Due to our good cooperation within the European Commerce Register's Forum
(http://www.ecrforum.org/) we do not have increased needs for a dedicated network of the
business registers. With respect to the need for access to information, we would like to
point to the fact that relevant information - even with added value - is provided by private
undertakings (i.e. information broker). We do not see the need for a competition between
state authorities and the private business world. In this context the role of the players
should be clearly defined: it is not (and should never be) the obligation of the register to
collect relevant instruments for the establishment of a legal body.

If one envisages a network of the business registers of the Member States the
"governance agreement" approach is a valuable one.

In the long run we do not see added value by combining financial/securities/company
information into one "basket" due to the complexity of the areas as such.

We recommend following up on the "BRITE" approach in the first phase with a possible
emigration into the IMI System in a later second phase, after having gained relevant
experience and knowledge during the first phase.

In our daily work we cooperate without any problems with foreign business registries.
Therefore we do not see a need for a formal legal obligation for cooperation between
business registries.
