EBSA welcomes the Commissions Single Market Strategy and especially the focus on the incomplete internal market for services.
Providers of business services, and services in general, are still, despite the good intensions in the Services Directive dating back to 2006, facing numerous obstacles when conducting business across borders in the internal market.
The concept of a Services Card is very interesting and could lead to potential benefits for business services providers in the EU. Realisation of this potential is according to EBSA linked to two key aspects; first a substantial reduction of red tape and administrative burdens and second the voluntary nature of a Services Card from the business side. The need to address regulatory barriers as well as insurance issues should also be explored further.
For the Services Card to significantly reduce the administrative burdens in connection with cross-border supply of services, EBSA believes that Member States should be obliged to work closer together. It would be beneficial for service providers if their home Member State would be the interlocutor for dealings with a potential host Member State. This would greatly alleviate the administrative burdens put on the business community, and allow public authorities to understand better the functioning of their own administrative procedures. In time, this could potentially lead to an overall reduction of transaction costs in the economy, benefitting the European economy at large.
Read EBSAs position paper on the Services Card here: ebsa-position-on-services-passport
EBSA do believe that the enforcement of the Service Directive and rules of the rules of the internal market should be improved. However, the Commission’s proposed Single Market Information Tool (SMIT) goes to far and is out of proportions. It can be difficult to procure the necessary information to address breaches of internal market rules, but the Commission already has access to a host of relevant information on breaches that is currently not being addressed, for instance through the SOLVIT network. Thus it seems disproportionate to require businesses (who have not breached the rules in questions) to deliver highly sensitive information under threat of massive penalties. These penalties apply not only for not replying to the Commissions requests but also for information that is inaccurate or may be deemed misleading.
Please read EBSAs potions paper on SMIT here: EBSA Position on SMIT