-----Original Message-----
From: Paul Tighe [mailto:paul.tighe@gmail.com]
Sent: Tuesday, January 26, 2010 7:22 PM
To: MARKT COMPLAW
Subject: Consultation reply Interconnection of Business Registers - Citizen

Dear sir/madam,
after reviewing the documens provided for consultation, I would like
to observe the following.

Firstly, IMI (which I believe has a bright future in other areas),
seems likely to generate increased workload for MSs in answering
registry queries from other MSs and the general public. It seems like
needless work for MSs to have to manually respond to every browser of
a business registry. This is work that can be done cheaper and faster
by an automated system which can access and retrieve the relevant
information from the registries of other MSs.

So, I turn to EBR and the possibility of using the BRITE project's
work to update its functioning.

Firstly, BRITE's work seems to offer a simple universal coding which
will be easy for MSs systems to work off of (REID). The BDS also seems
like a simple solution to a real problem.

However, I note from the Working Paper that BRITE includes a
centralised registry (CNI). This sounds expensive. I cannot guess the
running costs of such a project, but it doesn't take much to imagine
that maintaining a registry of every company in the EBR will require
significant resources.

I have serious doubts that a centralised system will present value for
money. I hope the Commission will think long and hard about costs
before committing itself to this course of action.

If BRITE proves too expensive, then the only prudent course in my
view, is for the Commission to involve itself in EBR's current system
of mutually compatible national registers and try to improve the
functioning of this group. In particular, the REID codes and a
modified BDS seem like they could bring much to the EBR system. The
Working Paper also raises serious technical questions about its legal
form.

However, the Commission Working Paper also includes a lot of
handwringing about the non-participation of some MSs in EBR. This
seems like total nonsense to me. If MSs do not wish to join this
grouping then I see little justification to compel them to do so.
Sharing information on business registers is a useful service, but it
is hardly critical to the functioning of the Internal Market.

Nonetheless, Community membership of EBR seems reasonable, given the
potential for Community dimension. The inclusion of non-MSs on the
other hand can only be a good thing in my view, and there would be
additional benefits to membership by new countries (such as the US
with which many European countries have branches and vice versa). I
would hope that whatever changes may be encouraged in EBR take into
account the needs of non-EU countries as well.

regards
Paul Tighe
