NOTE
10. april 2018
Dokumentnummer
Initialer-ERST
The Danish government’s
response to the public consultation on the
review of the SME definition
The Danish government supports the objective of the European Commis-
sion of ensuring that the SME definition remains fit for purpose and
meets its objectives in the current economic environment.
To the Danish government it is important that the revised SME definition
is not unnecessarily expanded compared to the definition from 2003
(Recommendation 2003/361/EC). As most enterprises in the EU already
can be classified as SMEs, a definition that allows more enterprises into
this classification will make it more difficult to help the genuine SMEs
whom the definition was created to help.
With regard to the three criteria in the definition, the Danish government
agrees that staff head count is the most important one and thus should be
taken into account. It is important that the current headcount criterion (<
250 in annual full-time equivalents) is not changed due to larger compa-
nies not necessarily having the same challenges as smaller companies,
and are thus not easily characterized as SME's.
When it comes to the financial parameters, the Danish government be-
lieves that it should still be possible to exceed one of the two financial
ceilings. The ceilings can be adjusted for inflation, but it is important that
they are not significantly raised any further, as this would again include
companies in the definition who does not have the need for relaxed rules,
such as smaller companies.
The court rulings from September 2016 make it clear that the question of
independence/ownership in Article 6 must be addressed. It is important
that the future SME definition does not entail further complexity in de-
termining whether a company is an SME or not. At the same time, the
definition must not be unnecessarily expanded or open up for large enter-
prises to get access to support intended for genuine SMEs, as the defini-
tion should make sure that administrative burdens and the likes are not a
competitive disadvantage for SME's, and this balance would be upset
with the inclusion of larger companies.
The Danish government takes into account the developments since the
definition was made in 2003, but finds it crucial that the revised SME