SOU, Alm.del - 2019-20 - Bilag 168: Kopi af breve til nyudnævnte kommissærer, fra finansministeren

Social- og Indenrigsudvalget 2019-20
SOU Alm.del Bilag 168
Offentligt

Thierry Breton

Commissioner for Internal Market

European Commission

MINISTER FOR INDUSTRY,

BUSINESS AND FINANCIAL

AFFAIRS

Dear Commissioner Thierry Breton,

Please accept my warmest congratulations on your appointment as

Commissioner for Internal Market.

A timely response to the challenges and seizing the opportunities posed

by climate change and rapid digitalization is of critical importance to

ensure a prosperous EU. I would like to present you with the overall

Danish agenda in your area of responsibility, as priorities for the Single

Market are elaborated further in the attached non-papers. I hope you will

read these with interest.

Towards a competitive and climate-friendly European industry

European industry is a key player in restoring the

EU’s

global competi-

tiveness as well as fulfilling the Paris Agreement. The upcoming action-

plan for industry should set a clear political direction with an emphasis

on cost-effective and market-based measures that encourage businesses

to make necessary investments needed for the transition to a competitive,

circular and climate-neutral European industry.

Furthermore, I would encourage you to make sure that the work on Im-

portant Projects of Common European Interest (IPCEIs) related to strate-

gic value chains contribute to our climate and environmental objectives.

Moreover, we should improve the transparency of IPCEIs by introducing

ex-ante consultation. This will allow all Member States to easily partici-

pate and contribute.

There is also a need to re-think the future set-up for identifying strategic

value chains. To this end, we need a new procedure for identifying,

amending or phasing out strategic value chains. The procedure should

maintain the original bottom-up approach characterizing the current Stra-

tegic Forum while ensuring political legitimacy and governance and di-

recting initiatives towards major challenges such as climate change.

Moreover, I encourage you to lay down the pillars for a robust frame-

work for secure, interoperable and trustworthy data sharing that can sus-

tain public trust in data usage and contribute to the green transition of

industry. We should openly discuss how best to encourage and ensure

more data sharing through an ethical and coherent European framework,

as the use of data is vital for European businesses if they are to be global

frontrunners of the data economy.

MINISTRY OF INDUSTRY, BUSI-

NESS AND FINANCIAL AFFAIRS

Slotsholmsgade 10-12

DK-1216 Copenhagen K

Tlf.

Fax

+45 33 92 33 50

+45 33 12 37 78

CVR-nr. 10 09 24 85

EAN nr. 5798000026001

[email protected]

www.em.dk

SOU, Alm.del - 2019-20 - Bilag 168: Kopi af breve til nyudnævnte kommissærer, fra finansministeren

Regarding the external dimension of EU industrial competitiveness, I

recognize the tendency towards increased unfair competition and the need

to react and safeguard European interests. The best way to preserve fair

global competition and a level playing field is through common rules

applicable to all, rooted in the WTO. Thus, it is encouraging that the in-

coming Commission aims to make reform of the multilateral trading sys-

tem a top priority. This must include an update of the rules so they ad-

dress unfair market-distorting trade practices

and reflect today’s digital

economy. In parallel, we may need EU instruments to handle distortive

behaviour from companies from third countries operating within the Sin-

gle Market without relaxing the principles of independent enforcement

and free and fair competition.

A fair Single Market fit for the digital age

Effective implementation and enforcement are key components towards

making the Single Market both fairer and smoother for law-abiding busi-

nesses, consumers and workers. We need a firm and ambitious long-term

action plan for better implementation and enforcement, containing con-

crete initiatives on how to improve the uniform implementation, applica-

tion and enforcement of our common rules. We have several proposals,

highlighted in the attached non-paper regarding better implementation

and enforcement.

Moreover, I encourage you to ensure that European legislation is digital-

by-default and future-proof as this it is a precondition for a well-

functioning Digital Single Market. In Denmark, we have introduced a set

of principles on digital-by-default and future-proof regulation. I would be

happy to share our experience on the use of these principles in lawmaking

and further discuss how such principles could be implemented at the Eu-

ropean level. Attached you will find a non-paper explaining the Danish

principles and priorities on this agenda.

Cross-border digital services is a vital tool to make life easier for citizens

and businesses within the Single Market. In this context, I would urge

you to take into account the special situation of the public sector as a

guarantor of maintaining public confidence in digital infrastructure sys-

tems and public digital procedures for instance regarding data trans-

parency and interoperability, and trustworthy electronic identification.

Regarding the new SME Strategy, I hope focus would be on the possibili-

ties for SMEs, solutions to the challenges posed by climate change and

rapid digitalization and ways to make it easier to scale-up and participate

in European and global value-chains.

SOU, Alm.del - 2019-20 - Bilag 168: Kopi af breve til nyudnævnte kommissærer, fra finansministeren

Digital trust as an enabler of Artificial Intelligence

I have positively noticed the aim of the new Commission to deliver a

European approach to artificial intelligence within your first 100 days in

office. In this regard, the aim should be to make data ethics a competitive

advantage for European businesses going hand-in-hand with innovation.

A European approach could make us a frontrunner in the responsible use

of artificial intelligence and data. By introducing a European Data Ethics

Seal we would enable consumers to easily identify companies who take

data ethics seriously. Together with a requirement for the largest Europe-

an companies to publish their data ethics policies, the digital economy

would become more transparent for consumers. Attached you will find a

non-paper explaining our suggestions to this agenda.

Moreover, access to cross-border digital service in the EU is important

for the non-discrimination of businesses, workers and citizens when op-

erating and acting on the internal market. However, I would urge you to

take into account the special situation of the public sector as a guarantor

of maintaining public confidence in digital infrastructure systems and

public digital procedures when making new proposals for the use of data,

AI and the further development of cross-border digital ecosystems in the

EU.

A modern and responsible framework for the platform-economy

It is time to modernize the regulatory framework of the platform econo-

my in order to ensure digital responsibility, better cross-border enforce-

ment and to address emerging issues that are not dealt with under the

current rules. In doing so, we should also tackle the increasing fragmen-

tation of the regulatory framework for digital services that constitute bar-

riers to scaling up within the Digital Single Market. A modernized

framework for the European platform economy should maintain the es-

sence of the e-Commerce Directive, namely the country of origin princi-

ple, which the European platform economy has benefitted immensely

from. At the same time, we face an important and necessary discussion

regarding liability regimes and the responsibilities of especially large and

influential companies in handling data versus the possibilities for smaller

companies to develop new business models and scale up across the Sin-

gle Market. We should modernize the regulatory framework to find hori-

zontal solutions that address the emerging issues in the platform econo-

my, eradicates regulatory fragmentation through uniform application and

enforcement of the notice and take down of illegal content across the EU

while strengthening the competitiveness of the European platform econ-

omy.

Strengthening the European defence industry through competition

The development of a well-functioning and competitive Single European

Defence Market, open also to SMEs, is crucial if the EU is to strengthen

SOU, Alm.del - 2019-20 - Bilag 168: Kopi af breve til nyudnævnte kommissærer, fra finansministeren

the technological and industrial base that is able to deliver the defence

capabilities that Europe needs. The European Defence Fund can be an

important instrument in this regard - if the key principle of ensuring

strong competition for all funds is adopted in its implementation and

work programmes.

I hope these ideas will be useful for you in laying out the agenda for your

important portfolio for the coming years and I look forward to working

together with you to strengthen European competitiveness to the benefit

of all Europeans.

Yours sincerely,

Simon Kollerup

SOU, Alm.del - 2019-20 - Bilag 168: Kopi af breve til nyudnævnte kommissærer, fra finansministeren

Strengthening the Single Market through better implementation and enforcement

Proposal

New transposition and application tools are needed to ensure that current rules are transparent and

uniformly implemented and complied with across Member States. Among these are:



Templates and analyses to ensure transparent implementation: Drawing on the experiences in financial

services, the use of implementation templates should be made obligatory on a trial basis to ensure that

businesses have access to an overview of the specific areas where national rules differ from the

adopted EU legislation. This should be supported by ongoing analyses on the differences in

implementation across Member States which should be initiated by the Commission in order to

increase knowhow and transparent implementation.

A strengthened Single Market Scoreboard: The Single Market Scoreboard should be developed to

promote enforcement and strengthen compliance in practice. The Commission is for example

encouraged to broaden its scope to cover the qualitative implementation of legislation. Furthermore,

the Single Market Scoreboard should reflect the developments in terms of national rules on goods and

services by linking the Scoreboard with the number of notifications in the TRIS and IMI databases.

Criteria for infringement procedures: Building on the principles set out in the Communication EU law:

Better results through etter appli atio ,

the Commission should develop and apply a set of criteria as

a basis for launching infringement procedures. These criteria should be used to ensure consistency in

the detailed process of assessment and selection. The criteria should also indicate overall political and

strategic priority areas of the Commission, including prioritisation of violations entailing distortion of

competition.

Single Market implementation reviews: With inspiration from the Environmental Implementation

Review (EIR), the Commission should conduct implementation reviews on a regular basis of each

Me er State’s i ple e tatio of sele ted

pieces of horisontal Single Market legislation. The aim

should be in constructive dialogue with Member States to set out proposals on how to improve the

implementation to strengthen the basic principles governing the Single Market. Inspiration may also be

found in the better regulation method related to neighbour

he ks .

Strengthening enforcement: Efficient and systematic efforts to enforce regulation are indispensable to

the optimization of the entire policy process. It must be clear what determines policy outcomes

–

the

rules or their a tual appli atio . I order to stre gthe the Co

issio ’s ork i this area an

institutional strengthening should be considered, e.g. by assigning a vice-president with responsibility

for better regulation, implementation and enforcement. Explicitly highlighting implementation and

enforcement as the responsibility of a vice-president would raise the political focus on this agenda and

make it a central element in every new policy initiative.



Challenge

Diverse application of the EU-law increases administrative burdens and reduces legal certainty for

usi esses detri e tal to ross order trade a d i est e t se urity. Opti izi g Europea usi esses’

framework conditions, including legal certainty necessitates coherent and effective application of the rules

governing the Single Market. A more transparent and uniform application of the Single Market acquis will

SOU, Alm.del - 2019-20 - Bilag 168: Kopi af breve til nyudnævnte kommissærer, fra finansministeren

benefit especially SMEs that are disproportionally affected by diverse application of EU-rules due to their

scarce resources and limited capacity to keep track of a complex and quickly changing legal environment.

Background

The enforcement and implementation agenda i a prominent priority in the current Commission. The launch

of the compliance package, including e.g. the regulation on a Single Digital Gateway and an action plan for

SOLVIT are important initiatives which aim at simplifying the life of businesses in practice. However, more

can be done by building on existing mechanisms and applying these more systematically and with more

transparency. Making the very basis of the Single Market function better is a precondition for developing

the Single Market further.

SOU, Alm.del - 2019-20 - Bilag 168: Kopi af breve til nyudnævnte kommissærer, fra finansministeren

Data and Ethics - The New European Competitive Advantage

Proposal

Data Ethics as Corporate Social Responsibility

The Commission should consider a revision of the directive as regards

disclosure of non-financial

and diversity information by certain large undertakings and groups.

The revision should include

provisions for certain large undertakings - to prepare a non-financial statement containing in-

formation relating to their data ethics policies as part of their annual management reports.

European Data Ethics Seal

The Commission should encourage the development of a European Data Ethics Seal by the rele-

vant industry and standardization bodies. The seal should be awarded to companies, products

and services that meet a pre-defined list of data ethical requirements e.g. companies or products

that meet high standards for data security, companies or products that do not collect unneces-

sary data on the user, or companies or products that have been tested for bias etc. The European

Data Ethi s Seal ould e a ay to operatio alize the Co

issio ’s idea of ethi s y desig a d

make it visible for consumers which companies, products and services to trust - and thus creating

a market incentive for producers to become more data ethical.

Standards on AI Trustworthiness

The Commission should investigate the possibilities for promoting the use of technical standards

on AI Trustworthiness in the European legislation. ISO/IEC and CEN/CENELEC as well as the IEEE

are currently working on different aspects of standardization of AI and ethics/trust. The inherent

agility of technical standards could create the necessary balance between long-term durability

and short-term efficiency.

Challenge

Trust is the most important component in ensuring wide uptake of digital technology and solu-

tions. It is thus of the utmost importance that the European Union succeeds in creating a legal

a d ethi al fra e ork that a e sure itize s’ trust i the e te h ologies. Moreo er,

the

responsible use of data has the potential to become a competitive advantage for European busi-

nesses in the competition with American and Chinese companies. In order to give EU businesses

a first mover advantage, the EU should take concrete steps to strengthen data and AI ethics

through transparency, and thus empowering consumers and businesses to choose products and

solutions that are based on a responsible use of AI and data.

Background

Our ambition as a European community should be to break down national silos to ensure that

the leading digital companies of the future will be European. EU has a very important global role

in terms of promoting the responsible and ethical approach to data use. We are convinced that

Europe not only could, but should lead the way for responsible use of data - and thereby poten-

tially gain an invaluable competitive advantage on the global marketplace.

SOU, Alm.del - 2019-20 - Bilag 168: Kopi af breve til nyudnævnte kommissærer, fra finansministeren

Digital-by-default and future-proof regulation

Proposal

To ensure that EU regulation is digital-by-default and future-proof, the Commission should introduce a set

of principles on digital-by-default and future-proof regulation and initiate targeted measures at all stages of

the legislative cycle to enforce these principles. These measures should have a two-fold purpose:

1. Enable digital administration to promote more user-friendly and efficient public services to

businesses and citizens as well as to improve enforcement and prevent errors and fraud.

2. Provide a future-oriented regulatory framework to accommodate and enable businesses to

innovate and apply new technologies and business models.

The set of principles could be the following six: 1) Simple and clear rules, 2) Accommodate new business

models and technology-neutrality, 3) Digital communication, 4) Automated digital case processing, 5)

Coherence and consistency across regulation and authorities - uniform concepts and reuse of data, 6)

Improving enforcement and preventing errors and fraud. Needless to say, safe and secure data handling is

a fundamental precondition that should accompany these efforts. See annex 1 for a description of the

principles.

It is vital to ensure that the principles on digital-by-default and future-proof regulation are considered by

the relevant Directorate-General in the early drafting stages of a proposal and in relation to the impact

assessments. The implementation of the following procedures will ensure proper enforcement of the

principles. An early screening could determine whether the principles are relevant and, if that is the case,

whether they have been followed. The existing better regulation structure within the Secretariat-General

could carry out the screening drawing on the expertise from relevant units in DG CONNECT and DG DIGIT.

Measures later in the legislative process can also be considered - such as ex-ante digital-by-default and

future-proof checks by the Regulatory Scrutiny Board. Finally, ex-ante and ex-post evaluations such as user

journeys, user-friendliness tests and REFIT-activities can evaluate whether regulation has been

meaningfully translated into user-friendly digital solutions and identify ways of making regulation more

future-oriented and fit for the digital age.

Challenge

The accelerating digital transformation of businesses and society poses both new opportunities and

challenges for EU regulation. EU regulation needs to be fit for the digital reality of businesses and citizens,

enable user-friendly digital solutions and promote innovation, including new technologies and business

models. Digital-by-default and future-proof regulation is a precondition for a well-functioning Digital Single

Market, which is both genuinely

digital

by promoting innovation, new technologies and business models

and

single

by enabling more seamless, efficient and user-friendly national and European digital public

services that reduce burdens for businesses and citizens operating across the EU. This is an opportunity to

improve public services and provide European businesses with the competitive edge which is crucial for

succeeding in the fast-moving global digital economy.

Background

Existing and new regulation is often not designed to accommodate the way in which new technologies and

business models can create new value for businesses and society. We still see proposals that are not suited

SOU, Alm.del - 2019-20 - Bilag 168: Kopi af breve til nyudnævnte kommissærer, fra finansministeren

to the current digital reality of businesses or are difficult to digitalise and automatise by public authorities.

The Commission has already included

a Research a d Innovation

Tool

a d a Digital Check i its Better

Regulation Toolbox. These are steps in the right direction, but there is a need to step up these efforts by

placing principles on digital-by-default and future-proof regulation at the heart of the

issio ’s

better

regulation machinery. This will ensure that EU regulation is suited to the digital reality, reduces

unnecessary burdens and enhances well-functioning national and European digital public services for the

benefit of businesses, citizens and the authorities themselves. We stand ready to engage in dialogue with

the Commission to develop such measures as we have introduced similar measures at national level.

SOU, Alm.del - 2019-20 - Bilag 168: Kopi af breve til nyudnævnte kommissærer, fra finansministeren

Annex 1: Principles for digital-by-default and future-proof regulation

To ensure that EU regulation is digital-by-default and future-proof, the Commission should introduce a set

of principles on digital-by-default and future-proof regulation and initiate targeted measures at all stages of

the legislative cycle to enforce these principles. These measures should have a two-fold purpose:

Enable digital administration to promote more user-friendly and efficient public services to

businesses and citizens as well as to improve enforcement and prevent errors and fraud.

II.

Provide a future-oriented regulatory framework to accommodate and enable businesses to

innovate and apply new technologies and business models.

Needless to say, safe and secure data handling is a fundamental precondition that should accompany these

efforts.

Principles

The following principles should be promoted at EU-level:

1. Simple and clear rules

Simple and clear rules are easy to administer and contribute to more uniform administration and digital

support. If the legislation is unclear or complex with many exceptions, requirements, schemes or discretion it

can be difficult to administer - also digitally. Legislation should focus on the main objectives while detailed

specifications should be handled in delegated or implementing acts which will enable easier and continuous

updating of the legislation.

2. Accommodate new business models and technology-neutrality

The legislation should foster innovation by accommodating emerging and new business models and

promoting the use of experiments and sandboxing. It must also be technology-neutral to ensure that it does

not regulate the use of technology which will subsequently become obsolete

3. Digital communication

The legislation must support user-friendly digital communication between citizens and businesses and the

public sector. For citizens who cannot use digital solutions, other solutions must still be offered.

4. Automated digital case processing

The legislation should underpin fully or partly automated digital case processing. As a general rule, the

legislation should apply objective criteria, clear and unambiguous definitions and common concepts rather

than special concepts. The goal is to enable automation by using objective criteria when it makes sense and to

ensure that it is still possible to exercise discretion in cases where it is professionally relevant.

5. Coherence and consistency across regulation and authorities - uniform concepts and reuse of

data

Legislation should be coherent across policy silos in order to prevent fragmentation and regulatory

uncertainty. Concepts and data must be reused across regulation and authorities to promote efficiency and

coherence to thereby reduce burdens for both authorities, citizens and businesses. If data already exists that

supports the concepts of the legislation, the legislation should reuse these or consider whether other similar

concepts may be used for data that is already available.

6. Improving enforcement and preventing errors and fraud

The legislation must be worded to permit effective IT application and data-driven solutions and tools to ensure

better compliance and enforcement through risk-based control. Such solutions can improve the combatting of

fraud or reduce errors considerably.

SOU, Alm.del - 2019-20 - Bilag 168: Kopi af breve til nyudnævnte kommissærer, fra finansministeren

A Competitive, Sustainable and Fair Single Market

The Single Market is a unique asset in the European cooperation connecting 500 million

consumers with 26 million businesses. Over the last 25 years, timely and ambitious steps have

resulted in the Single Market becoming a vital source of economic growth in all EU Member

States providing for more than 56 million jobs across the EU. However, in an ever-changing

environment where well-known challenges of climate change, unfair market practices, and

digital transformation are imminent, and where new cross border challenges keep arising, new

and targeted measures are needed to bolster and future-proof

EU’s global competitiveness.

this end, the EU should agree on a holistic EU Sustainable Growth Agenda where efforts

towards a climate-neutral economy goes hand in hand with measures promoting a competitive,

integrated and fair Single Market effectively combating fraud and circumvention of the

common rules in support of growth, employment and consumer interests.

In line with the European Council conclusions of March 2019 and the Council Conclusions on

the Single Market, Denmark outlines the following vision for a competitive, sustainable, and

fair Single Market:



Becoming a competitive climate-neutral economy.

The transition to a climate neutral

economy will broaden the realm of growth policies by giving rise to new business models

based on climate neutral, circular, and digital solutions. Such innovation and job

opportunities should be exploited to the fullest to increase European competitiveness while

bringing environmental benefits to EU citizens. To this end, a clear political direction

should be formulated with an emphasis on cost-effective and market-based measures that

encourage businesses to invest in renewable energy sources, new infrastructures, and in

research and development, allowing for the technological breakthroughs needed for

European businesses to become climate neutral while remaining competitive on a global

scale. Such investments should be sustainable and responsible, taking into account ethical,

social, and management issues, including amongst other things human rights and labor

rights.

Preserving EU leadership in clean tech solutions.

Tomorrow’s industry will depend

even more on a better use of new digital technologies allowing for more efficient

manufacturing and new smarter products intended to strengthen consumer convenience and

safety. To this end, businesses should have access to a non-fragmented, futureproof and

innovative Digital Single Market underpinned by a safe, secure and responsible European

platform and data economy. The further development of the European data economy

should focus on making the responsible and ethical use of data a competitive edge for

European businesses by amongst other placing the issue center stage in the Commission’s

work on artificial intelligence. Furthermore, it is important to promote the availability and

use of data in the EU, which is central to the development of innovative solutions

supporting the green transitioning such as data within the area of utilitiesy, mobility,

environment and the food sector, taking into account security and the General Data

Protection Regulation.

A strengthened focus on resource efficiency and circular economy.

The EU needs to

exploit the business opportunities resulting from the transition to a more sustainable,

resource efficient and climate neutral economy. Policies need to provide the necessary

coherence, consistency and certainty, creating incentives for a company’s transition to a

circular economy. To this end, a strategy for circular economy should be developed with a

particular focus on how digitalization and artificial intelligence can support circular



SOU, Alm.del - 2019-20 - Bilag 168: Kopi af breve til nyudnævnte kommissærer, fra finansministeren

solutions and business models. Such strategy should be underpinned by a comprehensive

action plan for a transition to a circular and climate neutral European industry.



An action plan for a sustainable and competitive European retail sector.

The further

development of the European retail sector

should be linked to the EU’s new sustainable

growth agenda and the path towards a climate-neutral economy. To this end, the

Commission should develop an action plan for a more sustainable retail sector including

through circular economy and reductions of greenhouse gas emissions from European

retailers and their supply chains. Such a plan should aim to further incentivize the sector’s

focus on sustainability and commitment to manage environmental impacts. The plan could

include initiatives to reduce the sector’s use resources in general, for example the use of

plastics while promoting the use of recyclable packaging as well as to reduce the use

throughout the whole value chain through actions in the retail sector. Such efforts should be

conducted in accordance with existing initiatives at EU level, in particular the work of the

Circular Plastic Alliance. Furthermore, the plan should address the need for electrification

in order to integrate more renewable energy, improving the energy efficiency and recycling

in the sector’s production mode and supply chain.

Ensuring a fair and well-functioning Single Market through uniform implementation

and effective enforcement.

An effective implementation and enforcement of Single

Market legislation is a key component towards making the Single Market fairer and more

beneficial for law-abiding businesses, consumers and workers. By streamlining

enforcement efforts and effectively combating deliberate attempts to circumvent and abuse

Single Market legislation, the incentive to abide by the Single Market rulebook will rise,

leading to greater trust and legal certainty essential for upholding consumer protection and

workers’ rights and

safety in the Single Market. To this end, the EU needs a firm and

ambitious long-term action plan for better implementation and enforcement of Single

Market rules, containing concrete initiatives on how to improve the uniform

implementation, application and enforcement of our common rules governing the Single

Market. For instance can the new European Labour Authority ELA play a key role in the

enforcement of relevant Union law. A stronger focus on effective enforcement will allow

businesses to rely on the same compliance set-up based on the same sets of rules when

expanding their businesses across the EU thus reducing businesses’ compliance costs

leading to greater competition through a greater variety of quality goods and services to

lower prices. The Single Market should be continuously adjusted to support the transition

to a climate neutral economy in the EU by 2050 at the latest.

Effective and sustainable capital markets.

Developing open, transparent and globally

competitive European capital markets is

key for European businesses’ possibility to invest

in and finance e.g. the transition to climate neutral productions and value chains. The

European capital markets should continue to develop towards securing a leading position

for the EU in promoting sustainable and responsible investments, enabling the financial

sector to support sustainable growth. At the same time, the effectiveness of the European

capital markets could be increased by facilitating access to cross-border investments,

thereby creating real value and tangible improvements for investors and businesses.

Strengthening efforts against fraud and financial crime.

It is paramount to create a

level playing field in the Single Market where both law-abiding businesses and frauds have

confidence in the rules being upheld and crimes being punished. Crimes or deliberate

circumvention of EU law undermines the trust and confidence in the Single Market

detrimental to both growth and welfare. The EU should therefore continue its fight against



SOU, Alm.del - 2019-20 - Bilag 168: Kopi af breve til nyudnævnte kommissærer, fra finansministeren

cross border incidents of money laundering and tax fraud. Amongst other initiatives, the

next steps could be to investigate the possibility to allocate special competences to an EU-

body to fight money laundering and create a Single Rule Book throughout the EU by

transforming parts of the anti-money laundering directive to a regulation. The EU should

also assist/support the financial sector in building a common infrastructure that can

strengthen customer due diligence processes with respect to legal certainty for individual

customers.



Providing tools for overcoming increasing complexity and legal fragmentation.

The

level of complexity and legal fragmentation in the rules governing the Single Market is on

the rise. When EU-legislation fails to create common ground across Member States and

break down barriers and new national, technical regulations are being adopted, businesses’

burden of compliance increases. To overcome the increasing complexity and legal

fragmentation especially in the digital economy, more focus should be devoted to ensuring

clear, simple and coherent rules providing for legal certainty. Businesses should have easy

access to tailor-made information regarding the rules they have to comply with when

scaling across borders within the Single Market. A better national dissemination of rights

and obligations for businesses could furthermore have a positive impact on businesses’

compliance with EU-law.

Regulation that is digital-by-default and future-proof.

A continued strong better

regulation agenda is essential to simplify legislation and reduce unnecessary burdens for

businesses. European regulation needs to become more innovation-friendly and forward-

looking to allow businesses to test, develop, and apply new business models. For Member

States to support businesses’ transformation and greater use of digital solutions, it is

important that EU-legislation enable digital administration relying on state-of-the-art

technology, reuse of relevant data and standards. To this end, the EU should ensure that

digitization, interoperability and automatization are comprehensively considered in every

step of the adoption of EU-legislation where relevant. Amongst other a set of principles on

digital-by-default and future-proof regulation could be introduced and enforced at all stages

of the legislative cycle.

