DBA main conclusions
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The DBA pilot has been completed successfully and yielded valuable insights.
Pilot partners managed to analyse the most important challenges for the implementation of the SDGR (like record matching, evidence-definition and powers validation), and developed an international infrastructure for cross-border exchange of company evidence by deploying and integrating DE4A common components to business registers and service providers. Also, a cross-border authentication and powers validation infrastructure for piloting was established, using eIDAS pilot nodes. This infrastructure was designed, implemented, extensively tested and thereafter used for real-life piloting with several companies, Data Owners and Data Evaluators.
Based on the executed eProcedures, interviews with all parties and representatives involved and on actual obsevations, using the OOP TS leads to many of the expected benefits the SDG regulations intends to create. Simpler eProcedures, shorter durations, immediate results, high quality of service and less effort for processing seem the most important benefits that were observed.
The piloted eProcedures have shown simplicity and speed, as well as lower cost for both companies and public authorities. The higher data quality results in less processing-errors for the Data Evaluator compared to the current way of executing procedures. A broad implementation is however a requirement to be cost-effective.
The need for receiving notifications about changes in business register entries was validated during analysis, design and interviews, regarding both changes in company data and company-concerned events. Analysis shows that this need cannot fully be fulfilled by BRIS, as for example not all public authorities have access to BRIS and BRIS does not cover all types of companies. Evaluating the Subscription and Notification pattern shows that benefits are present, but there seems to be a caviat. As the number of foreign companies in DE-systems is relatively low, the number of notifications will be low as well. Still, Data Evaluators would like to receive notifications so they can maintain a high quality of service delivery.
For Data Owners, integrating the OOP TS usally involves use of existing data services and an integration layer. Data Owners don’t encounter big chllenges, but also experience little benefits of the OOP TS.
Companies seem to focus on completing the online procedure as fast as possible and have little attention to read texts about – for example – the Explicit Request. Perhaps adding pop-ups and providing texts in the mother-tongue of the user increases awareness.
The used local infrastructure heavily determines the required effort for DE and DO integration. Member States therefore establish their own maximum velocity for implementing the necessary infrastructural, legal and procedural changes. Velocities differ between Member States because each Member State has a different starting point and therefore faces different challenges. Applying a general step-by-step strategy for implementing the SDG infrastructure, gradually increasing complexity, has proven to help with focus and management of the implementation.
The availability of an EU-wide operational eIDAS network and notified eIDs for representing companies (including powers validation) are prerequisites for implementing the SDG. As almost none of the Member States have notified eIDs for companies, temporary use of non-notified eIDAS were allowed for piloting the DBA procedures.
Full Powers validation os probaby sufficient for SME’s but large companies are expected to benefit from Fine Grained Powers validation and it makes sense to maintain this as a goal in the domain of validation the Powers of Representation. SEMPER specifications match the requirements for this goal. Starting with a simpler full-powers validation turns out to be a feasible and sensible first step. Arranging the appropriate mandate registration in the local Mandate management System proves to be challenging for representatives but is not part of the piloted process. Still, there is room for improvement in that domain.
Establishing a harmonized dataset that embodies the evidence to be exchanged cross- border turns out to be time-consuming. Having the evidence match the needs of Data Evaluators and making sure that this can be provided by Data Owners requires much analysis but is key in making the cross-border exchange of information valuable and durable. Focusing on a first limited, yet still valuable, set of data increases feasibility and secures progress.