127 submissions from 117 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission lists 986 submissions on this file. Shown here: the 127 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
Who showed up
52 submissions from industry — companies and their trade associations — against 23 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 2.3 industry submissions for every one from civil society.
Industry 52Civil society 23Public authorities, academia, other 52
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
What the room declares
37 of 117
in the EU Register
215
full-time lobbying staff
€24.2M+
declared costs a year
144
EP accreditations declared
Self-declared to the EU Transparency Register (snapshot 2 Sept 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 3 Jun 2020 — it ran from 20 Feb 2020.
Policy area
Digital & tech (DG CNECT)
Where it stands
Awaiting adoption
Commission reference
C(2022)9562
How it got here
Public consultation3 Jun 2020
Impact assess incep25 Aug 2020
Draft implementing regulation21 Jun 2022
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Implementing regulation.
One block of text on this file was submitted, identically, by three or more organizations. Shared text is a fact about the filings; what it means is for the reader.
“I am participating in this public consultation on the Open Data Directive, with respect to the high value dataset on Companies and Company Ownership, as I believe that open company data brings multiple important benefits to society: Discovery and deterrence of money laundering, which costs the EU almost €200 billion per year; Decrease of corruption in public procurement, which costs the EU around 5 billion euro per…”
Please see attached comments of ACT | The App Association (Transparency Reg. # 7202951387754) on the European Commission’s draft implementing regulation laying down a list of specific high-value datasets and the arrangements for their publication and reuse.
The European Commission will in Q3 adopt the Digitalisation of Energy Action Plan. The Implementing Regulation on High Value Data Sets was mentioned by DG ENER during its series of workshops held on the Action Plan in February (https://ec.europa.eu/info/events/workshops-digitalisation-energy-system-2022-feb-16_en). For that reason, it surprises us how little attention the Implementation Regulation gives to energy.
1. The basic data on “companies”. The concept of undertaking is an extremely broad concept and it seems important to define the scope of this category of “undertakings and ownership of undertakings” in order to achieve harmonisation between Member States.
Filed in Portuguese · English published by the European Commission
The Helmholtz Centre Potsdam German Research Centre for Geosciences GFZ (GFZ in short) is Germany’s national research center for the solid Earth Sciences. As such, we are both generating as well as utilizing data and data services for the national and international research community of geosciences.
The Horizon 2020 EOSC Pillar Project (https://www.eosc-pillar.eu/) conducted a comparative analysis of the legal landscape relevant for the development of open access and open data research policies and for the building and maintenance of open infrastructures.
According to the Annex of the IR the scope of the Earth Observation and Environment category is based on the INSPIRE data themes listed in the table. One of theme is Environmental monitoring Facilities theme. According to the definition, this theme covers location and operation of environmental monitoring facilities includes their observation and measurement.
The Land Government of Schleswig-Holstein: welcomes the Creative Commons BY 4.0 Licence or a more free data licence. It is in line with the Open Data Act of the Land of Schleswig-Holstein. According to Paragraph 5(1), ‘the data should be made available in the public domain, otherwise freely licensed’.
Filed in German · English published by the European Commission
The IGN welcomes the publication of this draft Regulation and its guidance which, by establishing a list of high-value datasets and the conditions under which they are made available, will allow progress in the harmonisation of open data for the benefit of the European Commission, its agencies, Member States and users.
Filed in French · English published by the European Commission
The Association for Computing Machinery (ACM) is the world’s largest and longest established professional society of individuals involved in all aspects of computing. ACM’s Europe Technology Policy Committee (“Europe TPC”) is charged with and committed to providing objective technical information to policy makers and the general public in the service of sound public policy-making.
The Netherlands Chamber of Commerce - as holder of the Business Register of the Netherlands - endorses the importance of business data for the European business community. The introduction of this implementing regulation will benefit from a clarification of the points below. Further clarification will avoid multiple solutions and interpretations of these issues.
The EU Open Data Directive’s main goal is to increase the availability of public sector data for re-use as raw material for innovation across all economic sectors. The Directive introduces the concept of High Value Datasets (HVDs). HVDs are datasets whose re-use is associated with important benefits for the society and economy.
Dear Members of DG CNECT, The Enel Group, a multinational company of the energy sector, welcomes the opportunity to provide comments to the initiative of the European Commission regarding the availability of “high-value” datasets (HVDS) held by the public sector.
We welcome with enthusiasm and hope the project to open up high-value data and publish it free of charge in a format that allows it to be reused. We fully support the recommendations made by Access Info (see PJ) and complement them by addressing the specificities of the fisheries sector.
Filed in French · English published by the European Commission
With regard to the proposal for an Implementing Regulation, in some respects some rules seem to me to be somewhat vague, particularly in the implementation of the APIs. However, these doubts could be clarified if technical specifications are published clarifying the rules to be adopted for this purpose.
Filed in Portuguese · English published by the European Commission
1. “Companies and company ownership” The draft Implementing Regulation calls for the publication of only basic company information and company documents, without the names of company legal owners, legal representatives, and beneficial owners.
The attached document sets out our full response. OpenCorporates is the largest open database of companies in the world. Our open website is used by millions of users each month, including SMEs and ordinary citizens. Our data has supported investigations such as the Panama/Paradise Papers and into Covid relief scheme fraud.
The Directorate for Geodata Integration of the Public Service of Wallonia welcomes the opportunity to comment on the European Commission’s draft regulation on open data — availability of public datasets. Our main remarks are set out below: 1) upgrading existing infrastructure and minimising costs for the public sector It is essential not to share this HvD data in different formats and infrastructure if there is…
Filed in French · English published by the European Commission
On the one hand, the Commission Implementing Regulation laying down a list of specific high-value datasets and their arrangement for their publication and re-use supports the interest of companies that can develop new innovative business models or optimise their business processes on the basis of public data.
Filed in German · English published by the European Commission
With this contribution, SGI Europe puts forward the key messages from employers and providers of services of general interest (SGIs) across Europe. As one of the cross-industry EU social partners, SGI Europe represents its members active in, amongst others, energy, healthcare, telecommunications, waste management, and water distribution.
Dear Sir or Madam, please find enclosed the opinion of the Federal Chamber of Tax Advisers on the draft delegated act ‘Commission Implementing Regulation laying down a list of specific high-value datasets and their arrangement for their publication and re-use’ with a request for consideration. Best greetings I.A.
Filed in German · English published by the European Commission
Dear madam, sir Sending you the feedback of the National Geographic Institute of Belgium, targeting the definition of the HVDs. Implementing regulation Article 2.2 and 2.3 Comment: the Directive 2007/2/EC includes the geospatial part of other domains like statistics, mobility and meteorological. These articles do not reflect what is described in the Annex. (5) ‘granularity’ means the level of detail of a dataset.
The Ministry of Finance of Finland welcomes the long-expected draft and the opportunity to comment on it. Interest in Finland towards the draft has been high and we have encouraged Finnish stakeholders to provide their own comments. Innovations and new types of business can be encouraged by providing high quality open data, free of charge, via APIs.
According to Article 13(1) of Directive (EU) 2019/1024 of the European Parliament and of the Council on open data and the re-use of public sector information, company data and company ownership are considered to be valuable datasets.
The Land Government of Baden-Württemberg welcomes in principle the extended and standardised uses of open data on the basis of the PSI Directive 2019/1024 and the now planned clarification through the Implementing Regulation establishing a list of certain high-value datasets (HVD) and the modalities of publication and re-use.
Filed in German · English published by the European Commission
Finnish Transport and Communications Agency Traficom supports the goals of the act. Regarding to the scope of the act, in Traficom’s view, the Directive on river information services (RIS) does not apply to inland waterways in Finland. In that case, the requirements based on the legal act would also not apply to this Finnish Data.
Transparency International joins the Public Consultation on Draft Implementing Regulation for Open Data Directive and calls on the Commission to act on the promise to include a requirement to open company information. Now as the EU Commission drafts the Implementing Regulation, it is troublesome that only basic company information and company documents are considered for open publication.
We fully understand the objective of this proposal for a regulation. However, it is important not to underestimate the costs it will generate for the public sector. We would therefore like to mention the following points of attention: Do not duplicate the existing infrastructure for sharing this HvD data (ex INSPIRE portal) For the sharing of a large number of these HvD data, there are already operational…
Filed in French · English published by the European Commission
Oceana is an international non-profit organisation dedicated to protecting the ocean. One of our areas of work is focused on the recovery of fisheries and on tackling Illegal, Unreported and Unregulated (IUU) fishing through increasing fisheries transparency.
European DataWarehouse GmbH (EDW) hereby advocates for the making of sustainable and green datasets open access in a machine-readable format through application processing interfaces (APIs) and bulk download. EDW was founded in 2012 as part of the implementation of the European Central Bank (ECB) ABS Loan Level Initiative to restore investors’ and supervisors’ confidence in European securitisation markets following…
Filed in German · English published by the European Commission
Insurance Europe welcomes the possibility to comment on the European Commission draft Implementing Regulation laying down a list of specific high-value datasets and the arrangements for their publication and re-use.
Geological Survey of Sweden’s response regarding draft act – Open data – availability of public datasets. Geological Survey of Sweden, the authority for issues relating to bedrock, soil and groundwater in Sweden, appreciate the opportunity to give feedback on the public consultation of the Inception Impact Assessment under the heading Open data – availability of public datasets.
TEKNIQ Arbejdsgiverne, the Danish association representing 4.100 mechanical and electrical contractors in the electrical, plumbing, heating, ventilation, and metals industries in Denmark, welcomes the European Commission’s proposal for an Implementing act on a list of High-Value Datasets as a contribution to the effective implementation of the Open Data Directive 2019/1024.
IBM welcomes the European Commission’s proposal for an Implementing Act on a list of High-Value Datasets. It will contribute to the effective implementation of the Open Data Directive, through making high-value public datasets available in a machine-readable format via APIs. Please read our full contribution in the attached file.
The sections ethical, legal and social aspects (ELSA), Common Infrastructures (infra), and (Meta)data terminologies and Provenance (meta) of Nationale Research Data Infrastructure (NFDI) e.V., welcome the EU initiative to strengthen the availability of public funded information and therefore defines a list of ‘high-value’ datasets held by the public sector.
Filed in German · English published by the European Commission
Dear Madam, I would like to submit the following comments on behalf of the Administration Générale de la Documentation Patrimoniale du SPF Finances. We are responsible for the implementation of the INSPIRE Directive as regards the Administrative Units and Parcels cadastral themes. I would therefore like to draw your attention to the following considerations.
Filed in French · English published by the European Commission
When it comes to Geopatial data, most datasets are already available in the Netherlands as open data. The specifications drawn up are in line with the INSPIRE definitions. According to Article 3 of the Implementing Regulation, the data sets must be made accessible via APIs.
K-Monitor is participating in this public consultation on the Open Data Directive, with respect to the high value dataset on Companies and Company Ownership, as K-Monitor believes that open company data brings multiple important benefits to society: Discovery and deterrence of money laundering, which costs the EU almost €200 billion per year; Decrease of corruption in public procurement, which costs the EU around 5…
This comment pertains to the list of specific datasets to be considered as high-value datasets (HVDs) listed in the draft Annex. Specifically, we suggest to expand the list of meteorological datasets to be considered as HVDs by climate simulation data of possible future climates. Please refer to the attached document for an elaboration of our suggestion. Thanks very much!
In this document there is some heterogeneity in terms of approach in the way the various HVDS thematic categories are dealt with, which makes the reading of the Annex difficult to interpret. Some specific comments are identified below: • Does the need for geographical coverage of the whole country also apply when the country is made up of geographically discontinuous territories with administrative autonomy? — e.g.
Filed in Portuguese · English published by the European Commission
The Daphne Caruana Galizia Foundation is participating in this public consultation on the Open Data Directive, with respect to the high value dataset on Companies and Company Ownership, as we believe that open company data is a vital tool in the fight against financial crime.
I.Commission Implementing Regulation Article 2 — Definitions Article 2 refers to Directive 2007/2/EC (INSPIRE) for the definitions of the data category ‘geospatial, earth observation, and environment’. This (very broad) reference to the ‘definitions’ of the Directive would allow drawing a broad interpretation of the APIs, which would mean that, in accordance with INSPIRE, a levy is required by means of a view…
Filed in German · English published by the European Commission
GÉANT fully supports this initiative, as it is quite a strong requirement to make significant high-value datasets available, which will promote reuse significantly. The guidelines proposed for implementing each element (e.g. CC-O or CC-BY licence, APIs etc) are also very appropriate but we do miss any reference to persistent identifiers. Overall, the ambition is impressive.
I am participating in this public consultation on the Open Data Directive, with respect to the high value dataset on Companies and Company Ownership, because this data is a necessary tool to make human rights due diligence (HRDD) by companies, investors and other stakeholders possible in an extensive way. Such HRDD is foreseen in the draft CSDD directive, in several sectoral due diligence frameworks (e.g.
Providing access to the widely applicable, open data is an essential condition for the widespread use of digitization, a sustainable, green economy, and data-driven decision-making. We considers the draft regulation important, but creating and maintaining stable, long-term interoperable data access is a significant challenge.
Dear Srs We attach contributions to the following Directives: — Directive 2008/56/EC of the European Parliament and of the Council of 17 June 2008 establishing a framework for community act ion in the field of marine environmental policy (Marine Strategy Framework Directive/MSFD) — Directive 2014/89/EU of the European Parliament and of the Council of 23 July 2014 establishing a framework for maritime spatial…
Filed in Portuguese · English published by the European Commission
Norwegian Mapping Authority – a public body under the Norwegian Ministry of Local Government and Regional Development has the following comments; SUSTAINABLE FUNDING Sustainability remains an issue that needs be addressed in the short and long term. The Regulation is more than just about opening the data. It requires investment in APIs and does also need outreach and education.
Dear Sir/Madam EGEC response to Draft Implementing Act on High Value Datasets (HVD) EGEC, the voice of the European geothermal industry, is a not-for-profit association representing the entire value-chain of the industry across 28 countries. It is included on the European Transparency Register number: 11458103335-07 Further information can be found at www.egec.org. We welcome your focus on HVDs.
Thank you for the opportunity to comment on the planned implementing act with a list of high value datasets and would like to make the following comments: The German Statutory Accident Insurance (Gesetzliche Unfallversicherung) shares the European Commission’s assessment that data have a high social and economic value.
Filed in German · English published by the European Commission
The Czech Hydrometeorological institute (CHMI) as the Czech national weather service has the following feedback concerning meteorological high value datasets description as proposed in Annex to the Commission Implementing Regulation laying down a list of specific high-value datasets and the arrangements for their publication and re-use.
“Companies and company ownership” The draft Implementing Regulation calls for the publication of only basic company information and company documents, without the names of company legal owners, legal representatives, and beneficial owners.
The data economy development has the potential to boost research and innovation, that are highly necessary for enhancing the wellbeing and competitiveness of Europe in the future. The proposal for an implementing act of the Open Data Directive on High-Value Datasets (HVDs) is one of the key tools in implementing the European Strategy for Data and opening and expanding the data economy.
The Association of German Transport companies (VDV) has read the proposed implementing regulation of the Commission related to high-value datasets. We welcome in particular that point 6.1 of the Annex related to the scope of the “mobility” datasets mentions data related to the transport networks as established in the INSPIRE Directive 2007/2/EC as well as river information data stemming from the RIS Directive…
The Executive Council of the Spanish Geographical Information Infrastructure (CODIIGE), created by the Geographic High Council, is made up of representatives from the three fields of the Administration, experts from the Geographic High Council Commissions, and experts in environmental policies.
EuroGeographics is an independent, international, not-for-profit organisation representing Europe’s National Mapping, Cadastral and Land Registration Authorities (NMCAs). Our strength lies in our extensive membership. We believe in a modern, digital and green society empowered by the use of trusted geospatial and other data from these official national sources, many of which are defined as high-value datasets.
It would be highly desirable for the Belgian regional authorities and the European Commission under this proposal for the automated monitoring and reporting already put in place under the INSPIRE Directive to be reused and used for this high-value open data without the need for further monitoring or reporting based on other methodologies, detailed rules or common provisions, in the interests of rationality…
Filed in French · English published by the European Commission
Doctrine, a French legaltech company providing legal information services to law professionals, welcomes the opportunity of commenting on the draft implementing Act, which is unfortunately a disappointment for many re-users who expected new opportunities due to the 2019 Directive.
Please find attached the comments from FEBIS ,the Federation of Business Information Services, the specialized and recognized industry body of providers of global B2B business intelligence services for managing trade risks. We also support the comments made by the PSI Alliance in their contribution.
Transparency International EU is participating in this public consultation on the Open Data Directive, with respect to the list of high value datasets a set out in the Implementing Regulation. Recalling that European Parliament and the Council agreed in 2019 to add “Companies and Company Ownership” data to the list, we would like to draw attention to the current proposal of only providing basic company information…
I am participating in this public consultation on the Open Data Directive, with respect to the high value dataset on Companies and Company Ownership, as I believe that open company data brings multiple important benefits to society: - Discovery and deterrence of money laundering, which costs the EU almost €200 billion per year; - Decrease of corruption in public procurement, which costs the EU around 5 billion euro…
Comments and questions on draft act - Open data – availability of public datasets National Land Survey of Finland Implementation rules for High Value Datasets are most welcome. Going into detail, there are a few observations below that may need further clarification.
An inclusion of the accounting documents (after ‘a.c.’ should not be included in the ‘high value dataset’, as provided for in point 5 of the Annex to the implementing act. 1. The inclusion leads to a contradictory approach to dealing with a.c. at European level and thus jeopardises the European Commission’s ESAP initiative as a key building block for the implementation of the Capital Markets Union.
Filed in German · English published by the European Commission
The Council for Social and Economic Data (SWD) welcomes the European Commission’s draft implementing regulation on the specification, publication and re-use of high-value datasets in the public sector. Improving access to high quality data for science is an overarching objective of the Council SWD.
Filed in German · English published by the European Commission
Feedback from EUMETNET OPERA-programme The Operational Program on the Exchange of weather RAdar information (OPERA, www.eumetnet.eu/opera) has coordinated weather radar collaboration among national weather services in Europe for more than 20 years in EUMETNET (Saltikoff et al. 2019, https://doi.org/10.3390/atmos10060320).
Article 3: "Public sector bodies holding high-value datasets listed in the Annex shall ensure that the datasets described or referenced in the Annex are made available in machine-readable formats via APIs. Where indicated in the Annex, the datasets shall also be made available as a bulk download." For some datasets bulk download may be a suitable alternative to APIs.
EUMETNET High Value Datasets Consultation Submission The members of the European Network of National Meteorological and Hydrological Services (EUMETNET) are fully committed to providing meteorological High Value datasets in accordance with the proposed Implementing Act.
I am participating in this public consultation on the Open Data Directive, with respect to the high value dataset on Companies and Company Ownership, as I believe that open company data brings multiple important benefits to society: Discovery and deterrence of money laundering, which costs the EU almost €200 billion per year; Decrease of corruption in public procurement, which costs the EU around 5 billion euro per…
General comments The Swedish mapping, cadastral and land registration authority, Lantmäteriet welcomes the draft act and the appointed high value datasets. Our perception of the scope is that it is fully in line with the petition for change in funding from user fees to public funding, that we have put forth in discussions with the Swedish government.
Member States shall support public bodies in order to ensure long-term sustainability of production of high-value datasets and the operational run of systems for publication of High-value datasets (HVD) and their regular updating while taking into account technological and market developments, within the framework of Directive (EU) 2019/1024
One of the objectives of the regulation is harmonising the implementation of the re-use conditions of high-value datasets. Requirement to use API and machine readable formats is indeed very much needed, but this leaves quite a lot open for implementation and probably leads to incompatible implementations.
Full opinion attached... PSI Alliance would like to thank you for the opportunity to comment on the Implementing Act laying down a list of specific High-Value DataSets (HVDS) and the arrangements for their publication and re-use.The present draft is unfortunately a disappointment for many re-users who expected new opportunities due to the 2019 Directive.
I am participating in this public consultation on the Open Data Directive, with respect to the high value dataset on Companies and Company Ownership, as I believe that open company data brings multiple important benefits to society: Discovery and deterrence of money laundering, which costs the EU almost €200 billion per year; Decrease of corruption in public procurement, which costs the EU around 5 billion euro per…
Thank you for this request for feedback. Due to the process I can only do this anonymous. As an employee of the Ministry of Infrastructure and Water Management Rijkswaterstaat I am providing (open)data for international use. In that line I am familiar with opendata, INSPIRE and alignment.
Finnish Transport Infrastructure Agency (FTIA) has reviewed the draft for valuable datasets. FTIA supports the goals of the act. Below you can find our feedback: • One of the datasets in scope concern orthoimagery (chapter 2.1). How should the openness of orthoimagery be interpreted: should all public sector orthoimagery, that are generated eg.
The goal of the regulation is excellent and it is compact. This regulation has much in common with the existing national regulation. It is good to have the similar common regulation in the whole EU. Free access to the open data could be beneficial many more parties and could create more innovations with increased efficiency and productivity. If the data has price in it, it only benefits those who are able to pay.
I am participating in this public consultation on the Open Data Directive, with respect to the high value dataset on Companies and Company Ownership, as I believe that open company data brings multiple important benefits to society: Discovery and deterrence of money laundering, which costs the EU almost €200 billion per year; Decrease of corruption in public procurement, which costs the EU around 5 billion euro per…
Having worked in compliance functions for half of my career, it is important that this corporate data is easily accessible, we are continuously seeing a hike in financial crimes across the globe, and one way to fight these criminals and uphold the global economies, is by ensuring, data is accessible and doesn't require convoluted processes to be used.
I am participating in this public consultation on the Open Data Directive, with respect to the high value dataset on Companies and Company Ownership, as I believe that open company data brings multiple important benefits to society: Discovery and deterrence of money laundering, which costs the EU almost €200 billion per year; Decrease of corruption in public procurement, which costs the EU around 5 billion euro per…
I am participating in this public consultation on the Open Data Directive, with respect to the high value dataset on Companies and Company Ownership, as I believe that open company data brings multiple important benefits to society: - Discovery and deterrence of money laundering, which costs the EU almost €200 billion per year; - Decrease of corruption in public procurement, which costs the EU around 5 billion euro…
Digitalisation can bring about increased efficiency and productivity. Good data management is a prerequisite to bring about this change. The City of Stockholm welcomes the EU:s high ambitions concerning the digital transition and acknowledges that there is an added value of availability of public datasets.
1. Any dataset that was financed entirely or predominantly with EU funds should be reusable. The easiest way to ensure this currently is to categorise them as high-value datasets. 2. The “Companies and company ownership” datasets should be expanded to include beneficiary owners, residency and past ownership. All this should be available in a machine-and-human-readable format 3.
ARTICLE 19 is participating in this public consultation on the Open Data Directive, with respect to the high value dataset on Companies and Company Ownership, as we believe that open company data brings multiple important benefits to society: -Discovery and deterrence of money laundering, which costs the EU almost €200 billion per year; -Decrease of corruption in public procurement, which costs the EU around 5…
Please find attached an assessment by the German Meteorological Service on the planned implementing act on high-value datasets in the category ‘Meteorology’. I.A. — German Meteorological Service (DWD) International Affairs, Frankfurter Street 135 ● D-63067 Offenbach Dr [name removed] Tel.: [phone removed] [email removed] www.dwd.de
Filed in German · English published by the European Commission
Municipalities are committed to the common good and provide a wide range of essential basic services to their citizens. Services such as drinking water, sanitation, waste management services are subject to fees payable by each household.
Filed in German · English published by the European Commission
We are pleased that this initiative is ongoing because open data is in the public interest. Our citizens’ association calls for the introduction of the passporting and registration of broadcasters, i.e. the obligation to publish the location and parameters of BTS broadcasters under the Public Access to Information Act.
Filed in Slovak · English published by the European Commission
We "Europeans for Safe Connections" welcome this initiative because in our european citizens' initiative "Stop (((5G))) – Stay connected but protected" we also write that according to the Aarhus Convention EU citizens have a right to ensure that the most up-to-date scientific data is taken into account when the EU adopts policies for the protection of the environment.
There is a need to incorporate public procurement (TED, https://ted.europa.eu/TED/browse/browseByMap.do) and from EU countries as high value datasets. European initiatives are being taken to standardise and publish all data.
Filed in Spanish · English published by the European Commission
-Good arrays/tables and background -Vocabulary and content are pretty diffucult. Those could be explicit and less complicated. -compact -The goal of the regulation is excellent -This regulation has much in common with national regulation. -It's good to have the similar and common regulation in the EU
Given the importance of procurement datasets and the growing efforts across EU jurisdictions to adopt open data contracting standards (OCDS), in particular but not only in relation to the new rules on eForms (Commission Implementing Regulation (EU) 2019/1780 of 23 September 2019), it is a missed opportunity for the specific list of statistical high-value datasets (HVD) not to include procurement statistics.
My initial thoughts without having read the consultation in detail, which I might do, should time permit. All information held by the Public Sector should be made available FREELY or else a basic charge which is affordable by all to cover equipment not time.
1) "Companies and company ownership" dataset contains only very modest information about company ownership - only attached documents, which can potentially contain the information. That is hardly usable for further processing and certainly does not follow good practices for publishing open data.
For cadastral data, inspire should be a minimum and Public Bodies should be forced to include additional info in case they have. As an example, inspire consider 6 categories for a building use (currentUse) those are: residential, agriculture, industrial, office, retail, publicServices.
A well functioning data economy in Europe is good for the economy and society when it is grounded in strong, responsible and common values. FBNed | Familiebedrijven Nederland supports the initiative for a follow up of the Open Data Directive which regulates the use and re-use of Public Sector Information.
Trainline is the leading independent rail and coach ticket vendor, selling rail and coach tickets to millions of travellers worldwide. Via our website and mobile app, people can seamlessly search, book and manage their journeys all in one place. We bring together routes, fares and journey times from over 270 rail and coach carriers across 45 countries.
SNCF welcomes the opportunity to provide comments to this initiative from the European Commission regarding the availability of “high-value” datasets held by the public sector. SNCF provides through a dedicated platform more than 200 data sets that cover a wide range of static and dynamic data to maximise the use of data and to develop interoperable and interconnected services.
COCIR welcomes the opportunity to provide feedback to the consultation on the availability of public datasets as provided for by Article 14 of the Open Data Directive. Public sector information is highly relevant for the healthcare sector and COCIR looks forward to the prospect of the availability of High Value Datasets in a European Health Data Space.
IBM supports the European Commission’s proposal for an Implementing act on a list of High-Value Datasets as a contribution to the effective implementation of the Open Data Directive 2019/1024. We agree with the objective to make specific high-value public datasets available, where appropriate, as there is significant potential in its re-use in new products and services.
The opening of mobility data is key for the emergence of new public transport and mobility services in general. In this respect, RATP has already qualified a large number of datasets be they static or dynamic, and is keen to help the community use these data-sets in the most effective ways.
Filed in French · English published by the European Commission
Please find attached our detailed feedback. Summary: The development of high-value datasets (HVDs) in specific fields will have major positive consequences for society. Such datasets offer significant potential for citizens and businesses, to help address societal challenges and to develop innovative services and products.
EUROCHAMBRES, the Association of European Chambers of Commerce and Industry representing over 20 million enterprises in Europe, acknowledges the potential of using open data to innovate and welcomes the New Open Data Directive. For the implementing act on a list of High-Value Datasets we suggest that - The underlying data of High-Value Datasets must be of high quality.
The Union des Transports Publics et ferroviaires (UTP) represents urban public transport companies, railway companies and railway infrastructure managers in France. The issue of the access and reuse of the mobility data is fundamental for the transport sector. Public transport operators and public transport authorities in France have already opened much of the mobility data they hold, whether static or dynamic.
The European Alliance for Research Excellence, a coalition of companies and research organisations formed in 2017 committed to the future of innovation and R&D in Europe, warmly welcomes the opportunity to provide feedback on the European Commission’s roadmap on Open Data – availability of public datasets.
The PSI Alliance is grateful for the opportunity to comment on the Implementing act on a list of High-Value Datasets. After taking part in the validation workshop at July the 28th we want to outline one key principle of the HVD definition: We welcome Article 14 of the directive 2019/1024 regarding HVDs, in particular that specific high-value datasets shall be: (a) available free of charge, subject to paragraphs 3, 4…
Austria has offered the online access to the Business Register (BR) since 1996. We are obliged by law to charge cost-covering fees. Due to the PSI directive 2013/377/EU, we license the data of the BR for reuse and charge a very small license fee in comparison to the fee, which is charged for the official and guaranteed single BR excerpt.
Feedback on the Inception Impact Assessment - Ares(2020)3977569 Section A of the Inception Impact Assessment defines the list of high value datasets (HVD) focusing on themes where the public sector is best positioned to act as a data provider.
Dear Sir/Ms., The Norwegian Ministry of Local Government and Modernisation is using the opportunity ot give feedback to the public consultation on "open data - availability of public datasets". Our feedback is given in the attahced letter to the European Commission.
The German Transport Association (Verband Deutscher Verkehrsunternehmen, VDV), representing 600 members offering public passenger transport and rail freight, appreciates the possibility to provide feedback on the impact assessment of the Implementing Act on high-value datasets.
Public transport (PT) companies as well as public transport authorities (PTA), are dedicated to improving their passengers’ experience and are keen on voluntarily sharing certain data they generate. Operators and authorities are uniquely suited to know which data will improve the service rendered to passengers and already make the data they hold accessible and reusable.
Intel welcomes the opportunity to comment on the Commission’s plans towards establishing High Value Datasets (HDVs) in accordance with the Open Data Directive. Intel is one of the world’s largest chipmakers. Intel (through its subsidiary Mobileye) is also the leading supplier of software that enables Advanced Driver Assist Systems (ADAS), with more than 25 automaker partners.
The Compass Group appreciates the opportunity to provide feedback after participating in the HVD Definition workshops regarding "Companies and company ownership". During the interview as well as during the workshops it was discussed whether data collections and registers, which are publicly accessible according to EU-law, should be released as High Value Datasets.
The AGFW, the German association on district heating and cooling and CHP (Combined Heat and Power), endorses the fact, that Commission acknowledges the importance of data and access to data for modern economy. However, regarding the definition of high-value datasets and the announced implementing act, the characteristics of the district heating and cooling (DHC) sector must be taken into account.
Developing data economy boosts innovation that is crucial for Europe's future competitiveness and wellbeing. In order to support this development, Europe must make efforts to improve both the quality and quantity of freely available data.
Dear Sirs, Please find attached the comments from FEBIS, the Federation of Business Information Services on the importance of ensuring a large scope for High value Datasets on company and company ownership. to ensure that business transparency remains high in the Internal market and that the Open Data and PSI directive will contribute efficiently to the success of the strategy for data as well as the EU Common Data…
Insurance Europe welcomes the objective of this initiative to ensure that a common EU-wide layer of public sector datasets is easily and freely available for re-use, which can lead to significant benefits for society, the environment and the economy. Public institutions can provide invaluable sources of data due to their comprehensiveness and the quality of the datasets.
CEEP, the European Centre of Employers and Enterprises providing Public Services and Services of general interest (SGIs), welcomed the opportunity to submit its input concerning the definition of High-Value datasets (HVD) and in particular the concerns when publishing certain sensitive data (critical infrastructures, data affecting business models).
Arthur's Legal, Strategies & Systems strongly supports and endorses the initiative by the European Commission for the Implementation Act on a list of High-Value Datasets. Technology-driven applications have transformed society along with every other sector of our economy and data – in all its many forms and categories – is the main catalyst for this transformation.
Philips welcomes the opportunity to provide feedback on the roadmap for an implementing act on a list of high-value datasets in the context of the Open Data Directive. The development of many products and services depends on data availability.
Please find attached our submission on the consulation on the Impact Assessment for High Value Datasets. Our submission focuses on Companies and Company Ownership HVD. This is a critical dataset for business integrity, for innovation, for better competition, for the fight against corruption and financial crime, for SMEs and for ordinary citizens.
As a fully data-driven company, HERE strongly believes that universal access to public data is crucial to enable innovation and create value for businesses, citizens, and society as a whole. Only an economy with a comprehensive open data strategy is future-proof.
We would like to thank the European Commission for this opportunity to contribute to the reflection regarding the implementation of the Open Data Directive and in particular the definition of the High Value Datasets provided by article 13.
In previous consultations Wikimedia has communicated to the Commission what criteria datasets should contain to be considered High Value Datasets. Therefore, we are taking the liberty to simply share a list of public datasets with the Commission that we believe should be open. We encourage the Commission to take the necessary steps to achieve this and offer public and technical support.
The VKU welcomes the Commission’s efforts to promote the European Data economy. By developing digital innovations, public Companies already make a significant contribution to modern services of general interest in Germany, this ensures quality of life, stability and local attraction.
Filed in German · English published by the European Commission
The Women’s Eco-nomic & Social Think Tank (WESTT) welcomes the opportunity to input into the Commission Roadmap consultation on Open data – availability of public datasets. It is essential that if the EU is to deliver on President Ursula Von der Leyen’s commitment to equality then enhanced transparency is required, and the availability of free public data, especially of high-value data sets can support this goal as…
Some ambiguities still need to be addressed in the definition of high value datasets. It is not clear why the transfer should be free of charge in the case of high-quality data treasures. There are also costs in generating so-called high-quality data. It must therefore be possible to charge fees for the transfer to third parties.
Filed in German · English published by the European Commission
The Commission shall adopt implementing acts setting the so-called "high-value datasets" and carrying out an impact assessment (Article 14 Directive (EU) 2019/1024). In our view, it is not yet clear whether this will also affect public water management (water supply and sewage disposal) and even whether certain high-value datasets will have to be made available free of charge Article 14(1)(a) Directive (EU)…
The National Council of Commercial Court Registrars (CNGTC) thanks the European Commission for this initiative. Created by Law No 90-1259 of 31 December 1990 (codified in Article L.741-2 of the Commercial Code), the CNGTC with legal personality is responsible for ensuring the defence of the collective interests of the profession of registrar of a commercial court.
Filed in French · English published by the European Commission
GFII has provided written contributions and participated to the focus group discussions and validation workshop on “the impact assessment study on the list of HVDS to be made available by Member States under the PSI directive”, recently organised and carried out by Deloitte for the DG Connect. These contributions have been mainly dedicated to the “company & company ownership” HVDS category.
To succeed in the ongoing digital and green transitions, Europe needs a thriving data economy based on common values and strong markets to which public bodies and undertakings, including publicly controlled companies, contribute by unleashing their vast data assets for innovation and research.
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