Strengthening EU Trade and Investment through Proportional Regulation for Small Mid-Cap Enterprises

The document provides feedback to the European Commission on the 2025 Omnibus Package (COM(2025) 501), advocating for proportional regulation tailored to small mid-cap enterprises (SMCs). It highlights the need to extend SME-friendly simplifications’such as reduced administrative burdens in GDPR, Prospectus Regulation, Batteries Regulation, and F-gas Regulation’to SMCs, which face similar challenges but are often overlooked. Central to the proposal is the establishment of the European Trade Indexes Registry (EUTIR), a decentralised, interoperable digital infrastructure built on blockchain technology (EBSI), designed to serve as a trust anchor for trade-related data. EUTIR aims to streamline compliance, enhance transparency, and support sustainability and digital trade by integrating key identifiers (LEI/vLEI, EORI) and enabling machine-readable, verifiable data exchange across platforms like eFTI, DPP, and CBAM. The document positions EUTIR as a cornerstone for EU competitiveness, facilitating green transition, capital market access, and global trade digitalisation while ensuring legal certainty and regulatory coherence.