Use Case "Doing Business in Another Member State" (DBA UC2)

[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

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.]