Small Mid-Caps Explained: Omnibus IV Creates a New EU Company Category

The Commission's stated aim is to remove the "cliff-edge" companies face when they grow beyond 250 employees, cease to be small and medium-sized enterprises and become subject to the full compliance obligations of large companies. It estimates that the package would cut around €400 million a year in administrative costs, on top of the €8 billion targeted by earlier simplification efforts.

What the package proposes

• SME-style relief for small mid-caps: access for the first time to certain existing SME benefits, including specific derogations under the General Data Protection Regulation and simpler prospectus rules for listing.
• GDPR record-keeping: SMEs, small mid-caps and organisations with fewer than 750 employees would only need to keep records of processing activities where processing is high risk under the GDPR.
• F-gas registration: around 10,000 companies in 2026 alone would no longer need to register in the EU F-gas Portal, many of them small car dealers trading a few second-hand vehicles.
• Digital product information: paper-based declarations of conformity and instructions for use in product legislation would give way to digital formats.
• Common specifications: a route to show conformity with EU product requirements where harmonised standards are not available.
• Batteries: due diligence obligations under the Batteries Regulation would be pushed back by two years, from 2025 to 2027, with guidelines published a year before they apply.

Who is affected

Growing companies just above the SME thresholds stand to benefit most from the small mid-caps category, particularly those processing personal data at scale without high-risk activities, and those considering a stock market listing. Battery producers and importers gain time to build supply chain due diligence systems. The Commission's questions and answers list eight acts to be amended, including the GDPR, the Markets in Financial Instruments Directive, the Prospectus Regulation, the Batteries Regulation, the Critical Entities Resilience Directive and the F-gas Regulation, and explain that the SME exemption from battery due diligence would be extended to small mid-caps.

What happens next

The proposals go to the European Parliament and the Council. The Commission describes Omnibus IV as part of a wider plan to cut administrative costs by 25% overall, and by 35% for SMEs, by the end of its mandate, and says a defence omnibus is tentatively planned for June 2025, followed by packages for the chemical industry and digital rules.

Sources

• European Commission: Commission proposes simplification measures to save EU businesses a further €400 million per year
• European Commission: Questions and answers on the simplification omnibus and small mid-caps