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Opinion of the European Economic and Social Committee – Communication from the European Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions – The Single Market: our European home market in an uncertain world – A Strategy for making the Single Market simple, seamless and strong (COM(2025) 500 final)

EESC 2025/01859

OJ C, C/2026/871, 27.2.2026, ELI: http://data.europa.eu/eli/C/2026/871/oj (BG, ES, CS, DA, DE, ET, EL, EN, FR, GA, HR, IT, LV, LT, HU, MT, NL, PL, PT, RO, SK, SL, FI, SV)

ELI: http://data.europa.eu/eli/C/2026/871/oj

Date of document:: 03/12/2025; Date of vote
Date of vote:: 03/12/2025
Date lodged:: 14/07/2025

Author:: European Economic and Social Committee
Responsible body:: Section for the Single Market, Production and Consumption, EESC_INT
Rapporteur:: Angelo PAGLIARA Giuseppe GUERINI Emilie PROUZET
Form:: Opinion
Internal reference:: INT/1094, AVIS-SECTION 2025/1859 FIN
Session:: 601

Treaty:

Treaty on the Functioning of the European Union

Legal basis:

12016E304

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Earlier related instruments:

52025DC0500 ESC Opinion

Instruments cited:

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Subject matter:

Internal market - Principles

Directory code:

01.40.10.00 General, financial and institutional matters / Provisions governing the institutions / General

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Official Journal
of the European Union

C series

C/2026/871

27.2.2026

Opinion of the European Economic and Social Committee

Communication from the European Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions – The Single Market: our European home market in an uncertain world

A Strategy for making the Single Market simple, seamless and strong

(COM(2025) 500 final)

(C/2026/871)

Rapporteur:

Emilie PROUZET

Rapporteur:

Angelo PAGLIARA

Rapporteur:

Giuseppe GUERINI

Advisors	Silvia BORELLI (for rapporteur Angelo PAGLIARA) Samuel CORNELLA (for rapporteur Giuseppe GUERINI)
Referral	European Commission, 14.7.2025
Legal basis	Article 304 of the Treaty on the Functioning of the European Union
Section responsible	Section for the Single Market, Production and Consumption
Adopted in section	14.11.2025
Adopted at plenary session	3.12.2025
Plenary session No	601
Outcome of vote (for/against/abstentions)	224/0/4

1. Conclusions and recommendations

1.1.

The European Economic and Social Committee (EESC) fully supports the priorities identified by the Commission, which respond to the challenges raised by stakeholders. It hopes that from now on all efforts will be focused on implementing them effectively.

1.2.

The EESC reiterates the need for a cohesive European response, capable of ensuring the full inclusion of all territories in the single market and addressing existing asymmetries. In this context, regulatory simplification is a strategic lever, but it must take place with full respect for social and workers’ rights. It is therefore essential that European and national parliaments and social partners be structurally involved from the early stages of the legislative process, particularly with regard to the Omnibus packages, on which the EESC will maintain a vigilant stance during adoption.

1.3.

The EESC intends to contribute more actively to the governance of the single market, including by assuming a strengthened role within the Single Market Enforcement Taskforce (SMET) process, in support of the action of Member States, which remain central actors in removing barriers.

1.4.

In light of growing concerns about the rising cost of living, the EESC calls on the Commission to put forward legislative proposals to address territorial supply constraints and to harmonise product labelling, in order to protect consumers and promote fair competition.

1.5.

The EESC welcomes the Commission’s announcement of a proposal for an optional ‘28th regime’ for businesses, but underlines the need for effective safeguards against potential abuses by ensuring a genuine link between the company’s registered headquarters and its economic activity, as well as full clarity on applicable labour and social standards. Parallel regimes that could circumvent existing rules and distort fair competition must be avoided.

1.6.

The EESC recognises the key role of standardisation as a driver of integration and innovation, but stresses that the related processes must be based on principles of transparency, inclusiveness and structured participation, especially in light of the growing impact of standards in sensitive sectors. It recommends that these principles be fully guaranteed in the forthcoming revision of the standardisation regulation.

1.7.

The EESC supports simplifying the recognition of professional qualifications, including for third-country nationals, but emphasises that qualifications must be clearly defined, verifiable and of proven quality. It expresses concern over the use of self-certification mechanisms, especially in sectors where qualifications directly affect health, safety and public responsibility.

1.8.

The EESC supports strengthening the European Labour Authority (ELA), recommending that its remit be extended to include situations involving third-country workers, and welcomes the expansion of its operational competences.

1.9.

In light of the Letta report, the EESC calls for the scope of the single market to be extended to strategic sectors such as energy and finance. It underlines the need for an inclusive governance model inspired by the social market economy, and calls for the revision of public procurement legislation to include simplified procedures. At the same time, appropriate ways should be found to take into account social, environmental and innovation objectives. Access to public procurement should always be linked to respect of the right to collective bargaining, and to compliance with relevant labour and social regulation and applicable collective agreements signed by the most representative social partners according to national labour law and practices.

2. Introduction and context

2.1.

On 21 May 2025, the Commission published its Communication titled The Single Market: our European home market in an uncertain world. A Strategy for making the Single Market simple, seamless and strong.

2.2.

The document covers the following pillars: i) fewer barriers, ii) a new approach to boosting European services, iii) more focus on small and medium-sized enterprises (SMEs) including innovative start-ups and scale-ups, iv) more effective digitalisation, v) more simplification, vi) more effective implementation and enforcement, vi) more ownership: increasing political and national engagement, vii) more synergy: paradigm shift in EU spending and viii) more protection: acting as a shield against unfair trade practices.

3. General comments

The EESC praises the single market as one of the main achievements of the European integration process, both technically and politically, which ensures prosperity and solidarity for EU citizens. However, the single market needs to be further strengthened and consolidated through concrete actions, as highlighted by the Commission in its strategy.

The EESC shares the priorities identified by the Commission, which respond to the challenges raised by all stakeholders for many years.

3.1. Simplification and competitiveness in a coherent regulatory framework

3.1.1.

The EESC emphasises the importance of the single market as a factor of stability, resilience and the necessary ‘minimum significant size’ in the current global context, which is marked by strong geopolitical and trade tensions. These challenges require a unified European response in a changed and uncertain environment.

3.1.2.

The EESC calls for a more competitive and simplified single market, as promoted in the Draghi and Letta reports and currently pursued by the Commission, while also underlining the need to maintain an effective and robust cohesion policy capable of ensuring the full inclusion of all territories within the single market and addressing the existing asymmetries and supporting the green and social transition.

3.1.3.

From the perspective of a more competitive and simplified single market, the EESC once again underlines the strategic importance of effectively applying the competitiveness check and impact assessment to regulations.

3.1.4.

Such simplification measures should not affect the high social, labour and fundamental rights enshrined in EU and national laws and in collective agreements. Social partners and European and national parliaments should be systematically involved in the drafting and consultation phases of the Omnibus simplification package, in line with the principles of democracy that feature the European social model (in line with Article 3 TEU).

3.1.5.

The EESC believes that the finance, energy and electronic communications sectors have now taken on a strategic and supranational dimension that goes beyond the initial construction of the single market. Such sectors should therefore be prioritised when planning the future of the single market, as the Letta report has already emphasised.

3.1.6.

The EESC supports the Commission’s objective of simplifying EU-derived rules and acknowledges that the recent Omnibus packages has made important progress in simplifying legislation and reducing compliance costs for businesses.

3.2. More ownership and joint responsibility of EU institutions and Member States

3.2.1.

The Commission identifies the adoption of the internal market by Member States as a key challenge. Without political will on their part, it will be impossible to remove barriers, prevent new ones from being created and strengthen the internal market. The EESC agrees, in principle, that Member States must show greater responsibility and awareness towards the single market, since no one can remove barriers to the market better than the Member States themselves.

3.2.2.

The EESC has been alarmed for years by the protectionist tendencies of Member States on the European market for goods and services and therefore supports measures identified in the communication to strengthen prevention, collaboration and corrections tools.

3.2.3.

At the same time, the EESC notes that the Letta report proposes a multi-stakeholder’s approach, including social partners in shaping the future of the single market consistently with the Treaties’ vision of a competitive ‘social market economy’, calling for the Commission’s attention in this respect.

3.2.4.

The EESC calls on the Commission to:

—	give priority to implementing measures to address this issue;

—	include the EESC in the work of the SMET;

—	ensure a genuine multi-level and inclusive governance structure, which strengthens not only the role of national governments but also includes European and national parliaments and social partners and relevant stakeholders in shaping and implementing single market policy;

—	explicitly recognise the European social dimension of the market, including the role of collective agreements, European and national labour standards and social enterprises, which must not be mischaracterised as market barriers.

3.2.5.

The EESC welcomes the integration of the single market dimension into the rule of law report (1).

3.2.6.

The EESC agrees with the Commission about the importance of effective enforcement of single market rules, since only timely and robust application ensures that the single market’s benefits actually reach citizens and businesses (an issue also emphasised in the Draghi and Letta reports). The EESC therefore takes note of the establishment of the ‘High-Level Sherpa Group on the Single Market’ and calls for meaningful participation of social partners in this process, expressing its readiness to actively collaborate with the Commission and Member States in this regard. Considering the existing mandate of the SMET, the EESC underlines the importance of ensuring consistency and efficiency between the SMET and the new Single Market Sherpa Group to avoid overlaps and guarantee coherent and effective enforcement architecture for the single market.

3.2.7.

Finally, the EESC strongly supports the Commission’s intention to speed up the handling of complaints procedures.

3.3. More digitalisation: key for smart implementation

3.3.1.

The EESC supports clearer and more harmonised rules for digital and data services to foster trust, innovation and legal certainty. It underlines that this must go hand in hand with the protection of users and workers, in line with the precautionary principle enshrined in the Treaties and the human-in-control principle. The EESC encourages the EU to ensure that digitalisation respects fundamental rights, including transparency, accountability and fair working conditions, and promote fair and democratic access to digital technologies and opportunities.

3.4. More focus on SMEs

3.4.1.

The EESC takes note of the proposal to introduce an SME ID tool based on self-assessment. The Committee warns that relying solely on self-declaration could create legal uncertainty and open the door to fraudulent practices. It is therefore essential to develop adequate safeguards and verification mechanisms to ensure that the tool is used transparently and in compliance with national and EU labour and social standards. In this context, the EESC also underlines the importance of ensuring that company law is applied in a way that upholds workers’ rights, encouraging the development of a robust and balanced regulatory framework that prevents potential misuse while supporting fair and transparent business practices.

3.5. More ambition to boost services

3.5.1.

The EESC fully supports strengthening the EU services market pursued by the Commission, recognising the central role of services in today’s economy. The EESC particularly emphasises the need to remove barriers in: i) the retail sector, which could raise gross value added (a 10 % barrier reduction could bring about + 0,6 % GVA according to Commission estimations), ii) construction, to enable more efficient and affordable buildings in light of the current housing crisis and iii) financial services, which remain significantly less competitive and attractive compared to markets like the US.

3.5.2.

The EESC highlights that effective and sustainable market integration requires the active involvement of social partners and full respect for fair competition principles, in order to safeguard labour rights and standards and ensure a level playing field. Particular attention should be paid to sectors such as construction and logistics, which are especially exposed to risks of social dumping. Therefore, a common European approach should be accompanied by appropriate safeguards, especially within the framework of public procurement.

4. Specific observations

4.1. Barriers related to horizontal issues

4.1.1.

The EESC welcomes the work to reconsider overly complex EU rules.

4.1.2.

In this regard, the EESC reiterates the importance of promoting full access to the potential of the single market for social economy entities as well. It therefore calls on the European Commission to review its recent decision to withdraw the proposal on the European Cross-Border Association (ECBA).

4.1.3.

Regarding a key issue for the single market like public procurements, the EESC stresses that the new draft directives expected in 2026 should especially focus on: i) simplification to promote greater cross-border mobility of businesses, which remains weak in the public contracts field and ii) better enforcement of the principles already promoted in directives 23, 24 and 25 of 2014. The draft directives should also ensure that access to public procurement is always linked to respect of the right to collective bargaining according to national labour law and practices, and to compliance with relevant labour and social regulation and applicable collective agreements signed by the most representative social partners under national labour legislation.

4.1.4.

The EESC welcomes the Commission’s announcement of a proposal to establish an optional ‘28th regulatory regime’ aimed at facilitating cross-border business activities through harmonised rules and a strong digital foundation. This initiative has the potential to reduce administrative burdens, support business alliances across Europe and serve as a stepping stone towards a more integrated European corporate framework.

4.1.5.

At the same time, the EESC stresses that this new regime must be designed with appropriate safeguards to prevent abuse, particularly the misuse of letterbox companies, by ensuring a genuine link between corporate headquarters and business activity (real seat principle). It is equally important to maintain legal clarity on the applicable labour and social standards, and to avoid the creation of parallel legal frameworks that could undermine fair competition or bypass existing national and European rules, including collective agreements.

4.1.6.

Furthermore, the EESC stresses the need to assess the actual impact of Directive (EU) 2019/1151 of the European Parliament and of the Council (2), particularly to ensure that digital procedures do not weaken anti-abuse safeguards.

4.1.7.

The EESC supports faster standardisation to promote innovation and market integration, but stresses that the scope of technical standards should be limited and must not interfere with labour rights and industrial relations. These areas must remain under the responsibility of democratically negotiated frameworks, including legislation, collective bargaining and social dialogue mechanisms.

4.1.8.

The EESC calls for the free and structured involvement of social partners and civil society organisations in any standard-setting process so that citizens, workers and consumers’ interests are duly considered.

4.2. Barriers related to goods

4.2.1.

The EESC acknowledges the fragmentation of rules on packaging, labelling and waste as one of the ‘terrible barriers’. In this context, the willingness of Member States to play the internal market game is key. The EESC highlights the need to assess the implications of the Triman case and similar cases witnessed in the last years, which have involved multiple Member States and questioned the compatibility of national labelling regulations with EU law. In the agri-food sector, initiatives on packaging and labelling must be aligned with the general regulation on the provision of food information, but also compatible with the needs of farmers and the food cultures of different countries and regions.

4.2.2.

The EESC agrees with the Commission that EU legislation on placing products on the market is a key asset of the single market and supports further harmonisation of product compliance and liability rules across the entire value chain, involving all stakeholders with a comprehensive approach (producers, processors, distributors, importers, etc.).

4.2.3.

The EESC agrees with the Commission that territorial supply constraints in retail and wholesale trade fragment the single market, restrict consumer choice and lead to price disparities across the EU. The EESC therefore encourages the Commission to consider a dedicated legislative initiative in this respect, noting that competition rules only partially address this issue when (concerted) practices violate Article 101 TFEU.

4.3. Barriers to services

4.3.1.

The EESC agrees with the Commission’s assessment: services make up the largest part of Europe’s economy.

4.3.2.

In this context, the EESC recognises that retail competitiveness is held back by restriction of the establishment of shops and their operations. A guide on proportionality could be a useful tool. However, the EESC is concerned that this will not be enough to compel Member States to change their frameworks, given that the situation is worsening for trade in many countries, particularly in France. The EESC therefore calls on the Commission to be extremely vigilant on this issue.

4.3.3.

In parallel, the EESC supports the Commission’s goal to improve the recognition of professional qualifications across Europe, as it is essential for freedom of movement for people within the single market. Special attention should, however, be paid to verifying declared skills, particularly in professions related to health, safety and welfare.

4.3.4.

The EESC welcomes the coherent approach adopted by the European Commission in addressing qualification recognition in both the ‘single market’ and ‘union for skills’ communications. While supporting efforts to facilitate the recognition of professional qualifications, including those from third countries, the Committee stresses that such recognition must ensure that declared skills are verifiable, clearly defined and of proven quality. In particular, the EESC warns against reliance on self-certification mechanisms, especially in professions that involve health, safety or high public responsibility.

4.3.5.

The EESC recognises the importance of improving the functioning of the single market for services as a driver of competitiveness, innovation and growth. However, this objective must be pursued in full compliance with existing social standards and the prerogatives of Member States in the field of labour law.

4.3.6.

In accordance with Article 114(2) TFEU, internal market legislation shall not affect national provisions relating to the rights and interests of employed persons. The EESC therefore underlines the need to ensure that future initiatives on freedom to provide services fully respect the national legislation and collective agreements applicable in the host country.

4.3.7.

The Committee encourages a balanced approach that promotes fair competition, improves service provision across borders and safeguards workers’ rights and equal treatment, thereby contributing to an integrated and socially sustainable single market as prescribed by Article 9 TFEU.

4.3.8.

The EESC calls on the Commission to define clear and objective criteria in its upcoming legal guidance to ensure legal certainty and prevent misuse of the principle of cross-border provision of services.

4.3.9.

The EESC acknowledges that Directive 2014/67/EU of the European Parliament and of the Council (3) has contributed to reducing fraud in the posting of workers. However, it notes that many companies, especially SMEs, continue to face unfair competition due to circumvention of the rules and persistent fraudulent practices. It stresses that enforcement of existing rules must remain a priority and highlights the importance of the prior declaration of posting for effective inspections by national authorities.

4.3.10.

The EESC proposes a reform of the rules on subcontracting, including in the context of posted workers, in order to prevent the unnecessary length of subcontracting chains and thereby to ensure the principle of equal treatment for all workers performing the same activity, regardless of their contractual position within the subcontracting structure.

4.3.11.

The EESC welcomes the Commission’s intention to strengthen the effectiveness of the European Labour Authority (ELA), including by enhancing its competences in handling personal data and by providing the authority with additional personnel. It also recommends extending the ELA’s remit to cover the situation of workers from third countries, who are currently excluded, in order to prevent abuses and improve the monitoring of compliance with rules within the single market.

4.3.12.

The EESC welcomes the proposal to digitalise the application procedure for the portable document ‘A1’ through a European Social Security Pass (ESSPASS). This proposal should provide the national competent authorities the possibility to digitally verify, in real time, any social security statements, including the portable document ‘A1’, thus reducing the risk of error and fraud.

Brussels, 3 December 2025.

The President

of the European Economic and Social Committee

Séamus BOLAND

(1) Opinion of the European Economic and Social Committee – The economic dimension of the rule of law (own-initiative opinion) (OJ C, C/2025/3190, 2.7.2025, ELI: https://eur-lex.europa.eu/eli/C/2025/3190/oj).

(2) Directive (EU) 2019/1151 of the European Parliament and of the Council of 20 June 2019 amending Directive (EU) 2017/1132 as regards the use of digital tools and processes in company law (OJ L 186, 11.7.2019, p. 80, ELI: http://data.europa.eu/eli/dir/2019/1151/oj).

(3) Directive 2014/67/EU of the European Parliament and of the Council of 15 May 2014 on the enforcement of Directive 96/71/EC concerning the posting of workers in the framework of the provision of services and amending Regulation (EU) No 1024/2012 on administrative cooperation through the Internal Market Information System (‘the IMI Regulation’) (OJ L 159, 28.5.2014, p. 11, ELI: http://data.europa.eu/eli/dir/2014/67/oj).

ELI: http://data.europa.eu/eli/C/2026/871/oj

ISSN 1977-091X (electronic edition)

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