innovate  and 
develop  new  products  and  services,  which  will  contribute  to  improving  the  overall 
innovation capacity of the European economy 

- 
Improved  contribution  to  European  welfare  and  prosperity:  Small  mid-caps 
will make a greater contribution to European welfare and prosperity, which will be 
reflected  in  increased  economic  growth,  improved  living  standards,  and  enhanced 
social cohesion 

- 
Improved visibility related to the resilience of critical entities: Small mid-caps 
that are identified as critical entities contribute to the overall protection and resilience 
of the EU. The facilitating measures they enjoy under national law will be described 
in national resilience strategies. 

Target groups: 

Overall, the proposal/initiative is focussing on the approximately 31,000 small mid-
caps in the EU. 

1.3.4. 

Indicators of performance 

Specify the indicators for monitoring progress and achievements. 

N/A 

1.4. 

The proposal/initiative relates to: None of the below. 

 a new action  
 a new action following a pilot project / preparatory action1  

 the extension of an existing action  

 a merger or redirection of one or more actions towards another/a new action 

1.5. 

Grounds for the proposal/initiative  

1.5.1.  Requirement(s) to be met in the short or long term including a detailed timeline for 

roll-out of the implementation of the initiative 

This proposal concerns two omnibus acts amending EU legislation. It can therefore 
only be carried out at EU level. 

1.5.2.  Added  value  of  EU  involvement  (it  may  result  from  different  factors,  e.g. 
coordination gains, legal certainty, greater effectiveness or complementarities). For 
the  purposes  of  this  section  'added  value  of  EU  involvement'  is  the  value  resulting 
from  EU  action,  that  is  additional  to  the  value  that  would  have  been  otherwise 
created by Member States alone. 

N/A 

1 

As referred to in Article 58(2), point (a) or (b) of the Financial Regulation. 

EN 

4 

  EN 

 
  
 
 
1.5.3.  Lessons learned from similar experiences in the past 

N/A 

1.5.4.  Compatibility with the multiannual financial framework and possible synergies with 

other appropriate instruments 

N/A 

1.5.5.  Assessment  of  the  different  available  financing  options,  including  scope  for 

redeployment 

N/A 

EN 

5 

  EN 

 
1.6. 

Duration of the proposal/initiative and of its financial impact 

 limited duration  

–    in effect from [DD/MM]YYYY to [DD/MM]YYYY  

–    financial  impact  from  YYYY  to  YYYY  for  commitment  appropriations  and 

from YYYY to YYYY for payment appropriations.  

 unlimited duration 

–  Implementation with a start-up period from YYYY to YYYY, 

–  followed by full-scale operation. 

1.7.  Method(s) of budget implementation planned2  

 Direct management by the Commission 

–   by its departments, including by its staff in the Union delegations;  

–    by the executive agencies  

 Shared management with the Member States  

 Indirect management by entrusting budget implementation tasks to: 

–   third countries or the bodies they have designated 

–   international organisations and their agencies (to be specified) 

–   the European Investment Bank and the European Investment Fund 

–   bodies referred to in Articles 70 and 71 of the Financial Regulation 

–   public law bodies 

–   bodies governed by private law with a public service mission to the extent that 

they are provided with adequate financial guarantees 

–   bodies governed by the private law of a Member State that are entrusted with 
the  implementation  of  a  public-private  partnership  and  that  are  provided  with 
adequate financial guarantees 

–   bodies or persons entrusted with the implementation of specific actions in the 
common  foreign  and  security  policy  pursuant  to  Title  V  of  the  Treaty  on 
European Union, and identified in the relevant basic act 

–  bodies  established  in  a  Member  State,  governed  by  the  private  law  of  a 
Member  State  or  Union  law  and  eligible  to  be  entrusted,  in  accordance  with 
sector-specific  rules,  with  the  implementation  of  Union  funds  or  budgetary 
guarantees,  to  the extent that such bodies are controlled by public law bodies or 
by bodies governed by private law with a public service mission, and are provided 
with adequate financial guarantees in the form of joint and several liability by the 
controlling bodies or equivalent financial guarantees and which may be, for each 
action, limited to the maximum amount of the Union support. 

2 

Details of budget implementation methods and references to the Financial Regulation may be found on 
the BUDGpedia site: https://myintracomm.ec.europa.eu/corp/budget/financial-rules/budget-
implementation/Pages/implementation-methods.aspx. 

EN 

6 

  EN 

 
 
 
MANAGEMENT MEASURES  

2.1.  Monitoring and reporting rules  

N/A 

2.2.  Management and control system(s)  

2.2.1. 

Justification  of  the  budget  implementation  method(s),  the  funding  implementation 
mechanism(s), the payment modalities and the control strategy proposed 

N/A 

2.2.2. 

Information concerning the risks identified and the internal control system(s) set up 
to mitigate them 

N/A 

2.2.3.  Estimation  and  justification  of  the  cost-effectiveness  of  the  controls  (ratio  between 
the control costs and the value of the related funds managed), and assessment of the 
expected levels of risk of error (at payment & at closure)  

N/A 

2.3.  Measures to prevent fraud and irregularities  

N/A 

EN 

7 

  EN 

 
3. 

3.1. 

ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE  

Heading(s)  of  the  multiannual  financial  framework  and  expenditure  budget 
line(s) affected  

•  Existing budget lines  

In order of multiannual financial framework headings and budget lines. 

Heading of 
multiannual 
financial 
framework 

Number  

N/A 

Budget line 

Type of 
expenditure 

Diff./Non-
diff.1 

from 
EFTA 
countries2 

Contribution  

from 
candidate 
countries 
and 
potential 
candidates3 

From 
other 
third 
countries 

other assigned 
revenue 

Diff./Non
-diff. 

YES/NO  YES/NO  YES/NO 

YES/NO 

•  New budget lines requested  

In order of multiannual financial framework headings and budget lines. 

Budget line 

Type of 
expenditure 

Heading of 
multiannual 
financial 
framework 

Number  

Diff./Non-
diff. 

from 
EFTA 
countries 

Contribution  

from 
candidate 
countries 
and 
potential 
candidates 

from 
other 
third 
countries 

other assigned 
revenue  

N/A 

[XX.YY.YY.YY] 

[XX.YY.YY.YY] 

Diff./Non
-diff. 

Diff./Non
-diff. 

Diff./Non
-diff. 

YES/NO  YES/NO  YES/NO 

YES/NO 

YES/NO  YES/NO  YES/NO 

YES/NO 

YES/NO  YES/NO  YES/NO 

YES/NO 

1 
2 
3 

Diff. = Differentiated appropriations / Non-diff. = Non-differentiated appropriations. 
EFTA: European Free Trade Association.  
Candidate countries and, where applicable, potential candidates from the Western Balkans. 

EN 

8 

  EN 

 
 
 
 
 
 
 
 
 
 
 
 
3.2. 

Estimated financial impact of the proposal on appropriations  

3.2.1. 

Summary of estimated impact on operational appropriations  

–    The proposal/initiative does not require the use of operational appropriations  

–    The proposal/initiative requires the use of operational appropriations, as explained below 

3.2.1.1.  Appropriations from voted budget 

Heading of multiannual financial framework  

Number 

EUR million (to three decimal places) 

DG: <…….> 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL MFF 
2021-2027 

Operational appropriations  

Budget line 

Budget line 

Commitments 

Payments 

Commitments 

Payments 

(1a) 

(2a) 

(1b) 

(2b) 

Appropriations of an administrative nature financed from the envelope of specific programmes1 
Budget line 

(3) 

TOTAL appropriations 
for DG <…….> 

Commitments 

Payments 

=1a+1b+3 

=2a+2b+3 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

DG: <…….> 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL MFF 
2021-2027 

Operational appropriations  
Budget line 

Commitments 

(1a) 

0.000 

1 

Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former ‘BA’ lines), indirect research, direct research. 

EN 

9 

EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Budget line 

Payments 

Commitments 

Payments 

(2a) 

(1b) 

(2b) 

Appropriations of an administrative nature financed from the envelope of specific programmes2 
Budget line 

(3) 

TOTAL appropriations 
for DG <…….> 

Commitments 

Payments 

=1a+1b+3 

=2a+2b+3 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

TOTAL 

operational 

appropriations  

Commitments 

Payments 

TOTAL  appropriations  of  an  administrative  nature  financed 
from the envelope for specific programmes  

TOTAL appropriations under 
HEADING <….> 

Commitments 

of the multiannual financial framework 

Payments 

(4) 

(5) 

(6) 

=4+6 

=5+6 

Heading of multiannual financial  
framework  

Number 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL MFF 
2021-2027 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

DG: <…….> 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL MFF 
2021-2027 

Operational appropriations  
Budget line 

Commitments 

(1a) 

0.000 

2 

Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former ‘BA’ lines), indirect research, direct research. 

EN 

10 

EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Budget line 

Payments 

Commitments 

Payments 

(2a) 

(1b) 

(2b) 

Appropriations of an administrative nature financed from the envelope of specific programmes3  
Budget line 

(3) 

TOTAL appropriations 
for DG <…….> 

Commitments 

Payments 

=1a+1b +3 

=2a+2b+3 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

DG: <…….> 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL MFF 
2021-2027 

Operational appropriations  

Budget line 

Budget line 

Commitments 

Payments 

Commitments 

Payments 

(1a) 

(2a) 

(1b) 

(2b) 

Appropriations of an administrative nature financed from the envelope of specific programmes4  
Budget line 

(3) 

TOTAL appropriations 
for DG <…….> 

Commitments 

Payments 

=1a+1b +3 

=2a+2b+3 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

TOTAL 

operational 

appropriations  

Commitments 

(4) 

0.000 

0.000 

0.000 

0.000 

0.000 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL MFF 
2021-2027 

3 
4 

Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former ‘BA’ lines), indirect research, direct research. 
Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former ‘BA’ lines), indirect research, direct research. 

EN 

11 

EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Payments 

TOTAL  appropriations  of  an  administrative  nature  financed 
from the envelope for specific programmes  

TOTAL appropriations under 
HEADING <….> 

Commitments 

of the multiannual financial framework 

Payments 

(5) 

(6) 

=4+6 

=5+6 

•  TOTAL  operational  appropriations 
operational headings) 

(all 

Commitments 

Payments 

•  TOTAL  appropriations  of  an  administrative  nature  financed 
from  the  envelope  for  specific  programmes  (all  operational 
headings) 

TOTAL appropriations Under Heading 1 
to 6 

Commitments 

of the multiannual financial framework 
(Reference amount) 

Payments 

(4) 

(5) 

(6) 

=4+6 

=5+6 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

Year 

2024 

Year 

2025 

0.000 

Year 

2026 

0.000 

Year 

2027 

0.000 

0.000 

TOTAL MFF 
2021-2027 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

Heading of multiannual financial framework  

7 

‘Administrative expenditure’5 

DG: <…….> 

 Human resources  
 Other administrative expenditure  

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL 
MFF 2021-
2027 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

5 

The necessary appropriations should be determined using the annual average cost figures available on the appropriate BUDGpedia webpage. 

EN 

12 

EN 

 
 
 
 
 
 
 
 
 
 
 
 
TOTAL DG <…….> 

Appropriations  

0.000 

0.000 

0.000 

0.000 

0.000 

DG: <…….> 

 Human resources  
 Other administrative expenditure  
TOTAL DG <…….> 

Appropriations  

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

TOTAL 
MFF 2021-
2027 

0.000 

0.000 

0.000 

TOTAL appropriations under HEADING 7 of the multiannual financial 
framework  

(Total 
commitments 
= Total 
payments) 

0.000 

0.000 

0.000 

0.000 

0.000 

EUR million (to three decimal places) 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL MFF 
2021-2027 

TOTAL appropriations under HEADINGS 1 to 7 

Commitments 

0.000 

0.000 

0.000 

0.000 

of the multiannual financial framework  

Payments 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

3.2.1.2.  Appropriations from external assigned revenues 

Heading of multiannual financial framework  

Number 

EUR million (to three decimal places) 

DG: <…….> 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL MFF 
2021-2027 

Operational appropriations  
Budget line 

Commitments 

(1a) 

0.000 

EN 

13 

EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Budget line 

Payments 

Commitments 

Payments 

(2a) 

(1b) 

(2b) 

Appropriations of an administrative nature financed from the envelope of specific programmes6 
Budget line 

(3) 

TOTAL appropriations 
for DG <…….> 

Commitments 

Payments 

=1a+1b+3 

=2a+2b+3 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

DG: <…….> 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL MFF 
2021-2027 

Operational appropriations  

Budget line 

Budget line 

Commitments 

Payments 

Commitments 

Payments 

(1a) 

(2a) 

(1b) 

(2b) 

Appropriations of an administrative nature financed from the envelope of specific programmes7 
Budget line 

(3) 

TOTAL appropriations 
for DG <…….> 

Commitments 

Payments 

=1a+1b+3 

=2a+2b+3 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

TOTAL 

operational 

appropriations  

Commitments 

Payments 

(4) 

(5) 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL MFF 
2021-2027 

6 
7 

Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former ‘BA’ lines), indirect research, direct research. 
Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former ‘BA’ lines), indirect research, direct research. 

EN 

14 

EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
TOTAL  appropriations  of  an  administrative  nature  financed 
from the envelope for specific programmes  

TOTAL appropriations under 
HEADING <….> 

Commitments 

of the multiannual financial framework 

Payments 

Heading of multiannual financial framework  

Number 

Operational appropriations  

Budget line 

Budget line 

DG: <…….> 

Commitments 

Payments 

Commitments 

Payments 

(6) 

=4+6 

=5+6 

(1a) 

(2a) 

(1b) 

(2b) 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL MFF 
2021-2027 

Appropriations of an administrative nature financed from the envelope of specific programmes8 
Budget line 

(3) 

TOTAL appropriations 
for DG <…….> 

Commitments 

Payments 

=1a+1b+3 

=2a+2b+3 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

DG: <…….> 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL MFF 
2021-2027 

Operational appropriations  

Budget line 

Commitments 

Payments 

(1a) 

(2a) 

0.000 

0.000 

8 

Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former ‘BA’ lines), indirect research, direct research. 

EN 

15 

EN 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Budget line 

Commitments 

Payments 

(1b) 

(2b) 

Appropriations of an administrative nature financed from the envelope of specific programmes9 
Budget line 

(3) 

TOTAL appropriations 
for DG <…….> 

Commitments 

Payments 

=1a+1b+3 

=2a+2b+3 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

TOTAL 

operational 

appropriations  

Commitments 

Payments 

TOTAL  appropriations  of  an  administrative  nature  financed 
from the envelope for specific programmes  

TOTAL appropriations under 
HEADING <….> 

Commitments 

of the multiannual financial framework 

Payments 

(4) 

(5) 

(6) 

=4+6 

=5+6 

•  TOTAL  operational  appropriations 
operational headings) 

(all 

Commitments 

Payments 

•  TOTAL  appropriations  of  an  administrative  nature  financed 
from  the  envelope  for  specific  programmes  (all  operational 
headings) 

(4) 

(5) 

(6) 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL MFF 
2021-2027 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL MFF 
2021-2027 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

9 

Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former ‘BA’ lines), indirect research, direct research. 

EN 

16 

EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
TOTAL appropriations under Headings 1 
to 6 

Commitments 

of the multiannual financial framework (Reference 
amount) 

Payments 

=4+6 

=5+6 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

Heading of multiannual financial framework  

7 

‘Administrative expenditure’10 

DG: <…….> 

 Human resources  
 Other administrative expenditure  

TOTAL DG <…….> 

Appropriations  

DG: <…….> 

 Human resources  
 Other administrative expenditure  

TOTAL DG <…….> 

Appropriations  

EUR million (to three decimal places) 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

TOTAL 
MFF 2021-
2027 

0.000 

0.000 

0.000 

TOTAL 
MFF 2021-
2027 

0.000 

0.000 

0.000 

TOTAL appropriations under HEADING 7 of the multiannual 
financial framework  

(Total 
commitments 
= Total 
payments) 

0.000 

0.000 

0.000 

0.000 

0.000 

Year 

Year 

Year 

Year 

TOTAL MFF 

EUR million (to three decimal places) 

10 

The necessary appropriations should be determined using the annual average cost figures available on the appropriate BUDGpedia webpage. 

EN 

17 

EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
TOTAL appropriations under HEADINGS 1 to 7 

Commitments 

0.000 

0.000 

0.000 

0.000 

0.000 

of the multiannual financial framework  

Payments 

0.000 

0.000 

0.000 

0.000 

0.000 

2024 

2025 

2026 

2027 

2021-2027 

3.2.2.  Estimated output funded from operational appropriations (not to be completed for decentralised agencies) 

Year  
2024 

Year  
2025 

Year  
2026 

Year  
2027 

OUTPUTS 

Commitment appropriations in EUR million (to three decimal places) 

Enter as many years as necessary to show the 
duration of the impact (see Section1.6) 

TOTAL 

o
N

Cost 

o
N

Cost 

o
N

Cost 

o
N

Cost 

o
N

Cost  N

o

Cost 

o
N

Cost 

Total 
No 

Total 
cost 

Indicate 
objectives and 
outputs  

 

Type11 

Avera
ge 
cost 

SPECIFIC OBJECTIVE No 112… 

- Output 

- Output 

- Output 

Subtotal for specific objective No 1 

SPECIFIC OBJECTIVE No 2 ... 

- Output 

Subtotal for specific objective No 2 

11 
12 

Outputs are products and services to be supplied (e.g. number of student exchanges financed, number of km of roads built, etc.). 
As described in Section 1.3.2. ‘Specific objective(s)’  

EN 

18 

EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
TOTALS 

EN 

19 

EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
3.2.3. 

Summary of estimated impact on administrative appropriations  

–  X  The  proposal/initiative  does  not  require  the  use  of  appropriations  of  an 

administrative nature  

–    The proposal/initiative requires the use of appropriations of an administrative 

nature, as explained below 

3.2.3.1. Appropriations from voted budget 

VOTED APPROPRIATIONS 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL 
2021 - 2027 

HEADING 7 

Human resources  

Other administrative expenditure  

Subtotal HEADING 7 

Outside HEADING 7 

Human resources  

Other expenditure of an administrative nature 

Subtotal outside HEADING 7 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

TOTAL 

0.000 

0.000 

0.000 

0.000 

0.000 

3.2.3.2.  Appropriations from external assigned revenues 

EXTERNAL ASSIGNED REVENUES 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL 
2021 - 2027 

HEADING 7 

Human resources  

Other administrative expenditure  

Subtotal HEADING 7 

Outside HEADING 7 

Human resources  

Other expenditure of an administrative nature 

Subtotal outside HEADING 7 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

TOTAL 

0.000 

0.000 

0.000 

0.000 

0.000 

3.2.3.3.  Total appropriations 

TOTAL 
VOTED APPROPRIATIONS + EXTERNAL 
ASSIGNED REVENUES 

Year 

Year 

Year 

Year 

2024 

2025 

2026 

2027 

TOTAL 
2021 - 
2027 

HEADING 7 

Human resources  

Other administrative expenditure  

Subtotal HEADING 7 

Outside HEADING 7 

Human resources  

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

EN 

20 

  EN 

 
 
 
Other expenditure of an administrative nature 

Subtotal outside HEADING 7 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

TOTAL 

0.000 

0.000 

0.000 

0.000 

0.000 

The  appropriations  required  for  human  resources  and  other  expenditure  of  an  administrative  nature 
will  be  met  by  appropriations  from  the  DG  that  are  already  assigned  to  management  of  the  action 
and/or  have  been  redeployed  within  the  DG,  together,  if  necessary,  with  any  additional  allocation 
which may be granted to the managing DG under the annual allocation procedure and in the light of 
budgetary constraints. 

3.2.4.  Estimated requirements of human resources  

–    The proposal/initiative does not require the use of human resources  

–    The  proposal/initiative  requires  the  use  of  human  resources,  as  explained 

below 

3.2.4.1.  Financed from voted budget 

VOTED APPROPRIATIONS 

Estimate to be expressed in full-time equivalent units (FTEs)1 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

 Establishment plan posts (officials and temporary staff) 

20 01 02 01 (Headquarters and Commission’s Representation Offices) 

20 01 02 03 (EU Delegations) 

01 01 01 01 (Indirect research) 

01 01 01 11 (Direct research) 

Other budget lines (specify) 

• External staff (inFTEs) 

20 02 01 (AC, END from the ‘global envelope’) 

20 02 03 (AC, AL, END and JPD in the EU Delegations) 

Admin. Support 
line 
[XX.01.YY.YY] 

- at Headquarters 

- in EU Delegations  

01 01 01 02 (AC, END - Indirect research) 

01 01 01 12 (AC, END - Direct research) 

Other budget lines (specify) - Heading 7 

Other budget lines (specify) - Outside Heading 7 

TOTAL 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

3.2.4.2.  Financed from external assigned revenues 

EXTERNAL ASSIGNED REVENUES 

 Establishment plan posts (officials and temporary staff) 

20 01 02 01 (Headquarters and Commission’s Representation Offices) 

20 01 02 03 (EU Delegations) 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

0 

0 

0 

0 

0 

0 

0 

0 

1 

Please specify below the table how many FTEs within the number indicated are already assigned to the 
management of the action and/or can be redeployed within your DG and what are your net needs. 

EN 

21 

  EN 

 
 
 
01 01 01 01 (Indirect research) 

01 01 01 11 (Direct research) 

Other budget lines (specify) 

• External staff (in full time equivalent units) 

20 02 01 (AC, END from the ‘global envelope’) 

20 02 03 (AC, AL, END and JPD in the EU Delegations) 

Admin. Support 
line  
[XX.01.YY.YY] 

- at Headquarters 

- in EU Delegations  

01 01 01 02 (AC, END - Indirect research) 

01 01 01 12 (AC, END - Direct research) 

Other budget lines (specify) - Heading 7 

Other budget lines (specify) - Outside Heading 7 

TOTAL 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

3.2.4.3.  Total requirements of human resources 

TOTAL VOTED APPROPRIATIONS + EXTERNAL ASSIGNED 
REVENUES 

Year 

Year 

Year 

Year 

2024 

2025 

2026 

2027 

 Establishment plan posts (officials and temporary staff) 

20 01 02 01 (Headquarters and Commission’s Representation Offices) 

20 01 02 03 (EU Delegations) 

01 01 01 01 (Indirect research) 

01 01 01 11 (Direct research) 

Other budget lines (specify) 

• External staff (in full time equivalent units) 

20 02 01 (AC, END from the ‘global envelope’) 

20 02 03 (AC, AL, END and JPD in the EU Delegations) 

Admin. Support 
line  
[XX.01.YY.YY] 

- at Headquarters 

- in EU Delegations  

01 01 01 02 (AC, END - Indirect research) 

01 01 01 12 (AC, END - Direct research) 

Other budget lines (specify) - Heading 7 

Other budget lines (specify) - Outside Heading 7 

TOTAL 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

The staff required to implement the proposal (in FTEs): N/A 

To be covered by 
current staff 
available in the 
Commission 
services  

Exceptional additional staff* 

To be financed 
under Heading 7 
or Research 

To be financed 
from BA line 

To be financed 
from fees 

EN 

22 

  EN 

 
 
 
 
N/A 

Establishment 
plan posts 

External 
staff 
(CA, SNEs, INT) 

* 

Description of tasks to be carried out by: 

Officials and temporary staff 

External staff 

3.2.5.  Overview of estimated impact on digital technology-related investments 

Compulsory: the best estimate of the digital technology-related investments entailed 
by the proposal/initiative should be included in the table below.  

Exceptionally,  when  required  for  the  implementation  of  the  proposal/initiative,  the 
appropriations under Heading 7 should be presented in the designated line.  

The appropriations under Headings 1-6 should be reflected as “Policy IT expenditure 
on operational programmes”. This expenditure refers to the operational budget to be 
used to re-use/ buy/ develop IT platforms/ tools directly linked to the implementation 
of the initiative and their associated investments (e.g. licences, studies, data storage 
etc).  The  information  provided  in  this  table  should  be  consistent  with  details 
presented under Section 4 “Digital dimensions”. 

TOTAL Digital and IT appropriations 

Year 

Year 

Year 

Year 

2024 

2025 

2026 

2027 

TOTAL 
MFF 
2021 - 
2027 

HEADING 7 

IT expenditure (corporate)  

Subtotal HEADING 7 

Outside HEADING 7 

Policy IT expenditure on operational 
programmes 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

Subtotal outside HEADING 7 

0.000 

0.000 

0.000 

0.000 

0.000 

TOTAL 

0.000 

0.000 

0.000 

0.000 

0.000 

3.2.6.  Compatibility with the current multiannual financial framework  

The proposal/initiative: 

–    can be fully financed through redeployment within the relevant heading of the 

multiannual financial framework (MFF) 

–    requires use of the unallocated margin under the relevant heading of the MFF 

and/or use of the special instruments as defined in the MFF Regulation 

–    requires a revision of the MFF 

EN 

23 

  EN 

 
 
 
 
 
 
 
 
 
 
 
3.2.7.  Third-party contributions  

The proposal/initiative: 

–    does not provide for co-financing by third parties 

–    provides for the co-financing by third parties estimated below: 

Appropriations in EUR million (to three decimal places) 

Year  
2024 

Year  
2025 

Year  
2026 

Year  
2027 

Total 

Specify the co-financing body  

TOTAL appropriations co-
financed  

3.3. 

Estimated impact on revenue  

–    The proposal/initiative has no financial impact on revenue. 

–    The proposal/initiative has the following financial impact: 

– 

– 

– 

Budget revenue line: 

Article …………. 

 

 

on own resources  

on other revenue 

  please indicate, if the revenue is assigned to expenditure lines 

Appropriations 
available for the 
current financial 
year 

EUR million (to three decimal places) 

Impact of the proposal/initiative2 

Year 2024 

Year 2025  Year 2026 

Year 2027 

For assigned revenue, specify the budget expenditure line(s) affected. 

Other  remarks  (e.g.  method/formula  used  for  calculating  the  impact  on  revenue  or 
any other information). 

4. 

DIGITAL DIMENSIONS 

4.1. 

Requirements of digital relevance 

-  Reference  to  Article:  Article  1  (1)  Description:  Definition  of  small  mid-cap  enterprises; 
affected  stakeholders  :  Member  states,  legal  entities  operators  in  scope  of  this  directive; 
High level process: Assess SMC status; Category: Data 

2 

As regards traditional own resources (customs duties, sugar levies), the amounts indicated must be net 
amounts, i.e. gross amounts after deduction of 20% for collection costs. 

EN 

24 

  EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
-  Reference  to  Article:  Article  1(2)  ;  Description:  Rules  for  admission  on  trading  on  the 
MTF;  Affected  stakeholders:  Member  States;  High  level  process:  Control  admission 
process; Category: Data;Digital Solution, Digital Public Service 

- Reference to Article: Article 2 ; Description:  Includes the new SMC category as part of 
elaborating  on  the  existence  of  a  strategy  for  businesses  including  SMEs  and  SMCs; 
Affected  stakeholders:  Member  States;  High  level  process:  Define  resilience  strategy  for 
critical entities; Category: Data;Digital Solution, Digital Public Service 

4.2. 

Data 

SMC status as specified in Article 1 (1) and Article 2. 

4.3. 

Digital solutions 

N/A 

4.4. 

Interoperability assessment 

Digital  public  service:  Admission  for  trading  on  MTF  markets  and  Critical  entities 
Resilience public service. 

Legal  layer  measure  :  the  new  recommendation  on  the  SMC  definition  provides  a 
harmonised understanding of SMC that can be used cross sectors and cross borders. 

Legal layer potential barrier solution: 

- 

the reference to the annual accounts of companies facilitates the assessment of the 
enterprises to which the rules will apply.  

-  Future interoperability with digital company law and platforms such as BRIS should 

be explored. 

-  The  development  of  an  SME/SMC  ID  will  reduce  the  administrative  burden  of 
declarations  and  assessments  of  the  applicable  status  of  a  company  and  allow  for 
exchange between managing authorities and other relevant actors. 

Semantic layer potential barrier:  neither the SME nor the SMC  definition are prescriptive 
beyond the reference to  the annual  financial accounts of companies. For digital solutions, 
the correlation between the SME/SMC definition and data stemming from  the accounting 
directive eg should be exploited. 

Technical interoperability potential barrier: No format has been defined for the data in the 
SME/SMC definition.   

4.5.  Measures to support digital implementation 

The  new  recommendation  on  SMC  definition  provides  a  harmonised  understanding  of 
SME/SMC that can be used cross sectors and cross borders. 

EN 

25 

  EN