DK, EE, FI, and LV non-paper on easing the reporting obligation for companies in unprecedented times
Reducing administrative burdens is a prerequisite for maintaining the competitiveness of European
businesses and facilitating
the EU’s green transition
amid geopolitical tension and increasing global
strategic competition. The European Commission's intention to rationalise and streamline reporting
obligations by 25%, without undermining policy objectives, is therefore both timely and necessary. The
initiatives tabled with the recently adopted work programme, aiming at bringing about more than EUR
3 billion in cost savings, are all steps in the right direction. However, as indicated by the spirit of the
Commission’s
call for evidence, these measures will have to be supplemented with additional measures
to further reduce businesses’ reporting burdens as well as administrative burdens beyond reporting.
On
26 October, the European Council also adopted conclusions emphasising the need
“to
take forward
work to simplify regulation and reduce the unnecessary administrative burden, including reporting
requirements, notably for SMEs and start-ups”.
Furthermore, the European Council called for additional
proposals, “seizing
the opportunities of the data economy and standardised business data”.
Ideas have already been put forward, including by France and Germany in
their paper on “Better
Regulation and Modern Administration in Europe”.
We acknowledge proposals which include practical
solutions that can help reduce burdens on businesses, such as a call for effective digital readiness in
legislation at Union level or advancing digitalisation in the legislative process. It is important to consider
different ideas, as focusing solely on the adoption and repeal of reporting requirements to reach the
target is likely to miss the vast potential to reduce burdens through optimising how legislation works on
the ground.
Seamless and secure exchange of business data
Digital bookkeeping, eInvoicing and automated business reporting highlight the vast benefits of
automated and standardised business reporting when complying with national and EU law. Companies
engaged in cross-border trade face the onerous task of sharing data with various business partners and
authorities across different Member States. Today, this data exchange is highly fragmented due to a
lack of standardisation, creating barriers to digitisation and automation.
To realise cost savings amounting to billions of euros, we should actively promote a seamless and secure
exchange of business data among companies within EU Member States by underpinning EU legislation
with common minimum standards and a robust, decentralised data infrastructure. The common digital
standards and components that the EU has already developed should be the foundation for this effort.
The Connecting Europe Facility (CEF) serves as a cornerstone in this endeavour, offering essential digital
building blocks such as eDelivery, eID, and eInvoicing that serve as critical infrastructure to facilitate
more effortless cross-border interactions for businesses within sectors ranging from economy and
finance to energy and public security etc.
Specific initiatives towards this purpose may encompass:
•
To fully unlock the potential of these foundational elements, it becomes imperative to achieve
broader adoption of these building blocks throughout EU legislation.
The particular case of sustainability reporting
While we fully support the new and ambitious EU rules on sustainability, the combined cost imposed
on companies is expected to be both significant and enduring when companies will be required to report
on their footprint across various dimensions, including company-wide activities and specific products.
To ensure coherence and consistency in the reporting it is of key importance that data can be structured