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Invest Europe’s response reiterates key messages and highlights the long-term benefits of the proposed simplification measures, if delivered in a consistent manner and taking into account how these sustainability frameworks will be used in practice.
Positions & consultation responses
In this 100-pages response, Invest Europe flagged various concerns regarding the state of EU capital markets, looking at improvements to be made to the AIFM Directive and its implementation in Member States. Notably, the response calls for an increase of the AIFMD threshold, a better recognition of the private equity features, a simplification of the managers' authorisation process across the EU, of pre-marketing requirements as well as depositary rules. It also gives the European Commission insights on the costs of AIFMD in various jurisdictions.
Positions & consultation responses
This position paper is a follow-up to Invest Europe's response to the public consultation on the review of DAC 1-6 from August 2024. It offers a critical assessment of the EU Directive DAC6, which mandates disclosure of potentially aggressive cross-border tax arrangements. While supporting its transparency goals, the letter highlights the Directive's excessive compliance burdens, inconsistent interpretations across Member States, and limited practical effectiveness. It calls for targeted reforms—such as clearer guidance, refined hallmarks, harmonized implementation, and streamlined procedures—to make DAC6 more proportionate, effective, and aligned with broader EU competitiveness and tax simplification objectives.
Positions & consultation responses
Private equity (PE), venture capital (VC), and infrastructure managers operate under a model setting that is distinctly apart from deposit-taking or high-frequency transactional institutions. As such, many of the more granular provisions in the RTS — including those concerning customers’ transactional behaviour, real-time remote identification, and direct engagement with natural persons — are of very limited applicability for the entire PE-, Infrastructure investment and VC industry. We encourage EBA to recognise these distinctions in application and guidance, in line with the proportionality principle.
Positions & consultation responses
Invest Europe’s response highlights the need to close Europe’s biotech commercialization gap by accelerating time to market for breakthrough innovations, bridging the biotech investment gap, unlocking the potential of data, AI and quantum computing, and strengthening Europe’s entrepreneurial workforce.
Positions & consultation responses
In this letter Invest Europe addresses the European Commission's upcoming review of VAT rules for financial and insurance services, emphasizing the critical importance of maintaining and harmonizing the VAT exemption for fund management across the EU. It argues that inconsistent interpretations among Member States create uncertainty and undermine competitiveness, especially for private equity and venture capital funds. Invest Europe urges the Commission to preserve the current exemptions to avoid increased costs and reduced investment in EU businesses, which would negatively impact economic growth and innovation.
Positions & consultation responses
Invest Europe’s response focuses on targeted improvements to CSRD, CSDDD and the EU Taxonomy to ensure they remain practical, proportionate and aligned with investor needs. Key recommendations include simplifying materiality assessments, ensuring realistic assurance and due diligence exercises, and improving interoperability with global and EU frameworks.
Positions & consultation responses
Member Only
During this webinar, we discussed the Alternative Investment Fund Managers' Directive and its implications on Invest Europe members.
Webinars
This response to the European Commission’s Call for Evidence outlines the industry’s views on the future direction of the SFDR, reaffirming – among other points – that it should remain a disclosure-based regime and that clear grandfathering provisions should be introduced.
Positions & consultation responses
In this paper, we set out our recommendations on the European Commission’s Sustainability Omnibus Proposal of 26 February 2025, including targeted improvements to ensure the framework remains simple, usable, scalable, and aligned with international standards, while supporting long-term value creation.
Positions & consultation responses
Invest Europe warmly thanks MEP Hadjipantela for an engaging discussion on his draft report addressing the role of simple tax rules and tax fragmentation in strengthening European competitiveness.
Positions & consultation responses
In its response, Invest Europe highlighted key barriers currently limiting PE and VC engagement in defence such regulatory fragmentation, uncertainty around exit pathways, the lack of common definitions and ESG alignment for defence investments, and an underdeveloped public private financing infrastructure to de-risk and scale capital deployment.
Positions & consultation responses
Invest Europe’s response to the European Commission’s initiative to strengthen the biotech and life sciences ecosystem outlines key priorities in addressing regulatory barriers in medtech, unlocking early-stage investment, aligning public and private capital, and reducing fragmentation across EU markets, while broadening access to capital from all sources.
Positions & consultation responses
Member Only
Recent geopolitical and policy developments – both within and beyond the EU – are influencing the sustainability conversation.
Webinars
Invest Europe would welcome the opportunity to highlight some key points on the operation of the 'investment fund' exemption (which limits the FSR reporting obligations to the funds involved in the transaction).
Positions & consultation responses