Dear Justice and Consumers,

Under the right of access to documents in the EU treaties, as developed in Regulation 1049/2001, I am requesting documents which contain the following information:

- The list or dataset containing all company names and company details (especially the EUID) held in the Business Registers Interconnection System (BRIS). Concerning company details I am referring to the information held in the central register on the European Central Platform and as is shown after looking for a company on https://e-justice.europa.eu/489/EN/busin...
- If not all this information is held by an EU institution, I would like to request any dataset or file containing all company names and EU ID's. If the whole of the EU is not covered yet, any such dataset or file by country or covering the countries already present or held.

Preferably I would like to receive this data as a csv-file or a current spreadsheet- or database format.

Yours faithfully,

Hans Lammerant

JUST ACCES DOCUMENTS, Justice and Consumers

[1]FW: access to documents request - list of company names and EUID in
BRIS - Ares(2021)5349479  (Please use this link only if you are an Ares
user – Svp, utilisez ce lien exclusivement si vous êtes un(e) utilisateur
d’Ares)

Dear Sir,

Thank you for your request for access to documents.

Unfortunately, you have not indicated your postal address.
This is necessary  for registering and handling your request in line with
the procedural requirements.
Please send us your full postal address at your earliest convenience.
Pending your reply, we reserve the right to refuse the registration of
your request.
Alternatively, you may use directly the electronic form available on the
Europa website:
[2]http://ec.europa.eu/transparency/regdoc/....
Apologies for our delay in sending you this e-mail but due to a technical
problem your request ended into the spam mailbox

Best regards,

Access to Documents Team

show quoted sections

Dear JUST ACCES DOCUMENTS,

my postal address is:

[ADDRESS REDACTED]
[ADDRESS REDACTED]
Belgium

However, as I am requesting a dataset, I would like to receive the result in digital form. When it is too large to send directly, you can also send a download-link to [email address]

Yours sincerely,

Hans Lammerant

JUST ACCES DOCUMENTS, Justice and Consumers

[1]RE: FW: access to documents request - list of company names and EUID in
BRIS - Ares(2021)5349479 - Ares(2021)5375743  (Please use this link only
if you are an Ares user – Svp, utilisez ce lien exclusivement si vous êtes
un(e) utilisateur d’Ares)

Dear Sir,
Thank you for your e-mail of 30/08/2021.

We hereby acknowledge receipt of your application for access to documents,
which was registered on 31/08/2021 under reference number GESTDEM 2021/
5284

In accordance with Regulation (EC) No 1049/2001 regarding public access to
European Parliament, Council and Commission documents, your application
will be handled within 15 working days. The time-limit will expire on
21/09/2021 . In case this time-limit needs to be extended, you will be
informed in due course.

For information on how we process your personal data visit our page
[2]https://ec.europa.eu/info/principles-and...

Yours faithfully,

Access to Documents Team

show quoted sections

JUST A3, Justice and Consumers

1 Attachment

Dear Mr Lammerant,

Please find attached a signed letter from Ms Salla SAASTAMOINEN, Acting Director-General, Directorate-General Justice and Consumers, dated 20 September 2021.

Kind regards,
JUST A3 Secretariat

Dear Justice and Consumers,

Please pass this on to the person who reviews confirmatory applications.

I am filing the following confirmatory application with regards to my access to documents request 'list of company names and EUID in BRIS', registered under reference number GESTDEM 2021/5284, and request the Commission to review its position expressed in the response by Acting Director-General Salla Saastamoinen of the DG Justice and Consumers.

In my request I asked for:
"- The list or dataset containing all company names and company details (especially the EUID) held in the Business Registers Interconnection System (BRIS). Concerning company details I am referring to the information held in the central register on the European Central Platform and as is shown after looking for a company on https://e-justice.europa.eu/489/EN/busin...
- If not all this information is held by an EU institution, I would like to request any dataset or file containing all company names and EU ID's. If the whole of the EU is not covered yet, any such dataset or file by country or covering the countries already present or held.

Preferably I would like to receive this data as a csv-file or a current spreadsheet- or database format."

In her response the Acting Director-General states that the Commission does not hold such dataset. As reason she states: "This is because BRIS, in accordance with Directive 2012/17/EU 1 is an interconnection of business registers, composed of the registers of the connected Member States, the European Central Platform and the European e-Justice Portal and there is no centralised register held on the European Central Platform. The company data transmitted through BRIS and thus through the European Central Platform emanates directly from the national business registers. Recital 10 of Directive 2012/17/EU also clearly states this by specifying that BRIS does not establish a centralised register database storing substantive information about companies."

However, this position does not seem to be an accurate presentation of BRIS. While the BRIS system is indeed a system to interconnect business registers of the Member States, there is a limited Central 'Legal Entity Data' (LED) present on the European Central Platform managed by the Commission. This is what is shown in the publicly available technical documentation of the system, e.g. on page 2 of the description of the architecture approach at https://joinup.ec.europa.eu/sites/defaul... or page 3 at https://joinup.ec.europa.eu/sites/defaul.... In BR02.pdf the dataset is described as "Central 'Legal Entity Data' (LED); this data set contains – only for the Member States that are willing to participate – an indexed copy of the common free data of all registered companies. The central LED is only a copy of the common free data that the participating business registers send to the Platform for indexing purposes."
This is the dataset I am referring to in my application.

The BRIS system may not be aimed at establishing any centralised registers database, this does not prevent this particular dataset present on the BRIS system to be a useful dataset and of interest. This remains true even when it does not fulfil the full role of a centralised register with all the substantive information stored in the business registers themselves.

Further, the information contained in this dataset is listed among the high-value datasets referred to in Article 13(1) of the PSI-directive 2019/1024 in its Annex 1. Even when the active publication of these datasets according to this directive has not been finalized, I do not see any grounds for withhelding this information, as held in the specified dataset, from public access.

A full history of my request and all correspondence is available on the Internet at this address: https://www.asktheeu.org/en/request/list...

Yours faithfully,

Hans Lammerant