We agree with the European Commission that further measures are necessary to improve the access to
information on companies in the European Union and thereby improve the application of the company
law directives. The need for this will become even stronger with the implementation of the Services
Directive and the still expected Statute for a European Private Company (SPE).

It is of particular importance that the users of the business register information can obtain the required
information as easily as possible and at reasonable cost. The best solution would be that they can
access the information from companies in other EU countries through the same Business Register
organization via which they access company information in their own country.

Additionally, we call upon the European Commission to lay down a minimum and comprehensive set of
mandatory information to be registered in the national registries. That will allow the development of a
European business extract/certificate of European enterprises, with the goal to further enhance uniformity
and legal certainty. This information must be correct and complete ensuring a high level of reliability.

In our view it is of the utmost importance that at least all business registers from the EU countries take an
active part in the EBR network to facilitate EU wide access to information. At the moment, a number of
EBR participants cannot be member of the EEIG due to legal reasons.

It is desirable that this cooperation is governed by a solid legal basis, through means of a governance
agreement or by EU legislation that obliges the competent organizations in the Member States to
participate in the cooperation. Such a legal basis, which will be binding for all business registers in the
EU member states, will also enhance the trust in the quality of the information and the systems which are
used.

On the other hand, it is important to note that within the framework of the current cooperation a lot has
already been achieved. Therefore we recommend not legislating too "heavily".

It is of the utmost importance that automated communication between business registers are based on
standards and allow interoperability.

We favour the implementation of the BRITE project results and consider the support of the European
Commission to implement these results necessary.

   -   Several components deserve to be used as standards in the communication between business
       registers. E.g. the international business register number (Registered Entity Identifier; REID), the
       register of business registers (Directory of Registers; DoR) and the Branch Disclosure Service
       (BDS). This ensures that the data of the head office, branches, parent companies and
       subsidiaries registered in different business registers are kept up-to-date.
   -   BRITE operations are automated which, compared to the manual (error prone) processing of e-
       mail inquiries via IMI, makes it more reliable and the costs lower.
   -   BRITE can offer cross border services against the established regular prices, while the
       information provision via IMI is free of charge. According to the Services Directive, competent
       authorities from other countries must be able to access information from registers under the same
       conditions as authorities from the home country. It would therefore be rather peculiar if authorities
       from other countries would get access against more favorable conditions (for example free of
       charge) than the authorities based in the country of the entity itself.

BRITE is a pilot project that needs political support to gather around its objective all EU business
registers. The support of the European Commission could focus on:
    - Establishing a working plan that will state when and under which conditions each component
        should be implemented by Member States.
    - Facilitating the development of ambitious objectives. E.g. information transmitted should have
        legal force, including in electronic form (as provided by the First Directive on Company Law).

 recommends the European Commission to support existing sources, systems and
registers first. However, IMI is an excellent instrument for the exchange of data for which there are
currently no digital systems available yet. IMI would be a complementary system for business register
information. Therefore  recommends making more efficient use of IMI:
    - Use the EBR system first to retrieve all the information on company registers through its
        multilingual interface.
    - Offer a computer interface (APIs) that enables access to information that would only be available
        via the IMI system.

 agrees that a permanent connection and an automated comparative check of the
content of the registers involved is required with regard to branch disclosures. The technical solution
could be provided by implementing the Branch Disclosure Service (BDS) from the BRITE-project.

We support the European Commission's idea to establish a legal basis for cooperation between business
registers with respect to foreign branches, since the 11th company law directive (89/666/EEC) currently
does not lay down a legal requirement for this type of cooperation.

Another innovative solution could be to lay down in the 11th company law directive that the registration of
a branch will take place on the register where the company is registered, and that the registration in the
jurisdiction where the company establishes the branch is automatically generated from the `mother'-register.

 strongly supports the cooperation and direct link between the electronic network set
up by the Transparency Directive for the storage of regulated information on listed companies and the
EBR centralized service providing access to the EU Member States business registers.

In some member states, despite the introduction of electronic business registers, law still requires
additional publication duties in paper form. We call for the immediate abolishment of these additional
costly and unnecessary duties. This is particularly burdensome for SMEs and has not any added value.
