ARTICLE
24 March 2026

European Commission Changes To SME Verification Coming In 2027

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After February 5, 2027, companies wishing to benefit from the reduced fees for micro, small, and medium-sized enterprises (SME) must apply for company size validation prior...
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After February 5, 2027, companies wishing to benefit from the reduced fees for micro, small, and medium-sized enterprises (SME) must apply for company size validation prior to submitting their Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) dossiers. This contrasts with the current process, where SME status is confirmed retrospectively, after registrations are submitted.

Under the European Commission's updated REACH Fee Regulation, SMEs planning to submit REACH registrations or applications for authorisation will need to apply for company size validation at least two months prior to submission to qualify for fee reductions. Companies are advised to apply for SME verification as early as possible to leave sufficient time for providing any missing information upon request by the European Chemicals Agency (ECHA). The application must include documentary evidence on headcount, turnover, and balance sheet data, including for linked and partner enterprises. ECHA will decide on company size status within two months of receipt of all relevant documentation. Recognized SME status will remain valid for three years from the date of ECHA's decision. If SME status is not recognized, an administrative charge may be imposed.

Alongside the ex-ante verification process, the updated REACH Fee Regulation also increased the standard fees and charges for large companies by 19.5 percent, to reflect inflation that has been in effect since November 5, 2025.

Companies can check the ECHA website for more information and guidance on SME definition, verification, and fees.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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