In a continent of SPAs and GmbHs, what’s the value of an Inc.?

A “freedom fries”-style linguistic argument has broken out over the naming of a corporate law proposal for startups, highlighting anti-American sentiment in Europe amid Donald Trump’s threats against Greenland.

European Commission President Ursula von der Leyen, during a speech in Davos, suggested using the name “EU Inc.” instead of the somewhat dry “28th regime.” Her suggestion has drawn disdain from the lead lawmaker on the proposal.

An American abbreviation like “Inc.” — short for the U.S.-specific “incorporated” legal entity — is “maybe not the right way to call this one” in the current geopolitical context, said René Repasi, a German Social Democrat.

The row reflects deeper resistance to the Americanization of language and culture in Europe. In a continent of French Sociétés Anonymes and German GmbHs, Brussels’ embrace of U.S. corporate terminology may be a bridge too far.

Some lawmakers have been rankled by the rise of “Acts” — from the Digital Markets Act to the AI Act — which mirror the punchy legislative branding of Capitol Hill, abandoning traditional European “directives” and “regulations” when used in the EU executive’s primary communication method, English.

Von der Leyen has also come under fire for rolling back her green agenda during her current, second mandate. Critics have said her drive to cut red tape is a poorly disguised attempt to appease President Donald Trump, who has criticized EU regulation for discriminating against U.S. business.

This latest geopolitically flavored semantic squabble summons memories of 2003, when an American lawmaker — upset with France’s refusal to join the invasion of Iraq — renamed “French fries” as “freedom fries” in three congressional cafeterias.

Repasi’s proposal for the 28th regime rebrand? Societas Europaea Unificata (S.EU), a Latin-derived term that translates to “unified European company.” Parliament voted in favor of his choice of name, which echoes past proposals like the 2008 Societas Privata Europaea.

“We go back to the roots of our continent’s languages,” said Repasi, explaining Parliament’s choice of a Latin-derived term rather than an American abbreviation.

“I cannot be the only one who struggles to pronounce the proposed name of the new corporate form,” Kim van Sparrentak said in Monday’s debate on the proposal. (The Dutch Greens MEP still voted for the proposal with the Latin-rooted name.)

Covering the basis

Beyond the naming spat, there are more profound ideological splits over the regime to create a single EU window for registering companies, which Commissioner Michael McGrath is expected to unveil in late March. The idea is to create a flourishing startup landscape, and stem a flight of talent and ideas across the Atlantic.

Repasi warned that the regime must not become a vehicle for “charlatans” to escape labor standards, echoing a complaint from Lukas Mandl, of the European People’s Party, that the proposal should not give rise to a “gold digger mentality” that could destabilize the European social partnership model.

“If there is no credible solution how employee participation … can be secured, I see difficulties that the progressive side of the House can support such a 28th regime,” he said, citing the failure of previous attempts like the SPE and SUP due to the same issue.

Another substantive issue may prove to be its legal basis, on which lawmakers haven’t yet agreed. It’s on this issue that the creators of the “EU Inc.” naming proposal — who were delighted to see von der Leyen endorse it — are really hoping to make an impact.

The “EU Inc.” movement, led by founders who have taken their roadshow to capitals across the bloc, is pushing for a regulation to ensure a single, directly applicable rulebook that prevents member states from “gold-plating” the law with national quirks.

If von der Leyen “chooses a title that’s very dear to pressure groups, that guarantees applause,” said Repasi, worrying that the Commission may put forward a proposal that would impinge on national labor rules.

The new name in particular “sends a wrong signal,” said Repasi.

The Parliament’s report steers towards what Repasi describes as a more pragmatic directive, a choice rooted in what he says is Council arithmetic.

A regulation on corporate law would require the unanimous consent of all 27 member countries, a high bar that Repasi fears would create a “Frankenstein’s monster” as each capital demands its own specific national carve-outs . 

By opting for a directive, the EU can move forward via qualified majority voting, bypassing the “unanimity trap” that famously saw previous attempts at corporate law harmonization languish for decades.

“If we want to have a regulation which ends up in unanimity … we can wait for Godot,” said Repasi.