We fear that companies will not be in a position to comply with the Regulation as the reporting obligations currently stand. The Regulation imposes requirements which are unfamiliar to business and which necessitate the design of elaborate internal compliance mechanisms that do not currently exist.
We recommend to:
• Narrow the scope of reporting obligations - A narrower approach would make burdens on companies manageable. This would also ensure e Commission focuses its efforts on the most relevant contributions.
• Exempt the disclosure of classified information - Disclosure of classified contracts to the Commission could trigger prosecution and penalties from third-country governments. To ensure trust, we ask to exempt businesses from the need to provide classified information.
• Allow all relevant parties to supply information directly to the Commission - Businesses may be required to reveal sensitive business information only available to suppliers and subcontractors. To ensure accurate and secure information sharing, we ask the Commission to establish a direct channel for subcontractors, suppliers and in the context of mergers and acquisitions.
• Clarify key concepts - Businesses need further guidance on how the Commission intends to implement some key concepts and mechanisms. Clear definitions would allow businesses to self-assess the contributions.
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Signatories:
Adigital
AIM European Brands Association
American Chamber of Commerce to the European Union
Australian Business in Europe (Belgium)
British Chamber of Commerce | EU and Belgium
Computer & Communications Industry Association
European Australian Business Council
Europe India Chamber of Commerce
Invest Europe
Japan Business Council in Europe
Korea Business Association Europe
National Foreign Trade Council
SwissHoldings
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