Position papers
-
AECM - EAPB Joint paper on the DNSH
State aid 23 September 2026AECM – Guarantors Europe (AECM) and the European Association of Public Banks (EAPB), welcome the European Commission’s efforts to simplify the application of the ‘Do No Significant Harm’ (DNSH) principle under the 2028–2034 Multiannual Financial Framework (MFF). We support the establishment of a specific, proportionate and workable approach to DNSH for financial instruments and budgetary guarantees, taking into account their particular characteristics and delivery structures.
Download -
Joint Position Paper on the Industrial Accelerator Act and the Net-Zero Industry Act: proposed amendments
Development, State aid, Sustainable finance 18 September 2026National Promotional Banks and Institutions (NPBIs) welcome plans to enhance the EUs resilience and to reinforce its industrial and manufacturing base, as stipulated also in the Industrial Accelerator Act (IAA). NPBIs are long-standing partners of their respective governments and the EU in financing corresponding projects. Most NPBIs already support renewable energies, hydrogen, safer supply chains, energetic renovations or the circular economy, today and will continue to do so in the future.
Download -
EAPB Statement on the proposed European Parliament Amendments to the Markets Infrastructure Package
Capital markets 14 September 2026The European Association of Public Banks (EAPB) welcomes the publication by the European Parliament's ECON Committee of the draft reports and tabled amendments on the Markets Infrastructure and Supervisory Package (MISP). As set out in our Position Paper of 7 May 2026, EAPB supports the broad direction of the Commission's proposal. The parliamentary process now under way will determine how far that direction is carried into the final texts.
Download -
EAPB Position Paper on the Second Draft of the Revised General Block Exemption Regulation (GBER)
State aid 28 August 2026The European Association of Public Banks (EAPB) welcomes the opportunity to provide comments on the second draft of the revised General Block Exemption Regulation (GBER). EAPB represents European public and promotional banks, which play an important role in implementing public policy objectives at European, national and regional level. Through their mandates, these institutions support investment, innovation, SMEs, infrastructure, the green and digital transitions, economic resilience and social development. They frequently implement programmes combining national and European resources and therefore rely extensively on the State aid framework.
Download -
EAPB position paper - proportionality for public and promotional banks
1 July 2026The EU is in the midst of the most significant banking simplification debate in a decade. The Commission report on banking competitiveness, expected in July 2026, will set the direction. The ECB Governing Council’s recommendations of December 2025, the EBA’s ongoing reporting simplification package, and proposals for a “small bank regime” from BaFin and others, all converge on one question: how to make the EU prudential framework less burdensome without weakening resilience.
Download - View more