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AECM Annual Seminar Berlin
18-19 June 2015

AECM Position on Temporary State Aid Framework - Sept 2009

News - 15/09/2009

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On 14 September, AECM published its position paper on the Temporary community framework for state aid measures to support access to finance in the current financial and economic crises published by the European Commission on 22 January 2009 to allow certain types of state aid in order to quickly respond to the impact of the financial crisis.

AECM views the Temporary Framework as very important in the context of the current crisis situation. Many of its member organisations have made use of the Framework to adapt existing products or launch new, temporary, products, to better serve the SMEs in this difficult market environment.

In the course of the application of the Framework, AECM's members have noticed a few areas which should be improved to maximise its impact on SME finance, such as

  • the possible inclusion of ex-post guarantees on a temporary basis, to allow banks to bring in additional institutional guarantees;
  • eliminating the wage bill restriction, which states that the amount of a loan that can be guaranteed to up to 90% should not exceed the total annual wage bill of the beneficiary. This scope restriction is too narrow and unnecessarily excludes capital-intensive companies as well as small start-ups, which typically have a very small employee basis;
  • allowing the cumulation of the measures under the temporary framework with de minimis aid for the same eligible costs, in order to make sure that a larger number of SMEs can benefit from the Framework.

Independently from the Temporary State Aid Framework, AECM also reiterated its position that the safe-harbour rates set by the Guarantee Notice are far too high to be a practical alternative to the other calculation methodologies of the state aid equivalent listed in the Guarantee Notice. AECM urges the Commission to reconsider these rates, if they are to constitute a realistic alternative methodology. Finally, AECM states that the maximum allowable gross grant equivalent admissible under the De Minimis Regulation for Agriculture of € 7.500 over three years is too low and should be raised substantially to € 100.000.



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