Europaudvalget 2016-17
EUU Alm.del Bilag 220
Offentligt
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NOTE
December 2016
Danish response to the open consultation on the Single Digital Gate-
way
General remarks
The Danish government supports the ambition to make it easier for busi-
nesses and citizens to access information on the single market and make
use of the contact points available for assistance and problem solving.
The Danish government welcomes the intention to streamline and im-
prove existing efforts by establishing the Single Digital Gateway (SDG).
Architecture of the Single Digital Gateway
The Danish government supports the concept of the SDG as a single entry
point at European level. In order to ensure a consistent approach to archi-
tecture, navigation and concepts for content at all levels, it is important
that the Commission takes the primary ownership of the portal. This also
applies to technical issues and digital solutions which should be devel-
oped by the Commission and take into account considerations of interop-
erability at Member State level. The Commission is invited to carefully
consider to which extent principles like once only and reuse of data may
be integrated in functionalities of the SDG.
At the overall European level, the SDG should provide an independent
layer of information, e.g. an overview of areas with common EU rules. At
Member State level, the Commission should ensure a similar structure,
user interface and ways to present content for all countries. This is crucial
to ensure a certain quality consistency and comparability across Member
States. The Commission should develop structures and concepts in close
cooperation with Member States and by involving businesses and citi-
zens. In this respect, it is important to map existing channels and infor-
mation to avoid overlap and duplication of information leading to confu-
sion for users and to heavy demands for maintenance.
Content according to the reality of users
It is important to obtain clarity regarding which areas of information that
should be available to users. Today, existing information services and
contact points (e.g. the product contact point, the point of single contact
and Solvit) each have a defined scope. However, from a user’s perspec-
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tive, there appears to be a need for the SDG to cover a broader range of
areas. The reality of businesses and citizens is often defined by complex
situations with a need for information related to more contact points or to
areas not covered by the current contact points. For businesses operating
cross border in the service area, aspects like e.g. VAT, social security and
working environment are of much interest. In Denmark, this has been
tackled trough an expansion of the point of single contact that today pro-
vides this type of information going beyond the obligations of the Ser-
vices Directive.
A focus on concrete user behavior and “user journeys” has been crucial
for the development of the current Danish point of single contact. The
commission is invited to take a similar approach for the SDG. This could
lead to information based on the logic of “life events” or typical situations
which businesses often find useful, e.g. by using the methodological ap-
proach from the European eGovernment benchmark reports. Once online
available, traffic and digital behavior should be systematically monitored
in order to base future adjustments on actual demand.
The landscape of single market opportunities is continuously subject to
change and it is important that the SDG takes this into account to ensure
its relevance and ensure added value for businesses with innovation po-
tential. In this respect, the Danish government encourages the Commis-
sion to look into ways to cover regulation areas of growing importance,
e.g. e-commerce and collaborative economy. To the extent that a full
overview over these types of rules cannot be established at Member State
level, the Commission should collect current available data and present
this to users at the overall European level of the SDG.
Strong governance framework
Based on the experiences with existing instruments, it is desirable that the
proposal on the SDG includes a strong governance framework, setting out
clear obligations and modes of cooperation for both the Commission and
Member States. If introducing a governance framework for the SDG, it is
crucial to clarify its status and relation to existing governance provisions
laid down in e.g. the Services Directive, the PSC Charter, the Regulation
for Mutual Recognition and the Solvit recommendations. Another issue to
be addressed is the resource situation of Member States. It seems neces-
sary that the Commission allocates resources to Member States to ensure
that substantial improvements can be achieved through the SDG, both in
terms of information, assistance and network activities.
Obligations for the Commission
The Commission’s main ownership of the gateway, its structure and over-
all functioning should be laid down in the governance framework. Fur-
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thermore, the Commission should be given a facilitating, supporting and
monitoring role. Building on existing single market networks and expert
groups, the Commission should facilitate that such formations share best
practice and work towards common operational goals. Finally, the Com-
mission should monitor and evaluate performance and activities of the
SDG and ensure that problems and development encountered in practice
are taken up at a policy level.
Obligations for Member states
For Member States there should be a number of obligations related to the
quality of information, assistance and cooperation. All information should
be subject to regular updates and, as a minimum, be available in English.
Quality criteria for good case handling practice should be defined, e.g.
deadlines for answering queries, means of communication and practices
of signposting. In terms of cooperation, a governance framework should
define Member States’ contribution to cross border network and reporting
activities. While setting out clear obligations, it is very important that a
governance framework maintains the flexibility of Member States in
terms of organisation across government administrations.