SFA Submissions

The SFA is recognised by those that matter as the "Voice of Small Business" in Ireland. We leverage this influence to ensure the best deal for small business. Our mission is to ensure that the Government, the opposition parties, the civil service and the general public, realise the importance of the small business sector. We regularly meet with Government Ministers directly on particular issues of concern and make submissions to Government Departments, we give evidence before Joint Oireachtas Committees and lobby influencers across the spectrum. Below you will find some of our most recent submissions that we have made.

Statement to the Seanad Public Consultation Committee

13/11/2018 - On13 November, the Small Firms Association appeared before the Seanad Public Consultation Committee to exam the creation of an integrated national strategy proposal document supporting the fostering, growth and sustainability of indigenous Irish SMEs. Sven Spollen-Behrens, SFA Director and Rebecca Harrison, Owner and Managing Director of Fishers in Newtownmountkennedy presented on behalf of SFA members. .. Read more


SFA submission to the public consultation for a new ‘Automatic Enrolment’ Retirement Savings System

05/11/2018 - The SFA made a submission to the Employment Affairs and Social Protection consultation on the proposed introduction of an Automatic Enrolment Retirement Savings System. .. Read more


Seanad public consultation on SMEs in Ireland

29/08/2018 - The Seanad Public Consultation Committee is conducting a public consultation on the issue of fostering and sustaining the Irish small and medium-sized business sector. .. Read more


Water charges for business: Submission on a new tariff framework

29/08/2018 - Over 500 different water and wastewater tariffs exist for businesses around the country. Irish Water has made proposals to harmonise these tariffs, covering both the future charges and the transition arrangements. The SFA submission expresses broad support for the proposals, while highlighting a number of suggestions that would strengthen the proposals and ensure a smooth transition for the small businesses in Ireland. .. Read more


SFA pre-Budget 2019 submission

16/07/2018 - The SFA's pre-Buget 2019 focuses on five key priorities for small business in the areas of business costs, capital gains tax, income tax and housing. It also outlines the need for a national Small Business Strategy to set out a common vision for small businesses in Ireland. .. Read more


A Small Business Strategy: The next leap forward for the Irish economy

24/05/2018 - The Small Firms Association has launched a campaign for a national Small Business Strategy for Ireland, just as ambitious as the strategic focus on FDI from the 1950s to the present day. The first three campaign documents are now available. .. Read more


A Small Business Strategy: The next leap forward for the Irish economy

24/05/2018 - The Small Firms Association has launched a campaign for a national Small Business Strategy for Ireland, just as ambitious as the strategic focus on FDI from the 1950s to the present day. The first three campaign documents are now available. .. Read more


SFA calls for minimum wage to remain constant in 2019

12/02/2018 - In its annual submission to the Low Pay Commission, the SFA has called for the National Minimum Wage to remain constant in 2019. In light of threats to competitiveness and the varied circumstances of businesses, the SFA believes that firm level negotiation remains the most appropriate method for setting wages. .. Read more


SFA assisting government in scoping an ‘SME Test’ for proposed legislation

01/11/2017 - An ‘SME Test’, which would assess the impact of proposed legislation on micro, small and medium size-enterprises, is now being designed by the Department of Business, Enterprise and Innovation. The SFA has made a submission outlining some important considerations. .. Read more


Action Plan for Jobs 2018 - 23 proposals to boost jobs creation in small businesses

29/09/2017 - The SFA submission on the Action Plan for Jobs 2018 highlights the importance of the small business community to employment and promotes an ambition to add a significant number of new jobs and also a focus on job retention measures. It contains 23 proposals that would boost job creation in small businesses, many of which came directly from SFA member companies. .. Read more


Submission on the cost of doing business

25/08/2017 - The SFA submission to the Joint Oireachtas Committee on Jobs, Enterprise and Innovation on the cost of doing business highlights the challenges for small business relating to labour costs, insurance costs and Local Authority rates and charges. It also makes a number of general proposals about cost monitoring by Government. .. Read more


SFA pre-Budget 2018 submission

19/07/2017 - The SFA has made a written submission to the Minister for Finance and Public Expenditure and Reform, Paschal Donohoe TD, and the Tánaiste and Minister for Enterprise and Innovation, Frances Fitzgerald TD, outlining the top priorities of the small business community for Budget 2018. .. Read more


Presentation to the Seanad Special Select Committee on Brexit

04/05/2017 - The SFA's presentation to the Seanad Special Select Committee on Brexti on 4 May 2017 outlines the implications for small businesses of hard and soft exit scenarios and outlines measures that the Government should take to support small firms. .. Read more


Submission on proposed increase in the employer National Training Fund levy

02/05/2017 - The SFA rejects the proposed increase in the National Training Fund levy by 0.1% per year over the next three years. This submission outlines alternative sources of employer contributions, proposes improvements to the operation of the NTF, and urges the government to urgently address the major issues of adequate Exchequer and student contributions to Higher Education and Further Education and Training. .. Read more


National Planning Framework: 'Ireland 2040 - Our Plan'

03/04/2017 - The SFA has made a submission on the broad principles of the National Planning Framework. It stated that the overarching priority for the small business community is that development will take place in a planned way, focused on the factors that can boost Ireland’s competitiveness and backed up with the necessary capital investment. .. Read more


SFA submission to the Department of Social Protection on making work pay

13/03/2017 - The SFA made a written submission to the Department of Social Protection on 10 March 2017, putting forward the perspective of small business owner-managers on the transition from welfare into employment. The submission outlined the current challenges for employers and provided a range of suggestions of how the take home pay of low income families could be increased without negatively affecting the financial position of businesses. .. Read more


Views of stakeholders on proposal for employers to reimburse welfare payments arising in cases of unfair dismissal

03/03/2017 - The SFA submitted a response to the Department of Social Protection on 3 March 2017 regarding the proposal for employers to reimburse welfare payments arising in cases of unfair dismissal. .. Read more


SFA Submission to the Joint Oireachtas Committee on Banded Hours Contracts Bill

21/02/2017 - On Tuesday, 14 February, SFA Director, Patricia Callan and SFA Executive, Ciara McGuone, met with the Joint Oireachtas Committee on Jobs, Enterprise & Innovation to lobby against the Sinn Fein Private Members Bill on the use of Banded Hours Contracts... .. Read more


National Minimum Wage Board and Lodgings Submission

13/02/2017 - The SFA made a submission to the Low Pay Commission in January 2017 on the National Minimum Wage board and lodgings. The SFA supports the retention of allowances for both board and lodgings in the context of the National Minimum Wage (NMW). .. Read more


Submission to the Low Pay Commission on the National Minimum Wage

10/02/2017 - On 9 February 2017, the Small Firms Association made its submission to the Low Pay Commission, presenting the issues facing small businesses around the country. The submission calls for the minimum wage to remain unchanged in 2018, outlining the reasons why it is neither appropriate nor viable to increase the rate at this time. .. Read more


Input on Revenue plans for PAYE modernisation

16/12/2016 - Revenue plans to modernise the PAYE system, with the changes coming into effect on 1 January 2019. The system would incorporate real time reporting, as has been successfully introduced in the UK. In this submission, the SFA outlines the views of small firms on this modernisation project, expressing a broad welcome as well as some specific concerns raised by members. .. Read more


Statement to the Oireachtas Committee on Jobs, Enterprise and Innovation on Brexit

14/11/2016 - On 8 November 2016, the Small Firms Association appeared before the Joint Oireachtas Committee on Jobs, Enterprise and Innovation to discuss "The likely economic impact of Brexit, with particular emphasis on jobs and enterprise and the steps being taken to mitigate these risks". .. Read more


Action Plan for Jobs 2017 - 25 proposals from the SFA

03/10/2016 - The SFA submission on the Action Plan for Jobs 2017 outlined 25 specific proposals to assist small firms maintain and create jobs over the coming years. The Action Plan for Jobs process aims to create an additional 200,000 jobs by 2020; 135,000 of them outside Dublin. .. Read more


Statement to the Oireachtas Finance Committee on the rising cost of motor insurance

08/09/2016 - On 8 September, the SFA appeared before the Joint Oireachtas Committee on Finance, Public Expenditure and Reform and Taoiseach to make a presentation about the rising cost of motor insurance. The SFA shared data from a member survey about the level and impact of rising premiums on small businesses and proposed solutions to tackle the crisis. .. Read more


SFA pre-Budget 2017 submission

22/08/2016 - On 22 August 2016, the SFA published its pre-Budget 2017 submission, outlining the taxation and expenditure priorities of the small business community. It contains proposals for how the Government can improve the business environment and support investment and jobs through changes in the tax regime and taking a strategic approach to expenditure in Budget 2017. .. Read more


SFA Submission on Employee Share Options

30/06/2016 - On 29 June, the SFA made a written submission to the Department of Finance on the taxation of share based remuneration... .. Read more


Department of Education and Skills Statement of Strategy 2016-2018

08/06/2016 - The SFA's submission to the Deparment of Education and Skills Statement of Strategy 2016-2018 focuses on two themes identified in the consultation document that directly relate to small business, namely 'Promoting creativity and entrepreneurial capacity in students' and 'Meeting the skills needs of the future'. .. Read more


Next Generation Business - A vision for small firms in Ireland

30/05/2016 - The SFA Vision sets out a roadmap for how to make Ireland the most vibrant small business community in the world – supporting entrepreneurship, valuing small business and rewarding risk takers. Economic analysis, a social narrative and over 60 concrete recommendations combine to trace the current small business landscape and project into the future. .. Read more


Submission on the use of intermediary-type structures and self-employment arrangements

04/04/2016 - On 31 March, the SFA responded to a consultation by the Department of Finance and the Department of Social Protection relating to self-employment arrangements. The SFA submission rejected the use of sweeping tax policy changes to address abuses of intermediary-type structures such as personal services companies and managed services companies. . .. Read more


SFA submission to the Low Pay Commission on the minimum wage

14/03/2016 - The Low Pay Commission has requested submissions on the appropriate rate of the National Minimum Wage. The SFA made this submission based on economic analysis and member experiences. .. Read more


SFA submission on sub-minimum rates of the National Minimum Wage

15/01/2016 - In January 2016, the SFA made a submission to the Low Pay Commission on sub-minima rates for young people, inexperienced workers and trainees. .. Read more


SFA Submission on zero hour and flexible working contracts

05/01/2016 - In early January 2016, the SFA responded to a consultation by the Department of Jobs, Enterprise and Innovation on the use of zero hour and flexible working contracts. .. Read more


SFA Submission on a National Skills Strategy 2015-2025

14/12/2015 - In December 2015, the SFA made a submission to government outlining the needs and priorities of small business in relation to education, training and skills in Ireland. .. Read more


SFA submission on the Action Plan for Jobs 2016

29/09/2015 - On 28 September 2015, the SFA made a written submission to Richard Bruton TD, Minister for Jobs, Enterprise and Innovation, setting out the small business priorities for the Action Plan for Jobs 2016. The SFA submission contains proposals of 28 concrete measures to promote job creation across all sectors and regions. .. Read more


SFA Submission on the Tax Treatment of Expenses

21/08/2015 - In August 2015, the SFA responded to a consultation paper issued by the Department of Finance on the tax treatment of expenses. The SFA called for a consistent, simplified approach, which would minimise the administrative burden for small businesses. The submission .. Read more


SFA pre-Budget 2016 Submission

04/08/2015 - The Small Firms Association has made a submission to Government in advance of Budget 2016, calling for measures to ensure that the recovery is felt across the country, throughout the economy and that its impact is sustainable and job-rich. The submission highlights reform of the Capital Gains Tax regime as a priority and urges the Government to reduce the CGT rate to 20% and reform the Entrepreneurial Relief to make it more accessible and meaningful. The SFA also calls for the discrimination against self-employed people and .. Read more


SFA Submission on Tax and Entrepreneurship

16/07/2015 - On 14 July 2015, the SFA made a written submission to the Department of Finance's Tax and Entrepreneurship Review. Drawing on established SFA policy positions and specific member input, the submission strongly called for a fairer and more attractive tax environment for small businesses. The SFA made the case for an end to .. Read more


SFA Submission on Period of Bankruptcy

15/07/2015 - The SFA called for a reduction in the period of bankruptcy period from three years to one in a submission to the Joint Oireachtas Committee on Justice, Defence and Equality. The SFA argued that in the case of honest business failure, the period of bankruptcy should be shortened to foster a more .. Read more


Submission on fees for card-based transactions

09/06/2015 - The SFA is committed to reducing the cost of doing business in Ireland. In a submission to the Department of Finance relating to interchange fees on card payments, the SFA argued for zero interchange on personal debit and credit card transactions. The submission also highlighted the need for limits on charges related to business debit cards .. Read more


SFA Submission on a Universal Retirement Saving Scheme

25/05/2015 - The SFA outlined its opposition to the introduction of a mandatory pensions regime in a submission to the Universal Retirement Savings Group, which is chaired by the Department of Social Protection. The SFA clearly outlined its fundamental opposition to any mandatory system and laid .. Read more


SFA Submission to the Central Bank Lending Code Consultation

21/04/2015 - The Central Bank is undertaking a review of their SME Lending Code to strengthen protections for small businesses in their dealings with financial institutions. To read a copy of the SFA Submission .. Read more


SFA Submission to the Low Pay Commission

21/04/2015 - The SFA made a submission to the recently established Low Pay Commission, whose remit is to decide on the appropriate movement in the level of the National Minimum Wage. To read the full .. Read more


SFA Submission to the Public Accounts Committee on Public Procurement

05/03/2015 - An SFA delegation met with the Public Accounts Committee to discuss issues relating to small firms access to Public Procurement opportunities on Thursday, 5th March. The SFA submission argues for fundamental reform of the public procurement system, to remove the emphasis on price, set targets for SME procurement, break contracts down into lots .. Read more


SFA Submission on Low Pay to the Joint Oireacthas Committee on Jobs, Enterprise and Innovation

03/03/2015 - The recent establishment of the Low Pay Commission is highly concerning for SFA members. Whilst the concept of an independent evidence-based assessment of the National Minimum Wage (NMW) rate, independent of politics, is desirable, it is unfortunate that none of the individual small business-owner managers who actually have real experience of the issues in running a small business which employs minimum wage or relatively low wage workers were selected as members of the Commission. The fact that no interviews took place to choose .. Read more


The SFA Submission on Action Plan for Jobs 2015

03/10/2014 - Following on from our meeting with Ministers Bruton and English in July, we have made a detailed written submission into the Action Plan for Jobs 2015. Many thanks to the many members who responded with their suggestions for policy changes to support small businesses in retaining and creating jobs. Proposals were submitted on topics such as .. Read more


SFA Pre-Budget Submission 2015 - "The Path to Growth"

07/07/2014 - In the SFA’s Pre-Budget 2015 Submission to Minister for Finance, Michael Noonan, TD, we argue that the fiscal adjustment should only deliver the minimum net fiscal adjustment package needed to reach the 2.9% fiscal deficit target, and not the €2billion previously planned. This would enable the government to put more money back in people’s pockets and boost consumption and investment which will lead to growth. Our policy priorities include .. Read more


Submission to the Public Accounts Committee on SMEs & Public Procurement

07/04/2014 - The Small Firms Association (SFA) is the “voice of small business” in Ireland representing over 7,500 companies and 6 affiliated organisations. We welcome this opportunity to make a written submission to the Public Accounts Committee on SME issues in public procurement. Public procurement is an essential element of delivering better public services in Ireland. It ensures value for money for taxpayers and the efficient allocation of resources, thereby enhancing the quality of public services and .. Read more


SFA Submission to the JOC on Education and Social Protection

21/03/2014 - At a time when Ireland should be encouraging more people to take risks and create employment, through setting up a business or becoming self-employed, we find increasingly that the lack of a social welfare safety net acts as a disincentive to work. For individuals who were self-employed or Directors of small businesses, who have experienced business failure, particularly in recent times, we have heard terrible stories of .. Read more


Submission to the Department of Finance on the Pay and File Date Consultation

11/11/2013 - The SFA welcomes the opportunity to input to the consultation on pay and files dates. Small firms account for the majority of businesses operating in Ireland and employ over half of the private sector workforce. Due to the important role small businesses play, it is important to ensure that Ireland’s tax regime is supportive of owner managed businesses and start ups. Ireland ranks relatively well in the World Bank’s Doing Business reports. In 2013, Ireland was placed .. Read more


SFA Submission to the Department of Education and Skills on the Apprenticeship Review

02/10/2013 - The SFA welcomes the opportunity to input to the review of the apprenticeship system and believe this review to deliver an updated model of training is timely. There is a universal agreement that investment in education has resulted in a skilled and flexible workforce which has been a key contributor to Ireland’s economic success; driving private sector growth and increasing productivity. Public and private investment in human .. Read more


SFA Pre-Budget Submission 2014 - “The Road from Austerity”

29/07/2013 - The SFA has prepared its Pre-Budget Submission 2014 called "The Road from Austerity", which was presented to the Minister for Finance, Michael Noonan, TD on Wednesday, 24th July 2013. The key issues which the SFA discussed with the Minister regarding Budget 2014 are .. Read more


National Entrepreneurship Policy Statement

08/07/2013 - The SFA welcomes the opportunity to input to the consultation on a national entrepreneurship policy statement for Ireland. We need a stronger performance from the entrepreneurial sector and this will only be possible if there is a national entrepreneurship strategy. The policy should drive entrepreneurship in a determined and coherent manner, similar to those that characterised the drive for foreign direct investment in Ireland, so as to harness the necessary resources – both public and private – at national, regional and local level. .. Read more


SFA Submission to the Department of Jobs, Enterprise and Innovation on the Audit Exemption Thresholds Consultation Paper

07/05/2013 - The SFA welcomes the opportunity to input to the consultation on audit exemption thresholds. Small firms account for the majority of businesses operating in Ireland and employ nearly half of the private sector workforce. Due to the important role small businesses play, it is important to ensure that Ireland’s tax regime is supportive of these firms. Ireland ranks relatively well in the World Bank’s Doing Business reports. In 2013, Ireland .. Read more


Submission to the Department of Finance & the Revenue Commissioners on the Taxation of Micro Enterprises: Reduction in Compliance Costs Consultation Paper

01/05/2013 - The SFA submitted a response to the Department of Finance and Revenue Commissioners consultation on the the taxation of micro enterprises: reduction in compliance costs consultation. The simplification of the tax system for micro enterprises is greatly desired and would be welcomed. The paper addresses the assessment of the Single Business Tax (SBT); the threshold and transitional arrangements of a simplified taxation regime and the opting in or out of any simplified regime. While the SFA recognise the .. Read more


SFA Submission on Action Plan for Jobs 2013

03/10/2012 - Below is a submission made by the SFA on the Action Plan for Jobs 2013. The SFA welcomes the opportunity to outline the proposals and ideas for measures that will assist our members in retaining and creating jobs in their business. .. Read more


SFA Submission on the transposition of the Late Payment in Commercial Transaction Directive

03/10/2012 - The SFA have made a Submission to the Department of Jobs, Enterprise and Innovation on the transposition of the Late Payment in Commercial Transaction Directive. Getting paid on time is a never ending problem for most small businesses. Research conducted by the Small Firms Association shows that late .. Read more


SFA Pre-Budget Submission 2013

27/08/2012 - Below is the SFA Pre-Budget Submission 2013 "The Path to Growth", which will be presented to the Minister for Finance, Michael Noonan, TD. The key issues which the SFA would like the Minister to focus on in this budget are the following .. Read more


SFA Submission on Corporate Killing

02/07/2012 - The SFA have submitted a submission to the Company Law and Business Regulations Unit in the Department of Jobs, Enterprise and Innovation on their views regarding the preparation of legislation to implement the main recommendations in the Law Reform Commission's Report on Corporate Killing .. Read more


SFA Submission on Next Generation Broadband Taskforce

02/07/2012 - The SFA have made a Submission to Minister Par Rabbitte, TD on the Next Generation Broadband Taskforce. The Submission addresses the need for access to broadband availability for small businesses in regional areas .. Read more


SFA Submission on the Credit Guarantee Bill 2012

02/07/2012 - The SFA have made a Submission on the Credit Guarantee Bill 2012 to the Select Sub - Committee on Jobs, Enterprise and Innovation. After 4 years of lobbying the SFA welcomes the eventual delivery of a credit guarantee scheme. Access to .. Read more


SFA Submission on Administrative Burdens

28/02/2012 - The SFA have made a submission to the High Level Group on Administrative Burdens that are placed on small businesses. Some of these burdens are .. Read more



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