4.3.2022
EN
Official Journal of the European Union
C 105/3
2.8.
The EESC welcomed the communication on Better Regulation, which emphasises that better regulation is the key to sustainable development.
This cannot be based on economic growth alone, but also requires a balance between the economic, sustainability and social dimensions. 2.9.
Despite this, several legislative proposals and debates point to new reporting obligations for micro, small and medium-sized enterprises (corporate sustainability reporting (4), pay transparency (5) and due diligence).
These obligations may apply to micro, small and medium-sized enterprises directly or indirectly, as a result of requests from large companies in the value chain; they also represent a cost for these enterprises, since they do not have the human and financial resources to meet the obligations, putting their business, business model and thus their very survival at risk, above all during periods of crisis. 2.10.
Yet micro, small and medium-sized enterprises are achieving encouraging results that are even better than national averages, and are doing so without any constraints.
The EESC calls for legislation to be conceived for the 21 million enterprises of this type in Europe, rather than designing it for the 0,2 % of businesses that are larger and then trying to apply those principles to the smaller ones.
The aim should be to meet the needs not just of business owners but also of their many employees.
The EESC would also like alternatives to reporting to be systematically put forward.
3.
Costs and benefits of reporting measures 3.1.
The Commission’s estimation of the costs and administrative burdens often lacks transparency and penalises micro, small and medium-sized enterprises.
There are, in addition, the indirect effects of value chain obligations, which the Commission struggles to quantify.
As stated in the Communication on Better Regulation, the amendments tabled by Parliament and the Council are only rarely subject to SME Tests.
Finally, the transposition of measures into national law is sometimes accompanied by additional costs. 3.2.
In order to meet these growing obligations, entrepreneurs can only either respond themselves, using the time set aside for their business activity, or call on external expertise.
Both methods affect the operations of a business and entail additional costs.
Costs are proportionally higher in microenterprises than in large companies.
On top of this, the EESC warns that the proliferation of reporting measures, though they seem minor when taken individually, have a considerable impact once combined. 3.3.
Yet in areas where there are no reporting obligations, good results are obtained: many micro, small and medium-sized enterprises, encouraged by their professional association or chambers of commerce, invest in the circular economy, as they see a benefit for their growth and reputation (6); the human size of micro, small and medium-sized enterprises facilitates exchanges between employers and employees, which makes gender pay gaps often smaller than the national average (7), etc.
Countries that have put in place thresholds for SMEs for some social legislation report a low number of formal complaints, which suggests that the latter can be models without having burdensome measures imposed on them.
The definition of an SME should be addressed, as recommended in EESC opinions (8). 3.4.
Micro, small and medium-sized enterprises, including social enterprises, play a full part in the circular economy, offering community-based services which strengthen social ties, creating non-relocatable jobs and wealth in areas without industry and certain public services, and providing business opportunities and employment for socially vulnerable groups.
More than half of dual-learning apprentices are trained in micro, small and medium-sized enterprises, enabling such entities to play an active role in youth employment.
Their business model and human scale promotes the implementation of artificial intelligence where humans remain in control, and focuses on quality of life at work and participatory governance. 3.5.
The addition of reporting measures is often seen as an unfair burden, which impacts negatively on their business activity and risks denying them access to public procurement or funding, while failing to deliver significant progress on policies that they have often initiated themselves.
This accumulation feeds resentment towards a Europe that is considered overly bureaucratic and disconnected from the grassroots level. 3.6.
Furthermore, the EESC considers that social and environmental objectives will only be achieved by targeting the causes of imbalances, not by increasing binding requirements.
(4) (5) (6) (7) (8)
Proposal for a directive on corporate sustainability reporting [2021/0104(COD)]).
Proposal for a directive to strengthen the application of the principle of equal pay for equal work or work of equal value between men and women through pay transparency and enforcement mechanisms [2021/0050(COD)].
An example of a craft business that has put in place circular economy measures without any transparency obligation in the Netherlands: https://www.deb.nl/ondernemersverhalen/slagerij-van-koppen-dacht-na-over-duurzaamheid/ Les entreprises de proximité au féminin, March 2019: https://u2p-france.fr/sites/default/files/etude_les_entreprises_de_proximite_au_ feminin.pdf OJ C 345, 13.10.2017, p. 15 and OJ C 81, 2.3.2018, p. 1.