Availability of information via the EBR is not good enough as compared to that
                 available on the websites of each of the national companies registers. It is
                 substantially less in many cases. Customers want the same information to be
                 available. They are not so concerned about standardization. They want access to the
                 underlying information contained in the registers databases.

We agree with the concept of making legal and financial data available through the
                 same source

Participation by all EU states must be mandatory and at a level where the service
                 provided is at least equal to that provided on the national website.

All documents (pdfs / tiffs etc) should be digitally signed by the originally submitter
                 and by any intermediate that handles or stores them. This is to guarantee legitimacy
                 and security.

The operation of the service should be multilingual to support European languages

Any on-line documents such as the Company Profile from the EBR should be based
                 around the maximum dataset available for a company/jurisdiction and presented
                 according to an agreed standard, such as XBRL.

Service levels i.e. opening hours etc. should be consistent across registers. Support
                 for help incidents should be available within a defined timescale according to an
                 agreed standard.

Operating standards must be regularized. For example, search algorithms must be
                 made consistent across registers, document naming conventions must be
                 standardized etc.

Since we started dealing with EBR our feeling is that each of the registers does not treat dealing with
its international customers on the same terms as their national customers. In other words, national
customers are more important. We are saying that this mindset must change. Every customer,
national or international, must be treated equally on every level and most importantly all the data in
the register must be made available to all customers.

We are not sure whether this is, or is not, the case but there would appear to be an extreme
reluctance on the part of some registers to actively promote inter-register and pan-European
cooperation. Whether this is because of budgetary concerns, increased workload, language barriers,
reluctance to change long established processes, we are not sure. However, we are certain that there
is a reluctance to engage.
It is our firm opinion that unless it becomes obligatory then there will be little change in the level of
service. We would hope that it would be enshrined in EU law and that minimum standards are set
that compel member states to provide services. Member states should have an input into the
process but they should not be left to decide how it works. In many cases, if the parties themselves
are left to decide, decisions tend to be made that centre around the lowest common denominator
which will not be up to the required level of service to make the network work optimally.
