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 since it is to be expected that the cross-border trade in services will also increase
due to the implementation of the Services Directive. Furthermore, as already stated by the Commission, once the
Statute for an European Private Company (SPE) is adopted, the number of cases that require cross-border
cooperation may increase significantly.

In our view it is of the utmost importance that at least all EU countries accede to the EBR-network to facilitate EU
wide access to information. It is of particular importance that the users of the business register information can obtain
the required information as easily as possible. In this regard, 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 format and content for an European
business extract, with the goal to further enhance uniformity and legal certainty.

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-countries, will also enhance the trust in
the quality of the information and the systems which are used. This would be an improvement with regard to the
current situation in which a number of EBR-participants cannot be member of the EEIG due to legal reasons. 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 to legislate too "heavily".

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.

We favor the implementation of the results of the BRITE-project and consider the support of the European
Commission to implement these results invaluable.

Several components deserve to be used as standards in the communication between business registers, such as the
international business register number (Registered Entity Identifier; REID), the register of business registers
(Directory of Registers; DoR) and the Branch Disclosure Service (BDS), with which the data of the head office and
branches and parent companies and subsidiaries are registered in the business registers of the different Member
States can be kept up-to-date. EBR is currently in the process of transposing the BRITE-results to concrete systems
and products. The European Commission could indicate to member States when and under which conditions each
component should be implemented.

The accompanying reliable digital communication can only take place with the systems developed in the BRITE
project. IMI is clearly not suited for this. However, IMI is an excellent instrument for the exchange of other data for
which there are currently no digital systems available yet. The advantages of the EBR / BRITE route are that ,
contrary to the manual (error prone) processing of e-mail inquiries via IMI, systems can function completely
automated and the provision of information can take place 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.

Eventually it is of the utmost importance that automated communication between business registers will be part of
IT-systems in each country on a standard basis.

As a general recommendation we would very much favor if the European Commission takes the
approach/determines that existing sources, systems and registers be used first. Only information thats not available
through the existing means should be retrieved using IMI. This way IMI would be an excellent complementary system
for business register information. With regard to business register information IMI can fulfill a valuable role when
online information is not available.

Perhaps that via a technical interface, IMI can be used as a carrier of digital communication to deliver information,
that is retrieved via EBR or local business registers, to an IMI-user.

agrees that a permanent connection and an automated comparative check
of the content of the two registers 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 la down a legal
requirement for this type of cooperation.

Another innovative solution could be to lay down in the 11 company law directive that the registration of a branch
should take place in the register where the company is registered, and that no further registration should be
necessary in the jurisdiction where the company establishes the branch.
