Document 3a
Ref. Ares(2015)1582655 - 14/04/2015
Ref. Ares(2020)3259704 - 23/06/2020
09.04.2015
Implementation of the transparency rules: state of play
1.
STATISTICS ON MEETINGS RECORDING
1.1. Publication of information on meetings held between Commissioners and
organisations or self-employed individuals
2708 meetings in total have been encoded by Commissioners and Cabinets for the period
between 1 December 2014 and 15 March 2015.
The highest numbers of meetings have been held by Commissioner Cañete and his
cabinet (256); Vice-President Katainen and his cabinet (242); and Commissioner
Malmström and her cabinet (201).
For the full set of statistics, please see the annex.
1.2. Publication of information on meetings held between Directors-General
and organisations or self-employed individuals
319 meetings in total have been encoded by Directors-General for the period between 1
December 2014 and 15 March 2015.
The highest numbers of meetings have been held by the Directors-General for Energy
(45); Communications Networks, Content and Technology (40) and Mobility and
Transport (31).
For the full set of statistics, please see the annex.
2.
PLANNED IMPROVEMENTS TO THE MEETINGS IT TOOL
Responding to user requests and to experience gained since the launch of the internal IT
tool for the recording of meetings in December 2014, the Secretariat-General is working
on several technical improvements. The main forthcoming upgrades include the
following:
Modernised design and user-friendly "look and feel";
Introduction of an
Edit button allowing for the retroactive correction of encoded
information;
Possibility to search and select from the Transparency Register names of entities
met directly, and to see the status of "suspended" registrants.
The new version will be developed and tested during the month of April and is expected
to be rolled out in May.
Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111
3.
DEADLINE FOR UPDATING TRANSPARENCY REGISTER ENTRIES AND IMPACT ON
REGISTRANTS
The Transparency Register currently contains over 8,300 registrants. At the time of the
launch of the new version on 27 January 2015, all registrants were given 3 months (i. e.
until 28 April 2015) to update the entirety of their data by switching over to the new
registration form and filling in/validating all required fields. As of mid-March, the total
number of registrants that have updated their data is around 5230, i.e. approx. 65%.
Registrants that have not updated their data have received two email reminders (the latest
one was sent on 27 March 2015).
Registrants that do not perform the update by the deadline will automatically move to
"suspended status" as from 29 April 2015, i.e. they will become publicly invisible but
will still be able to access and edit their data. If within 14 calendar days they still do not
update their data, they will be automatically "disbarred", i.e. permanently erased from the
database. At this point they will have to submit a brand new registration in order to re-
join the system. Registrants receive an automatic notification when they are
suspended/disbarred.
Outside this three-month migration period, all registrants are in any case required to carry
out an annual update; failure to do so implies the application of the exact same measures
concerning suspension and disbarment.
Diagram of the annual update procedure:
Suspension/disbarment can also occur due to a self-withdrawal or a quality check carried
out by the Joint Transparency Register Secretariat (JTRS) revealing an irrelevant or
otherwise problematic entry, or in the context of the alerts and complaints procedure.
2
Most probably as of the end of April/beginning of May, the overall number of registrants
is expected to drop substantially, as a number of them will not have performed the
required update. This can be expected due to a variety of reasons: obsolescence, lack of
attention/interest, wrong contact details, etc.
Note that a meeting with a suspended or disbarred entity cannot be encoded via the
meetings IT tool as the registration is from that moment deemed "inactive." This means
that Commissioners/Cabinet members/Directors-General will have to cancel their
meetings if entities that are currently registered do not meet the deadline for updating. In
the next version of the tool planned for May it will be possible for users of the tool to see
registrants in "suspended status."
4.
AREAS FOR ADDITIONAL GUIDANCE
On the basis of experience gained and questions received, it seems that additional
guidance needs to be provided about the following issues:
Dealing with suspended registrants: the recommended good practice when
scheduling a meeting with an interest representative is to (1) check whether it the
latter is registered, and subsequently, especially for meetings scheduled a long
time in advance, (2) to confirm again a couple of days before a meeting that the
entity is still active in the Transparency Register. The reason is that if an entity is
in "suspended status" (see possible reasons above) it will no longer be publicly
visible in the Transparency Register and the meeting cannot be recorded via the
dedicated tool.
Coverage of the Decisions: certain Commission services (e.g. HR, OIB, OIL,
PMO) appear to have been unaware, until recently, that the new transparency
policies concern their Head of Service as well. Consequently, they have only
lately set up the respective Europa webpages enabling the Heads of Service to
publish information on meetings.
Definition of "international organisation"1
: there have been uncertainties as to
what is meant by "international organisations" to be excluded from the scope of
the two Decisions. It should be clarified that by "international organisation" it is
meant, an "international
intergovernmental organisation," i.e. one composed of
countries as members, such as the UN and its Agencies, WHO, Council of
Europe, etc. For this reason, the recital refers to "protecting the international
relations of the Union."
Extension of obligation to meet only registered entities: it
appears that certain
Directorates-General (e.g. AGRI and FISMA) have decided to extend the rule
"not in the Register, no meeting" to all staff. It should be noted that whilst such
unilateral measures may be taken by Directors-General, the formal rule concerns
only Commissioners, their staff and heads of departments.
Public scrutiny: transparency activists are scrutinising closely information on
meetings published by the Commission. Unwarranted criticisms about omissions
and inconsistencies should be avoided. It remains the individual responsibility of
each Cabinet and service to ensure that the required information is provided in a
timely and accurate manner.
1 Recital (8) of Decisions C(2014) 9048 and C(2014) 9051 of 25.11.2014
3
ANNEX
1. Meetings held by Directors-General
Note: Directors-General with 0 meetings not included
Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111
2. Meetings held by Commissioners and their Cabinet members
5
Document Outline