Interest representation vis-à-vis the EU institutions is a constructive and necessary input for effective decisions. German business therefore has a great interest in dialogue between the EU institutions and all stakeholders being organised in an open, transparent and regular manner. However, the Commission's proposal runs contrary to such a dialogue, since on decisive points it would merely lead to an increase in bureaucracy instead of transparency.
German business calls for an open, transparent and regular dialogue
The proposal provides that prior registration should be obligatory for all discussions between interest representatives and Members of the European Parliament, the current and future Council Presidency as well as Commission representatives from Director level upwards. Correct registration in the EU transparency register entails a substantial bureaucratic effort. It therefore seems disproportionate to link a one-off dialogue with Members of the European Parliament to prior registration, in particular for small and medium-sized enterprises and small local associations.
In addition, if the current proposal becomes applicable, registered organisations would have to indicate the estimated number of persons involved in the activities covered by the register and to express this number in full-time equivalents: 10 percent , 25 percent , 50 percent , 75 percent or 100 percent . The problematic aspect of this is that an exact estimate of the number of persons who are occupied with EU interest representation at a level of 10 percent is not possible, in particular in large, globally active undertakings and even with a very substantial bureaucratic effort.
The Commission's proposal introduces new categories without defining them clearly. This lack of clarity obstructs the requirement that information in the register must be comparable, and hence weakens transparency. Among other things, non-profit organisations would have to submit the following documentation: their full budget for the last completed financial year, every individual contribution exceeding 10 percent of the full budget as well as the name of the contributor for amounts exceeding Euro 10,000. The task of business associations as specified in their statutes consists in safeguarding and promoting the common interests of their members. By contrast, the submission of individual members' contributions wrongly gives the impression that business associations represent the interests of large individual members. This puts at risk the perception of associations as representatives of common interests.
Create transparency and legal uncertainty and avoid unnecessary red tape
The new Commission proposal is far removed from creating more transparency. Interest representatives would be obliged to place ever more data in the public domain without ensuring that the EU institutions have relevant, clear and comparable information. This is conducive to incorrect interpretations and reporting which harms reputations, and punishes precisely those companies and business associations which have followed the rules properly.