szukaj

ZPP Position on the Proposed Military Mobility Regulation

The European Union faces challenges in moving defence equipment and personnel across borders, caused in large part by fragmented national regulations. The proposed Military Mobility Package introduces a Regulation which seeks to address these issues, by standardising transport procedures for military goods and staff throughout the EU. In this Report, the Union of Entrepreneurs and Employers outlines key aspects of the proposal and shares insights based on consultations within Poland’s defence sector.

See more: ZPP Position on the Proposed Military Mobility Regulation

Open Letter on the Digital Omnibus Proposal

Warsaw, 9.12.2025

Open Letter on the Digital Omnibus Proposal

Dear Members of the Council of the European Union,
Dear Members of the European Parliament,

On behalf of the undersigned organisations, we express our strong support for the direction the European Commission has taken with its “Digital Omnibus” package proposal. However, we must unequivocally state that its current scope remains insufficient. This initiative marks a promising and much-needed first step toward meaningful deregulation in Europe, but it stops short of the bold, pragmatic, and forward-looking measures required to unlock Europe’s digital potential and secure its long-term economic prosperity.

Europe is steadily losing its global standing and must now take decisive, visionary action to reverse this trend. We cannot hope to achieve genuine “strategic autonomy” if we are incapable of developing our own foundational technologies. Nor can Europe expect to retain influence on the world stage in the 21st century without being a leading economic and technological power – an imperative more pressing than ever.

For these reasons, we urge that the European Commission’s proposal be seen not as a final goal, but as a starting point that must be strengthened and expanded. A vibrant, innovative, and data-driven economy is indispensable to the success of the European project. Economic progress is not a threat to our values – it is the very condition for preserving them.

CLARITY & SIMPLIFYING THE LAW
The growing complexity of EU regulation creates invisible barriers and mounting costs for business – particularly Europe’s SMEs and start-ups, the driving force of our economy. Instead of building new products, innovators are forced to spend resources on lawyers and consultants just to determine whether their idea is even legal. As a result, the AI Act and other recent EU proposals risk becoming a web of “spaghetti law” – decipherable only by paid experts, rather than clear, functional texts meant to guide innovation.

This excessive complexity risks turning the AI Act into an unintended barrier to entry. Companies may abandon AI development not because they cannot build safe products, but because they cannot confidently determine whether they comply with the rules. This chilling effect in practice favours only the largest, best-resourced players – undermining the very innovation Europe seeks to promote.

Call to action: To avoid this, the AI Act must be radically simplified. It should establish clear, proportionate and genuinely understandable compliance pathways for small and medium-sized enterprises, while upholding the high standards of fundamental rights protection that underpin the constitutional traditions of the Member States and of the Union as a whole.

STOP THE CLOCK
The AI Act, the world’s first comprehensive framework for regulating AI, has adopted an overly restrictive, a priori approach that treats AI primarily as a threat. Its extensive prohibitions and administratively burdensome obligations risk critically impeding innovation and placing European developers and users at a severe disadvantage in the global AI race. The urgent call to “stop the clock” is therefore imperative – specifically, the two-year postponement of the remaining provisions of the AI Act as proposed by initiatives such as the “EU AI Champions,” supported by major industry leaders including Airbus and Siemens. This pause would provide European companies with the necessary time for effective implementation while allowing for a fundamental review and simplification of the current framework, preventing Europe from falling further behind global competitors such as the United States, which are actively pursuing an AI strategy focused on “winning the race.”

Call to action: It is essential to unambiguously “stop the clock” and implement an unconditional two-year postponement of the remaining provisions of the AI Act, that haven’t yet entered into force. As a bare minimum the timeline extension should be a separate legislative proposal within the Omnibus package, enabling a swift adoption to avoid legal uncertainty for the industry.

GDPR
We commend the Commission for its political courage in presenting a meaningful improvement to the data protection regime that Europe’s digital industry so urgently needs. For years, public debate around Europe’s lag in the AI revolution has centered on the AI Act, but as the Draghi report rightly identified, our data protection framework has posed an even greater barrier to innovation. While we welcome the targeted amendments to the AI Act, the proposed clarification to the GDPR – specifically confirming that development and training of AI systems can rely on legitimate interest as a legal basis – represents perhaps the single most important step for creating truly European AI.

Call to action: Ensure that the rules governing the use of legitimate interest for AI development and training are clear, coherent and easily understandable for businesses. The framework must deliver genuine legal certainty and harmonisation across the Union, leaving no room for divergent or restrictive interpretations by supervisory authorities.

CYBERSECURITY
We welcome the Commission’s efforts to streamline cybersecurity rules through initiatives such as the Single Entry Point (SEP) for incident reporting. This is a positive first step toward reducing fragmentation. However, much more needs to be done to ensure clarity, harmonisation, and trust across the EU’s cybersecurity framework. Today, overlapping requirements under NIS2, CRA, and DORA create unnecessary complexity and compliance costs, diverting resources away from actual risk mitigation. Further simplification of AIA-CRA conformity is necessary for example. It should be possible to demonstrate conformity under both legal acts through common conformity assessment, not just certification (as currently foreseen by AI Act).

Many critical gaps remain: inconsistent reporting obligations across Europe, liability protection for reporting is missing, and conformity harmonisation is absent from the Digital Omnibus. Without addressing these issues, companies will continue to face redundant audits and fragmented national rules, undermining the goal of a unified cybersecurity framework.

Call to action:

  • Ensure that the SEP allows companies to report to the relevant national authority in their country of main establishment.
  • Ensure that companies operating across the EU report into the country of their main establishment.
  • Introduce liability protection clauses for reporting to build trust and encourage transparency.
  • Address fragmentation by including conformity harmonisation in the Digital Omnibus, eliminating overlapping audit requirements under NIS2, CRA, and DORA.

COPYRIGHT
The development of AI models needs clear and flexible copyright rules that permit the use of copyrighted works in training. The industry is relying on the Text and Data Mining (TDM) exceptions enshrined in Articles 3 and 4 of the copyright in the digital single market (CDSM) directive, which are not perfect, but are the result of a hard fought compromise. Recently however, this situation is being challenged – both politically within the European Parliament, and judicially by some member state courts. Without legal protection for acts of transient use of copyrighted works during AI model training all research in the field in Europe will stop. This would be a calamity with consequences far graver than the burdens of the AI Act and must be avoided.

Call to action: The legal basis for AI development in the EU in Articles 3 and 4 of the CDSM Directive is fundamental to innovation and must be firmly safeguarded against any attempt to narrow or undermine them. Furthermore, they must be clarified and expanded to provide a stable, pan-European legal basis for all forms of AI training across the EU.

We pledge our full support to advancing this proposal through the legislative process and expanding wherever possible. In particular, we will advocate for clear legal provisions enabling the postponement of the AI Act’s obligations and for the establishment of a robust legal basis for legitimate interest in AI training under the GDPR. We are committed to working closely with members of the European Parliament and the Council to ensure that this package is adopted swiftly and effectively, delivering on its promise and the broader objectives outlined in the above calls to action.

We stand ready to assist you in this essential mission.

Respectfully,

Tomasz Snażyk – CEO – AI Chamber
Csongor Bias – MD – Startup Hungary
Jakub Bińkowski – Board Member – The Union of Entrepreneurs and Employers (ZPP)
Simonas Černiauskas – CEO – Infobalt
Milena Jabůrková – Vice-President – Confederation of Industry of the Czech Republic
Jolanta Jaworska – President – Digital Technology Employers’ Association Lewiatan
Lukáš Kačena – Director – PRG.ai, Czech National AI platform
Michał Kanownik – CEO – Digital Poland Association
Michal Kardoš – Executive Director – Slovak Alliance for Innovation Economy (SAPIE)
Peter J. Kofler – Chairman of the Board – Danish Entrepreneurs
Egle Markeviciute – EU Affairs Manager – Consumer Choice Center Europe
Gergana Passy – President – Digital National Alliance, Bulgaria
Marek Tatała – CEO – Economic Freedom Foundation

See: Open Letter on the Digital Omnibus Proposal

ZPP Position on the EU Defence Industry Transformation Roadmap

Brussels, 1.12.2025

ZPP Position on the EU Defence Industry Transformation Roadmap

The European Commission presented its new European Defence Industry Transformation Roadmap, which seeks to apply lessons learned from the war in Ukraine for adapting Europe’s defence capabilities to the realities of modern warfare. While we believe some of the findings presented in the Roadmap to be of merit, we are concerned that it may reflect a shift away from established and proven defence industry actors, which could both reduce European preparedness in the face of ever-growing threats and undermine competitiveness.

See more: ZPP Position on the EU Defence Industry Transformation Roadmap

ZPP Position – The State of the Energy Union’s Need for Nuclear Considerations

Brussels, 26 November 2025

ZPP Position – The State of the Energy Union’s Need for Nuclear Considerations

On 6 November 2025, the European Commission published the 2025 edition of its State of the Energy Union Report. While the Report gives an overview of the progress being made in achieving Europe’s energy targets and outlines the next steps needed, the Union of Entrepreneurs and Employers (ZPP) finds it sorely lacking in one field: nuclear energy.

Read our position here

Press Release: European Defence at the Frontier: Unmanned Systems and Strategic Readiness

Brussels, 19 Nov 2025

Press Release: European Defence at the Frontier: Unmanned Systems and Strategic Readiness

On Wednesday, 12 November 2025, the Union of Entrepreneurs and Employers (ZPP) and European Enterprise Alliance (EEA) organised a high-level policy discussion titled “European Defence at the Frontier: Unmanned Systems and Strategic Readiness”, hosted by MEP Kosma Złotowski, MEP Rasa Juknevičienė, and MEP Michał Dworczyk in the European Parliament in Brussels.

The discussion brought together EU representatives and experts including KOSMA ZŁOTOWSKI, Member of the European Parliament; RASA JUKNEVIČIENĖ, Member of the European Parliament and former Minister of Defence of Lithuania; REINIS POZŅAKS, Member of the European Parliament and the Committee on Security and Defence (SEDE); PEKKA TOVERI, Member of the European Parliament and the SEDE Committee; JONAS CEDERLÖF, Deputy Head of Unit, Strategy, Interinstitutional Relations, and Security at the European Commission’s DG DEFIS; STÉPHANE OUAKI, Acting Director of the European Innovation Council and SMEs Executive Agency (EISMEA); DAREK SAUNDERS, Head of Research and Technology Sector at Frontex; JAMIE SHEA, Senior Fellow for Peace, Security and Defence with Friends of Europe; MAŁGORZATA DAROWSKA, WB Group’s Director for EU Affairs; and JAKUB BIŃKOWSKI, Board Member at Union of Entrepreneurs and Employers (ZPP).

The discussion was moderated by LUSYNE KESZISZJAN, Head of the Union of Entrepreneurs and Employers Brussels Office.

In his opening remarks, MEP KOSMA ZŁOTOWSKI began by stressing the urgency of finding an effective response to the growing hybrid threat that drones pose for Europe. He called for comprehensive, European solutions, both for fielding our own drones and for countering hostile UAS, all developed within the Union and deployed in both civilian and military conditions. As the event later drew to a close, MEP Złotowski ended with a short but powerful message of only five words: “we must produce effective drones”.

MEP RASA JUKNEVIČIENĖ considered the changing security landscape in Europe, stating that “be it eastern border, be it the European Union, be it the European continent, we are at war”. She stated that while conventional warfare may currently be limited to Ukraine, this does not make the threat any less real for the rest of Europe. MEP Juknevičienė urged policymakers and defence actors to learn from the situation in Ukraine, drawing from the experiences of deploying UAS and countering hostile drone actions.

MEP REINIS POZŅAKS’ keynote address focused on his role as rapporteur for the forthcoming report ‘Drones and new systems of warfare – the EU’s need to adapt to be fit for today’s security challenges’. He opened by stating that “drones are not a toy anymore in the budget,” reflecting their growing priority for spending. He then went on to discuss how this is a field in which Europe will always be in a race with its global competitors, with it sometimes being ahead and sometimes falling behind, but with a need to be ready for both scenarios. This requires creating a supportive ecosystem for the civil defence infrastructure and early warning systems required to stave off potential threats. MEP Pozņaks also commented on the unique nature of drone developments given their constant need for updates. Referring to the fact that nearly every brigade in the Ukrainian military having a drone workshop, he highlighted that improved uptake of UAS systems into EU defence policies needs to account not only for the initial demand, but also the continuous need for updates on the frontlines.

MEP PEKKA TOVERI considered the two forms of dangers posed by hostile UAS actions. The first is the threat of mass attacks along the Eastern border, while the latter involves covert deployment of drones from within the EU to attack critical infrastructures anywhere in the Union. He made it clear that these two scenarios require very distinct solutions, and thus urges C-UAS development to show consideration for the different scenarios in which UAS may be deployed against Europe.

JONAS CEDERLÖF, as the European Commission coordinator for the European Drone Defence Initiative, provided his insights from the Commission’s position as a coordinating body and provider of funding. He stressed that European defence actors are already doing a lot of good work, but that they need to accelerate their work and push their ambitions further. He emphasised that there needs to be a balance between predictability and agility, which will be enabled by the European Defence Fund. Mr. Cederlöf also discussed the role given to Member States going forward, as national actors will come together to address synchronised needs on mutually important questions, particularly through the use of common procurement projects made possible by the forthcoming European Defence Industry Programme. Finally, he pointed out that the Commission is working hard to remove unnecessary fragmentation without giving rise to monopolies, stressing that competition within the Union will also boost Europe’s global competitiveness.

STÉPHANE OUAKI provided another perspective from within the Commission, focusing on the side of funding innovation. The Horizon Europe programme has already provided substantial support for startups and SMEs in the deep tech sector including UAS development. With the recent changes from the so-called Mini-Defence Omnibus, funding programmes will no longer be limited to dual-use technologies either but will instead also be available for dedicated defence products. Because of this, he expressed optimism about the European Innovation Council’s ability to provide strong support for the industry moving forward.

DAREK SAUNDERS discussed the dual-use applications of drones when it comes to the field of border management. He emphasised that UAS and C-UAS technologies must work in concert in comprehensive surveillance systems, and that these systems should be integrated across all areas of surveillance including land, air, maritime, and space. Mr. Saunders called for consideration to be shown for all components that go into these systems, considering not only the drones themselves but also the communications systems, Command and Control structures, and cybersecurity measures. Similarly, he highlighted the value in highly trained operators, stating that even with a perfect system it is the operator who determines whether the UAS operates at its best or is misused. Mr. Saunders ended his intervention by reflecting on the current slow pace of Frontex’s innovation process, stating that simplified research and procurement processes as well as an increase in supply are all essential factors to reaching the agency’s needs.

MAŁGORZATA DAROWSKA stressed that in addition to up-and-coming SMEs and startups, the European defence ecosystem also has a strong presence of capable mid-caps that already have the capacity for meeting the security needs. These companies have battle-proven and interoperable products, but due to the lack of a supportive market in Europe they are forced to sell internationally instead. Therefore, she called for policymakers to implement legislation that makes the European Single Market more conducive for European producers to sell within the Union. One particularly important aspect of such reforms would be to ensure that only trusted suppliers producing user-safe products should be allowed to operate on the European market, since an oversaturation of suppliers could raise security concerns. Ms. Darowska also called attention to the particularities of the drone industry, pointing out that it is a field that does not necessarily focus on inventing new technologies, but rather on integrating existing products from other fields such as communications to advance the innovativeness. She finished her intervention by stating that UAS and C-UAS technologies are two sides of the same coin, and as such need to be approached with the same logic.

Drawing from an extensive career in security policy, JAMIE SHEA began by explaining why UAS pose such a great threat to European society. He raised their superior mobility – both in the sense of being able to quickly move from one country to another, but also in their ability to be deployed from practically anywhere – the difficulty of determining who is operating a drone, and their inexpensiveness. Dr. Shea called for legal frameworks and civilian security capabilities to be updated to better reflect this new nature of threats, including streamlined police responses, greater perimeter defence in vulnerable areas such as airports, and a better intelligence picture of operators by means of a drone registration system. He also called for C-UAS technologies to be developed in a way that ensures civilian safety, since high-tech jammers are less likely to cause collateral damage than shooting down hostile UAS.

JAKUB BIŃKOWSKI approached his intervention through a lens of economic policy, and noted that Europe as a whole is showing unprecedented support for the defence industry, with the example of Poland’s defence budget for 2026 being set at nearly €47 billion. That being said, he also stresses the need to ensure that this increased funding is utilised effectively, and that they address both the pressing concern for defending Europe against current aggressors, but also the need for building resilience against future threats. Mr. Bińkowski called for defence funding to target three key areas: established companies with strong track records should receive further assistance in scaling up to meet rising demands, smaller subsectors within the defence industry need support for developing highly technical and innovative solutions, and making effective use of Europe’s great human capital.

PRESS RELEASE

Call to Action on the OMNIBUS I Simplification Package

Brussels, 7.11.2025

Call to Action on the Omnibus I Simplification Package


Together with 19 associations across Europe, we call on EU policymakers to address the growing regulatory pressure facing European companies at a time of rising energy costs, declining investment, and weakening competitiveness. As the European Parliament prepares to vote on the Omnibus I Simplification Package on 13 November 2025, our coalition urges decision-makers to ensure that the proposal delivers real, effective simplification. The aim is not to reduce Europe’s sustainability ambition, but to make reporting requirements proportionate, cost-effective, and focused on material information, enabling companies to invest in genuine decarbonisation and innovation rather than expanding administrative overhead. The full document below sets out our assessment of the challenges and the adjustments needed to align sustainability reporting with Europe’s economic and industrial realities.

 

Call to Action on the OMNIBUS I Simplification Package

Artificial intelligence and digitalisation for energy – a roadmap

Brussels, 6.11.2025

Artificial intelligence and digitalisation for energy – a roadmap

Union of Entrepreneurs and Employers has submitted both an open public consultation and a call for evidence on Artificial Intelligence and digitalisation for energy – a roadmap. Our response reflects the perspective of businesses working at the core of Europe’s energy transition, highlighting the need for interoperable standards, secure data access, and effective deployment of AI tools. We emphasise smart grids, demand-side flexibility, and digital innovation as critical enablers of decarbonisation and competitiveness. ZPP remains ready to support the EU in shaping a trusted governance framework for digitalisation in the energy sector.

 

Read more

ZPP Policy Brief on the Defence Readiness Roadmap 2030

Brussels, 5.11.2025

ZPP Policy Brief on the Defence Readiness Roadmap 2030

In its new communication “Preserving Peace – Defence Readiness Roadmap 2030”, the European Commission presents objectives and milestones for achieving the state of military preparedness required to face the ever-growing risks surrounding Europe. The Commission expresses a clear priority in deploying innovative modern warfare capabilities. In this report, we explain each of the proposal areas discussed in the Roadmap, as well as provide a concise overview of all the milestones presented.

More info: ZPP Policy Brief on the Defence Readiness Roadmap 2030

ZPP submits its position on the proposed EU Programme for the Single Market and Customs 2028–2034 to the Polish Ministry of Technology and Development

ZPP submits its position on the proposed EU Programme for the Single Market and Customs 2028–2034 to the Polish Ministry of Technology and Development

 

The Union of Entrepreneurs and Employers (ZPP) has submitted its position on the European Commission’s proposal COM(2025) 590, establishing a new Programme for the Single Market and Customs for 2028–2034 to the Polish Ministry of Technology and Development. The initiative seeks to merge four existing EU instruments – the Single Market, Customs, Fiscalis (Taxation Cooperation), and EU Anti-Fraud Programme – into one coherent framework supporting competitiveness, trade, and enforcement across the Union.

In its feedback, ZPP welcomes the consolidation and highlights the Programme’s potential to strengthen the EU’s customs system, enhance cooperation, and accelerate digital transformation through initiatives such as the EU Customs Data Hub. The Programme must remain closely aligned with the ongoing Union Customs Code (UCC) reform to avoid duplication and ensure effective implementation.

ZPP’s position outlines key priorities for business, including digitalisation and interoperability, simplification for SMEs, proportional platform liability, and a harmonised approach to customs fees. We also call for dedicated EU funding to modernise Poland’s customs infrastructure and active involvement of Polish experts in shaping the EU Customs Authority and related governance structures.

 

Read more.

UCC – Update Briefing

UCC – Update Briefing

The European Union is entering a decisive stage in negotiations on the Union Customs Code (UCC) reform, aiming to build a centralized, data-driven, and fully digital customs system.


Our latest update outlines the current state of play between the Council, Parliament, and Commission, key points of agreements, from the €150 de minimis removal to platform liability, and what these changes mean for businesses and digital platforms. A reform that will reshape cross-border trade, customs enforcement, and digital commerce across Europe by 2038.

 

Read full update.

 

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