fully supports the European Commission's approach, developed in the Green
Paper, for the enhanced interconnection of Business Registers across Europe.

We believe that an efficient electronic network of Business Registers in the European Union's
Member States is a catalyst for facilitating cross-border economic activities and increasing
transparency, by giving direct and easy access to companies' financial and legal statements.

A better interconnection of Business Registers requires improved interoperability, a common
semantic and shared business rules.
To achieve these targets, we would like to promote the use of a unique open source exchange
standard based on XML, which is already used for tagging and exchanging financial
information by a large number of Business Registers in Europe (and by worldwide regulators
such as the SEC in the US; the Bank of Spain, the Bank of France and the National Bank of
Belgium in Europe; the Bank of Japan in Asia; or by tax authorities, as in the United
Kingdom and the Netherlands, amongst many others).

This standard is the eXtensible Business Reporting Language, also known as  or
"interactive data".
We promote  as it allows:

     A standard (and not a physical network) for the exchange of electronic structured
      data between Business Registers, which can be used on various kinds of networks;
   Global compatibility with Internet technologies and electronic platforms, as it is
      based on XML;
   Direct access to individual data in  registered information, which in turn allows
      easy comparison of figures or characteristics from different companies;
   The use of multilingual labels, to facilitate the understanding of reported data
      throughout Europe;
   The ability to implement a common structure (described in an  taxonomy),
      adjusted by local extensions, which is relevant to managing a dual approach
      combining global/European shared rules with local/national specificities;
   The possibility to add an optional legal validity to each  file (digitally signing
      the reports), which is important for guaranteeing the origin of the data supplied by the
      Business Registers.

   Exchanges with other organizations apart from the Business Registers, such as banks,
      stock markets, regulators or large companies, that use  for internal, financial or
      regulatory reporting;
   Exchanges with companies or authorities outside Europe, which already use this
      technology.

We also believe that the use of  could significantly improve the access of European
companies to registered data and reduce the administrative burden, as it greatly simplifies
the filing and consultation of individual financial or legal data.

     Since 2008, Infogreffe publishes the financial statements of French companies as
          files as well as PDF files. There is no additional cost for analysts to access this
         electronically structured data.
     In Spain, since 2009, it is mandatory to use the  format for the digital
         presentation of financial statements. At the moment, almost 70% of the deposits are
         digital, i.e. there are now more than 600 000  financial statements of Spanish
         companies available online (these  files will be published on the Registrars'
         website without any additional cost, starting March 2010).

 is being adopted by an increasing number of Business Registers. This is the first time
that the same standard is used by so many Registers, and opens opportunities for more
interoperability and enhanced interconnection.

An improved network of the Business Registers across Europe is necessary.  provides
solutions for better access to company data across Europe, improving the European Business
Register's initial efforts to define a common semantic on the commercial information stored
into the national Business Registers.
     Today, Business Registers in Europe have published millions of  files and the
        number continues to grow. This trend started with companies' annual accounts and is
        now spreading to various companies' legal filings, affording new opportunities to
        increase transparency, share information among national registers, and facilitate
        benchmark analysis by end-users.
     Even if each local Business Register has now developed its own taxonomy (
        public data dictionary) based on its national laws and its local accounting standards,
        links can be made between similar concepts in these taxonomies, to create a common
        semantic in addition to the technical interoperability resulting from the use of the
        same technology.

A governance agreement should facilitate common definitions of concepts. The use of a
common technical standard must be completed by defining the broadest set of common
information describing businesses, to be entered in all Business Registers in Europe.
     It is necessary to design and propose a common European Business Certificate, to use
       a Unique Company Identifier as planned by the BRITE project (REID) and to share a
       set of financial information based on the European directive for Annual Accounts
       drawn up according to local GAAP.
     These common concepts (commercial and financial information for companies) could
       be technically shared in a core Business Registers' taxonomy, available in different
       languages and character sets, for a better interconnection of Business Registers
       across Europe.

 can help to connect the European network of the Business Registers to the electronic
network set up under the Transparency Directive as  is often used for regulatory
reporting and financial reporting purposes.
     has been promoted by the Committee of European Banking Supervisors and by
       national banking supervisors. Some European securities regulators (as CNMV in
       Spain) also use .

The interconnection of Business Registers may rely on the principles developed by the BRITE
project which focuses on file transfers and interoperability, and on the usage of IMI to
connect Business Registers with other authorities. Again, we propose the use of  as a
common technology to transfer company identification and data between Registers ≠ on a
multilingual and multi-scheme basis, open to a wide variety of information concerning cross-
border companies or operations.
     We promote  as it is already used by Business Registers across Europe.
     We promote  as it is also used by other interested parties for national and cross-
        border financial information.
     We promote  as it is possible to share digitally signed  instance
        documents, which are necessary for a complete and effective exchange process in the
        case of cross-border mergers and transfers of head-quarters.
