EU SMALL BUSINESS ACT REVIEW: POLISH COMMENTS
1. Introduction:
The SME sector is of a paramount importance in the development of economy,
both nationally and at the EU level. Micro, small and medium enterprises are crucial
for economy’s development because of their contribution to the growth of GDP
and employment.
Considering the above, it is important to notice, that creating the favourable conditions
for development of SME sector is necessary for guaranteeing strong and long-term growth
and creating new and better jobs on EU single market.
Poland views the actions undertaken by Member States as having the leading role
for the effectiveness of the SME policy and the EU policy should provide support
and supplement Member States’ actions.
Poland supports the initiative of the publication of the Communication Think Small First.
A Small Business Act for Europe (SBA) and welcomes the emphasis placed on SMEs
by the European Commission (EC). Poland perceives the SBA as a key initiative aiming
to stimulate the potential for growth and employment of small and medium-sized enterprises
in Europe. The SBA was built on the Commission’s and Member States’ policy achievements
and what Poland finds to be of vital importance, it creates a new policy framework which
integrates the existing enterprise policy instrument constituting modern SME policy.
Implementation of all the guidelines both in the SBA Communication and The Council’s
action plan for Small Business Act for Europe is the key element for current entrepreneurship
and SME policy in Poland.
2. Reviewing of SBA:
Together with the publication of the SBA a set of ten principles has been identified to guide
the conception and implementation of policies towards SME’s both at Community
and Member States level.
Poland supports the EC’s opinion that, in light of the current process of implementation
of the measures included in the SBA, there is no need to change the priorities of the SBA,
and thus remodeling of policies for the SME sector. Nevertheless, Poland would like
to stress the need to reinforce and follow-up within the principles areas of the SBA.
3. Linking the SBA closely to the Europe 2020 strategy:
Poland stresses the importance of proper recognition and highlighting the issues concerning
the support of the SME sector in the “Europe 2020” Strategy. Poland perceives “Europe
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2020” Strategy as one of the most important strategic documents
of entrepreneurship policy and SME development in the long term perspective.
outlining
The key flagship initiatives of Europe 2020 Strategy are as follows:
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Innovation Union,
Youth on the move,
A digital agenda for Europe,
Resource efficient Europe,
An industrial policy for the globalisation era,
An agenda for new skills and jobs,
European platform against poverty.
Linking the reviewed SBA strictly to the Commission’s new policy agenda - the Europe
2020 Strategy, is of vital importance in the light of continuity and complementarity
of Community documents. Taking into account above mentioned approach Poland
encourages EC to indicate in the SBA Review clear assignment of the priority areas
of the SBA into key flagship initiatives of Europe 2020 in order to visualize
the complementarity of these two documents.
Bearing in mind all the flagship initiatives, Poland would like to keep the focus on the three
agreed SBA priority areas which have been remaining unchanged from the moment
of publication of the SBA. We should make an effort to include all new initiatives into
the existing ten SBA principles.
3.1. Further implementing of the Think Small First principle:
Crucial for the further strengthening of the effective SME sector support policy is taking
under consideration the SME issues in the EU policies through the implementation
of the Think Small First principle, which should be applied as the generally accepted rule,
not the exception, of all legislative actions.
Poland would like to highlight in the SBA Review the importance of considering Think Small
First principle in other relevant EU initiatives such as: Sustainable Industrial Policy,
Sustainable Consumption and Production, Standardization and Innovation and Lead Markets.
Poland encourages EC to include in the SBA Review the following issues:
a) Focus more on the outcomes of the carried out activities,
b) Ensure that the SME Test is carried out when preparing any regulation, which may
impact SME sector,
c) Bear in mind SME’s inability to cope with increase regulatory burden, thus reducing
regulatory proposals where it is possible,
d) Avoid regulation where it is possible,
e) Pay more attention to SME consultation, extending the consultation period where
possible,
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f) Equally important for the effectiveness of supportive policy for the SME sector is taking
under consideration the need of constant dialogue with all interested entities.
3.2. Access to finance for SME sector:
Difficulties in access to capital for SMEs is still one of the most urgent obstacle on the way
to develop and foster the SME sector. Poland supports initiatives of EC such as creation
of European Investment Bank’s micro credit fund for SMEs.
Poland would like this issue to be underlined in the SBA Review together with stressing
that the simultaneous actions on improving access to finance for SMEs have to be undertaken
at the Member States level as well.
Poland encourages EC to include in the SBA Review the following issues:
a) Foster other than bank loans possibilities to access to capital for SMEs such as loan
and guarantee funds, business angels or venture capital funds,
b) Facilitate full use of funding available in the European Funds for SMEs including easing
the access to the Framework Programmes,
c) Facilitate access to capital for innovative enterprises especially at the initial stage
of their development,
d) Proceed actions in the area of the Directive 2000/35/EC on late payments with a view
to ensuring that SMEs are paid on time for any commercial transaction.
3.3. Facilitating access to markets for SMEs:
Poland fully supports constant actions at the EU level towards the improvement of market
access for SMEs. Actions should be focused on full implementation of four Treaty Freedoms
and accompanying elimination of the still remaining barriers on the single market for SMEs.
Poland encourages EC to include in the SBA Review the following issues:
a) Underline the importance of services sector within the internal market. Mobilization
of all Member States in the area of possibly fast completion of implementation
of the Services Directive is indispensable due to the necessity of following the principle
of equal treatment of business entities.
b) Necessity of further simplification of the procedures related to recognition
of professional skills,
c) Focus on exploitation of opportunities and tools offered by the impact assessment
and evaluation of regulation effects, including interdisciplinary research and analytical
tools, i.e. ex-ante, ongoing and ex-post analysis to facilitate cross-border activities
of SMEs,
d) Concentrate on the future of the digital sector and the possibility to create a digital single
market,
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e) Further opening public procurement sector for SME’s,
f) Strengthen actions at the EU level
of the entrepreneurs in the SOLVIT system,
towards
increasing
the
participations
g) Further elimination of barriers in international trade such as existing technical standards,
intellectual property rights and the issue of subsidies not approved by the WTO.
4. Enhancing implementation of measures, improving governance and publicity
of the SBA:
Poland encourages EC to include in the SBA Review the following issues:
a) Review the role of currently used tools to support SME performance and analyze SME
policies, including the SBA fact sheet, SBA conference, Performance Review, and how
they fit into new national reform programmes for the Europe 2020 Strategy
implementation to avoid any unnecessary reporting on one hand and achieve
coordination on the other.
b) Follow the actions to develop a clear set of indicators to monitor the progress of Member
States in implementing SBA principles.
c) Evaluate effectiveness of actions as well as recommendations for the future,
are of high importance in the process of effective support of SME sector
in Europe. EC could spread patterns for an appropriate evaluation system among
Member States.
d) Undertake further initiatives at the Community level to enhance the process of exchange
of good practices. Poland confirms the effectiveness of the exchange of good practices
of the expert groups organized around particular issues, as evidenced by the action
of Community Group of National Coordinators on Bankruptcy and Second Chance.
e) Increase promotional efforts by using EC’s different information web-platforms
in achieving SBA to be better seen by all entities involved, especially by entrepreneurs.
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