Rationalisation of reporting requirements

In response to the European Commissions Public Consultation on rationalisation of reporting requirements, MedTech Europe highlights reporting requirements which could be minimised, simplified and/or digitalised in medtech sector whilst maintaining a high level of protection of health, transparency, and traceability to the benefit of patients and users.

SPECTARIS welcomes the opportunity to provide input on the Commissions call for feedback regarding administrative burden and reporting obligations. We are in full support of the associated goals to rationalize inefficiencies and reduce the overall administrative burden.

When we take the example of sustainability reporting, businesses have to dedicate more time and resources to comply with the Corporate Sustainability Reporting Directive (CSRD) requirements. The sustainability reporting of the CSRD requires external auditing which in turn, It is paramount that legislation is made easily applicable not only for the benefit of businesses which should not have to duplicate their…

IOGP Europe supports the European Commissions overall goal of regulating the transition through a structured and detailed EU reporting framework and is incessantly working to comply with all the requirements and obligations arising from it.

DHL Group supports the Commission's effort to simplify reporting for EU businesses without compromising policy goals. The proposed Union Customs Code reforms aim for substantial cost savings, but the specifics in the implementing legislation are critical. DHL urges consistent, meaningful reporting and streamlining of EU legislation, including Sustainable Finance, suggesting a 25% reduction in reporting requirements.

Caisse des Dépôts Group supports the ambition of the European Commission to rationalise and simplify the reporting requirements imposed on companies and administrations, and the overall objective of reducing the administrative burden linked to these obligations by 25%. Please find attached, Caisse des Dépôts Group input.

The National Centre for the Balance and Management of Emissions (NCE) in Poland welcomes the European Commission’s initiative to carry out this consultation and therefore proposes to simplify the reporting obligation under Article 21 of Directive 2003/87/EC of the European Parliament and of the Council of 13 October 2003 establishing a scheme for greenhouse gas emission allowance trading within the Community and…

Filed in Polish · English published by the European Commission

The Commission’s package of measures has good starting points. Fortunately, the Commission responds to long-awaited discharges on A1 certification and the posting of staff, as well as discharges on European business statistics, the Union Customs Code and the Accounting Directive. It is also good that the application of the European Sustainability Reporting Standards is delayed.

Filed in German · English published by the European Commission

CEN and CENELEC welcome the European Commissions decision to rationalize reporting requirements on European businesses to alleviate administrative burdens and to reinforce the global competitiveness of European industry. As two of the three European Standardization Organizations, CEN and CENELEC have a long history of developing standards supporting the Single Market and boosting European economic competitiveness.

The Confederation of Netherlands' Industry and Employers VNO-NCW and Royal Dutch Association MKB-Nederland are the largest entrepreneurs organisation in the Netherlands. Over 160 (branch) associations are members of VNO-NCW, representing more than 185.000 enterprises.

Managed Funds Association (MFA) welcomes the European Commissions initiative to identify reporting requirements in EU legislation that can be removed or rationalised without undermining policy objectives. MFA, based in Washington, DC, New York, Brussels, and London, represents the global alternative asset management industry.

The EEA welcomes the European Commission's initiative to reduce red tape across industries. This exercise provides an opportunity to address the redundancies and complexities related to the Regulation (EU) 2018/644 on cross-border parcel delivery services (the Regulation), which the EEA has brought to the Commissions attention before.

BusinessEurope highly appreciates the Commissions efforts to follow up on the reduction of reporting requirements by 25% with a publication of respective measures in the Commission Annual Work Program 2024. We also welcome the Commissions confirmation to expand this work by launching this call for evidence.

Cassa Depositi e Prestiti (CDP) is the Italian National Promotional Institution and one of the largest Italian financial institutions, with total assets above 400bn. CDP (together with the EIB Group and other European NPBIs and IFIs) is one of the 13 Implementing Partners (IP) of the InvestEU Programme and, as such, it has direct access to an EU guarantee to support national and local investments in line with key EU…

Gas Infrastructure Europe welcomes the initiative of the European Commission, which aims to identify reporting requirements in EU legislation that can be removed or rationalised without undermining the policy objectives of the European Union. GIE, as the voice of the gas infrastructure operators of Europe, would like to emphasise the importance of rationalising such burdens.

We would like to thank you for the opportunity to comment on the EU consultation on streamlining reporting obligations. The Commission’s package of measures has good starting points. Fortunately, the Commission responds to long-awaited discharges on A1 certification and the posting of staff, as well as discharges on the European Business Statistics, the Union Customs Code and the Accounting Directive.

Filed in German · English published by the European Commission

Allwyn is a leading multi-national lottery operator with significant scale. We operate lotteries in a number of countries in Europe and North America, including Austria, Czech Republic, Greece and Cyprus, Italy, UK and the United States (Illinois). We primarily focus on lotteries, including draw-based and instant-win lottery games, and distribute our products through both physical retail and online channels.

The Federal Medical Association represents the totality of the approximately 557,000 doctors in Germany organised in the 17 regional medical associations (LÄK). We would like to thank you for the opportunity to comment. 1. European Health Data Space The reduction of administrative burden by abolishing existing EU rules must not be undermined by the creation of new obligations.

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Finland Chamber of Commerce welcomes the opportunity to provide feedback on administrative burden and rationalisation of reporting requirements. We strongly support the stated objective to reduce reporting burden by 25% as well as the proposals to raise the thresholds for determining the size of companies and to postpone the application of sector-specific sustainability reporting standards.

The BDE Bundesverband der Deutschen Entsorgungs-, Wasser- und Kreislaufwirtschaft e. V. (Federation of the German Waste, Water and Circular Economy Management Industry) has composed a statement on the call for feedback on the rationalization of reporting burden, which can be found attached.

The European Data Centre Association (EUDCA) welcomes the proposal to reduce reporting requirements significantly. Promoting the "only once" principle is core for European data centre operators. EUDCA members comply with a multitude of reporting requirements, which have a two-fold burden: (1) Operators need to collect and verify the data through independent audits and assurances.

The EU air quality reporting and publishing obligations should be analysed and reduced. New are there are general air quality reporting and publishing provisions in the directives 2004/107/EC and 2008/50/EC. They are supplemented by the Decision 2011/850/EU strictly regarding air quality data reporting (+ Commission guidance document + user guides for air quality data flows).

Filed in Polish · English published by the European Commission

The Commission’s package of measures has good starting points. Fortunately, the Commission responds to long-awaited discharges on A1 certification and the posting of staff, as well as discharges on European business statistics, the Union Customs Code and the Accounting Directive. It is also good that the application of the European Sustainability Reporting Standards is delayed.

Filed in German · English published by the European Commission

Chemical Industry Federation Finland thanks for the opportunity to give feedback on reporting reduction initiative. This is a very welcome and important project from the Commission which successfully implemented will save the Scarce resources in the companies but also in the authorities.

Filed in Finnish · English published by the European Commission

C. Overall assessment of the Commission’s package of measures has good starting points. Fortunately, the Commission responds to long-awaited discharges on A1 certification and the posting of staff, as well as discharges on European business statistics, the Union Customs Code and the Accounting Directive. It is also good that the application of the European Sustainability Reporting Standards is delayed.

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The European Copper Institute (ECI) welcomes the European Commissions (EC) initiative to rationalize reporting requirements across EU legislation. In the context of the Corporate Sustainability Reporting Directive (CSRD) and the upcoming European Sustainability Reporting Standards (ESRS), a much wider spectrum of companies is required to report on more and in a more granular manner Environmental, Social, and…

PensioPlus welcomes the European Commissions initiative to ease burdensome reporting requirements. Administrative burden is identified by Belgian IORPs as greatest threat to their survival. In the past years, the regulatory burden on IORPs has increased significantly due to the 2016 review of the IORP Directive, the introduction of additional EIOPA reporting requirements and applicable horizontal legislation such as…

As a regional chamber of commerce, we consider the Commission’s consultation on “Administrative burdens – streamlining reporting requirements” to be very important in order to relieve companies of obligations that are not their core business, especially in view of the fact that many national rules are based on EU standards.

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ICE welcomes the opportunity - as part of the EU initiative rationalization of reporting requirements - to provide concrete suggestions for rationalisation, modernisation or optimisation, or other possible efficiency gains. Please find our input attached.

EU consultation on administrative burden streamlining of reporting requirements overall assessment The Commission’s package of measures has good starting points. Fortunately, the Commission responds to long-awaited discharges on A1 certification and the posting of staff, as well as discharges on the European Business Statistics, the Union Customs Code and the Accounting Directive.

Filed in German · English published by the European Commission

IPC fully supports the European Commissions initiative to reduce reporting burdens for companies in Europe. We encourage the European Commission to continue this important initiative and trust that an intended 25% reduction in burden marks the beginning of a long term, necessary rationalization process.

We Mean Business Coalition works with 13,000+ companies, and we are great supporters of the EU Taxonomy and the SFDR. But to maximize the support among the companies, we would like if the European Commission would carefully consider the purposes of the reporting. Who are the users? How are they to use the reporting?

MOL Group welcomes the call for evidence launched by the European Commission with the aim to rationalise the administrative burden of reporting obligations. We fully recognise the purpose of reporting obligations to monitor compliance with the requirements prescribed by EU, international and national legislations, and to ensure comparability and disclosure of data of public interest.

A. In September 2022, Commission President Ursula von der Leyen announced a relief package for small and medium-sized enterprises (SMEs). As an additional measure, the European Commission announced in mid-March 2023 the reduction of existing administrative and reporting requirements by 25 %. The European Commission’s package of measures has some good starting points.

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ONCE Social Group has followed and supported the development of corporate reporting and sustainable finance requirements, in particular with regards to the Corporate Sustainability Reporting Directive and the European Sustainability Reporting Standards.

The EPC is finalising a discussion paper on making the EUs regulatory environment fit for competitive businesses, including propositions for reducing reporting requirements. The piece will be published before Christmas. Please see below the abstract: Amidst an increasingly difficult economic situation, Europes decrease in competitiveness is arguably the most dangerous threat to the blocs long-term prosperity.

The IKEA brand and franchise system unite thousands of co-workers and hundreds of companies with different owners around the world. With divided responsibilities, companies operating under the IKEA brand and franchise system are responsible for the entire IKEA value chain with an end-to-end perspective from product development, sourcing to retail in more than 60 markets.

A. In September 2022, Commission President Ursula von der Leyen announced a relief package for small and medium-sized enterprises (SMEs). As an additional measure, the European Commission announced in mid-March 2023 the reduction of existing administrative and reporting requirements by 25 %. The European Commission’s package of measures has some good starting points.

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The European Banking Federation (EBF) welcomes the opportunity to put forward our comments on the European Commissions call for evidence on its initiative for the rationalisation of reporting requirements. The EBF is very supportive of all efforts for rationalizing and simplifying reporting requirements not only to improve the system but also helping to increase the competitiveness of EU businesses.

EFIC - the European Furniture Industries Confederation - welcomes the possibility to give feedback on the Commission's public consultation on administrative burden and rationalisation of reporting requirements. EFIC represents over 70% of the total turnover of the European Furniture Industries, a sector employing 1 million people in about 120.000 enterprises across the EU and generating a turnover of over 100…

We will provide some general comments and views as regards this project to cut red tape on reporting requirements. Comments given by the Confederation of Finnish Industries EK. It is welcomed that, as part of this project, the thresholds for micro and small-to-medium-sized enterprises (SMEs) are being raised, and sector-specific reporting standards (ESRS) for sustainability are being delayed.

GIEs Recommendations to rationalize reporting requirements, supported by Gas Networks Ireland Gas Networks Ireland and Gas Infrastructure Europe welcomes the initiative of the European Commission which aims to identify reporting requirements in EU legislation that can be removed or rationalised without undermining the policy objectives of the European Union.

Orgalim represents Europes technology industries, comprised of 770,000 innovative companies spanning the mechanical engineering, electrical engineering and electronics, ICT and metal technology branches. Together they represent the EUs largest manufacturing sector, generating annual turnover of 2,906 billion, manufacturing one third of all European exports and providing 11.19 million direct jobs.

Directors see transparency of reporting as an essential prerequisite to create trust between economic actors. They also accept the position that it is necessary to hold companies accountable for their possible societal or ecological externalities. In the degree that mandatory reporting increases this trust and accountability, some impositions of reporting requirements will be needed.

Family entrepreneurs expressly welcome the Commission’s approach to reducing red tape in the field of documentary requirements. In view of the new obligations created in the current parliamentary term and the reporting obligations that have already been initiated and are being implemented, the requirement for a 25 % reduction is undoubtedly too small.

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WWF European Policy Office would like to raise major concerns about the European Commissions agenda to rationalise reporting requirements, because of two major risks: 1. While the Commission specifies that this should be done without undermining the policy objectives, the WWF European Policy Office experience in the last three decades is that there is a frequent confusion sometimes on purpose between reducing…

The Council of European Municipalities and Regions (CEMR) welcomes the ongoing simplification efforts for EU regulations and the valuable stakeholder consultation process. Local and regional governments play a key role in promoting economic growth and in all sectors and support sustainable business practices.

The German retail sector suffers from sharply increased costs due to high energy and procurement prices on the one hand, and weak private consumption on the other hand. As a result of the tense economic situation, the HDE expects that around 9,000 shops in Germany will have to close their doors in 2023.

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The Association of Municipal Enterprises (VKU) strongly supports efforts at EU level to cut red tape in order not only to help the economy and society cope with current crises, but also to facilitate the efficient implementation of the upcoming transformation processes. The announcement of the review of the SME definition in the Communication from the European Commission on the SME Relief Package is central to this.

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Are these (reporting) requirements only originating from EU law? The reporting requirements are often originating from EU law and are specified and be made even more complicate on a national level. Are there specific areas (type of reporting requirements or policy areas) that are particularly problematic?

FuelsEurope represents 39 European Companies operating in the fuels & industrial value chains products manufacturing industry. The association represents such companies in the policy debate with EU Institutions and other stakeholders, providing an expert opinion on the production process, distribution and use of industrys products, contributing to a regulatory framework that: - Promotes EU excellence in technologies…

The Valencian Innovation Agency (AVI), as a public-law entity of the Generalitat, which aims to improve the Valencian production model by developing its innovative capacity, has been managing calls for competitive tendering grants for the strengthening and development of the Valencian Innovation System to improve the production model, and we have acted as the ERDF fund management centre within the European Regional…

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Grupa Azoty S.A. welcomes the European Commission's initiative to reduce reporting obligations. Despite representing a group of large entrepreneurs, we are of the opinion that the reporting burdens, in particular in the field of economy, finance and digital policy, on both SME and large entrepreneurs are significant, and it depends on public and private entities to what extent they will be reduced.

ANIET welcomes and congratulates the Commission on this Public Consultation. ANIET Associação Nacional da Indústria Extrativa e Transformadora (hereinafter ANIET), founded in 1975, holding NIPC 501 419 411 and headquartered at Rua Júlio Dinis 931.1 rd left-hand, 4050-327 in Porto, is the business and sectoral association, representing the three sub-sectors Ornamental Ricks, Industrial Ricks and Mines (metallic and…

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The Lower Saxony Ministry of Economic Affairs, Transport, Buildings and Digitalisation (MW) commissioned the Lower Saxony Clearinghouse to issue an opinion on the consultation of the European Commission on reporting obligations in EU legislation, which we enclose.

Filed in German · English published by the European Commission

Insurance Europe welcomes the European Commissions initiative to identify reporting requirements in EU legislation that can be removed or rationalised without undermining policy objectives. The insurance industry applauds the EC for its commitment to rationalise and simplify reporting requirements for companies and administrations and for its objective of reducing such burdens by 25%, in line with the strategy to…

In accordance with paragraph 1 Article 42 of Regulation (EU) 2021/1060 of the European Parliament and of the Council of 24 June 2021 the Member State or managing authority shall electronically transmit to the Commission aggregated data for each programme by 31 January, 30 April, 31 July, 30 September and 30 November each year, with the exception of the data required in paragraph 1.

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The Bavarian Crafts Day would like to thank you for being able to provide feedback on the initiative to rationalise reporting obligations. In the attached opinion, the Bavarian Crafts Day lists concrete examples of cutting red tape at European level. The examples given are not exhaustive.

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PensionsEurope welcomes this EC call for evidence initiative that aims to identify reporting requirements in EU legislation that can be removed or rationalized without undermining the policy objectives of the EU. Pension funds are important due to their social role.

European Commission Recommendation (EU) 2022/758 on protecting journalists and human rights defenders engaging in public participation from manifestly unfounded or abusive court proceedings (‘Strategic lawsuits against public participation’) adopted on 27 April 2022 (‘the Recommendation’), states in paragraph 29 that Member States should entrust one or more authorities with the collection and aggregation of data on…

Filed in Lithuanian · English published by the European Commission

The Open Allies Foundation presents its position on the reporting obligations of the telecommunications industry in Poland. The plurality of responsibilities, as well as frequent changes in regulation in this area, lead to difficulties in their proper implementation and the considerable amount of time spent on implementing new procedures in organisations.

Filed in Polish · English published by the European Commission

The Bundesverband der deutschen Industrie e.V. (BDI) participates in this consultation with a list of proposals for reporting obligations in EU law that should be simplified or removed (paper attached). This list is a joint compilation of the four umbrella associations of German industry: BDI, BDA, ZDH and DIHK.

Filed in German · English published by the European Commission

First of all, we would like to thank you for the initiative of rationalising the reporting requirements. We have to admit its been a challenge lately to cope with administrative burden added to the governments and companies. Every time, such a sizable regulation is applied, companies have to hire new people just to comply. There are only 4 people working in Estonian companies in average.

PwC International Ltd (PwC), on behalf of the PwC network, is pleased to provide feedback on the rationalisation of reporting requirements. We provide suggestions in the following focus areas: Consistency and alignment across reporting requirements, reporting requirements that would benefit from further clarity and an ongoing assessment of existing policies. Please see attached our detailed response letter.

The French Banking Federation (FBF) is very supportive of all initiatives for rationalising and simplifying reporting requirements not only to improve the system but also helping to increase the competitiveness of EU businesses.

The VDMA represents 3.600 German and European mechanical and plant engineering companies. The industry stands for innovation, export-orientation and medium-sized companies. The VDMA believes that the EU Internal Market is one of the biggest achievements of the EU. Especially in the small and medium-sized mechanical and plant engineering sector, the close integration within the EU is evident.

The Lithuanian Business Confederation, one of the largest organisations uniting businesses in Lithuania, submits observations from its members on actions/reports that increase administrative burden and/or costs. 1.

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The reporting requirements for businesses have significantly increased, especially in the realms of environment, sustainability, climate, energy, and finance policies. For instance, sector-specific European sustainability reporting standards stemming from the Corporate Sustainability Reporting Directive and mentioned in the Commission's work programme for 2024, reporting related to climate and environmental taxonomy…

BEUC welcomes the opportunity to comment on this initiative, particularly because requirements to provide information from businesses to consumers are included. We underline the importance of the Commissions clarification that certification, labelling, permitting, and similar processes are excluded.

The Test & Measurement Coalition was created in 2005 and represents an ad-hoc group of companies active in producing test & measurement industrial type products (Category 9). The Coalition members are leading companies in the sector including Agilent Technologies, Fluke Corporation, Keithley Instruments, Keysight Technologies, National Instruments, Thermo Fisher Scientific and Tektronix.

JBCE welcomes the opportunity to contribute to this initiative aimed at reducing administrative burdens by 25% in the face of ever-increasing regulatory compliance. We would like to endorse the European Commissions idea of streamlining, digitizing, and optimizing reporting requirements for companies through this call for evidence.While reporting information which are vital to achieve policy objectives such as…

The Federation of the European Sporting Goods Industry (FESI) welcomes the ambition of the Commission to put forward concrete proposals to rationalise reporting requirements and reduce them by 25%. We acknowledge that reporting requirements are necessary to ensure proper implementation and evaluation of EU legislation.

Please find enclosed the Board of Swedish Industry and Commerce for Better Regulations (NNR), contribution to the Commissions call for evidence on rationalization of reporting requirements. The attached document is based on input provided mainly by four of the NNRs members; the Confederation of Swedish Enterprise, the Association of Swedish Engineering Industries, the Swedish Bankers Association and the Swedish…

EuroCommerce represents the retail and wholesale sector throughout the EU. Retail and wholesale plays an essential role in the lives of everyone and the European economy. Over a billion times a day, it provides an essential service and serves as the link between manufacturers and 450 million consumers across Europe. It is a dynamic, highly competitive and customer-focused sector.

CERMI welcomes the opportunity to provide feedback on the Commissions consultation on rationalization of the reporting requirements of EU legislation. CERMI have followed and supported the development of corporate reporting and sustainable finance requirements, in particular with regards to the Corporate Sustainability Reporting Directive and the European Sustainability Reporting Standards.

The IKEA brand and franchise system unite thousands of co-workers and hundreds of companies with different owners around the world. With divided responsibilities, companies operating under the IKEA brand and franchise system are responsible for the entire IKEA value chain with an end-to-end perspective from product development, sourcing to retail in more than 60 markets.

As a large European listed company, in compliance to the relevant European and national regulation laws regarding Sustainability issues (and more recently also EU Taxonomy topics), we have been reporting for over two decades and are quite aware of the complex time-consuming processes and associated costs that are linked to these requirements, and therefore certainly appreciate the Commissions objective of…

PAUL HARTMANN AG welcomed the initiative and proposed the following in order to streamline reporting requirements. 1. Medical device legislation in Europe: In addition to the MDR, numerous other legal requirements need to be identified, assessed and monitored.

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Hungarian Gas Storage Ltd. welcomes the initiative to provide feedback on the current administrative burdens and the aim to identify reporting requirements in EU legislation that can be removed or rationalised without undermining the policy objectives. The company's main request and suggestion is to have the regular manual data subission services to authorities terminated.

As part of the ongoing analysis of the problems encountered by cooperative banks in Poland in their activities, the attention of the National Union of Cooperative Banks has drawn numerous signals about excessive reporting requirements imposed on banks.

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The Danish Agriculture and Food Council welcoming the Commissions initiative to rationalise and simplify reporting requirements for companies and administrations. Thus, we are concerned that reporting requirements will hypothetically risk the competitiveness of EU businesses on a global market.

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—In general, how much time and resources are devoted to meeting reporting requirements? Please indicate, as far as possible, the number of hours per month/year or the number of employees, expressed in full-time equivalents, needed to fulfil the reporting requirements.

Filed in Slovenian · English published by the European Commission

The farmer must issue the same data repeatedly. It would be much more reasonable if the EU collected data from agencies to which the farmer has already provided data. Many data are available from the statistical office, the tax office, the organization that performs inspections. At the EU level, it should be made clear which agencies collect which data and in the future directly ask them for input.

AnimalhealthEurope is the association representing manufacturers of animal medicines, vaccines and other animal health products in Europe. It represents both corporate members and national animal health associations.

The Federal Chamber of Tax Consultants is grateful for the opportunity to comment on the initiative to rationalise reporting obligations of 17 October 2023, which aims to reduce reporting obligations for businesses and administrations based on EU law. In its subsequent comments, the Federal Chamber of Tax Consultants makes specific proposals to reduce reporting obligations and avoid double reporting.

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From the point of view of the Lithuanian Transport Safety Administration, reporting to the European Commission, its agencies and other competent authorities could be streamlined and simplified by establishing a common framework for their submission.

Filed in Lithuanian · English published by the European Commission

The Spanish Chamber of Commerce highly appreciates all those programmes and policies aimed at reducing administrative burdens and simplifying administrative procedures, thus creating an environment conducive to the development of business activity and increasing the competitiveness of businesses.

Filed in Spanish · English published by the European Commission

We welcome the aim of the Commission to improve the competitiveness of EU businesses in global markets and support the Commissions initiative to rationalise reporting requirements. We welcome the request for feedback, ideas and input to identify further opportunities for streamlining reporting requirements in EU legislation without undermining the policy objectives.

The European Disability Forum (EDF) has followed and supported the development of corporate reporting and sustainable finance requirements, in particular with regards to the Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards. These are instruments that ensure that companies will report on the employment and inclusion of persons with disabilities in a mindful way.

Accountancy Europe welcomes the European Commissions (EC) efforts to make the EU Single Market more competitive and to rationalise regulatory requirements in order to make it easier for businesses to operate and thrive.

Small and medium-sized enterprises provide a basis for people’s prosperity, as well as for sustainability and for a social Europe, but does not have staff departments or directorates-general for overburdening administrative processes. The administrative burden has reached a level which is no longer reasonable for small and medium-sized enterprises.

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The NGO Support Centre Recommendations based on the association’s experience of 2 projects implemented under an agreement with the Commission 1) Respondents to report once a year, a shorter period (e.g. quarterly) would be too short.

Filed in Polish · English published by the European Commission

We would like to thank you for the opportunity to comment. The initiative Streamlining the European Commission’s reporting obligations aims to identify reporting obligations in EU legislation that can be abolished or streamlined without jeopardising policy objectives.

Filed in German · English published by the European Commission

The German Insurance Association welcomes the European Commissions initiative to reduce the burden of reporting and fully supports the call for evidence on the rationalisation of reporting requirements. Please find our detailed proposals in the attached position paper.

The ZDH welcomes the SME relief package presented on 12 September 2023, as well as the previous proposals to achieve a 25 % reduction in reporting requirements, which were presented on 17 October together with the work programme for 2024. It is an important and long-awaited signal that the European Commission is focusing more on cutting red tape.

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ResMed thanks the European Commission for the opportunity to respond to its Call for Evidence on the rationalization of reporting requirements. As a company with a global footprint and with products sold in over 140 countries, we strongly support the commitment to roll back red tape and believe this to be crucial in enhancing EU competitiveness on the world stage.

Please find below an opinion on the basis of the experience of the Managing Authority of ERDF funds for the implementation of, inter alia, R & D infrastructure projects. I would like to ask you to re-evaluate the validity of the monitoring and withdrawal mechanism by the Member States for the duration of the economic usefulness of the infrastructure if support is granted on the basis of Article 26 of Regulation…

Filed in Polish · English published by the European Commission

DATEV welcomes this initiative. We observe with concern the increasing governmental interventions and the resulting mounting administrative burden on businesses. The increasing red tape significantly impacts entrepreneurship, the competitiveness, and the innovative capacity of the EU.

Taxonomy 2.8: Non-Life Business reports (s.18 and other) Previously, information was released regarding the materiality threshold for Non-life reports/templates. The impression was that the threshold would be adjusted so that Life companies with a not material percentage of non-life business would not have to report these. We do not consider that the change made is enough.

Preliminary remarks The German Banking Industry Committee (GBIC) welcomes the European Commissions goal of a 25 percent reduction in the burden on companies and administrative organizations resulting from reporting requirements.

Please find attached the reply of the European Federation of Accountants and Auditors for SMEs (EFAA for SMEs). EFAA for SMEs is the umbrella organisation for national accountants and auditors organisations whose individual members provide professional services primarily to SMEs. EFAA has 15 members throughout Europe representing almost 380,000 accountants and auditors.

Common output and result indicators as defined in Annex I to Regulation (EU) 2021/1057 of the European Parliament and of the Council of 24 June 2021 establishing the European Social Fund Plus (ESF+) and repealing Regulation (EU) No 1296/2013 should be differentiated by thematic area in order to better demonstrate the effects of interventions and to strengthen the role of common indicators in the programming and…

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The Dutch Federation of Pension Funds welcomes the European Commissions initiative to rationalize reporting requirements. We support the alignment of reporting requirements and underline the importance of data quality.

AEIP welcomes the Commissions initiative to ease burdensome reporting requirements. In the past years, the regulatory burden on Institutions for Occupational Retirement Provision (IORPs) has increased significantly due to the 2016 review of the IORP Directive and applicable horizontal legislation such as sustainable finance legislation and Digital Operational Resilience Act (DORA).

We see two major challenges for RAG Energy Storage regarding reporting obligations: Contract reporting: Firstly, we are confronted with a golden plating of EU requirements, e.g., disclosing every single storage contract, which isnt the case in other member states. On top we will be obliged to report details on the contract initiation in the near future.

A considerable number of cases where it is necessary to assess the administrative burden or submit other types of reports during the preparation of legal acts arise in cases where the provisions of European Union legal acts are transposed into national law.

In view of the many new reporting requirements resulting from the transformation, streamlining is essential. The chemical and pharmaceutical industry’s proposals are set out in the Annex. The following should also be discussed in advance with stakeholders (e.g.

Filed in German · English published by the European Commission

The European Commission has invited information (see ARES(2023)7011321-16/10/2023) on <...> the most ineffective and burdensome reporting requirements for businesses and Member States. The European Commission has found that an initiative to cover national measures that implement EU rules in such a way that they go beyond legal requirements, or those national measures, make the relevant reporting requirements more…

Filed in Lithuanian · English published by the European Commission

We are a French company specialising in the manufacture and sale of stripping people. We are present at the international level, with 5 production plants (3 in Europe), 21 distribution subsidiaries (8 in Europe), and 1 900 collaborators. We have been on the stock exchange since 1998.

Filed in French · English published by the European Commission

The most obvious example of legislation that duplicates existing measures is the Proportionality Test Directive (PTD), given that - Article 59.3, Professional Qualifications Directive (PQD) contains requirements relating to transparency; restrictions on access to professions are required to be (a) non-discriminatory, (b) justified by overriding reasons of general interest, (c) proportionate - suitable for attaining…

As a market infrastructure provider, Deutsche Börse Group (DBG) is subject to several EU reporting frameworks and non-EU regimes. Against this background, DBG welcomes the European Commissions commitment to streamline the reporting landscape to reduce the reporting burden and make reporting more efficient.

The Foundation for Family Business and Policy thanked for the opportunity to comment. Bureaucracy is an important location factor. From the point of view of family businesses, the Commission’s first proposals to rationalise reporting obligations for businesses and Member States are therefore a correct signal.

Filed in German · English published by the European Commission

CEPE would like to identify two key areas where administrative burden could be reduced without affecting the legislative objectives. 1) Poison center notification under CLP (Regulation 1272 2008): the level of details required is going beyond what is strictly necessary for medical treatment in case of poisoning incident (mostly symptomatic treatment).

The BPI is grateful for the Commission’s initiative to streamline reporting requirements with a view to reducing red tape. We would like to address below the reporting obligations arising from the so-called Variation Regulation (Regulation (EU) No 1234/2008 on the examination of variations to the marketing authorisation of medicinal products for human and veterinary use) and the related Classification Guideline, the…

Filed in German · English published by the European Commission

In her State of the Union address on 13 September 2023, European Commission President Ursula von der Leyen placed a key position on strengthening European competitiveness and presented a so-called “relief package” for small and medium-sized enterprises. We very much welcome this and consider the measures mentioned therein and their implementation to be a priority in European economic policy.

Filed in German · English published by the European Commission

Dear all. As SME we are involved in the EU projects since FP7 programme and we are familiar with many different programme rules. We can confirm that the overall reporting processes are quite good when we talk on the EU level reporting (directly to the portal). The huge problem is reporting for projects on the national level.

The Office shall, within its competence, submit the reports provided for in the implementation of the provisions of EU directives laid down in national law. The assessment of the administrative burden of reporting was not carried out as it is not appropriate because it does not add value.

Filed in Lithuanian · English published by the European Commission

Small and medium-sized enterprises (SMEs) are a priority for the district of Anhalt-Bitterfeld. They are the backbone of our domestic economy and have helped our district of Anhalt-Bitterfeld to develop positively. Thus, they bring together ideas and activities that contribute to the attractiveness of living on the ground.

Filed in German · English published by the European Commission

The Commissions effort to reduce the reporting burden on companies should further facilitate undertakings to properly prepare and provide quality reporting. Minimising the undue reporting burden will not only reduce costs for companies, but will also ensure that only the information which is useful to investors is reported on.

The Finnish Commerce Federation welcomes the opportunity to provide feedback on the rationalisation of reporting requirements. Our proposals for some general principles to take into account in the rationalisation process as well as detailed examples on overly burdensome, redundant and/or ineffective reporting obligations are outlined in the attached paper.

The Regulation on European business statistics – (EU) 2019/2152: More direct cooperation between the tax offices in the Member States and the respective national statistical office is desirable in order to avoid double reporting for businesses. In Austria intra-Community supplies in EU countries must be reported to the tax office via the recapitulative statement (ZM) and, in addition, for statistics, e.g.

Filed in German · English published by the European Commission

We strongly support the European Commission's initiative on the rationalisation of reporting requirements, also removing redundant or duplicating obligations. We acknowledge the importance to strike the right balance between the burdens and costs borne by companies and benefits of customers, investors, communities and stakeholders in general.

With the European Green Deal, the EU has set itself ambitious energy and climate targets. The energy sector is at the heart of efforts to decarbonise the European economy. The expansion of renewable energies, the roll-out of a hydrogen economy and the development of the corresponding infrastructure will gradually reduce own emissions and lay the groundwork for the decarbonisation of other sectors.

Filed in German · English published by the European Commission

Response of the Global Legal Entity Identifier Foundation (GLEIF) to the European Commissions Public Consultation on the Rationalisation of Reporting Requirements to reduce the reporting and administrative burden placed upon businesses due to EU legislation. Submitted by: [name removed], CEO GLEIF [email removed] Please refer to the attachment for the detailed response.

As of 2024, more and more companies will report according to the European Sustainability Reporting Standards (ESRS) published in July. Unfortunately, the lengthy drafting and consultation process over the past few years has not led to the hoped-for practical consolidation. This is not altered by the involvement of many companies of all sizes and other stakeholders.

Filed in German · English published by the European Commission

Proposals by the Bavarian Chamber of Physicians (BLÄK) for cutting red tape at EU level can be found in principle: Red tape has increased sharply in both the outpatient and inpatient sectors in recent years. In the meantime, an important part of the patient’s medical working time is lost due to administrative activities such as data collection and documentation.

Filed in German · English published by the European Commission

We see the possibility of reducing administrative burdens in three of our public administrations: 1. Type approval authority (accreditation) – > Provide digitally v. templates for approval certificates; Development of e-COC... 2. Technical Inspection Service (TK) – > Reporting for the Monitoring Langs de Weg 3. Access to occupation – > Reporting obligations under Regulations 1071/2009, 1072/2009, 1073/2009.

Filed in Dutch · English published by the European Commission

AFNOR has already contributed to the Commission's consultation on ESRS reporting standards, and on the rationalisation of financial reporting standards, dealt with within Task Force 1 "Single Market, Key Performance Indicators and Industrial Ecosystems" of the European Union Industrial Forum.

In recent years, businesses and employers have seen their tax and employment obligations vis-à-vis the administration have increased considerably, mainly all those related to the employment area of the company. This makes it very difficult to manage a company and the tasks on which it should focus that it is basically on the production of its product or service, on growth and on generating employment.

Filed in Spanish · English published by the European Commission

The German Tax Consultants Association (DStV) supports the Commission’s approach outlined in the SME Relief Package to implement a reduction in bureaucratic burdens on businesses, in particular SMEs. For this reason, the DStV warmly welcomes the initiative to streamline reporting requirements and the sectoral proposals already launched to modernise and reduce reporting requirements.

Filed in German · English published by the European Commission

EU and National Authorities could facilitate firms reporting compliance by promoting data standardization, which cannot be accomplished without setting out clear definitions of data attributes. Guidelines on reporting and Q&As documentation seem to be one of the appropriate formats where Authorities could provide referred clarifications.

Simplification of Environmental Requirements: We propose the creation of a unified and digitalised system for environmental reporting. This would help save time and resources in environmental compliance, especially in areas such as waste management and species protection.

Filed in Spanish · English published by the European Commission

Reclaim Finance warns the EU Commission about the potential risks that any significant cut in EU reporting requirements related to climate and the environment could trigger. The NGO urges the Commission to ensure that: 1) No further cuts are made to the ESRS requirements: The Commission decided to weaken the CSRD framework by making reporting conditional to a materiality assessment and making specific data points…

Feedback to the Rationalization of Reporting Requirements in the European Union It's commendable that the Commission recognizes the challenges faced by SMEs, where burdensome reporting requirements can be a significant obstacle. A predictable regulatory environment and an efficient institutional framework indeed contribute to enhancing competitiveness, fostering fairness, and providing relief from crises.

Assessing the administrative burden, especially when EU regulation is implemented in national law, requires additional time and human resources. Member states are obliged to implement the provisions of EU directives in any way (the calculation of the administrative burden does not affect the decision, it is not possible to choose whether it is appropriate to transfer the provisions or not), so the administrative…

We are the research and education institute, related to European trade unions with a global objective to facilitate capacity building through information, training and research at European level, and improve the degree of involvement of workers representatives in European governance.

The Polish authorities regularly request data held by other offices from economic operators or ask for excess data to be provided. This practice is often not justified in Polish legislation. Moreover, often the obligations imposed by Polish law on businesses are broader than the minimum obligations set out in directives or other European legislation.

Filed in Polish · English published by the European Commission

FBN Belgium representing 113 Family Business with a diverse spectrum thanks you for giving us the opportunity to express ourselves on the critical issue of reducing the administrative burden on businesses. As active stakeholders in the Belgium family business landscape, our members feel daily the weight of excessive reporting obligations that has an impact on their ability to compete effectively within the market.

Hello We have been insurance brokers for 20 years and today we are doing our business only via our website: live insurance we have closed our physical insurance sales point since 2018. Our difficulty over years is the increase in rules and administrative burdens that are more difficult to manage administratively.

Filed in French · English published by the European Commission

I have always believed that an important handicap for organisations in general, and SMEs in particular, is excessive bureaucracy, the lack of smooth communication and of partners or advisers for organisations in need of information support, and above all, for the good and proper use of the resources made available to us by the European Union, as well as the lack of awareness of many companies and SMEs across Europe…

Filed in Spanish · English published by the European Commission

One of the biggest obstacles and barriers that owners of startups, small and medium-sized companies face is the lack of sufficient support from large companies or government agencies and investors to support them and finding a great difficulty in finding a partner, which in turn reflects the success of these small companies in order to achieve economic growth for them.