Europaudvalget 2015-16
EUU Alm.del Bilag 771
Offentligt
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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.
 EUU, Alm.del - 2015-16 - Bilag 771: Notat om dansk høringssvar vedr. Kommissions forslag om at indføre et frivilligt elektronisk servicepas
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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.