ERU, Alm.del - 2015-16 - Bilag 330: Erhvervs- og Vækstministeriets notat samt høringssvar vedrørende Kommissions forslag om at indføre et frivilligt elektronisk servicepas, fra erhvervs- og vækstministeren

Erhvervs-, Vækst- og Eksportudvalget 2015-16
ERU Alm.del Bilag 330
Offentligt

July 2016

Danish response to the open consultation on the services passport

The Danish government supports the ambition to increase competition in

European services markets. Today, businesses face multiple and overlapping

requests when they wish to operate cross border. The introduction of a ser-

vices passport has the potential to be an effective tool to eliminate adminis-

trative burdens, thereby facilitating cross-border provision of services. It is

crucial that the passport leads to actual improvements for European busi-

nesses operating cross-border and does not entail new unnecessary adminis-

trative burdens for businesses or national authorities.

The Danish government supports the aim of

facilitating mutual recogni-

tion

within the scope of the Services Directive to ensure that businesses do

not have to comply with different sets of national rules seeking to achieve a

similar outcome. If proposals on harmonisation of national rules in certain

sectors are introduced as a part of the services passport, the Danish gov-

ernment will consider these on a case by case basis.

The scope of the services passport

is still to be clarified. The services

passport should be available for both temporary service provision and sec-

ondary establishment. As for the range of information, procedures and reg-

istrations to be covered, it would be preferable to focus on a number of

basic data related to company structures with a clear comparability across

Member States. The Commission could initially launch a pilot with a limited

scope, e.g. one or two business services. Experiences from these sectors as

well as the specific characteristics of different sectors should be taken into

account before expanding to other services sectors.

The passport should be based on intelligent digital solutions

and inte-

grated with relevant already existing European and national registers, portals

and procedures allowing for a seamless exchange of data without creating

parallel procedures, taking into account that Member States have different e-

government procedures. The Danish government supports the use of the

IMI system, as authorities are already familiar with the system, and it has

proven to be well-functioning in other areas.

The passport should be electronic

and the provision of information by

businesses should be based on a strict once only principle. Moreover, appli-

cation modules should be developed and designed with a comprehensive

involvement of businesses, organisations and authorities, thereby ensuring

that solutions lead to added value and a reduction of administrative burdens

in practice.

ERU, Alm.del - 2015-16 - Bilag 330: Erhvervs- og Vækstministeriets notat samt høringssvar vedrørende Kommissions forslag om at indføre et frivilligt elektronisk servicepas, fra erhvervs- og vækstministeren

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Regarding the

cooperation between home and host Member States,

there is a need to clarify areas of competences, procedures and language

practices. Overlaps in case handling flows should be avoided and clear dis-

tinctions regarding rights to accept and reject information should be made

as well as clear deadlines. The services passport should still provide the pos-

sibility of ex ante control and ex post checks in host Member States.

The Danish government supports that the

services passport is voluntary.

However, the Commission should be aware of the risk that the passport

could de facto become obligatory in certain sectors due to market demands

from e.g. associations in the construction sector based on the experience

from the A1 form in the area of social security. This would create problems

for businesses that have chosen not to use the services passport.

Finally, it is important to keep in mind that a considerable share

of red tape

is related to uncertainty about which requirements to fulfill

on the dif-

ferent European Markets -. In this regard, the Commission should also pay

attention to other EU portals and procedures, such as Points of Single Con-

tacts and the recognition of professional qualifications system. The Single

Digital Gateway should ensure clear communication on and easy access to

the passport.