Our organisations, representing a broad array of industries from Europe and its leading trading partners, support the objectives of Regulation (EU) 2022/2560 on foreign subsidies distorting the internal market (the ‘Regulation’).

Despite positive recent steps from the European Commission (the ‘Commission’) to clarify the obligations imposed by the Regulation, the proposed Implementing Regulation (the ‘Draft IR’) would still generate unintended consequences and create a disproportionate burden for EU and non-EU businesses with a global presence. We fear that companies will not be in a position to comply with the Regulation as the reporting obligations currently stand. The Regulation imposes requirements which are unfamiliar to business and which necessitate the design of elaborate internal compliance mechanisms that do not currently exist. The uncertainty in the proposed regime risks creating a chilling effect on investment and participation in the European economy.

With this in mind, we set out the main areas in which further refinement of the Draft IR is essential in order to create a framework that is both legally proportionate and operationally workable for companies and the Commission alike. Read the whole statement here.

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