Accountancy Europe has responded to the European Commission’s consultation on the 28th regime, drawing on the expertise of our Corporate Governance Policy Group. Our response outlines the building blocks needed to create a strong, reliable, high-quality brand for 28th regime companies – one that investors can trust and that provides seamless procedures for companies choosing to opt in.
Digitalisation should be at the heart of the regime’s processes, although paper-based alternatives may remain necessary during a transition period. Ultimately, the regime’s success will depend on how it is received by businesses, investors, and markets. It should therefore be flexible and accessible to a broad range of entities. That said, establishing the regime must come first, and we recognise that the Commission may initially restrict it to smaller companies.
We propose staggered minimum share capital requirements according to company size, paired with robust creditor protection, underpinned by reliable company data. Companies in the regime could also benefit from tailored tax frameworks, such as an expanded Head Office Tax System (HOT) for SMEs that would also cover subsidiaries. In addition, we support progress towards a European Business Code.
We further encourage the Commission to explore innovative financing mechanisms, including a guarantee fund for intellectual property (IP)-backed loans for smaller companies, as part of the 28th regime.
These and other recommendations are detailed in our full consultation response, aimed at helping the 28th regime become a genuine European success story.
