From: Knote, Kilian (Bisnode UK) [mailto:kilian.knote@bisnode.com]
Sent: Monday, January 04, 2010 6:43 PM
To: SCHMIDT-GERDTS Matthias (MARKT)
Subject: RE: consultation business registers

Dear Sir or Madam,

Thank you for giving me the opportunity to respond to the consultation regarding
interoperability of company registers. As part of a European group of companies, which
includes Soliditet and Hoppenstedt Credit Check, Bisnode is one of the leading business and
credit information providers in Europe and has experience with trading and developing usage
for data. Especially, Bisnode has experience with interconnectivity of different registers, as
well as the necessity for the information to be readily at hand. We are aware of the challenges
when comparing international data.

The consultation is very much at the heart of our business, and indeed of the entire industry of
business information providers. We believe that more technological interoperability of
registers can greatly improve standards, but also believe the steps currently taken by the
registers are going into the right direction.

This is a technical question at first, and a legal question second. Already, the information is
very much standardized. Already, it is fairly easy via a simple Google search to find the
information one is looking for from another market. However, to make this information
usable, users will have to use private suppliers like Soliditet in Nordic Countries, Hoppenstedt
Business Information in Germany, or Dun & Bradstreet. Private industry has invested heavily
to make this information available cross-border, because the public task for business registers
is the provision of the data filed at that register.

The EU is already developing systems for increased comparability of the registers. The
consultation itself appears therefore slightly out-of-date. The main aspect for co-operability
between the registers would be complete introduction of the XBRL standard in filings, as well
as allowing and encouraging access of this information to 3rd party re-users. This would allow
for systems where the information is directly usable by the recipient, the language problems
could be solved within the recipient's software and the information is widely usable. Re-users
would have de-creased costs and market entry for specialised solutions, and end-users would
be able to access and understand the filings of foreign business registers. It is not necessary to
offer these solutions between the registries. The registries do not need to develop "secure, pre-
established channels" for communication. A website with a reasonably high Yahoo and
Google rating that links to all European registries would be sufficient, if the information is
being offered in XBRL.

Alternatively, it would be cheaper for European registries, rather than developing these
communication channels, to buy the typed and added-value information from any commercial
re-user, such as Soliditet, Hoppenstedt or Dun & Bradstreet. If a business register intends to
offer foreign data as well, it should purchase this information on the market, rather than
entering into a hugely expensive project developing the described channels. The outcome
would be similar to the offerings like commercial re-users, which would lead to higher
flexibility than the channels described in the consultation. With the rapid introduction of
XBRL, it is even likely that any project like this would be superseded by private
developments and XBRL. Neither of the proposed solutions are future proof, which would be
a requirement for a development of this size.

Therefore, neither option 1 or option 2 in the Green Paper appear appropriate. Both contain a
strong element of development before the standard is set. Both are hugely expensive solutions
that fail to make use of the resources available by the private sector. The EU will "do its own
thing" rather than choosing the cheaper and more effective solution of using re-sellers of the
information. It is not clear why the EU would want to develop an infrastructure that already
exists in the private sector. We therefore suggest investing increasingly into the development
of XBRL instead, which will lead to the same result  information from another market being
available - but would increase flexibility, favour the private sector, allow for easy data
exchanges, add value to the information provided and would benefit the public task while
allowing for easier quality checks within registries.

Should the reason be that the official registers should only distribute official information, it
must be considered that the official information in many member states is not verified, and
less reliable than the information contained in the databases of re-users. Many of the problems
described in the Green Paper could be eradicated by a regular data cleaning exercise, using
private suppliers' data. Why would the EU add a process to the registries' duties that is clearly
competitive with the private information industry? This would add instability and insecurity
in the business information industry, which would harm investment and in turn harm existing
cross-border information provision. Therefore, the process would have a negative effect,
rather than a positive one.

The EU should encourage open standards that can be used by official registries as well as the
private industry. The EU should try to encourage filings in XBRL and information provision
by registries in XBRL. This would encourage businesses to transport this data cross-border
and would increase transparency. The two options considered in the consultation will be using
public money to compete with the private industry to do something that already exists.

Kind regards,

Kilian Knote,
Business Law Consultant, Credit Solutions




Kilian Knote LLM
Business Law Consultant | Bisnode UK Holdings Limited
Tel: +44 (0)20 8481 8708 | Fax: +44 (0)20 8783 1915
Mob: +44 (0)7855773908 | Email: kknote@bisnode.co.uk
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