DBA D4.7 Initial Running Phase Report
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[Work in progress]
Executive Summary
This document embodies the intermediate report on the DE4A Doing Business Abroad pilot, providing preliminary conclusions and lessons learned from piloting the cross-border exchange of information in the context of the Single Digital Gateway. It is the first of two reports on this matter, covering preparatory activities towards real-life piloting the use cases for Doing Business Abroad. Preparations include the analysis on several topics (like use of eIDAS, company representation and interaction patterns), deployment of DE4A common components, integration into Member State specific solutions, testing of integrations between Member States and common infrastructure components and involving companies to participate in the pilot.
The main achievements of the Doing Business Abroad pilot are the SDGR-related analyses and the international infrastructure supporting the SDGR-principles.
The conducted analyses of challenges the SDGR introduces, such as powers validation, evidence definition and usability of interaction patterns, are to be considered an important prerequisite for implementing the SDGR. The established international infrastructure confirms the conclusions and choices of these analyses, and facilitates cross-border authentication and authorization of company-representatives, as well as the cross-border exchange of evidence about companies. These infrastructure was developed and extensively tested in a systematic approach, resulting in a proven and secure operation that can be used for actual piloting the first cross-border use case: starting a business in another Member State. The established infrastructure proves a good basis for extension with functionality for the second use case: keeping the company data up to date with the data evaluator and processing of business events. Designs and architectures for the second use case have been completed and impact assessment on national infrastructures have been done as well, providing a good basis for development towards the second part of the pilot.
These results have been achieved despite many challenges, like prioritization and availability of resources due to the pandemic and the ongoing shaping of the SDGR Implementing Act. These, and other challenges posed risks for DE4A progress and timeline, and unfortunately required several partners to terminate their involvement in the DE4A programme. Five combinations of Data Owners and Data Evaluators have fully completed the development and test cycle and are ready to run real-life pilots. The remaining combinations between other Data Owners and Data Evaluators will be ready later in 2022.
Evaluation of all preparatory activities regarding the implementation of the infrastructure to support SDG-use cases for companies, have led to important (preliminary) conclusions and lessons learned. Arguably the most important conclusion would be that the DE4A components used to facilitate the pilot for the SDG-use cases, proved deployable and implementable without any major or unexpected difficulties. Several tests have confirmed that the solution works, and does what it is supposed to do: facilitate the cross-border request and exchange of evidence for business procedures mentioned in the SDG Annex II. Furthermore, a proper and widely available solution for authentication and company representation is found to be an important prerequisite for European implementation of the SDG. With this respect, eIDAS including legal person attributes is already in place today and has proven fit for most of the cases to pilot. Unfortunately, use of eIDAS in real life is limited to natural person authentication only. For implementing the annex II SDG-procedures for businesses, Member States should notify and accept company representation and legal person attributes as well in their production systems.
Doing Business Abroad partners all faced different (local) challenges when implementing the international solution. These challenges were both technical and organizational, and lead to different velocities per Member State when implementing the DE4A solutions. Using a general implementation approach where complexity is introduced very gradually seems paramount. By aiming for a very small and simple start and thereafter stepping towards increasingly complex milestones, partners can organize and focus their implementation-activities and confirm their results with other Member States before commencing a next plateau in the implementation. The approach also helped with the coordination and communication within Member States, as usually several authorities will be involved when implementing the SDG. Installing a project-team on Member State level to coordinate activities from different national authorities, would be advisable. Before starting actual implementation, this team should take several months to align resources and priorities within the Member State, and perform preliminary technical/organizational assessments on both the SDG- and the eIDAS-domain.
Additional conclusions and lessons learned are expected from running pilots for both use cases, having real companies and representatives involved.