Use Case "Doing Business in Another Member State" (DBA UC2)
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[Final]
Definition
The Use Case "Doing Business in Another Member State" of the Doing Business Abroad Pilot (DBA UC2) uses the Subscription and Notification Pattern.
This use case focusses at assessing the consequence for active eServices in case of a business event, e.g. company goes bankrupt, company stops it’s activities, company merges, etc. The data consumer may subscribe to notifications on selected business events. In case such an event occurs, the data provider notifies the data consumer. The data consumer needs to assess the relevance of the notification. It can then for example request the updated data from the data provider or decide it doesn’t need any additional data. Furthermore, the data consumer may intervene in an active eService (e.g. stop periodical grants or impose a tax obligation). The data consumer may also use the notifications as input to a general fraud prevention and protection procedure.
Major design decisions
[move to dedicated page for UC2 design decisions]
BRIS will not be used for subscription & notification. The notifications send resorting under BRIS regulation are out of scope of DE4A. The DE4A pattern has its own subscriptions and notifications that do no relate to BRIS regulation. Note that in some cases this could lead to the situation that a Data Evaluator receives both a BRIS and a DE4A notification for one business event.
Note the BRIS proposed change in the technical working group: Subscription will be replaced by a push notification through registering international branches in the registry of the mother company. Thereby reversing the responsibilities.
Data model
Message ‘Subscription request’
| Element | Description | M/O | Example value |
| Legal Person Identifier | Identification of the company following the eIDAS regulation: country code / country code / company identifier | O | RO/AT/90000471 |
| Requested action | Indicates whether a subscription or the cancellation of a subscription is requested by the sender: ‘subscribe’ or ‘unsubscribe’ | M | subscribe |
| Participant ID | The OOP TS participant identifier that identifies the organisation that is the subscriber (and thus will receive business event notifications) | O | SE000000013 |
| Business event type | The business event to subscribe to. If omitted, subscribe to all business events | O | |
| Legal person identifier | Identification of the company following the standard for EUID, <country code><business register code>.<company identifier>_<optional check character>. EUID is used for all companies registered in a European business register. | M | |
| Subscription period | The period for which the subscription is valid. If omitted subscription is valid until a unsubcribe request. | O | |
| TBD: event catalogue | The domain of events the subscription is | ||
| TBD: subscription period | The date of beginning and ending (optional) of the subscription |
Message ‘Subscription confirmation’
| Element | Description | Example value |
| Legal Person Identifier | ||
| Subscription timestamp | ||
| Subscription result | Subscription successful ; subscription cancellation successful | |
| Subscription request reference | ||
| Subscription reference | Local identifier of the subscription. Not needed but can be useful in exception flows |
Message ‘Subscription error’
| Element | Description | Example value |
| Legal Person Identifier | ||
| Request type | Subscribe / unsubscribe | |
| Error timestamp | ||
| Subscriber identification | ||
| Error message | Subscribe: company unknown, (participant not authorized)
Unsubscribe: company unknown, company not active, subscription unknown, subscription not active >move this text to subpage DBA |
|
| Subscription request reference |
Message ‘Business event notification’
| Element | Description | M/O | Example value |
| Legal Person Identifier | Identification of the company following the eIDAS regulation: country code / country code / company identifier | O | |
| Business event identification | The identification of the business event (list of value: OOP TS business event catalogue) | O | |
| Business event timestamp | Date and time of business event | M | 2021-05-01 15:01:27 |
| Subscription reference | Identification of the subscription as registered at DO (local id) which can be used in communication between DO and DE. Not essential but can be useful in exception flows | O | |
| Legal person identifier | Identification of the company following the standard for EUID, <country code><business register code>.<company identifier>_<optional check character>. EUID is used for all companies registered in a European business register. | M | SEBOLREG.5560802 |
| Second legal person identifier | Identification of a second company or a second EUID, used for example if the original EUID is changed | O | SEBOLREG.5594521 |
| Business event type | The business event that triggered the notification, see Event - evidence mapping table above. | M | National merger |
| Business sub event type | The subtype of the business event. | O | Initiated |
Business event - evidence mapping
| DE4A Business event | Event includes changes in | Related evidence type | Comment |
|---|---|---|---|
| Company info event | EUID, Updated company name/updated address/updated head quarters/changed identifier (EUID)/changed legal form/changed representatives | Company registration | Split this event in: address change, name change, ...? And with a status change, notify the specific status? |
| Annual report event | Annual reports | Annual report | What is the event? New annual report available, annual report changed, ...? Split this event? |
| Directors disqualification event | Disqualifications updated for directors | Directors disqualification | |
| National merger event | Merger initiated/completed/cancelled, transferring company identifier, aquring company identifier | Notifications are only relevant when the transferring company has subscribers. | |
| Cross border merger event | Merger initiated/completed/cancelled, transferrring company identifier, aquaring company identifier | Notifications are relevant when the transferring company has subscribers.
This event is also relevant without a subscription. The business register of a company involved in a merger wants notifications even if there is no prior subscription to the foreign company in the cross border merger. |
Legal Consideration
[Starting from exciting national and union law: Looking at this specific use case of DBA, we should have an analysis of applicable law to uncover what is and what is not possible today, given the specific combination of MS that are participating in the exchange. Cooperation between the pilot DBA and legal experts in the DE4A program. If we are able to get to a preliminary analysis in the next two to three weeks we might include it in the DBA chapter of D2.5. Otherwise it could become a working paper in context of the solution architecture for the new DBA pattern.]