Eurodiaconia member, Diakonie Deutschland, together with its partners of the Association of German Non-statutory Social Welfare Organizations (BAGFW), released their position paper on the review of EU State Aid law. The position paper has been submitted to the European Commission, now in view of a potential review, as parts of the current State Aid Law will only be applicable until the end of 2023. Relatedly, in December 2021 the European Commission had also invited stakeholders to respond to a consultation on the General Block Exemption Regulation (GBER).  

Diakonie Deutschland, with BAGFW, presents background on the tension between the EU’s objective of promoting a common internal market based on mutual competition, in contrast to Member States’ mandates to ensure social welfare models. As non-statutory social welfare organizations providing these social services within their respective Member States, with as many as 120,000 institutions in Germany, BAGFW depicts the essential need to review and modify state aid rules applicable to these organizations.  

BAGFW suggest precise amendments accompanied with explanations to improve state aid, including amendments to the General Block Exemption Regulation (GBER) and the Commission Regulation on de minimis aid granted to undertakings providing services of general economic interest. The key demands aim to facilitate clear application of state aid laws and SGEI exemptions, adjust ceilings and accumulation rules to support the financial requirements of service providers, and to assist non-statutory welfare organizations in the pandemic recovery. These proposed amendments are anchored in the shared positions that state aid laws and regulations can be modified to better support effective, transparent and non-bureaucratic provision of social services.  

To find out more about the recommendations and amendments of BAGFW, click here.

You can also access the position paper in German here, as well as an orientation aid in English here.