Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulations (EU) 2016/679, (EU) 2016/1036, (EU) 2016/1037, (EU) 2017/1129, (EU) 2023/1542 and (EU) 2024/573 as regards the extension of certain mitigating measures available for small and medium sized enterprises to small mid-cap enterprises and further simplification measures
Date: 2025-07-02
Institutions: Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, European Commission
Subjects: administrative formalities, competition law, data-processing law, electricity storage device, environmental law, financial legislation, financial market, market access, single market, size of business

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   EUROPEAN COMMISSION  Brussels, 2.7.2025  COM(2025) 501 final/3 2025/0130 (COD)  Cancels and replaces the Word version COM(2025) 501 final/2 transmitted on 23.5.2025 Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulations (EU) 2016/679, (EU) 2016/1036, (EU) 2016/1037, (EU) 2017/1129, (EU) 2023/1542 and (EU) 2024/573 as regards the extension of certain mitigating measures available for small and medium sized enterprises to small mid-cap enterprises and further simplification measures {SWD(2025) 501 final}  
 
 
EXPLANATORY MEMORANDUM 

1.1. 

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 
through 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 and committed to reduce 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.  

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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. enterprises 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. 

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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  that  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  Directive  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 

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final, 

available 

SME  Relief  Package,  COM/2023/535 
at:  https://eur-lex.europa.eu/legal-
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 enterprises 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 
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32014R0651 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv%3AOJ.C_.2021.508.01.0001.01.ENG&toc=OJ%3AC%3A2021%3A508
%3ATOC 

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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 
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,  in  acts  where 
SMEs  are  defined  by  reference  to  parts  of  the  Annex  to  Commission  Recommendation 
2003/361/EC,  such as  the thresholds set  out  in  Article 2 of that  Recommendation, a similar 
approach will be applied when defining SMCs.  

The aim is to support SMCs dealing with similar challenges to those of 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 and 
propose simplification measures to the benefit of SMEs and SMCs in the following legislation 
acts: 

•  Regulation (EU) 2016/679 lays down provisions on general data protection (GDPR). 
Article 30 of Regulation (EU) 2016/679 states that each controller and processor must 
maintain  a  record  of  processing  activities  and  sets  out  what  information  this  record 
should  contain.  Paragraph  5  of  Article  30  provides  for  a  derogation  for  SMEs  and 
organisations  with  fewer  than  250  employees,  whereby  such  entities  do  not  have  to 
keep such record, provided that certain conditions are fulfilled. This proposal aims to 
simplify  and  clarify  the  derogation  from  the  record-keeping  obligation  under  that 
article  by  making  the  record-keeping  mandatory  only  when  the  processing  activities 
are likely to result in a ‘high risk’ to data subjects’ rights and freedoms. At the same 
time,  the  scope  of  the  derogation  should  be  broadened  to  include  SMCs  and 
organisations with fewer than 750 employees. 

Article  40  of  Regulation  (EU)  2016/679  lays  down  that  the  Member  States,  the 
supervisory authorities, the  Board, and the  Commission must encourage  associations 
and other bodies representing categories of controllers or processors to draw up codes 
of  conduct,  taking  account  of  the  specific  features  of  the  various  processing  sectors 
and the specific needs of micro, small and medium-sized enterprises. The scope of this 
provision should be extended to SMCs, so that their specific needs are also taken into 
account when codes of conduct are drawn up.   

Article  42  of  Regulation  (EU)  2016/679  lays  down  that  the  Member  States,  the 
supervisory authorities, the Board and the Commission must encourage, in particular 
at  Union  level,  the  establishment  of  data  protection  certification  mechanisms  and  of 
data protection seals and marks by certification bodies referred to in Article 43 GDPR, 
or  by  competent  supervisory  authorities,  and  in  that  context  the  specific  needs  of 
SMEs shall be taken into account. The scope of this provision should be extended to 
SMCs, so that their specific needs are also taken into account when certifications are 
issued. 

•  Regulation (EU) 2016/1036 on protection against dumped imports from countries not 
members of the European Union, includes provisions to facilitate access of SMEs to 

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trade  defence  instruments,  namely  by  providing  general  information  and,  where 
possible, facilitating procedures for them. Article 5 (1a) of Regulation (EU) 2016/1036 
aims at facilitating access to the trade defence instrument. In that context, assistance to 
SMEs  is  provided  through  a  dedicated  helpdesk  which  helps  them  with  general 
information and explanations on procedures and on how to submit a complaint, or by 
releasing standard questionnaires. In order to ensure that SMCs also benefit from the 
guidance and assistance of a helpdesk, the scope of this provision should be extended 
to  them.  Article  6  (9)  of  Regulation  (EU)  2016/1036  provides  for  the  timing  of  the 
investigation procedures. It lays down a provision whereby investigation periods shall, 
whenever  possible,  coincide  with  the  financial  year  for  fragmented  sectors  largely 
composed of SMEs. The scope of this provision should be extended to SMCs so that 
they  also  benefit  from  the  facilitation  and  predictability  brought  about  by  aligning 
investigation periods with the financial year. 

•  Regulation (EU) 2016/1037 on protection against subsidised imports from countries 
not  members  of  the  European  Union,  includes  provisions  to  facilitate  access  to  the 
trade  defence  instrument.  In  that  context,  assistance  to  SMEs  is  provided  through  a 
dedicated  Helpdesk  which  helps  them  with  general  information  and  explanations  on 
procedures and on how to submit a complaint, or by releasing standard questionnaires. 
In  order  to  ensure  that  SMCs  also  benefit  from  the  guidance  and  assistance  of  a 
helpdesk,  the  scope  of  this  provision  should  be  extended  to  them.    Article  11  (9)  of 
Regulation (EU) 2016/1037 provides for the timing of the investigation procedures. It 
lays  down  a  provision  whereby  investigation  periods  shall,  whenever  possible, 
coincide  with  the  financial  year  for  fragmented  sectors  largely  composed  of  SMEs. 
The scope of this provision should be extended to SMCs so that they also benefit from 
the facilitation and predictability brought about by aligning investigation proceedings 
with the financial year. 

•  Regulation (EU) 2017/1129, as amended by Regulation (EU) 2024/2809, refers to the 
possibility  of  creating  an  alleviated  form  of  a  prospectus  –  an  EU  Growth  issuance 
prospectus.  That  type  of  prospectus  may  typically  be  drawn  up  by  SMEs  and,  in 
certain cases, also by other types of companies. It would be appropriate to extend the 
use  of  that  alleviated  prospectus  also  to  SMCs  to  reduce  their  cost  of  listing  and 
potentially  make  those  companies  more  attractive  to  investors,  thus  facilitating  the 
access to funding by SMCs. 

Since Regulation (EU) 2017/1129 has been amended by Regulation (EU) 2024/2809, 
the provision concerning the EU Growth issuance prospectus will apply as of 5 March 
2026. It is therefore appropriate to also delay the application date of the amendments 
to Regulation (EU) 2017/1129 set out in this Regulation until 5 March 2026.  

•  Regulation  (EU)  2023/1542  lays  down  provisions  on  batteries.  Article  47  of 
Regulation  (EU)  2023/1542  exempts  SMEs  from  certain  obligations  on  battery  due 
diligence  policies.  The  scope  of  this  provision  should  be  extended  to  SMCs,  so  that 
they  are  also  exempted  from  these  obligations.  Further  to  Article  52,  the  economic 
operators referred to in Article 48(1) are required - on an annual basis – to review and 
make  publicly  available,  including  on  the  Internet,  a  report  on  their  battery  due 
diligence  policy.  With  a  view  to  reducing  the  administrative  burden  on  economic 
operators, this requirement to review and make publicly available their due diligence 
policy should be amended so that it applies every three years instead of annually. This 
burden reduction measure should apply to all economic operators, including SMCs. 

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•  Regulation (EU) 2024/573 on fluorinated greenhouse gases16 (F-gas Regulation) lays 
down  provisions,  among  others,  on  products  and  equipment  containing  fluorinated 
greenhouse  gases.  The  F-gas  Regulation  that  entered  into  force  in  2024  expanded  a 
registration requirement in the F-gas Portal to all imports of products and equipment, 
including those imports that are not subject to reporting requirements. It also includes 
a  new  registration  obligation  for  exports  of  products  and  equipment  containing  F-
gases, including those exports that are not subject to an export restriction. If a trader is 
not able to present  a valid registration in the  F-gas Portal,  customs  should block the 
goods. Such trade licenses mainly serve the purpose of facilitating enforcement. 

Since  the  entry  into  force  of  the  Regulation,  the  Commission  received  many 
registration requests and inquiries from traders in products and equipment containing 
F-gases. They mostly concern relatively small companies that trade with used cars that 
have  F-gases  in  the  air-conditioning  equipment,  for  which  there  are  no  restrictions, 
that require enforcement.   

To register, importers and exporters must submit an electronic application form to the 
Commission  and  provide  the  required  information  related  to  their  business  activities 
and their legal and financial identity. The Commission validates the registration in the 
F-gas Portal.  

It  appears  that  this  requirement  is  not  fully  proportionate,  and  that  the  registration 
requirement  should  be  better  targeted  to  companies  that  perform  activities  that  are 
covered  by  other  obligations  in  the  F-gas  Regulation  to  serve  the  purpose  of 
facilitating the enforcement. It is therefore proposed to limit the obligation to imports 
that  also  need  to  be  reported  and  to  exports  that  are  covered  by  limitations  on  the 
global  warming  potential  of  the  F-gas  contained  in  the  products  and  equipment. 
Furthermore,  this  amendment  is  in  line  with  the Commission’s  Impact  Assessment17 
that  did  not include  any  extended obligation  for importers  and  exporters  of  products 
and  equipment  in  the  preferred  option,  while  at  the  same  time  respecting  the 
intervention logic regarding the need to facilitate the enforcement of a new limitation 
on certain exported products and equipment that was introduced by the co-legislators. 
This simplification is expected to mainly benefit SMEs and SMCs. 

• 

Consistency with existing policy provisions in the policy area 

This  proposal  is  part  of  a  package  of  measures  aimed  at  cutting  red  tape  for  SMCs  by 
extending  to  them  certain  provisions  that  SMEs  currently  benefit  from.  Its  purpose  is  to 
deliver  on  the  Commission’s  commitment  to  i)  make  business  easier  and  reduce 
administrative burden, and ii) extend proportionality in EU law to SMCs. 

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. 

The  proposed  amendment  to  the  F-gas  Regulation  only  targets  registration  requirements  for 
importers and exporters of products and equipment, typically in small quantities, which do not 
affect the effectiveness of the Regulation or the fulfilment of international obligations under 
the Montreal Protocol. 

16 
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https://eur-lex.europa.eu/eli/reg/2024/573/oj 
SWD(2022) 96 final 

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• 

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. 

2. 

• 

LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY 

Legal basis 

This proposal is based on Article 16, Article 114,  Article 192 (1) and Article 207 (2) of the 
Treaty  on  the  Functioning  of  the  European  Union,  which  are  the  legal  basis  of  the  acts  it 
amends.  To  the  extent  that  this  Regulation  amends  Regulation  (EU)  2023/1542,  the 
appropriate  legal  basis  in  so  far  as  those  amendments  are  concerned,  is  Article  114.  This 
proposal does not amend specific rules on the management of waste batteries which would be 
based on Article 192(1) of the Treaty. To the extent that this Regulation amends Regulation 
(EU)  2024/573  the  appropriate  legal  basis,  in  so  far  as  those  amendments  are  concerned,  is 
Article 192(1) TFEU.   

All 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  such  legislation  easier  to  apply  and  less 
burdensome for them. 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 companies 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 the rules currently applicable to SMEs, as 
well as from the amendment of the F-gas Regulation. 

• 

Proportionality 

Extending  to  SMCs  certain  provisions  already  applicable  to  SMEs  simplifies  the  legal 
framework  by  making  minimum  changes  to  existing  obligations  for  Member  States,  which 
should  hereinafter  confer  to  SMCs  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 chosen 
by the co-legislator for those acts, and cover enterprises that are three times the size of those 
SMEs. 

As  regards  the  amendment  of  the  F-gas  Regulation,  the  simplification  is  ensuring  that  the 
proportionality of the registration requirement is improved. 

3. 

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N/A. 

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RESULTS 
CONSULTATIONS AND IMPACT ASSESSMENTS 

EX-POST 

EVALUATIONS, 

OF 

STAKEHOLDER 

Ex-post evaluations/fitness checks of existing legislation 

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Stakeholder consultations 

• 
In line with the commitment made in the SME Relief Package18 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 definition of small mid-cap enterprises 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  the  6th 
February 2025.  

As regards the F-gas Regulation, the Commission is in direct contact with all traders that need 
to  register  in  the  F-gas  Portal.  During  the  early  months  of  2025,  the  Commission  received 
around 2000 registration requests per month, typically from micro and small enterprises that 
were not covered by the requirement to register under the previous F-gas Regulation and that 
have  no  prior  knowledge  about  the  F-gas  Regulation  or  the  F-gas  Portal.  Many  of  those 
stakeholders had equipment that was being blocked by customs at the border and consider the 
requirements to register to be disproportionate. In addition, one Member State in which many 
of the traders are active, has requested the Commission to simplify the rules. 

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 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 of legislation in view of simplifying it or 
extending  to  SMCs  certain  measures  currently  applicable  to  SMEs.  They  are  based  on 
experience  from  implementing  legislation.  The  changes  only  ensure  a  more  efficient  and 
effective 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. 

As  regards  the  amendment  of  the  F-gas  Regulation,  the  simplification  is  in  line  with  the 
preferred  option  and  intervention  logic  in  the  impact  assessment  accompanying  the 
Commission’s  proposal  in  2022.  The  amendment  will  reduce  the  administrative  costs  for 

18 

SME  Relief  Package,  COM(2023)  535 
content/EN/TXT/?uri=COM%3A2023%3A535%3AFIN 

final,  available  at:  https://eur-lex.europa.eu/legal-

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traders,  in  particular  SMEs  and  SMCs,  while  having  no  negative  impacts  on  reaching  the 
climate  objectives  of  that  Regulation.  On  the  contrary,  it  will  enable  the  Member  States’ 
authorities,  customs  and  the  Commission  to  instead  focus  on  cases  that  are  relevant  for 
enforcing restrictions in the F-gas Regulation. 

• 

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 applicable to SMEs. 

This is a REFIT proposal, aiming to simplify legislation and cut burdens for stakeholders. 

• 

Fundamental rights 

N/A. 

•4. 

BUDGETARY IMPLICATIONS 

N/A. 

5. 

• 

N/A. 

OTHER ELEMENTS 

Implementation plans and monitoring, evaluation and reporting arrangements 

• 

Detailed explanation of the specific provisions of the proposal 

Regarding Regulation (EU) 2016/679 on General Data Protection (GDPR):  

Article  30  states  that  each  controller  and  processor  shall  maintain  a  record  of  processing 
activities and sets out what information this record should contain. Paragraph 5 of this Article 
provides  for  a  derogation  for  SMEs  and  organisations  with  fewer  than  250  employees, 
whereby such entities do not have to keep such a record, provided that certain conditions are 
fulfilled.  This  proposal  aims  to  simplify  and  clarify  the  derogation  from  the  record-keeping 
obligation  under  Article  30(5)  by  making  the  record-keeping  mandatory  only  when  the 
processing activities are likely to result in a ‘high risk’ to data subjects’ rights and freedoms. 
At  the  same  time,  the  scope  of  the  derogation  should  be  broadened  to  include  SMCs  and 
organisations  with  fewer  than  750  employees.  Article  30(5)  should  therefore  be  amended 
accordingly.   

A  recital  in  this  amending  Regulation  will  clarify  that  also  SMCs  are  exempted  from  the 
record-keeping  obligation,  unless  their  processing  is  likely  to  result  in  a  ‘high  risk’  to  data 
subjects,  as  defined  in  Article  35,  and  that  the  processing  of  special  categories  of  personal 
data  in  accordance  with  Article  9(2)(b)  does  not,  as  such,  trigger  the  obligation  to  maintain 
records of processing.   

Article 40 lays down that the Member States, the supervisory authorities, the Board and the 
Commission  must  encourage  associations  and  other  bodies  representing  categories  of 
controllers or processors to draw up codes of conduct, taking account of the specific features 
of  the  various  processing  sectors  and  the  specific  needs  of  micro,  small  and  medium-sized 
enterprises.  The  scope  of  this  provision  should  be  extended  to  SMCs,  so  that  their  specific 
needs  are  also  considered  when  drawing  up  codes  of  conduct.  Consequently,  a  reference  to 
SMCs should be added to Article 40(1).  

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Article 42 lays down that the Member States, the supervisory authorities, the Board and the 
Commission must encourage, in particular at Union level, the establishment of data protection 
certification  mechanisms  and  of  data  protection  seals  and  marks  by  the  certification  bodies 
referred  to  in  Article  43,  or  by  competent  supervisory  authorities,  and  in  that  context,  the 
specific  needs  of  SMEs  must  be  taken  into  account.  The  scope  of  this  provision  should  be 
extended  to  SMCs,  so  that  their  specific  needs  are  also  considered  when  certifications  are 
issued. A reference to SMCs should therefore be added to Article 42(1). 

Regarding Regulation (EU) 2016/1036 on protection against dumped imports from countries 
not members of the European Union: 

Article  5  (1a)  lays  down  that  the  Commission  must  facilitate  access  to  the  trade  defence 
instrument for diverse and fragmented industry sectors, largely composed of SMEs, through a 
dedicated  SME  helpdesk,  for  example  by  raising  awareness,  providing  general  information 
and  explanations  on  procedures  and  on  how  to  submit  a  complaint,  by  releasing  standard 
questionnaires  in  all  official  languages  of  the  Union  and  by  replying  to  general,  non-case-
specific queries. This Article should be amended to extend its scope to SMCs and have them 
benefit equally from the guidance and assistance of a helpdesk. Definitions of both SMEs and 
SMCs should also be included. 

Article 6 (9) lays down that investigation periods must, whenever possible, especially in the 
case of diverse and fragmented sectors largely composed of SMEs, coincide with the financial 
year. This Article should be amended to extend its scope to SMCs in order for them to equally 
benefit from this provision. 

Regarding  Regulation  (EU)  2016/1037  on  protection  against  subsidised  imports  from 
countries not members of the European Union: 

Article  10  (1a)  lays  down  that  the  Commission  must  facilitate  access  to  the  trade  defence 
instrument for diverse and fragmented industry sectors, largely composed of SMEs, through a 
dedicated  SME  helpdesk,  for  example  by  raising  awareness,  providing  general  information 
and  explanations  on  procedures  and  on  how  to  submit  a  complaint,  by  releasing  standard 
questionnaires  in  all  official  languages  of  the  Union  and  by  replying  to  general,  non-case-
specific queries. This Article should be amended to extend its scope to SMCs and have them 
benefit from the guidance and assistance of a helpdesk. Definitions of both SMEs and SMCs 
should also be included. 

Article 11 (9) lays down that investigation periods must, whenever possible, especially in the 
case of diverse and fragmented sectors largely composed of SMEs, coincide with the financial 
year. This Article should be amended to extend its scope to SMCs in order for them to equally 
benefit from this provision. 

Regarding Regulation (EU) 2017/1129 on the prospectus to be published when securities are 
offered to the public or admitted to trading on a regulated market: 

Article 1(4) and (5) of Regulation (EU) 2017/1129 sets out exemptions from the prospectus 
obligation for certain offers of securities to the public or admissions to trading on a regulated 
market.  This  article  should  be  amended  to  include  a  new  exemption  from  the  obligation  to 
publish  a  prospectus  for  offers  of  securities  to  the  public  where  such  offers  result  from  the 
conversion  of  liabilities  executed  by  EU  resolution  authorities  under  the  EU  framework  for 
the  resolution  of  banks  or  insurers  (Directives  2014/59/EU  and  (EU)  2025/1)  or  by  third-
country authorities under a comparable legal framework. Additionally, the existing resolution-
specific exemption from the obligation to publish a prospectus for the admission of securities 
to  trading  on  an  EU  regulated  market  under  Article  1(5),  point  (c)  of  Regulation  (EU) 

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2017/1129  should  be  extended  to  actions  taken  by  third-country  authorities  in  a  similar 
context. 

Article  2  of  Regulation  (EU)  2017/1129  sets  out  the  relevant  definitions  in  the  Regulation. 
This Article should be amended to introduce a definition for SMCs as a distinct category of 
enterprises from SMEs and to introduce, via a cross-reference to Article 2(1), points (88) and 
(90),  of  Directive  2014/59/EU  and  to  Article  2,  points  (72)  and  (74),  of  Directive  (EU) 
2025/1,  definitions  for  a  ‘relevant  third-country  authority’  and  ‘third-country  resolution 
proceedings’.  

Article 15a of Regulation (EU) 2017/1129, as amended by Regulation (EU) 2024/2809, refers 
to  the  possibility  of  creating  an  alleviated  form  of  a  prospectus  –  an  EU  Growth  issuance 
prospectus. That type of prospectus may typically be drawn up by SMEs and, in certain cases, 
also  by  other  types  of  enterprises.  The  use  of  that  alleviated  prospectus  should  also  be 
extended to SMCs to reduce their cost of listing and potentially make those enterprises more 
attractive to investors, thus facilitating SMC access to funding.  

Regarding Regulation (EU) 2023/1542 on batteries and waste batteries:  

Article  47  exempts  SMEs  from  certain  obligations  on  battery  due  diligence  policies.  SMEs 
are described as ‘economic operators that had a net turnover of less than EUR 40 million in 
the financial year preceding the last financial year, and that are not part of a group, consisting 
of  parent  and  subsidiary  undertakings,  which,  on  a  consolidated  basis,  exceeds  the  limit  of 
EUR 40 million’. The scope of this provision should be extended to SMCs, so that they are 
equally exempted from these obligations. To ensure consistency, SMCs  should be described 
in the same way bearing in mind that they are entities three times the size of SMEs, i.e. based 
on a net turnover which should therefore be less than EUR 150 million. 

Further to Article 52, the economic operators referred to in Article 48(1) are required - on an 
annual  basis  –  to  review and make publicly  available, including  on the internet,  a report on 
their  battery  due  diligence  policy.   With  a  view  to  reducing  the  administrative  burden  on 
economic  operators,  this  requirement  to  review  and  make  publicly  available  their  due 
diligence policy should  be amended so that  it applies every three years instead of annually. 
This burden reduction measure should apply to all economic operators, including SMCs. 

Regarding Regulation (EU) 2024/573 on fluorinated greenhouse gases: 

Article 20(4)(a) currently requires all importers and all exporters of products and equipment 
to register in the F-gas Portal. In accordance with Article 20(5), a valid registration in the F-
gas Portal at the moment of import or export constitutes a required licence. To ensure that the 
requirement  to  register  in  the  F-gas  Portal  is  targeted  at  activities  that  are  relevant  for 
enforcement,  Article  20(4)(a)  is  amended  so  that  the  registration  requirement  for  imported 
products and equipment is limited to those imports subject to reporting requirements (which 
include  de-minimis  thresholds),  and  the  registration  requirement  for  exported  products  and 
equipment is removed, except if it concerns exports of certain products and equipment with F-
gases  having  a  Global  Warming  Potential  of  1000  or  more  that  are  subject  to  an  export 
restriction. This simplification measure is expected to mainly benefit SMEs and SMCs. 

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2025/0130 (COD) 

Proposal for a 

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 

amending Regulations (EU) 2016/679, (EU) 2016/1036, (EU) 2016/1037, (EU) 2017/1129, 
(EU) 2023/1542 and (EU) 2024/573 as regards the extension of certain mitigating 
measures available for small and medium sized enterprises to small mid-cap enterprises 
and further simplification 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 16, Article 114, Article 192 (1) and Article 207 (2) 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 Committee1, 
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 

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 rationalise 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 

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. 

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SME definition7, and those in the broader range of small mid-cap enterprises. Action 
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 economy8. 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. 
Regulations (EU) 2016/67910, (EU) 2016/103611, (EU) 2016/103712, (EU) 2017/112913 
and  (EU)  2023/154214  of  the  European  Parliament  and  of  the  Council  contain  a 
number  of  provisions  that  aim  at  providing  support,  simplification  or  mitigating 
measures  to  SMEs.  More  specifically,  those  provisions  are  aimed  at  alleviating 
administrative  burdens,  reducing  or  eliminating  market  entry  barriers,  facilitating 

SMEs are defined as enterprises 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 
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 
Regulation  (EU)  2016/679  of  the  European  Parliament  and  of  the  Council  of  27  April  2016  on  the 
protection of natural persons with regard to the processing of personal data and on the free movement of 
such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, 4.5.2016, 
p. 1, ELI: http://data.europa.eu/eli/reg/2016/679/oj) 
Regulation  (EU)  2016/1036  of  the  European  Parliament  and  of  the  Council  of  8  June  2016  on 
protection  against  dumped  imports  from  countries  not  members  of  the  European  Union  (OJ  L  176, 
30.6.2016, p. 21, ELI: http://data.europa.eu/eli/reg/2016/1036/oj) 
Regulation (EU) 2016/1037 of the European Parliament and of the Council of 8 June 2016 on protection 
against subsidised imports from countries not members of the European Union (OJ L 176, 30.6.2016, p. 
55, ELI: http://data.europa.eu/eli/reg/2016/1037/oj) 
Regulation  (EU)  2017/1129  of  the  European  Parliament  and  of  the  Council  of  14  June  2017  on  the 
prospectus  to  be  published  when  securities  are  offered  to  the  public  or  admitted  to  trading  on  a 
regulated  market,  and  repealing  Directive  2003/71/EC  (OJ  L  168,  30.6.2017,  p.  12,  ELI: 
http://data.europa.eu/eli/reg/2017/1129/oj) 
Regulation (EU) 2023/1542 of the European Parliament and of the Council of 12 July 2023 concerning 
batteries  and  waste  batteries,  amending  Directive  2008/98/EC  and  Regulation  (EU)  2019/1020  and 
ELI: 
repealing 
http://data.europa.eu/eli/reg/2023/1542/oj). 

2006/66/EC 

28.7.2023, 

Directive 

191, 

(OJ 

1, 

p. 

L 

(4) 

(5) 

(6) 

7 

8 

9 
10 

11 

12 

13 

14 

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2 

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(7) 

(8) 

(9) 

compliance,  considering  the  specific  situation  of  SMEs  when  implementing  their 
obligations and when assessing the economic and social impacts of those obligations, 
providing dedicated guidance, support and assistance to SMEs. 

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.  

Regulation (EU) 2016/679 provides for the protection of natural persons with regard to 
the  processing  of  personal  data  and  free  movement  of  such  data.  The  obligation  to 
maintain records of processing should be simplified so that it applies to all enterprises 
and  organisations  with  fewer  than  750  employees,  provided  that  their  processing 
activities are not likely to result in a high risk to the data subjects’ rights and freedoms.  

In order to reflect the above, it is necessary to amend Article 30(5) of Regulation (EU) 
2016/679, by extending the scope of the derogation from the record-keeping obligation 
to SMCs and organisations with fewer than 750 employees to allow also them to profit 
from  that  derogation  and  by  providing  that  the  derogation  applies  unless  the 
processing  is  likely  to  result  in  a  ‘high  risk’  to  data  subjects’  rights  and  freedoms, 
within  the  meaning  of  Article  35  of  Regulation  (EU)  2016/679.  In  particular  the 
processing  of  personal  data  referred  to  in  paragraph  3  of  that  provision  should  be 
considered as requiring the data controller or the processor to maintain records of its 
processing activities.  

(10) 

In this context, the processing of special categories of personal data which is necessary 
for  the  purposes  of  carrying  out  the  obligations  and  exercising  specific  rights  of  the 
controller  or  of  the  data  subject  in  the  field  of  employment  and  social  security  and 
social  protection  law,  as  referred  to  in  Article  9(2),  point  (b),  of  Regulation  (EU) 
2016/679, should not as such require that records of processing be maintained.  

(11)  Furthermore, in order to extend to SMCs, the provisions that are available for micro, 
small  and  medium-sized  enterprises  under  Regulation  (EU)  2016/679,  the  following 
articles should also be amended:  

–  Article 4, which contains the definitions applicable for the purpose of Regulation 
(EU)  2016/679.  For  reasons  of  clarity,  definitions  should  be  added  for  micro, 
small and medium-sized enterprises, and for small mid-cap enterprises. For small 
and  medium-sized  enterprises,  it  is  appropriate  to  follow  the  choice  of  the  co-
legislator  as  expressed  in  recital  (13)  of  the  preamble  to  Regulation  (EU) 
2016/679.  For  SMCs,  reference  should  be  made  to  point  2  of  Commission 
Recommendation  of  21.5.2025  on  the  definition  of  small  mid-cap  enterprises  -  
C(2025) 3500 final.  

–  Article  40,  which  provides  that  Member  States,  the  supervisory  authorities,  the 
Board  and  the  Commission  are  to  encourage  associations  and  other  bodies 
representing categories of controllers or processors to draw up codes of conduct, 
and that the specific needs of micro, small and medium-sized enterprises are to be 
taken into account when doing so. This requirement should be extended to include 
the specific needs of SMCs. 

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–  Article 42, which provides that when Member States, the supervisory authorities, 
the Board and the Commission are to encourage, in particular at Union level, the 
establishment  of  data  protection  certification  mechanisms  and  of  data  protection 
seals and marks by certification bodies referred to in Article 43 of that Regulation 
or  by  competent  supervisory  authorities,  the  specific  needs  of  micro,  small  and 
medium-sized  enterprises  are  to  be  taken  into  account.  This  requirement  should 
also be extended to include the specific needs of SMCs. 

(12)  The  European  Data  Protection  Supervisor  and  the  European  Data  Protection  Board 
were  consulted,  in  accordance  with  Article  42(1)  and  (2)  of  Regulation  (EC) 
2018/1725, and they delivered a joint opinion on [XXX, date]. 

(13)  Regulations  (EU)  2016/1036  and  (EU)  2016/1037  are  part  of  the  Union’s  trade 
defence  system.  They  allow  the  Union  to  investigate  and  address  dumping  and 
subsidisation by third countries and restore a level playing field in the Union market. 
If an investigation confirms the existence of such practices and resulting injury to the 
Union  industry,  the  Commission  imposes  an  anti-dumping  or  countervailing  duty, 
provided  such  imposition  is  not  against  the  Union  interest.  Anti-dumping  and  anti-
subsidy investigations require active involvement from enterprises. Investigations are 
normally initiated on the basis of a formal complaint from the affected Union industry 
that  must  contain  evidence  of  the  unfair  practice  and  of  the  injury  it  has  caused. 
Investigations require active involvement of, and data from, producers, importers and 
users of the product in the Union. Mainly because of their fragmentation and lack of 
resources, it is often very difficult for SMEs to understand trade defence and cooperate 
in  trade  defence  proceedings.  This  is  why  Regulations  (EU)  2016/1036  and  (EU) 
2016/1037  include  provisions  to  overcome  the  barriers  that  stop  smaller  enterprises 
from accessing and using trade defence, namely through a dedicated helpdesk, and by, 
whenever  possible,  aligning  investigation  periods  with  the  financial  year.  It  is 
considered appropriate to ensure that SMCs also benefit from those provisions. 

(14)  Regulation  (EU)  2017/1129  sets  out  requirements  for  drawing  up  of  a  prospectus  in 
cases  where securities are offered to the public or admitted to trading on a  regulated 
market.  That  Regulation,  as  amended  by  Regulation  (EU)  2024/2809,  provides  for  a 
streamlined  EU  Growth  issuance  prospectus  that  has  lighter  requirements,  compared 
to a standard prospectus, to make the listing process less burdensome and less costly 
for  certain  types  of  enterprises  and  in  certain  cases.  The  main  categories  of 
beneficiaries  of  such  streamlined  prospectus  are  enterprises  with  a  growth  potential, 
notably  SMEs  and  other  enterprises  whose  securities  are  admitted  or  are  to  be 
admitted to trading on an SME growth market. In order to reduce the burden for SMCs 
and potentially make them more attractive to investors, it is appropriate to also enable 
SMCs to draw up an EU Growth issuance prospectus  for their offers of securities to 
the public, including when such offers are accompanied with an admission to trading 
on a multilateral trading facility. 

(15) 

In  order  to  clarify  the  treatment  of  SMCs  in  Regulation  (EU)  2017/1129,  it  is 
necessary to introduce in its Article 2 a definition of SMC, distinct from the definition 
of  an  SME.  Small  mid-cap  enterprises  for  the  purpose  of  that  Regulation  should  be 
defined either as enterprises that meet at least two out of the three criteria based on the 
average number of employees, a total balance sheet and an annual net turnover, or as 
enterprises  that  meet  the  definition  of  small  mid-cap  enterprises  set  out  under 
Directive 2014/65/EU. 

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(16)  SMEs and SMCs are particularly dependent on services provided by credit institutions 
and  insurers,  often  relying  on  only  one  or  few  principal  providers  of  these  services. 
Resolution  regimes  ensure  uninterrupted  access  to  deposits  and  critical  functions 
where  a  financial  institution  fails.  Where  resolution  authorities  use  their  power  to 
convert liabilities of a financial institution to resolve it in a timely manner and ensure 
the continuity of critical functions, prior preparation and publication of a prospectus is 
not  feasible  due  to  the  short  timeframe  imposed  in  the  context  of  a  resolution.  It  is 
therefore  important  to  introduce  an  exemption  from  the  obligation  to  publish  a 
prospectus  that  applies  to  an  offer  to  the  public  of  both  securities  resulting  from  a 
conversion due to the exercise of powers under Directive 2014/59/EU of the European 
Parliament and of the Council15 and Directive (EU) 2025/1 of the European Parliament 
and of the Council16 and securities resulting from a conversion due to the exercise of a 
comparable  power  in  third-country  resolution  proceedings  that  implements  the 
Financial  Stability  Board’s  ‘Key  Attributes  of  Effective  Resolution  Regimes  for 
Financial Institutions’, published in October 2011. Equally, the existing exemption for 
the  admission  to  trading  on  a  regulated  market  of  securities  resulting  from  a 
conversion  due  to  the  exercise  of  powers  under  Directive  2014/59/EU  and 
Directive (EU) 2025/1 from the obligation to publish a prospectus should be extended 
to securities resulting from a conversion due to the exercise of a comparable power in 
third-country  resolution  proceedings  that  implements  those  internationally  agreed 
standards. 

(17)  The  provision  in  Regulation  (EU)  2017/1129  concerning  the  EU  Growth  issuance 
prospectus will apply as of 5 March 2026, as the Commission is required to develop 
delegated acts to specify the reduced content and the standardised format and sequence 
of  that  prospectus.  It  is  therefore  appropriate  to  defer  the  application  of  the 
amendments  to  Regulation  (EU)  2017/1129  concerning  the  EU  Growth  issuance 
prospectus set out in this Regulation to 5 March 2026.  

(18)  Regulation (EU) 2023/1542 establishes rules concerning batteries and waste batteries. 
Article 47 of that Regulation exempts SMEs from certain obligations regarding battery 
due  diligence  policies.  The  scope  of  that  provision  should  be  extended  to  SMCs,  so 
that  they  are  also  exempted  from  those  obligations.  To  ensure  consistency,  it  is 
appropriate to refer to SMCs in the same way bearing in mind that they are entities up 
to three times the size of SMEs, i.e. with a net turnover which should thus be less than 
EUR 150 million.  

(19)  Pursuant to Article 52 of Regulation (EU) 2023/1542, economic operators referred to 
in Article 48(1) of that Regulation are required  - on an annual basis – to review and 
make  publicly  available,  including  on  the  internet,  a  report  on  their  battery  due 
diligence  policy.  With  a  view  to  reducing  the  administrative  burden  on  economic 
operators, operators should be required to review and make publicly avilable their due 

15 

16 

Directive  2014/59/EU  of  the  European  Parliament  and  of  the  Council  of  15 May  2014  establishing  a 
framework  for  the  recovery  and  resolution  of  credit  institutions  and  investment  firms  and  amending 
Council  Directive  82/891/EEC,  and  Directives  2001/24/EC,  2002/47/EC,  2004/25/EC,  2005/56/EC, 
2007/36/EC, 2011/35/EU, 2012/30/EU and 2013/36/EU, and Regulations (EU) No 1093/2010 and (EU) 
No 648/2012, of the European Parliament and of the Council (OJ L 173, 12.6.2014, p. 190). 
Directive  (EU)  2025/1  of  the  European  Parliament  and  of  the  Council  of  27 November  2024 
establishing a framework for the recovery and resolution of insurance and reinsurance undertakings and 
amending  Directives  2002/47/EC,  2004/25/EC,  2007/36/EC,  2014/59/EU  and  (EU)  2017/1132  and 
Regulations  (EU)  No 1094/2010,  (EU)  No 648/2012,  (EU)  No 806/2014  and  (EU)  2017/1129  (OJ L, 
2025/1, 8.1.2025, ELI: http://data.europa.eu/eli/dir/2025/1/oj). 

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5 

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diligence policy only only every three years instead of annually. This burden reduction 
should apply to all economic operators, including SMCs. 

(20)  The  requirement  in  Article  20(4),  point  (a)  of  Regulation  (EU)  2024/573  of  the 
European  Parliament  and  of  the  Council17  to  register  in  the  F-gas  Portal  prior  to 
carrying out any imports and exports of products and equipment containing fluorinated 
greenhouses  gases,  is  intended  to  facilitate  enforcement.  However,  the  burden 
resulting  from  that  requirement  may  be  disproportionate  compared  to  its  benefit,  in 
particular  for  SMEs  and  SMCs.  Therefore,  the  registration  requirement  should  be 
limited to imports for which reporting requirments apply and to exports for which an 
export  limitation  exists.  To  the  extent  that  this  Regulation  amends  Regulation  (EU) 
2024/573 the appropriate legal basis, in so far as those amendments are concerned, is 
Article 192(1) TFEU.  

(21) 

Regulations (EU) 2016/679, (EU) 2016/1036, (EU) 2016/1037, (EU) 2017/1129, (EU) 
2023/1542 and (EU) 2024/573 should therefore be amended accordingly, 

HAVE ADOPTED THIS REGULATION: 

Article 1 

Amendments to Regulation (EU) 2016/679   

Regulation (EU) 2016/679 is amended as follows:  

(1) 

in Article 4, the following points (27) and (28) are added:  

‘(27) ‘micro, small, and medium-sized enterprises’ means enterprises as defined in Article 2 
of the Annex to Commission Recommendation 2003/361/EC*;  

(28)  ‘small  mid-cap  enterprises’  means  enterprises  as  defined  in  point  (2)  of  the  Annex  to 
Commission Recommendation  of 21.5.2025 on the definition of small  mid-cap enterprises  -  
C(2025) 3500 final**.; 

________  

*  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.’ ; 

(2) 

in Article 30, paragraph 5 is replaced by the following:  

’5.  The  obligations  referred  to  in  paragraphs  1  and  2  shall  not  apply  to  an  enterprise  or  an 
organisation employing fewer than 750 persons unless the processing it carries out is likely to 
result in a high risk to the rights and freedoms of data subjects, within the meaning of Article 
35.’;  

(3) 

in Article 40, paragraph 1 is replaced by the following:  

‘1.  The  Member  States,  the  supervisory  authorities,  the  Board  and  the  Commission  shall 
encourage the drawing up of codes of conduct intended to contribute to the proper application 

17 

Regulation  (EU)  2024/573  of  the  European  Parliament  and  of  the  Council  of  7  February  2024  on 
fluorinated greenhouse gases, amending Directive (EU) 2019/1937 and repealing Regulation (EU) No 
517/2014 (OJ L 2024/573, 20.02.2024, ELI: http://data.europa.eu/eli/reg/2024/573/oj) 

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6 

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of  this  Regulation,  taking  account  of  the  specific  features  of  the  various  processing  sectors 
and  the  specific  needs  of  micro,  small  and  medium-sized  enterprises  and  of  small  mid-cap 
enterprises.’;  

(4) 

in Article 42, paragraph 1 is replaced by the following:  

‘1.  The  Member  States,  the  supervisory  authorities,  the  Board  and  the  Commission  shall 
encourage,  in  particular  at  Union  level,  the  establishment  of  data  protection  certification 
mechanisms  and  of  data  protection  seals  and  marks,  for  the  purpose  of  demonstrating 
compliance with this Regulation of processing operations by controllers and processors. The 
specific needs of micro, small and medium-sized enterprises and of small mid-cap enterprises 
shall be taken into account.’ 

Article 2 

Regulation (EU) No 2016/1036 is amended as follows: 

Amendments to Regulation (EU) 2016/1036 

(1) 

in Article 5 (1a), the first subparagraph is replaced by the following:  

‘The  Commission  shall  facilitate  access  to  the  trade  defence  instrument  for  diverse  and 
fragmented  industry  sectors,  largely  composed  of  small  and  medium-sized  enterprises 
(‘SMEs’)*  or  small  mid-cap  enterprises  (‘SMCs’)**,  through  a  dedicated  Helpdesk,  for 
example  by  awareness  raising,  by  providing  general  information  and  explanations  on 
procedures  and  on  how  to  submit  a  complaint,  by  releasing  standard  questionnaires  in  all 
official languages of the Union and by replying to general, non-case-specific queries.’ 

________  

*  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.’ ; 

(2) 

in Article 6, paragraph 9, is replaced by the following:  

‘9.  For  proceedings  initiated  pursuant  to  Article  5(9),  an  investigation  shall,  whenever 
possible, be concluded within one year. In any event, such investigations shall in all cases be 
concluded within 14 months  of initiation, in  accordance with  the findings made pursuant  to 
Article  8  for  undertakings  or  the  findings  made  pursuant  to  Article  9  for  definitive  action. 
Investigation  periods  shall,  whenever  possible,  especially  in  the  case  of  diverse  and 
fragmented sectors largely composed of SMEs or SMCs, coincide with the financial year.’. 

Article 3 

Regulation (EU) No 2016/1037 is amended as follows: 

Amendments to Regulation (EU) 2016/1037 

(1) 

in Article 10 (1a, the first subparagraph is replaced by the following:  

‘.The Commission shall facilitate access to the trade defence instrument for diverse 
and  fragmented  industry  sectors,  largely  composed  of  small  and  medium-sized 
enterprises  (SMEs)(*)  or  small  mid-caps  enterprises  (SMCs)(**),  through  a 
dedicated  Helpdesk,  for  example  by  awareness  raising,  by  providing  general 

EN 

7 

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information  and  explanations  on  procedures  and  on  how  to  submit  a  complaint,  by 
releasing  standard  questionnaires  in  all  official  languages  of  the  Union  and  by 
replying to general, non-case-specific queries.’ 

________  

*  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.’ ; 

(2) 

in Article 11, paragraph 9 is replaced by the following:  

‘9.  For  proceedings  initiated  pursuant  to  Article  10(11),  an  investigation  shall,  whenever 
possible, be concluded within one year. In any event, such investigations shall in all cases be 
concluded within 13 months of their initiation, in accordance with the findings made pursuant 
to  Article  13  for  undertakings  or  the  findings  made  pursuant  to  Article  15  for  definitive 
action.  Investigation  periods  shall,  whenever  possible,  especially  in  the  case  of  diverse  and 
fragmented sectors largely composed of SMEs or SMCs, coincide with the financial year.’. 

Article 4 

Amendments to Regulation (EU) 2017/1129 

Regulation (EU) 2017/1129 is amended as follows:  

(1) 

(a) 

Article 1 is amended as follows: 

in paragraph 4, the following point (dc) is inserted: 

‘(dc) an offer of securities resulting from the conversion or exchange of other 
securities, own funds or eligible liabilities by a resolution authority due to the 
exercise of a power referred to in Article 53(2), Article 59(2) or Article 63(1) 
of Directive 2014/59/EU or the exercise of a power referred to in Article 35(1), 
Article  39(2)  or  Article  42(1)  of  Directive  (EU)  2025/1  of  the  European 
Parliament and of the Council (*) or by a relevant third-country authority due to 
the exercise of a comparable power in third-country resolution proceedings;’;  

____________ 

(*)   Directive  (EU)  2025/1  of  the  European  Parliament  and  of  the  Council  of  27 November  2024 
establishing  a framework  for  the  recovery  and  resolution  of  insurance  and  reinsurance  undertakings 
and  amending  Directives  2002/47/EC,  2004/25/EC,  2007/36/EC,  2014/59/EU  and  (EU)  2017/1132 
and  Regulations  (EU)  No 1094/2010,  (EU)  No 648/2012,  (EU)  No 806/2014  and  (EU)  2017/1129 
(OJ L, 2025/1, 8.1.2025, ELI: http://data.europa.eu/eli/dir/2025/1/oj). 

in paragraph 5, point (c) is replaced by the following: 

‘(c)  securities  resulting  from  the  conversion  or  exchange  of  other  securities,  own 
funds  or  eligible  liabilities  by  a resolution  authority  due  to  the  exercise  of  a power 
referred to in Article 53(2), Article 59(2) or Article 63(1) of Directive 2014/59/EU or 
the exercise of a power referred to in Article 35(1), Article 39(2) or Article 42(1) of 
Directive (EU) 2025/1 or by a relevant third-country authority due to the exercise of 
a comparable power in third-country resolution proceedings;’; 

Article 2 is amended as follows: 

the following points (dc) and (dd) are inserted: 

(b) 

(2) 

(3) 

(a) 

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8 

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(4) 

(5) 

‘(dc)  ‘relevant  third-country  authority’  means  a  relevant  third-country  authority  as 
defined  in  Article  2(1),  point  (90),  of  Directive  2014/59/EU  or  a  relevant  third-
country authority as defined in Article 2, point (74), of Directive (EU) 2025/1; 

‘third-country 

resolution  proceedings’  means 

(dd) 
resolution 
proceedings as defined in Article 2(1), point (88), of Directive 2014/59/EU or third-
country resolution proceedings as defined in Article 2, point (72), of Directive (EU) 
2025/1;’; 

third-country 

(a) 

in Article 2, the following point (fa) is inserted: 

“(fa) ‘small mid-cap enterprises’ or ‘SMCs’ means any of the following:  

(i) 

companies which, according to their last annual or consolidated accounts, 
meet  at  least  two  of  the  following  three  criteria:  an  average  number  of 
employees during the financial year of less than 750, a total balance sheet 
not  exceeding  EUR  129  000  000  and  an  annual  net  turnover  not 
exceeding EUR 150 000 000;  

(ii) 

small  mid-cap  enterprises  as  defined  in  Article  4(1),  point  (13a),  of 
Directive 2014/65/EU;”; 

(6) 

in Article 15a, paragraph 1 is replaced by the following:  

‘1.  Without  prejudice  to  Article  1(4)  and  Article  3(2)  and  (2a),  the  following 
persons may draw up an EU Growth issuance prospectus in the case of an offer 
of  securities  to  the  public,  provided  that  they  have  no  securities  admitted  to 
trading on a regulated market:   

(a) 

(b) 

(c) 

(d) 

 SMEs;  

 SMCs;  

 issuers, other than SMEs and SMCs, whose securities are, or are to be admitted 
to trading on an SME growth market;  

 offerors of securities that have been issued by issuers referred to in points (a), 
(b), and (c).’. 

Article 5 

Amendments to Regulation (EU) 2023/1542  

Regulation (EU) 2023/1542 is amended as follows:  

(1) in Article 47, the first paragraph is replaced by the following:  

‘This Chapter does not apply to economic operators that had a net turnover of less than EUR 
150 million in  the financial year preceding  the last  financial year,  and that are not  part of a 
group,  consisting  of  parent  and  subsidiary  undertakings,  which,  on  a  consolidated  basis, 
exceeds the limit of EUR 150 million.’; 

(2) in Article 52(3), the first sentence is replaced by the following: 

‘The economic operator referred to in Article 48(1) shall, by the latest one year after the date 
specified in Article 48(1) and at least every three years thereafter, review and make publicly 
available, including on the internet, a report on its battery due diligence policy.’. 

EN 

9 

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Article 6 

Amendment to Regulation (EU) 2024/573  

Regulation (EU) 2024/573 is amended as follows: 

in Article 20(4), point (a) is replaced by the following: 

‘(a) the following imports and exports, except in the case of temporary storage as defined in 
Article 5, point (17), of Regulation (EU) No 952/2013: 

(i) the import or export of fluorinated greenhouse gases; 

(ii) the placing on the market of products and equipment containing fluorinated greenhouse 
gases that requires reporting under Article 26; 

(iii)  the  export  of  products  and  equipment  as  referred  to  in  Article  22(3)  containing  or 
whose functioning relies upon, fluorinated greenhouse gases with a GWP of 1000 or more 
as from the prohibition date stated in Annex IV;’. 

Article 7 

Entry into force and application  

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

Article 4, points (2)(b) and (3), shall apply as of 5 March 2026.  

This Regulation shall be binding in its entirety and directly applicable in the Member States in 
accordance with the Treaties. 

Done at Brussels, 

For the European Parliament 
The President 

For the Council 
The President 

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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 

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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 

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1. 

FRAMEWORK OF THE PROPOSAL/INITIATIVE  

1.1. 

Title of the proposal/initiative 

Proposal  for  a  REGULATION  OF  THE  EUROPEAN  PARLIAMENT  AND  OF 
THE  COUNCIL  amending  Regulations  (EU)  2016/679,  (EU)  2016/1036,  (EU) 
2016/1037,  (EU)  2017/1129,    (EU)  2023/1542  and  (EU)  2024/573  as  regards  the 
extension  of  certain  mitigating  measures  available  for  small  and  medium  sized 
enterprises to small mid-cap enterprises and further simplification measures 

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 and to simplify a registration requirement for certain 
importers and exporters, by putting forward proposals for 2 omnibus acts amending 
an number of EU legislative acts. 

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 
beneficiaries/groups targeted: 

is  expected 

to  have 

the  following  effects  on 

the 

Reduced administrative burdens: Small mid-caps and importers and exporters 
- 
of certain products and equipment containing F-gases, in particlurar small enterprises 
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  

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

EN 

3 

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- 
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  

Target groups: 

The proposal/initiative is targeted at the approximately 38,000 small mid-caps in the 
EU,  which  are  defined  as  enterprises  with  between  250  and  749  staff  (for  the 
estimation  here:  relying  on  head-count  only).  In  addition,  up  to  10  000  traders  are 
estimated to be exempted from the obligation to register in the F-gas Portal per year. 

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 

1.5.3.  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 

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

EN 

4 

  EN 

 
 
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  4;  Description:  approval  process  of  EU  Growth  prospectus 
document;  affected  stakeholders  :  Member  states,  legal  entities  operators  in  scope  of  this 
regulaiton; High level process: Assess SMC status; Category: Data. 

Reference  to  Article:  Article  5;  Description:  Market  surveillance  verification  process ; 

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 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
affected  stakeholders :  Member  States’  market  surveillance  authorities  or  national 
authorities;High level process: Assess SMC status; Category: Data. 

4.2. 

Data 

EU Growth prospectus could be structured for further interoperability. 

SMC definition. 

4.3. 

Digital solutions 

N/A 

4.4. 

Interoperability assessment 

Digital public service: Approval  process of EU Growth prospectus document. 

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