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Bitkom e.V.

Bitkom

Bitkom is a German association representing over 2,200 companies in the digital economy.

Lobbying Activity

Response to Amendment lifting the limitation in the number of registrations for the Automated Parking Systems

22 Dec 2025

The current EU small series regime for fully automated and automated vehicles limits the number of approvals in a way that risks hampering innovation. Such restrictions can prevent economies of scale, undermine planning certainty for manufacturers and operators, and may delay the widespread deployment of automated driving technologies in Europe. Against this background, we strongly welcome the European Commissions initiative to lift the limitation in the number of registrations for Automated Valet Parking (AVP) systems and to amend Regulation (EU) 2022/1426 accordingly, including the introduction of specific technical requirements for AVP in a new Annex V. This is an important first step towards enabling large-scale type-approval of fully automated vehicles for series production in the EU. By lifting the small series limitation, the draft Implementing Regulation improves legal certainty for manufacturers and operators, facilitates investments in automated driving functions and related software architectures, and supports economies of scale in production and operation, thereby strengthening Europes international competitiveness in automated driving technologies. AVP, however, should only be treated as a first use case. It is essential that the regulatory framework be opened up to further Level 4 applications beyond parking. We therefore support the overall direction of the draft and the gradual opening of the market beyond small series, starting with the AVP use case.
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Bitkom calls for technology-neutral indicators in Digital Decade review

19 Dec 2025
Topic — The EU is reviewing its 2030 digital targets and monitoring framework for progress.
Message — Bitkom proposes refining digital targets to ensure they are measurable and technologically neutral. They suggest deleting specific infrastructure metrics in favor of broader connectivity indicators. The association also argues that meeting targets depends on policymakers first providing better energy frameworks.123
Why — This would lower regulatory pressure on companies by shifting accountability for missed targets to government policy.45
Impact — Rural households may lose out on fiber as operators pivot toward cheaper wireless alternatives.67
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Bitkom urges EU to avoid new audiovisual media legislation

19 Dec 2025
Topic — The European Commission is evaluating the effectiveness of the Audiovisual Media Services Directive.
Message — Bitkom opposes new EU-level legislation, favoring better enforcement and deregulation. They insist that the country-of-origin principle remains the cornerstone of the internal market.12
Why — Maintaining the status quo avoids higher operational costs and protects members' business models.3
Impact — Stricter content quotas would harm consumers by reducing variety and driving up prices.45
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Bitkom urges EU Quantum Act to focus on commercial scaling

12 Dec 2025
Topic — EU initiative to accelerate research and industrial deployment of quantum technologies.
Message — Bitkom calls for a unified roadmap and a dedicated body to manage quantum funding. They urge the EU to turn research into products through industrial scaling. The group seeks harmonized rules for technology protection to ensure predictability for businesses.1234
Why — Member companies would benefit from increased funding and easier access to global markets.5
Impact — Rivals from non-allied nations may face stricter screening and restricted access to technology.6
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Meeting with Tiemo Wölken (Member of the European Parliament)

10 Dec 2025 · General exchange on digital policy

Meeting with Despina Spanou (Deputy Director-General Communications Networks, Content and Technology)

13 Nov 2025 · European Business Wallets and Digital Omnibus

Meeting with Miguel Jose Garcia Jones (Cabinet of Commissioner Wopke Hoekstra), Olivia Gippner (Cabinet of Commissioner Wopke Hoekstra)

13 Nov 2025 · The intersection of digitalization and climate policy in the European Union, data centers, AI, and sustainability efforts.

Meeting with Kilian Gross (Head of Unit Communications Networks, Content and Technology)

12 Nov 2025 · Exchange of views on AI Act standardisation

Meeting with Estelle Goeger (Cabinet of Executive Vice-President Stéphane Séjourné)

12 Nov 2025 · Digital Industry issues

Meeting with Angelika Niebler (Member of the European Parliament)

6 Nov 2025 · Simplification

German digital industry urges 24-month delay for AI Act requirements

4 Nov 2025
Topic — EU strategy for deploying digitalisation and artificial intelligence in energy sector.
Message — Bitkom requests postponing the most demanding AI Act requirements by at least 24 months, citing unavailability of technical standards before end of 2026. They seek regulatory clarity through consistent European implementation and differentiation between B2B and B2C applications.12
Why — This would reduce compliance burdens and legal uncertainty for German tech companies developing AI systems.34
Impact — Consumer safety protections are weakened by delaying high-risk AI system safeguards for two years.5
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Response to Digital package – digital omnibus

14 Oct 2025

Bitkom highly welcomes the Commissions plan for a digital omnibus package which is offering a vital opportunity to streamline the current digital framework. Please see our position paper attached for our proposals.
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Response to Sequential recording of data into qualified electronic ledgers

2 Oct 2025

Bitkom highlights the need for greater precision and practicality in the draft Implementing Act on qualified electronic ledgers. Clear and consistent terminology, differentiated definitions, and the correction of technical inaccuracies are essental to avoid ambiguity. At the same time, requirements for supervision must remain workable in practice, particularly in situation where urgent security updates are needed. Overall, the framework should ensure legal clarity, technical accuracy, and operational feasibility for trust service providers.
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Bitkom Urges Recognition of Payment Certificates in EU Standards

2 Oct 2025
Topic — The EU is establishing technical specifications for qualified certificates used in website authentication.
Message — Bitkom calls for the explicit inclusion of payment sector certificates used outside browsers to ensure legal certainty. They recommend adopting ETSI standards to prevent payment certificates from being subject to restrictive browser validity rules. Additionally, trust service providers should not be forced into opaque browser root store programs.123
Why — Maintaining longer certificate lifespans avoids the cost and disruption of frequent technical renewals.45
Impact — Browser vendors would lose the power to exclude trust providers through non-transparent root store programs.6
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Response to Formats of advanced electronic signatures and seals to be recognised by public sector bodies

2 Oct 2025

Bitkom welcomes the current draft of the Implementing Act on advanced electronic signatures and seals. Our only recommendation at this stage is to address the specific technical point outlined in the attached document.
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Response to Qualified electronic archiving services

2 Oct 2025

Bitkom stresses that qualified electronic archiving must be clearly defined in line with eIDAS, with archiving and preservation treated as distinct but complementary services. Moreover, a future-proof framework should build on modern, widely accepted standards that support cross-border recognition and provide clarity for providers and users alike.
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Response to General requirements for qualified trust service providers

2 Oct 2025

Bitkom underlines the importance of keeping compliance and security requirements for qualified trust service providers proportionate and practical. Excessive or overly broad notification duties, redundant provisions, and unclear references risk creating legal uncertainty, administrative overload, and operational inefficiencies without adding supervisory value. Instead, notifications should focus only on substantive changes that genuinely impact compliance or security. Finally, any new obligations must be introduced with a reasonable transition period to allow providers to adapt effectively.
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Meeting with Sergey Lagodinsky (Member of the European Parliament)

25 Sept 2025 · Speaker Event

Response to European Judicial Training Strategy 2025 - 2030

5 Sept 2025

We hereby submit our feedback on the 20252030 European Judicial Training Strategy, attached for your consideration.
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German Digital Association Seeks Flexible EU Cybersecurity Certificate Changes

28 Aug 2025
Topic — Amendment to EU Common Criteria cybersecurity certification scheme and state-of-the-art documents.
Message — Bitkom requests that minor bug fixes and security patches not automatically trigger mandatory re-evaluation as major changes. They seek clear transition rules allowing ongoing projects to conclude under original standards and harmonized criteria for certificate maintenance across EU schemes.123
Why — This would reduce time and cost burdens while maintaining practical usability for industry.45
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Response to Revision of the 'New Legislative Framework'

27 Aug 2025

Bitkom calls for targeted legislative updates to adapt the NLF to new challenges while preserving its two core principles: i) Setting essential requirements in legislation and providing the primary technical means of meeting those requirements with harmonised standards and (ii) a risk-based modular conformity assessment systemespecially Module A, which enables low-burden in-house compliance. Please find our full answer to the Call for Evidence attached.
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Bitkom Urges Limited Technical Specifications and Expanded Digital Labelling

27 Aug 2025
Topic — EU proposal for aligning product legislation with the digital age via common specifications.
Message — Bitkom requests that common specifications serve only as a limited fallback developed with industry experts. They also advocate for e-labelling, digital-only contact details, and digital safety information.12
Why — This would lower compliance costs and ensure European products remain competitive in international markets.34
Impact — Citizens without reliable digital access could face barriers to accessing essential safety information.5
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Bitkom urges more risk-based and practical GDPR reforms

25 Aug 2025
Topic — EU proposal to reduce administrative GDPR burdens for small and medium-sized enterprises.
Message — Bitkom advocates for a genuine risk-based approach where obligations are reduced for low-risk activities regardless of company size. They call for a clearer definition of high risk to avoid legal uncertainty and facilitate innovation.12
Why — This would allow companies to redirect resources from administrative tasks toward digital innovation.3
Impact — Data subjects could lose transparency if limits are placed on information access requests.4
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Response to EU label on product durability and EU notice on consumers’ legal guarantee rights

28 Jul 2025

Bitkom supports the objective of improving transparency on consumer rights and product durability. However, the current draft implementing regulation raises concerns. From a linguistic, practical, and legal perspective, the design and terminology are likely to lead to misunderstanding, administrative burden, and confusion for both consumers and businesses. We call on the Commission to: - Ensure clear and consistent legal terminology, aligned with national consumer protection frameworks; - Redesign the visual and textual elements of the notice and label for better clarity and practical feasibility. Further comments and recommendations are provided in the attached statement.
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Response to Conformity standards for non-qualified trust service providers

17 Jul 2025

Bitkom emphasizes that substantial improvements are necessary to ensure the clear and proportionate implementation of the Implementing Act on Risk Management Procedures for Non-Qualified Trust Service Providers under eIDAS-Regulation (EU) No. 2024/1183. The draft regulation includes redundant provisions and lacks clarity regarding user risk communication, identity verification requirements, and secure data retention. Enhanced transparency obligations and harmonization with core security standards are essential to foster trust, regulatory coherence, and a risk-based approach. Furthermore, a sufficient transitional period is needed to enable smooth and effective adoption. Please find our full position in the document attached.
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Response to Conformity Assessment Bodies accreditation

17 Jul 2025

Summary: Bitkom stresses that the draft Implementing Act on the Accreditation of Conformity Assessment Bodies under eIDAS-Regulation (EU) No. 2024/1183 requires greater clarity on roles and responsibilities, consistency of terminology, and sufficient flexibility to accommodate updated standards. Without clear differentiation of requirements, legal alignment with eIDAS and ETSI standards, and practical, proportionate procedures, the draft Regulation risks confusion and delays for all stakeholders. Substantial improvements are needed to ensure clear and timely implementation of eIDAS-Regulation, together with the European Digital Identity Wallet (EUDI-Wallet) and new Trust Services. Please find our full position in the document attached.
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Response to Trusted Lists

17 Jul 2025

Bitkom highlights the necessity of extending the deadline for the application of the Implementing Act on Trusted Lists under eIDAS Regulation (EU) No. 2024/1183 from 6 to 12 months. This extension is essential to allow both Trust Service Providers and Supervisory Bodies adequate time to adapt, ensuring alignment with the updated framework without disrupting existing infrastructures or undermining trust among public authorities and private sector users. Specific comments on the implementing regulation: A transitional period of 12 months instead of 6 is necessary to allow for the adaptation of both Trust Service Providers and Supervisory Bodies. This time is essential to ensure alignment with the revised framework without disrupting existing infrastructures or undermining trust in the services currently used by public authorities and private actors alike.
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Bitkom Urges Reform of Overlapping European Data Regulations

16 Jul 2025
Topic — The consultation seeks views on creating a coherent EU Data Union Strategy.
Message — Bitkom calls for a simplification of overlapping data laws to make implementation easier. They request governance reforms including more staff and reviewable decision-making.12
Why — Streamlined rules would lower transaction costs and reduce the effort required for compliance.34
Impact — Data protection authorities could lose influence due to new legal reviews of their decisions.56
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Response to Revision of the Standardisation Regulation

16 Jul 2025

The European Standardisation System (ESS) continues to be a well-functioning framework that ensures Europes global competitiveness by delivering high-quality standards. The New Legislative Framework (NLF) has been pivotal to the success of the Single Market. In the Public-Private Partnership of the ESS, European legislators can establish essential requirements, while technical implementation standards are developed by experts from across Europe. The PPP ensures that profound knowledge of industry, innovation, and market needs contribute to shaping harmonised European Standards (hENs). This promotes widespread acceptance and implementation of these standards among European stakeholders. A revision of the Standardisation Regulation should focus on re-establishing core benefits of the system that have been limited through the changes made to the ESS over the last years. Firstly, the alignment of harmonised standards with international standards of ISO and IEC facilitates global market access and lowers costs by eliminating the need for different product specifications across various markets. The alignment also ensures optimal resource utilization and expertise, while preventing redundant efforts in standard development for European standardisation experts. Secondly, the fast listing of harmonised standards enables easier market access within the EU and reduces compliance burdens. Early access to harmonised standards offers legal certainty through the presumption of conformity and eliminates the need to involve third parties in conformity assessments, resulting in crucial cost savings, especially for SMEs. We therefore advocate for only necessary and targeted amendments to Regulation 1025/2012 that address implementation challenges in fulfilling the above goals without destabilising the proven foundation of the ESS. Please see our full position in the document attached.
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Bitkom urges faster digitalization of EU vehicle registration documents

15 Jul 2025
Topic — The EU is modernizing roadworthiness rules by digitalizing vehicle registration and registration data.
Message — Bitkom requests that digital registration certificates support organizational wallets for large fleets and be distributable via companies' own apps. They also propose removing the obligation to carry physical documents and shortening the implementation timeline to one year.123
Why — Fleet operators would significantly cut costs and administrative effort by eliminating physical document management and storage.45
Impact — Non-EU citizens could be excluded from digital mobility services if certificates are restricted to EU-only identity wallets.6
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German digital association Bitkom urges clear sovereign cloud rules

2 Jul 2025
Topic — The consultation proposes measures to expand the EU’s cloud and AI capacity.
Message — The organization calls for a precise definition of sovereign cloud to ensure legal certainty. They advocate for simplified, digitalized approval processes and stable investment incentives for infrastructure expansion. Additionally, the public sector should act as an anchor customer to support European market growth.123
Why — Streamlined permitting and public funding would lower costs and boost member investment.4
Impact — Global cloud providers could face exclusion due to strict localization requirements.5
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Meeting with Emmanuelle Du Chalard (Head of Unit Communications Networks, Content and Technology)

30 Jun 2025 · Latest developments in copyright policy

Meeting with Matthias Jorgensen (Acting Director Trade), Matthias Jorgensen (Acting Director Trade)

26 Jun 2025 · Exchange about EU – US trade relations

Bitkom Urges EU to Streamline Fragmented Cybersecurity Reporting Rules

19 Jun 2025
Topic — The consultation addresses the revision of the EU Cybersecurity Act to improve regulatory coherence and certification.
Message — Bitkom advocates for a "one incident, one report" principle to eliminate redundant reporting obligations. They want ENISA to coordinate harmonisation efforts and map international standards against EU requirements.123
Why — This would reduce compliance costs and administrative burdens for companies operating across multiple borders.45
Impact — Proponents of geopolitical certification requirements lose influence if schemes are strictly limited to technical criteria.67
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Meeting with Sergey Lagodinsky (Member of the European Parliament) and Airbus

12 Jun 2025 · Exchange of Views

Response to Digital services for simplifying business operations and reducing administrative costs – the business wallet

11 Jun 2025

In the attached position paper, Bitkom highlights the key challenges organizations face in B2B and B2G contexts and to some extent in B2C, B2M and B2E and outlines essential use cases alongside technical and legal requirements to be integrated into the forthcoming EU legislation on the EUBW. The term EUDI-Wallet initially covers digital identity wallets for both natural and legal persons under the revised eIDAS Regulation. Recently, the term European Business Wallet (EUBW) was introduced specifically for legal entities. In this document, we use EUDI-Wallet to refer exclusively to wallets for natural persons (citizens), and EUBW for wallets related to legal persons and organisational contexts including identities for employees and machines. If designed effectively, the EUBW could serve as a foundational tool for secure, seamless, and cross-border data exchange between businesses and public authorities by simplifying administrative workflows, reducing redundant data submissions, enhancing data quality, and improving compliance across both regulatory and commercial contexts. In a broad B2B context, the EUBW could support a variety of use cases, such as including Know-Your-Customer (KYC) and Know-Your-Business (KYB) procedures, the execution of digital contracts, supply chain documentation, and digital product passports. By linking verifiable credentials to legal entities and their representatives, it could help automate complex workflows, strengthen trust, and enable secure, cross-border data sharing. However, the success of the EUBW would depend on its integration with a broader modernization of administrative and legal frameworks. Existing legislation would need to be reviewed for digital compatibility, and procedural requirements harmonized across sectors and Member States. The EUBW should not be focused on government-to-government or purely administrative processes, as the Single Digital Gateway Regulation already offers some suitable mechanisms for such interactions. Instead, the wallet should focus on supporting economic actors, particularly in the private sector. Ultimately, it could serve as a foundation to rethink and enhance digital processes across both public administrations and businesses. Please refer for more details to the attached position paper.
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Bitkom calls for flexible regulation and better AI infrastructure

3 Jun 2025
Topic — The initiative aims to accelerate AI adoption across European industrial and public sectors.
Message — Bitkom calls for open access to infrastructure and flexible, innovation-friendly regulation. They recommend easing visa processes and supporting open-source AI with minimal hurdles.123
Why — Reduced legal uncertainty would allow companies to focus on innovation instead of compliance.4
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Response to Quantum Strategy of the EU

2 Jun 2025

Bitkom is Germanys digital industry association, representing over 2,200 companies across the digital economy. Since 2018, Bitkom has played a leading role in shaping quantum policy and driving industrial development. With more than 430 experts from over 180 companies, Bitkom covers the entire quantum innovation landscapefrom enabling technologies and microelectronics to hardware, software, and applications. It serves as a key platform for knowledge exchange and policy dialogue between industry, research institutions, and policymakers at regional, national, and European levels. Bitkom welcomes the Commissions ambition and supports a coordinated, future-oriented approach. To succeed, the strategy must focus on overcoming fragmentation, supporting commercial scaling, and ensuring global competitiveness. Europe must move beyond isolated demonstrators to build a unified ecosystem that drives industrial adoption, safeguards technological sovereignty, and delivers economic and societal value. Key Takeaways: - Unify the Ecosystem: One Strategy, One Roadmap, One Scorecard: Fragmented national efforts and disconnected funding slow Europes progress to commercial quantum technologies. The EU needs a shared roadmap, harmonised funding mechanisms, and coordinated governance. A public progress scorecard should track delivery and ensure accountability. Consolidating Member States efforts around promising approaches will accelerate impact and reduce duplication. - Scale Quantum Value Chain Through Strategic Investment and Procurement: Europe must move beyond demonstrators and build a scalable quantum value chainfrom research to industrial deployment. This requires targeted investment in infrastructure, including hardware, software, and enabling technologies. Public procurement must actively create early demand for solutions and provide market signals across quantum computing, communication, and sensing. - Enable Industrial Applications Through Access, Infrastructure & Use Cases: To unlock economic value, Europe must ensure broad and cost-effective access to quantum systems. Public infrastructure, vendor-neutral platforms, and hybrid system integration must support cross-sector application development. Flagship use cases, standardized APIs, and collaboration between research, startups, and industry are critical to drive adoption. - Modernize Funding to Leverage Private Capital and Accelerate Deployment: A unified EU Quantum Investment Fund should combine grants, equity, and guarantees. Public financing must be complemented by co-investment models, tax incentives, and funding instruments that crowd in private capital, reduce risk, and enable scale-up of market-ready quantum technologies. - Strengthen Global Partnerships to Secure Europes Strategic Autonomy: Europe must deepen international cooperation with like-minded partners to access critical technologies, diversify supply chains, and accelerate quantum deployment. Strategic alliances should support cross-border commercialization and enhance Europes role in global standard-setting. At the same time, Europe must reduce dependencies in sensitive areas to align quantum capabilities with broader economic security and sovereignty goals.
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Bitkom rejects redundant EU rules for radio software updates

27 May 2025
Topic — The EU is reviewing rules for software updates on radio equipment.
Message — Bitkom requests that the Commission maintains the current regulatory status rather than introducing redundant new requirements. They suggest that any new rules should only target a niche segment of high-risk products.12
Why — This would prevent unnecessary costs and administrative work for compliant tech companies.3
Impact — Non-compliant companies would face tougher oversight if market surveillance is strengthened.4
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Response to International Digital Strategy

20 May 2025

In an era where digital technologies shape global influence and control over data, infrastructure, and standards defines strategic power, a guiding International Digital Strategy is essential to protect European democratic values and strengthen our economic resilience. Bitkom, therefore, highly welcomes the European Commissions initiative to set out its international digital policy efforts in a holistic approach to represent its interest on a global stage. Europe should not only support international rules, fair competition, cooperation, and free trade, but also actively uphold these values and build new strategic partnerships. To be effective, the strategy should pursue the following key objectives: - Boost Competitiveness: Strengthen Europes digital economy by streamlining regulation, ensuring legal clarity, and facilitating secure cross-border data flows. - Defend Multilateralism: Promote free, rules-based trade and counter the emergence of fragmented digital ecosystems that divide the world into isolated spheres with conflicting norms and standards. - Ensure Security and Resilience: Our digital infrastructure as well as institutions must be secure and resilient in the face of crises, with strong protection against cyberattacks. To combat international cybercrime, the European Union should take a leading role in fostering international collaboration. - Leverage Digitalization to Advance Sustainability: Digitalization must contribute to climate protection, help achieve climate targets and foster more sustainable economic practices globally. - Attract Global Talent and Drive Innovation: Position European research institutions and digital programs for global success, making Europe a magnet for the worlds best talent. Furthermore, the strategy should build on existing national-level international digital strategies to avoid duplication or contradiction. A well-aligned European strategy will enhance digital sovereignty - not as a move toward isolation, but as a means to preserve Europes ability to act autonomously and to secure access to critical technologies. If grounded in the right priorities, the International Digital Strategy can become a cornerstone for deepening international cooperation, advancing global digital governance, and reinforcing Europes competitiveness. A more comprehensive explanation of our position is provided in the attached document.
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Meeting with Hannes Heide (Member of the European Parliament) and Wirtschaftskammer Österreich

13 May 2025 · General exchange of views

Response to A Culture Compass for Europe

9 May 2025

Bitkom Member Companies Continuing Commitment to Enriching European Culture Bitkom, as a leading association of digital companies in Germany, is proud to assemble key players and supporters of cultural expressions, particularly in the media, and providers of platforms and networks for their conveyance throughout Europe, among its members. Those undertakings are at the forefront of producing, distributing and giving prominence to original, diverse and high-quality content that significantly contributes to the diverse culture and media landscape in Europe. In 2023, a remarkable 4.5 billion euros were invested into original content only in Germany, accounting for 20% of the EU's total spending on cultural production (cf. European Audiovisual Observatory, 2024). This places Germany second only to the UK in terms of investment in audiovisual media. Moreover, spending on original content in Germany is increasing by approximately 4% per year, a rate that surpasses inflation and demonstrates a robust commitment to cultural growth. Bitkom members play a pivotal role in this cultural enrichment. They produce a substantial portion of this content across various fields, including linear TV, streaming services, entertainment, news, and sports. This diverse range of content not only entertains but also informs and connects people across Europe, fostering a shared cultural identity and understanding. Our members remain committed to continuing their efforts to produce high-quality content that reflects the rich diversity and heritage of Europe. By expanding and upgrading delivery networks, by leveraging innovative technologies and creative talents, Bitkom members ensure that European culture remains vibrant and dynamic and that changing usage patterns are being met. Bitkom's commitment to culture is unwavering. We believe that a thriving cultural sector is essential for the social, economic and democratic well-being of Europe. As such, we will continue to work on and support the production and distribution of European content and ensure that Europe remains a global leader in cultural innovation.
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Meeting with Axel Voss (Member of the European Parliament, Rapporteur) and Google and

6 May 2025 · Copyright and generative AI

Meeting with Sergey Lagodinsky (Member of the European Parliament)

29 Apr 2025 · Panellist

Meeting with Alexandra Geese (Member of the European Parliament) and Deutsche Telekom and

29 Apr 2025 · Event: DACH-Tech

Meeting with Tiemo Wölken (Member of the European Parliament) and Medienverband der freien Presse e.V.

22 Apr 2025 · AI and Copyright

Meeting with Maria Zafra Saura (Cabinet of Commissioner Michael McGrath)

15 Apr 2025 · Data protection, e-privacy, simplification

Response to Technical description of important and critical products with digital elements

12 Apr 2025

Thank you for the opportunity to comment on the draft Technical Description of Important and Critical Products with Digital Elements. Please find our feedback in the attached file. We welcome the initiative and remain available for further dialogue.
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Meeting with Thomas Schmitz (Cabinet of Executive Vice-President Henna Virkkunen) and Apple Inc. and

11 Apr 2025 · Copyright levies reform

Meeting with Silke Dalton (Cabinet of Executive Vice-President Henna Virkkunen)

8 Apr 2025 · Existing and upcoming legislation in the Telecom sector

Meeting with Marie-Agnes Strack-Zimmermann (Member of the European Parliament)

3 Apr 2025 · Exchange about EU digital policy

Meeting with Sergey Lagodinsky (Member of the European Parliament)

27 Mar 2025 · Participation Event

Meeting with Christian Doleschal (Member of the European Parliament, Shadow rapporteur)

26 Mar 2025 · Revision der Vergaberichtlinien

Meeting with Marco Giorello (Head of Unit Communications Networks, Content and Technology) and Bureau Européen des Unions de Consommateurs and

19 Mar 2025 · Code of Conduct on Online Advertising – Workshop 4

Response to EU Start-up and Scale-up Strategy

17 Mar 2025

Bitkom strongly supports the European Commissions intention to finally address the obstacles holding back young, innovative companies in the EU. Startups and scaleups are facing severe disadvantages compared to their US or Chinese competitors, such as access to finance, regulatory and bureaucratic burdens and fragmentation, access to markets, access to talent, and access to infrastructure, knowledge, and services. The following actions should be taken by the EU and its Member States to overcome these barriers. - Channelling Capital: Startups & Scaleups Need a Fully Integrated Capital Markets Union: Europe's institutional investors are sitting on trillions of euros, yet they are barely investing in technology startups and VC. Over the past decade, venture capital investment in the EU has averaged only 0.3 % of GDP, which is less than a third of the figure in the US.1 A well-designed, preferential tax treatment for equity investment in startups, especially in key sectors, could drive more capital into high-growth companies. - Introduce a 28th Regime: One Uniform Legal Framework for Scaling: Instead of dealing with 27 national legal systems, innovative companies should operate under a single framework of corporate, insolvency, and labor law, as well as taxation. We cannot emphasize enough how important this initiative is for startups and scaleups. A 28th Regime must provide a default legal structure and enable fast, digital registration valid across all Member States for seamless cross-border expansion without needing multiple legal entities. - Address the Talent Gap: Easier Hiring, Mobility & Startup Visas: Beyond retraining and reskilling its own workforce, Europe must rethink its approach to international mobility. A fast-track EU-wide tech visa would allow companies to recruit top talent globally. Tax incentives to attract talent would further boost Europes ability to compete for the best minds. The EU should make it easier for international students to stay. Reforms for remote working and stock option tax reforms should be a priority on the agenda.
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Meeting with Marco Giorello (Head of Unit Communications Networks, Content and Technology) and Apple Inc. and

13 Mar 2025 · Code of Conduct on Online Advertising – Workshop 3

Response to Savings and Investments Union

7 Mar 2025

Bitkom strongly supports the European Commissions intention to finally address the obstacles to the free movement of capital within the Union. However, it is essential to ensure that it does not create new complexities, but rather helps to reduce bureaucracy and regulatory burdens. A fragmented interpretation of EU legislation at the national level must be avoided. Key Takeaways: - Address the European Unions Historic Investment Need: To achieve its climate targets, drive forward the digital transformation, strengthen its defense capabilities and compete globally with the USA and China, the EU needs annual investments of at least 750 to 800 billion. This sum exceeds five times the amount of the post-World War II Marshall Plan. Public funding alone will not get us there. The EU needs to mobilize huge amounts of private savings into the capital markets by initiating a European VC initiative, harmonizing and simplifying VC taxation, and setting up a strong DefTech Fund. - Unlock Pension Funds for Venture Capital Investments: Pension funds are well placed to provide the long-term investments needed to finance the major transformations that lie ahead. However, of the investments made by European institutional investors, only $218 billion is allocated to VC, compared to $1.1 trillion in the US. The EU should encourage pension funds to invest in venture capital and high-growth startups by removing the barriers holding them back. - Strengthening EU Capital Markets by Increasing Depth and Liquidity: Creating a robust capital market is essential to address the persistent inefficiencies within the EU which hinder economic growth and innovation. A fully integrated and liquid capital market would leverage private savings, boost productive investment and enhance the global competitiveness of European businesses, unlocking an estimated 470 billion annually. To achieve this, the EU must develop more attractive exit markets, harmonize cross-border financial services, and create valuable secondary markets for startups and VC equity.
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Bitkom Calls for Harmonized EU Public Procurement Rules

7 Mar 2025
Topic — Evaluation of EU directives governing public procurement and concession contracts.
Message — Bitkom demands a narrower scope for direct awards to public entities to ensure competition. They call for one-to-one implementation across member states to eliminate burdensome national rules. The association recommends replacing geographical bidder restrictions with specific security and sustainability criteria.123
Why — Digital firms would gain easier market entry and lower costs through standardized rules.45
Impact — Public sector entities lose the ability to award contracts internally without facing competition.67
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Meeting with Marco Giorello (Head of Unit Communications Networks, Content and Technology) and EuroCommerce and

6 Mar 2025 · Code of Conduct on Online Advertising – Workshop 2

Bitkom Urges EU to Digitalize the Water Resilience Strategy

4 Mar 2025
Topic — The EU is creating a multi-annual plan to achieve a water resilient Europe.
Message — Bitkom calls for expanding water reuse regulations to include industrial and digital applications. They recommend harmonized quality standards and using digital tools to monitor water consumption. EU funding should incentivize the adoption of digital technologies for better water management.123
Why — Harmonized standards would create investment security and accelerate the adoption of digital solutions.4
Impact — Freshwater suppliers may lose revenue as industries transition to recycled and alternative water sources.5
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Meeting with Marco Giorello (Head of Unit Communications Networks, Content and Technology) and EuroCommerce and

4 Mar 2025 · Code of Conduct on Online Advertising – Workshop 1

Meeting with Jan Ceyssens (Cabinet of Commissioner Jessika Roswall)

19 Feb 2025 · Exchange of views on positive climate contributions of digital technologies

Meeting with Max Lemke (Head of Unit Communications Networks, Content and Technology)

18 Feb 2025 · Speaking at closed Bitkom Working Group on Software Defined Vehicles event

Meeting with Ekaterina Zaharieva (Commissioner) and

14 Feb 2025 · Discussion with the President of Bitkom, on the Startups and Scaleups Strategy and relevant parts of the Horizon Europe Programme.

Meeting with Rita Wezenbeek (Director Communications Networks, Content and Technology) and

11 Feb 2025 · Opening Session: DSA roundtable discussions on online advertising (Article 46 DSA)

Bitkom urges EU to prioritize digital enforcement over new laws

31 Jan 2025
Topic — The European Commission is developing a strategy to strengthen and integrate the EU Single Market.
Message — Bitkom wants the EU to prioritize enforcing existing digital rules before proposing new legislation. They advocate for a 25% reduction in reporting obligations and a unified startup legal framework.1234
Why — Digital firms would benefit from lower administrative costs and easier access to the Single Market.56
Impact — National governments lose the power to set unique domestic standards that protect local industrial interests.7
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Meeting with Svenja Hahn (Member of the European Parliament) and BUSINESSEUROPE and

29 Jan 2025 · Renew Europe Stakeholder Roundtable: “Elevator Pitch for Better Single Market Rules”

Meeting with Axel Voss (Member of the European Parliament, Rapporteur)

16 Jan 2025 · Copyright and generative AI

Meeting with Axel Voss (Member of the European Parliament, Rapporteur)

28 Nov 2024 · Copyright and generative AI

Meeting with Aura Salla (Member of the European Parliament)

14 Nov 2024 · Introductory meeting

Meeting with Sergey Lagodinsky (Member of the European Parliament)

4 Nov 2024 · Speaker

Meeting with Marion Walsmann (Member of the European Parliament)

10 Oct 2024 · Digitale Transformation

Meeting with Christian Ehler (Member of the European Parliament)

2 Oct 2024 · Digitalpolitik

Meeting with Oliver Schenk (Member of the European Parliament)

4 Sept 2024 · Priorities for the next legislative term

Meeting with Matthias Ecke (Member of the European Parliament)

3 Sept 2024 · Kennenlernen / Digitalpolitik

Meeting with Sergey Lagodinsky (Member of the European Parliament)

3 Sept 2024 · Exchange of Views

Meeting with Andrea Wechsler (Member of the European Parliament) and European Association Automotive Suppliers and

3 Sept 2024 · EU Energy and Industry Policy

Meeting with Tiemo Wölken (Member of the European Parliament)

2 Sept 2024 · General exchange on digital policy issues (staff level)

Response to Rules specifying the obligations laid down in Articles 21(5) and 23(11) of the NIS 2 Directive

25 Jul 2024

Please find attached Bikom's input to the European Commissions public consultation on the implementing act under Articles 21 and 23 of the Directive (EU) 2022/2555.
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Meeting with Axel Voss (Member of the European Parliament)

25 Jul 2024 · Digital files

Response to EU implementation of recent amendments to the Annexes of the Basel Convention regarding trade in e-waste (2)

3 Jul 2024

Bitkom welcomes the revision of the EU Waste Shipment Regulation. The Waste Shipment Regulation is an important regulation to reduce risks for the environment and human health and to advance to a circular economy and to implement the Basel Convention and the OECD Council Decision regarding transboundary movement of waste electrical and electronic equipment (WEEE). Please find attached our position paper.
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Response to EU implementation of recent amendments to the Annexes of the Basel Convention regarding trade in e-waste

3 Jul 2024

Bitkom welcomes the revision of the EU Waste Shipment Regulation. The Waste Shipment Regulation is an important regulation to reduce risks for the environment and human health and to advance to a circular economy and to implement the Basel Convention and the OECD Council Decision regarding transboundary movement of waste electrical and electronic equipment (WEEE). Please find attached our position paper.
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Response to How to master Europe’s digital infrastructure needs?

28 Jun 2024

Bitkom highly welcomes the EU Commission's intention to prepare a review of the current framework to foster competitiveness, competition and investment in the European telecommunications market. An EU-wide harmonised market improves the conditions for investment and expansion in the telecommunications sector. This will strengthen the competitiveness of European companies, which depend on the digital infrastructure in all areas. Bitkom therefore highly appreciates the efforts of the EU Commission to stimulate the roll-out of connectivity, as set out in the targets for the Digital Decade 2030. Please find attached in more detail our feedback on the Commissions white paper.
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Meeting with René Repasi (Member of the European Parliament)

6 Jun 2024 · "Tacheles-Spezial" Online Diskussion zu digitalpolitischen Themen

Response to Recommendation to monitor outbound investments for further risk assessment

17 Apr 2024

Bitkom, representing 2,200 companies from the digital economy in Germany, views the proposal with great concern. It has the potential to restrict the free flow of investments and could create a chilling effect on European investments abroad, which would have a negative impact on European economic growth. Given the potential economic impact of the measure, we believe that a more thorough and comprehensive debate is necessary. We therefore welcome the opportunity to contribute the opinion of the German digital economy to this matter. However, we also urge the Commission and member states to engage in a much wider debate on the matter before kicking off any analysis. For a more detailed critique on the matter, please see the attached PDF.
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Meeting with Reinhard Bütikofer (Member of the European Parliament)

10 Apr 2024 · exchange of views

Meeting with Sergey Lagodinsky (Member of the European Parliament)

9 Apr 2024 · Digitalpolitischer Rück- und Ausblick zu KI- und Datenpolitik

Response to White Paper on Dual-Use Export Controls

25 Mar 2024

Effective and efficient export controls are vital for the European economy, ensuring security and economic stability. At the same time, the experience of recent years, in particular following Russia's illegal invasion of Ukraine, has shown that European export controls need to be adapted. The White Paper highlights the current problems with European export controls and offers an opportunity to solve them. Bitkom supports these efforts and recommends that the Member States and the Commission seek a coherent approach that addresses the problems caused by individual national lists and the dysfunctionality of the various international export control bodies, such as the Wassenaar Arrangement.
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Meeting with Rasmus Andresen (Member of the European Parliament) and Bundesverband der Deutschen Industrie e.V. and

5 Mar 2024 · socio economic situation

Meeting with Anna Cavazzini (Member of the European Parliament, Committee chair) and Apple Inc. and

23 Feb 2024 · Aktuelle Themen in der Europapolitik und Sachsen

Bitkom calls for GDPR reforms to boost digital innovation

8 Feb 2024
Topic — The European Commission is reviewing the application of the General Data Protection Regulation.
Message — Bitkom requests more flexible rules for emerging technologies and the removal of overlapping regulations. They urge authorities to adopt a risk-based approach instead of a zero-risk policy. The group also asks for clearer guidelines on data anonymization and international transfers.12
Why — Streamlining regulations would reduce the high compliance costs and bureaucratic burden on digital businesses.3
Impact — National regulators would see their discretionary power limited by stricter European Commission definitions.4
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Meeting with Miriam Lexmann (Member of the European Parliament)

16 Nov 2023 · Platform workers directive

Meeting with Anna Cavazzini (Member of the European Parliament, Shadow rapporteur) and Bureau Européen des Unions de Consommateurs and

7 Nov 2023 · Reform of the Union Customs Code

Response to Revision of the Union Customs Code

1 Nov 2023

Bitkom welcomes the reform of the UCC as it has the potential to deliver a more efficient, secure and business-friendly Customs Union. However, achieving this goal will require a common interpretation of the UCC by Member States and the actual implementation of various proposed improved customs mechanisms. We also recommend prioritising the security of the data hub and working closely with business in implementing the reform.
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Meeting with Sabine Verheyen (Member of the European Parliament, Rapporteur)

11 Oct 2023 · European Media Freedom Act

Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

29 Sept 2023 · on digital policy

Response to Evaluation of Standardisation Regulation (EU) No 1025/2012

27 Sept 2023

The Regulation 1025/2012 is a Strong Base for European Standardisation Summary In general, and as it has already been expressed in position papers on the EU standardisation strategy before, Bitkom does not see the necessity for revising Regulation 1025/2012. Reasoning Bitkom welcomes the opportunity to provide feedback and comments on whether the Regulation 1025/2012 can still sufficiently respond to the new opportunities and challenges of globalisation, ensure public safety, and support green and digital transformation. Bitkom is the leading German association for the digital industry and our working group on standardization has a broad level of expertise from the ICT sector on standardisation and standards policy. We agree that standardisation is a key topic for the competitiveness of European industry. In particular, when regarding the competitiveness on the global markets. Europe is an export-oriented continent. The success of German and European industry largely builds on international standards and on having European standards identical to international standards. Industry is the leading contributor to standardisation. The transparent procedures of standardisation and the role standards play in support of regulation, ensure that the interests of all stakeholders are adequately represented and considered. Standardisation operates on a consensus model, ensuring that the interests of all stakeholders are addressed, thereby promoting, and fostering inclusivity. In general, and as it has already been expressed in position papers1 on the EU standardisation strategy before, Bitkom does not see the necessity for revising Regulation 1025/2012. The Regulation 1025/2012 sets the framework for the European standardisation system very well. This includes provisions on inclusiveness and on engaging with societal stakeholders. As such, we believe that these stakeholders should also be included in any revision process of the Regulation 1025/2012. The three European standardisation organisations collaborate effectively, addressing their respective areas of expertise with precision and efficiency. Thus far, the challenges that have arisen in the context of Regulation 1025/2012 have stemmed from its implementation, rather than from the legal framework itself. Several of them have successfully been addressed, e.g. in the EC-EFTA-ESO Task Force. This could be a good blueprint for a pragmatic way ahead towards more effective implementation of EU regulations. Therefore, it is essential for the relevance of the consultation that implementation aspects are also covered by the consultation, particularly regarding the process of citation of harmonised standards. Potential changes to the regulation and its implementation should be addressed separately. Bitkom holds the perspective that Regulation 1025/2012 is aptly crafted to tackle the upcoming standardisation challenges, particularly in the rapidly evolving sphere of digitalisation. We believe that the provisions and guidelines within this regulation are forward-thinking, making it a cornerstone for addressing the complexities presented by digital transformation in the years to come.
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Meeting with Andrus Ansip (Member of the European Parliament, Rapporteur) and Unilever and Independent Retail Europe (formerly UGAL - Union of Groups of Independent Retailers of Europe)

27 Sept 2023 · Green Claims

Response to Establishing the digital euro

6 Sept 2023

Dear Sir or Madam, please find attached Bitkom's evaluation of the European Commission's proposed legislation on the digital euro. Sincerely, Benedikt Faupel
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German digital association Bitkom urges harmonized GDPR interpretation

4 Sept 2023
Topic — This consultation addresses procedural rules for cooperation between national data protection authorities.
Message — Bitkom calls for a structured dialogue with industry experts to streamline GDPR interpretation. They request stronger rights to be heard and protected confidentiality during proceedings.12
Why — Harmonization would remove competitive disadvantages for companies facing restrictive national data interpretations.3
Impact — Complainants would face restricted access to administrative files to protect company confidentiality.4
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Meeting with Maria-Manuel Leitão-Marques (Member of the European Parliament, Shadow rapporteur)

30 Aug 2023 · Virtual Worlds

Bitkom rejects EU Green Claims Directive over bureaucratic burdens

18 Jul 2023
Topic — The consultation addresses a proposal requiring companies to verify their environmental claims.
Message — Bitkom calls for the removal of mandatory pre-approval procedures for environmental claims. They also request extending the transitional implementation period to at least 30 months.12
Why — These changes would lower compliance costs and ensure companies communicate product improvements faster.34
Impact — Consumer protection organisations lose the intended administrative relief of pre-verified certificates for monitoring claims.5
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Bitkom urges streamlined climate metrics in EU reporting standards

6 Jul 2023
Topic — New EU rules specifying how companies must report environmental and social impacts.
Message — Bitkom recommends focusing mandatory climate disclosures on key metrics like emissions and energy consumption. They also want reporting requirements aligned with other EU laws to reduce complexity.12
Why — Simplified disclosure rules would lower compliance costs and reduce bureaucratic burdens for companies.3
Impact — Transparency advocates lose detailed data if site-specific pollution reporting requirements are deleted.4
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Meeting with Chris Uregian (Cabinet of Vice-President Margaritis Schinas), Despina Spanou (Cabinet of Vice-President Margaritis Schinas)

4 Jul 2023 · cybersecurity policy and digital skills policy

Meeting with René Repasi (Member of the European Parliament, Shadow rapporteur)

9 Jun 2023 · Exchange of views on the Product Liability Directive/ Produkthaftungsrichtlinie (PLD) - Staff Level

Meeting with Alin Mituța (Member of the European Parliament, Rapporteur) and Open Fiber

31 May 2023 · Gigabit Infrastructure Act

Response to Promoting sustainability in consumer after-sales

25 May 2023

Bitkom e.V. ist der Digitalverband Deutschlands und vertritt mehr als 2.000 Mitgliedsunternehmen aus der digitalen Wirtschaft. Die Bitkom-Mitglieder beschäftigen in Deutschland mehr als 2 Millionen Mitarbeiterinnen und Mitarbeiter. Zu den Mitgliedern zählen mehr als 1.000 Mittelständler, über 500 Startups und nahezu alle Global Player. Wir bedanken uns für die Möglichkeit zur Stellungnahme, unsere ausführliche Rückmeldung finden Sie in der angehängten Datei. Das Wichtigste zusammengefasst: Bitkom begrüßt und unterstützt den von der Europäischen Kommission vorgelegten Vorschlag für eine Richtlinie zur Förderung der Reparatur von Waren (Recht auf Reparatur). Der Vorschlag schafft einen sinnvollen und angemessenen Rahmen auf EU-Ebene, um mehr Verbraucherinnen und Verbrauchern den Zugang zu qualitativ hochwertigen und sicheren Reparaturen zu ermöglichen. Wir begrüßen insbesondere die Entscheidung der Kommission, einen marktbasierten Ansatz für Reparaturen außerhalb der gesetzlichen Gewährleistung zu verfolgen. Ebenso begrüßen wir den im Entwurf gewählten produktspezifischen Ansatz sowie die Fokussierung auf Verbrauchsgüterkäufe. Wir unterstützen die größtmögliche Harmonisierung von Reparaturanforderungen in der EU und schlagen geringfügige Änderungen am Vorschlag der EU-Kommission vor: - Möglichkeit, defekte Produkte durch wiederaufbereitete Produkte zu ersetzen. Dies dient nicht nur der ökologischen und ökonomischen Nachhaltigkeit, sondern bietet den Verbraucherinnen und Verbrauchern auch eine schnellere Abhilfe im Vergleich zur individuellen Reparatur. - Eine einzige Plattform für Reparaturinformationen pro Mitgliedstaat, um Fragmentierung zu vermeiden. Zur Gewährleistung der Verbrauchersicherheit sollten sich nur Hersteller (OEM), welche Reparaturdienstleistungen anbieten und Werkstätten, die den neuen Qualitätsstandard erfüllen, auf der Plattform registrieren können. - Festlegung eines klaren Zeitrahmens für die Entwicklung des freiwilligen europäischen Qualitätsstandards für Reparaturdienstleistungen und davon unabhängige Beschränkung der Reparaturbetriebe auf solche mit entsprechender Sachkunde. Der Schwerpunkt sollte hierbei insgesamt auf der Sicherheit der Nutzerinnen und Nutzer liegen.
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Response to Review of the Broadband Cost Reduction Directive (Directive 2014/61/EU)

11 May 2023

Bitkom strongly supports the objectives of the Gigabit Infrastructure Act. A high-performance digital infrastructure is crucial for economic development and prosperity in Europe as well as the transition to a green economy. In order for the GIA to fully take effect, we set out our recommendations for the Commission's proposal in the attached position paper. We very much appreciate the opportunity to provide feedback through this consultation and look forward to further contributing to discussions on the GIA throughout the legislative process.
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Response to Virtual worlds, such as metaverse

3 May 2023

We very much appreciate the opportunity to provide feedback to this call for evidence. The metaverse is the future of the internet. How it will be shaped and what role Europe will have in building it, is being decided now. Therefore, we very much welcome that the European Commission is already addressing the metaverse at this early stage and recognises the opportunities it will open. Please find attached our detailed position which sets out five key recommendations: 1) Build on existing regulations, do not create a new Lex Metaverse. 2) Dismantle regulations that hinder the development of the metaverse. 3) Involve all players, businesses, and the public in building the metaverse. 4) Build on existing standards and specifications, and support the European vision of the metaverse within the framework of international approaches. 5) Aim for an open, interoperable, and interconnected metaverse ecosystem that can be accessed by anyone, anywhere, and at any time globally. We hope that our input proves useful for this initiative and look forward to further contribute to the ongoing discussions on virtual worlds.
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Meeting with Paul Tang (Member of the European Parliament, Shadow rapporteur) and Meta Platforms Ireland Limited and its various subsidiaries and DIGITALEUROPE

27 Apr 2023 · Staff Level: DigitalEurope/Bitkom Roundtable “Combating Child Sexual Abuse Online – finding a way forward"

Meeting with Maria-Manuel Leitão-Marques (Member of the European Parliament, Shadow rapporteur) and MedTech Europe and

20 Apr 2023 · Product Liability Directive

Response to VAT in the Digital Age

3 Apr 2023

Bitkom welcomes the Commissions proposal for a directive on VAT rules for the digital age as a meaningful initiative to simplify the current VAT system. In the attached position paper, we elaborate on our considerations with regards to 1) Digital Reporting Requirements, 2) the VAT treatment of the platform economy, and 3) single VAT registration in the EU and IOSS. We appreciate the opportunity to provide feedback to this highly important initiative and hope that our position provides a useful input to the legislative process.
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Bitkom Urges Innovation-Friendly GDPR Enforcement and Stronger Respondent Rights

24 Mar 2023
Topic — This consultation aims to streamline cooperation between national data protection authorities in cross-border cases.
Message — Bitkom requests a progressive, innovation-friendly interpretation of existing data protection rules. They also demand a systematic right for respondents to be heard before the EDPB.12
Why — These measures would reduce legal uncertainty and enforcement complexity for digital companies.3
Impact — Privacy complainants could face reduced procedural influence to protect corporate confidentiality.4
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Meeting with Anna Cavazzini (Member of the European Parliament, Committee chair)

15 Mar 2023 · Digital files in IMCO

Meeting with Svenja Hahn (Member of the European Parliament, Shadow rapporteur) and Telefonica, S.A. and

15 Mar 2023 · AI Act, Standardisation

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

8 Mar 2023 · Corporate Sustainability Due Diligence

Meeting with Wojtek Talko (Cabinet of Vice-President Věra Jourová)

7 Mar 2023 · Presentation of Bitkom project related to the Internet

Meeting with Pascal Arimont (Member of the European Parliament, Rapporteur)

7 Mar 2023 · Revision of the Product Liability Directive

Meeting with Maurits-Jan Prinz (Cabinet of Commissioner Thierry Breton)

27 Feb 2023 · Metaverse

Meeting with Nicola Danti (Member of the European Parliament, Rapporteur) and Bureau Européen des Unions de Consommateurs and

27 Feb 2023 · Stakeholder consultation on the Cyber Resilience Act

Meeting with Petra Kammerevert (Member of the European Parliament) and Google and

1 Feb 2023 · European Media Freedom Act

Bitkom urges longer timelines for new EU cybersecurity rules

20 Jan 2023
Topic — The EU is setting mandatory cybersecurity standards for manufacturers of digital products.
Message — Bitkom calls for extending the implementation period up to 48 months for critical products. They also want incident reporting windows expanded to 72 hours and classification based on intended use.123
Why — Longer deadlines and simplified reporting would reduce administrative burdens and compliance costs.4
Impact — Delaying the new rules leaves private users and critical infrastructure vulnerable to attacks.5
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Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

12 Jan 2023 · Digital in the EU green deal

Response to Instant Payments

3 Jan 2023

Bitkom welcomes the Commissions proposal to accelerate the rollout of instant payments as an opportunity to drive further innovation in payment services. We appreciate the opportunity to provide feedback on the proposed regulation. Our preliminary position paper lays out our ideas on how the draft regulation can be further developed with regards to the scope, pricing, and IBAN name checking. We look forward to contributing further input to the debate as the legislative procedure unfolds.
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Bitkom warns against broad liability for stand-alone software

11 Dec 2022
Topic — Updating EU product liability rules for digital products and artificial intelligence.
Message — Bitkom demands that stand-alone software be excluded from the scope of strict liability. They request a clear exemption for open-source software within the main legal text. The association also warns that disclosure rules could expose sensitive business trade secrets.12
Why — Excluding software would prevent innovation from being hindered and avoid higher consumer prices.3
Impact — Consumers would lose the ability to claim compensation for psychological harm or data loss.4
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Meeting with Sabine Verheyen (Member of the European Parliament, Shadow rapporteur)

6 Dec 2022 · AVMD

Meeting with Alexandra Geese (Member of the European Parliament, Shadow rapporteur) and Deutsche Welle and VAUNET - Verband Privater Medien e. V.

16 Nov 2022 · Event: The importance of advertising for media freedom

Meeting with Renate Nikolay (Cabinet of Vice-President Věra Jourová)

16 Nov 2022 · Digital transition

Response to Type approval of motor vehicles regarding access to in-vehicle generated data

2 Aug 2022

Bitkom welcomes the EU Commission's initiative with the aim to facilitate the use of data for a smarter, safer, and sustainable mobility ecosystem. However, we would like to also underline that relying on market principles will be key to fostering the enormous potential of data-driven solutions in the field of mobility. Thus, Bitkom advocates for a careful approach to legislative action on access to vehicle data, functions and resources. Our full position can be found attached.
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Meeting with Filomena Chirico (Cabinet of Commissioner Thierry Breton)

30 Jun 2022 · Tour d’horizon of EU digital policies

Response to Sustainable Products Initiative

22 Jun 2022

Bitkom welcomes the European Commission's intention to work towards products that are as sustainable, environmentally conscious and circular as possible. With the revision of the existing ecodesign directive, the European Commission is taking an important step towards a sustainable and climate-neutral Europe. Please find attached our feedback on the Ecodesign for Sustainable Products Regulation Proposal (ESPR).
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Meeting with Despina Spanou (Cabinet of Vice-President Margaritis Schinas)

15 Jun 2022 · Cybersecurity skills

Meeting with Ralf Kuhne (Cabinet of Commissioner Stella Kyriakides)

1 Jun 2022 · VTC meeting on European Health Data Space

German digital association Bitkom urges limits on corporate liability

23 May 2022
Topic — New EU rules requiring companies to address human rights risks in supply chains.
Message — Bitkom requests limiting legal liability to direct suppliers rather than the entire value chain. They also propose including smaller businesses in the scope using a graduated system of obligations.12
Why — This would shield companies from legal responsibility for actions of distant business partners.3
Impact — Victims of human rights abuses by indirect suppliers lose the right to seek damages.4
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Meeting with Tsvetelina Penkova (Member of the European Parliament, Shadow rapporteur for opinion)

18 May 2022 · To discuss the proposal for a Regulation on harmonised rules on fair access to and use of data

Response to European chips act package – Regulation

9 May 2022

Bitkom welcomes the proposal for the EU Chips Act and support the holistic view of the semiconductor value chain reaching beyond the production increase and showing commitment to strengthen chip design competencies and technology transfer in Europe. We call for maintaining general openness of the markets and closer collaboration with like-minded global partners. Europe should focus on growing its excellence in selected most promising segments and creating interdependencies with other economies, instead of interventions via export authorisations and imposing orders prioritisation. We encourage the Chips Act to consider further targeted actions as part of a structured approach to attract and train industry talent throughout the semiconductor ecosystem to meet the large skilled workforce needs. Chapter II: Chips for Europe Initiative - The specific actions under the Initiative should be based on the strategic needs of the downstream industries and with their close engagement. Terms and conditions to access the design capacities and the technology available via virtual platform as well as access to pilot lines should be clarified. - We commend the pronounced focus on scale-ups, SMEs and midcaps, but underline the importance of closely involving larger companies of downstream industries into planned actions to ensure the needed leveraging of technology development in Europe as compared to international competitors. Chapter III: Security of supply - We welcome the approach to incentivize new investments in domestic chips design and manufacturing by enabling public support for the “first-of-a-kind” (FOAK) semiconductor facilities. We propose to adopt further support schemes to provide incentives and competitive advantages over other global regions for the operational phases of FOAK facilities, such as e.g. energy prices, attractive working conditions, or tax incentives. - A key factor in assessing the viability for public support of FOAK projects should be demonstratable qualitative future demand of today's downstream industries in terms of computing power and energy efficiency, as well as the technological requirements of future applications of digital economy. The demand side of the ecosystem should be strengthened and there should be incentives for long-term cooperation between the end user and the production sites in Europe. Chapter IV: Monitoring & Crisis Response - We propose the establishment of a central EU body for the implementation of monitoring & information gathering measures to avoid fragmentation and duplication. The specific scenarios and types of information collected by the Commission should be further defined in the Regulation based on consultation with the industrial stakeholders along the semiconductor value chain and downstream industries. - We call for the further elaboration on specific terms & conditions and feasibility analysis regarding priorisation of crisis-relevant chips in consultation with manufacturing and downstream industries in Europe. - The common purchasing provision should be first analyzed upon its technical feasibility. It will also imply the exchange of highly sensitive information with the central procurement body and could impose further negative effects on global semiconductor supply. We therefore urge to review the proportionality and effectiveness of this provision and to clarify the handling of sensitive data. Chapter V: Governance - The European Semiconductor Board should closely cooperate with industries within the semiconductor ecosystem, including downstream industries. Synergies with the European industrial alliance on processors and semiconductor technologies should be established and parallel structures should be avoided. be avoided.
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Meeting with Rovana Plumb (Member of the European Parliament, Rapporteur)

28 Apr 2022 · ITS Directive Revision

Bitkom warns Data Act may harm innovation without trade secret protections

19 Apr 2022
Topic — The EU Data Act proposal regulates access to and use of data from connected devices.
Message — Bitkom requests excluding trade secrets from sharing obligations and extending the implementation timeline for complex products. They also advocate for reasonable compensation for data holders to maintain investment incentives.12
Why — These changes would lower compliance risks and protect the commercial value of proprietary data.3
Impact — Third-party service providers would face more restricted access to data needed for competing after-market services.4
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Response to Technical requirements for unlimited series, small series, special purpose vehicles and fully automated vehicles

19 Apr 2022

Bitkom welcomes the EU’s initiative to set out clear requirements for the type-approval of automated vehicles. However, the limitation to small series threatens to hamper innovation and the acquisition of valuable experience. Please find attached in more detail our feedback on the draft.
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Response to Update of references in Annexes I and II to the General Vehicle Safety Regvulation

19 Apr 2022

Please find attached our feedback on the draft.
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Response to Amendment to the Regulation (EU) No 1025/2012 European standardisation

7 Apr 2022

Bitkom welcomes the opportunity to provide feedback and thoughts on the European Commission’s legal proposal for amending Regulation 1025/2012 on standardisation as presented together with the European standardisation strategy on 2nd February 2022. Please find attached our position paper.
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Meeting with Norbert Lins (Member of the European Parliament, Committee chair)

22 Mar 2022 · Agriculture

Response to European Digital Identity (EUid)

2 Sept 2021

Bitkom begrüßt den Entwurf der EU-Kommission, da dieser einen weiteren wichtigen Grundstein für sichere digitale Identitäten und Vertrauensdienste in der Europäischen Union legt. Die digitale Souveränität Europas wird gestärkt, indem digitale Identitäten etabliert und diese von EU-Bürgern EU-weit selbstbestimmt genutzt werden können. Bitkom bedankt sich für die Möglichkeit im Rahmen des Konsultationsprozesses Stellung zu nehmen. Die Stellungnahme finden Sie anbei.
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Response to Standardisation Strategy

6 Aug 2021

Bitkom welcomes the European Commission initiative for a standardisation strategy for Europe and appreciates the opportunity to provide feedback to the Roadmap for this initiative. The German ICT industry is highly engaged in standardisation activities, puts significant investment into the development of standards and actively participates to policy and regulatory initiatives related to standardisation at European and national level. We very much value the New Legislative Framework and its processes. Bitkom has several working groups dealing with respective topics, including a working group on standardisation addressing strategic aspects as well as several specific working groups, e.g. on EMC, LVD, product safety, etc. Bitkom also regularly interlocks with the German government on standardisation matters. We supported the initiatives started under the German EU presidency and their continuation. This included work on proposals for a horizontal regulation on cybersecurity and exchange on possible improvements of the processes around the New Legislative Framework (NLF) and on the legal opinion initiated by the German government. Against this background and spectrum of expertise Bitkom provides the following considerations for the Roadmap for a standardisation strategy for Europe. The use of open standards should be a key strategic element for technological sovereignty: Standardisation is key for technological sovereignty. It brings all stakeholders together, including public authorities, for collaborative and transparent technology development. The NLF is at the core of the European Standardisation System: Bitkom welcomes the European Commission’s clarity on the need to further improve the processes around the NLF to prevent blockages and delayed citation. Bitkom also supports that standardisation requests should be open and not too prescriptive. Strong link to international standardisation is important for EU competitiveness: The strength of the European standardisation system is its close linkage to international standardisation. This should further be strengthened, including measures to support participation in international and global standardisation, e.g. with special funding programmes and support actions. Technical specifications from fora/consortia are key for ICT: No ICT infrastructure is possible without using specifications from the leading fora/consortia in ICT like IETF, OASIS, W3C, IEEE or Ecma, in addition to those from the formal standards organizations. It is important to consider these fora/consortia in the context of a standardisation strategy for Europe. The respective specifications are essential for the twin transition as well as in the context of the economic recovery of Europe after the pandemic. Multi-Stakeholder Platform for ICT Standardisation (MSP) is key to support the Twin Transition for the digital decade: The MSP has proven to be of utmost value as an expert group advising the European Commission on ICT standardisation work. Its role should further be strengthened and it should be leveraged for the upcoming challenges of digitalisation. Education and awareness are important: Bitkom supports the expressed need for education and awareness about standardisation. It is important that such education and awareness are broadly organised and that different actors as well as target groups are well defined. Improve processes on the operational side rather than amending Regulation 1025/2012: We don’t see a need to amend the Regulation. Bitkom recommends instead to focus on improvements on the operational side. Ready to support further consultation: Bitkom agrees to the proposal for further stakeholder consultation. We believe the three areas where feedback is sought are comprehensive. Bitkom shall be happy to also contribute and is ready to engage in any further dialogue and exchange.
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Response to Revision of the Machinery Directive

16 Jul 2021

Vielen Dank für die Möglichkeit Stellung zu nehmen zum Vorschlag für die Maschinenverordnung. Aus Sicht des Bitkom wäre es wünschenswert, wenn die im Anhang dargestellten Aspekte bei der geplanten Überarbeitung berücksichtigt werden.
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Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

11 Jun 2021 · EU digital policy priorities

Meeting with Svenja Hahn (Member of the European Parliament, Shadow rapporteur) and Bureau Européen des Unions de Consommateurs and IBM Corporation

27 May 2021 · Artificial Intelligence Act (AIA)

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

9 Apr 2021 · digital finance

Meeting with Dennis Radtke (Member of the European Parliament, Shadow rapporteur)

11 Mar 2021 · Platform work

Response to Legislative framework for the governance of common European data spaces

8 Feb 2021

If done right, the European Commission’s initial proposal on the Data Governance Act (DGA) has the potential to be an important step towards a European data economy. While previous discussions about the use of data have focused primarily on the important topic of data protection, there is an increasing awareness for the innovative potential of data, which is why we welcome that the DGA addresses all types of data (personal, non-personal, government sector and specific data sets). In order to accelerate the digital transformation of European economies, the data economy has to be enabled with a clear and harmonized framework. For that, existing regulations - sector specific and others - need to be carefully assessed to determine which rules are fit for purpose, which need amending and which should be developed into a broader rulebook for the EU’s data economy. It should also be highlighted that the aim is not to have a single integrated data space but to connect various initiatives for data sharing – also across different domains – on a technical level to ensure their interoperability. While the DGA can only be a step in this direction, we welcome the initiative and aim to comment based on 12 principles and some detailed comments in our Position Paper.
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Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

8 Jan 2021 · Various digital issues: digitalisation in response to COVID-19 in Germany, GAIA-X governance & use cases, start-ups, cybersecurity, DSA-DMA, data spaces.

Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis) and Siemens AG and Robert Bosch GmbH

6 Jan 2021 · RRF, industry strategy, digital strategy

Response to Commission Implementing Decision on standard contractual clauses for the transfer of personal data to third countries

10 Dec 2020

We welcome the European Commission public consultation period on the Draft implementing decision and its Annex to discuss the standard contractual clauses (SCCs) for transferring personal data to non-EU countries as this is an important issue and an opportunity for stakeholders across all industries to provide input. Please find attached our detailed Position Paper. If there are any questions or further elaborations are needed please reach out to us.
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Meeting with Axel Voss (Member of the European Parliament)

25 Nov 2020 · Artificial Intelligence

Meeting with Christiane Canenbley (Cabinet of Executive Vice-President Margrethe Vestager), Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

19 Nov 2020 · Gaia X

Meeting with Filomena Chirico (Cabinet of Commissioner Thierry Breton) and Meta Platforms Ireland Limited and its various subsidiaries and

16 Nov 2020 · DSA

Response to Review of the general product safety directive

31 Aug 2020

For Bitkom and its members, the safety of the products placed on the market is the top priority. Therefore the General Product Safety Directive (GPSD) has a high priority for us and we appreciate the opportunity to provide feedback on the roadmap for its revision. Since its enforcement the GPSD has made a significant contribution to the safety of consumer products. The provisions of the GPSD are technology-neutral and cover a wide range of products, especially those that are not within the scope of an EU harmonization directive. Therefore, the GPSD supports innovative and emerging technologies like AI, IoT, Robotics etc. All new innovations/interrelations not in scope of specific safety regulations are already covered by the GPSD and its safety net. An explicit reference to those technologies would inhibit innovation and would require frequent revisions. GPSD and Market Surveillance Regulation (EU) 2019/1020 together allow a coordinated and effective execution of market surveillance and recalls, including online commerce and fulfillment center questions. For the purposes of effective market surveillance and enforcement, and of simplification for economic operators, only the provisions of the Market Surveillance Regulation should apply. Considering all these aspects Bitkom sees no need for a comprehensive revision of the GPSD and prefers the improved implementation and enforcement of the existing legal framework suggested in Option 1. Further guidance and interpretation documents would support the implementation at national and EU level, especially for SMEs.
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Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

23 Jun 2020 · Digital issues

Meeting with Axel Voss (Member of the European Parliament, Rapporteur)

28 May 2020 · AI Civil Liability

Meeting with Phil Hogan (Commissioner) and

7 May 2020 · Digital Trade. Covid -19

Response to Action Plan on the Customs Union

20 Apr 2020

To whom it may concern, We appreciate the opportunity to provide feedback on the Roadmap “Taking the Customs Union to the next level“. First, we would like to express our content to DG TAXUD with the roadmap and its focus on customs risk management and the objective of an EU Level-Playing Field. In order to turn the roadmap into a long-term customs union strategy Bitkom, Germany’s leading digital association representing more than 2,700 companies of the digital economy, would like to emphasize the following points with regards to 1) the risk-based customs management and 2) the necessary EU level playing field. 1. Risk-based Customs Management • Capacity for risk-based customs management using digital tools: Customs authorities need tob e able to perform targeted risk-based customs Management. Importers and Exporters already provide enough data to allow risk-based analysis. Customs authorities need to be enabled to use these data for state-of-the-art risk-based and smart analysis. To this end, the IT infrastructure needs to be improved allowing risk-based approach for inspections and regulatory audits. In addition, staff at customs authorities need to be properly trained risk-based data analysis. • Facilitation of risk-based customs management via company risk profiles: Customs authorities should establish practice oriented company risk profiles, from low to high, considering among others following parameters: majority of the imported goods are duty free (zero rated); legal form of a company is a corporation (saving of import duties does not increase the income of their legal representatives); company does not deal with excise goods; company has implemented an Customs (and Export Control) related customs internal control program;company does participate in security initiatives. • Transparent customs controls: Customs authorities should define nature and frequency of customs controls according to company‘s risk profile. In some cases at the moment, customs authorities repeatedly conduct inspections of the same kind of shipments (same goods) though there were no prior findings. • Trade facilitation to low risk companies: Companies with low risk profles should be eligible for tangible benefits such as simplified procedures and simplified declarations with less data. Also, since the majority of the shipments are repetitive, import and export-declaration should be submitted on monthly basis instead of transaction based declarations. Trusted traders with proper Internal Control Programs should be exempted from transaction based regulatory audits. Instead, the ICP shall be controlled regularly. • Better coordination to avoid redundant audits: Audits conducted by the Federal Office of Civil Aviation is partially redundant with the AEO audit conducted by customs authorities. 2. Necessary EU Level-Playing Field • Harmonize the treatment of AEOs within the EU: Currently AEOs are treated differently by national customs authorities, for examples regarding pertaining inspections or AEO-benefits. There should be an equal level playing field within the EU. • Harmonize treatment of traders within the EU: With regards to regulatory audits and customs declaration topics like goods description or document coding, German companies are faced with stricter interpretation leading to more bureaucratic workload than in other EU countries. There should be an equal level playing field within the EU for all traders. Bitkom remains at your disposal to discuss our recommendations in depth.
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Response to Light deployment regime for small-area wireless access points

2 Apr 2020

Germany’s digital industries association BITKOM supports the joint response by GSMA, ETNO, SCF, DIGITALEUROPE and GSA. In the following we therefore quote the key comments to the EC proposal of Implementing Regulation for SAWAPs and attach the respective document with the proposed amendments as submitted by DIGITALEUROPE, through which we have contributed to and agreed on the joint response. Our organizations welcome the European Commission proposal to give effect to the SAWAP provisions of the EECC to allow harmonized light deployment regimes leveraging simple criteria such as volume, emission power and compliance of SAWAP installation with the applicable European Standards (EN50401 and EN62232). We welcome Recital 16 that allows Member States to adopt less restrictive approaches, noting that many Member States already permit larger volumes or higher powers than those defined in the proposed SAWAP regulation or provide for no restrictions at all indoor as opposed to the proposed SAWAP regulation. Our objective is that the criteria defined in this Implementing Regulation (IR) support the fast deployment of SAWAPs to meet the criteria of broadband objectives of the European Commission. Therefore, we propose changes to strengthen the effectiveness of the proposed measures. 1. The current SAWAPs deployed outdoor or indoor in larger areas such as museums, stadiums, convention centres, airports, metro-transport stations, railway stations, or shopping centres, have an emission power of 10 W or more as defined in 3GPP specifications and as such belong to classes E100 or sometimes E+. Therefore, the criteria for applicability of the IR should be 10 W emission power so that it applies to a wide range of installations. 2. Installation classes E10 and below are generally dedicated to indoor applications and deployed very close to where people work and live. Therefore, limiting the applicability of the draft IR to class E10, corresponding to emission power 0.5 W, which is similar to a mobile phone, means that it will have very limited potential benefit for stakeholders in real world deployments. 3. The proposed volume of 20 litres applies to limited functionality SAWAP that can serve a single mobile radio access technology in a single sector, potentially across multiple bands, excluding the auxiliary equipment (for example, the power supply) that is not part of the 20 litres. 4. A minimum volume of 50 litres is required to support multi-technology or multi-operator SAWAP. Unless this is permitted, we will see a negative business impact on small cells deployment (and future synergetic usage of co-located technologies like cellular vehicle-to-everything) and an overall risk of Europe falling behind other regions. 5. The proposed IR will have to be updated shortly after the update of EN62232 in order to incorporate the simple deployment criteria for active antenna systems (AAS) for example those using millimetre waves. We recommend to review the provisions of the IR six months after publication of the updated EN62232. The attached document sets out the proposed amendments.
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Response to Evaluation of the Electromagnetic Compatibility Directive

20 Feb 2020

Bitkom begrüßt die Möglichkeit, Feedback zur Roadmap für die Evaluierung der EMV-Richtlinie zu geben. Für Bitkom und seine Hardware produzierenden Mitglieder ist die EMV-Richtlinie einer der wichtigsten regulatorischen Bausteine zur Bewertung der Konformität von Produkten, die auf dem europäischen Markt in Verkehr gebracht werden. Die derzeitige Ausgabe der EMV-Richtlinie ist erst seit April 2016 in der Anwendung und hat aus unserer Erfahrung zu keinen nennenswerten Problemen geführt. Aus unserer Sicht ist die Richtlinie immer noch zweckmäßig. Sie ist effektiv, effizient und kohärent und bietet einen Mehrwert für Hersteller, Behörden und Anwender gleichermaßen. Aus übergeordneter Sicht ist die Richtlinie seit ihrer letzten Überarbeitung im Jahr 2014 als Teil des NLF-Anpassungspakets erfolgreich an den NLF angeglichen worden. Grundsätzlich weisen die an den NLF angeglichenen Richtlinien auf Grund der Referenzklauseln des Beschlusses 768/2008/EG eine gewisse Redundanz auf. Dennoch halten wir die derzeitige Modularität der EU-Produktgesetzgebung für sinnvoll und befürchten, dass jede Art von Zusammenlegung mit anderen Richtlinien, wie der Funkanlagenrichtlinie, zu Verwirrung, Komplexität oder sogar zu einem Bruch führen könnte. Was die sektorspezifischen Aspekte betrifft, so sind uns die Diskussionen in der EMV-Arbeitsgruppe über Kabel (genauer gesagt "konfektionierte Kabel" oder RMCD) bekannt. Kabel (mit Ausnahme von speziellen Kabeln und solchen mit aktiver Elektronik) sind auf Grund ihrer technischen Beschaffenheit nicht EMV relevant. Daher sollte die Aussage in Artikel 2(2)(d), dass solche Bauteile nicht in den Anwendungsbereich der EMV fallen, in der Richtlinie verbleiben. Die Anwendung von rechtlichen EMV-Festlegungen auf Kabel selbst wäre nicht zielführend. Zusammenfassend sehen wir keinen zwingenden Grund, der eine Revision der EMV-Richtlinie zum jetzigen Zeitpunkt rechtfertigen würde. Wir sind gerne bereit, zusätzliche Beiträge zum laufenden Evaluierungsprozess zu leisten und stehen für weitere Diskussionen zur Verfügung.
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Response to European Partnership on High Performance Computing

27 Aug 2019

Bitkom wishes to express its support towards evolving the EuroHPC Joint Undertaking into a European Partnership on High Performance Computing in the context of the next Multi Annual Financial Framework (MFF). For the roadmap at hand, we see great potential, but also room for improvement in certain areas. That includes especially industrial needs, which are mentioned in the roadmap, but not substantiated. Also, the term HPC is mostly reduced to supercomputers. We do not consider the sole acquisition of supercomputers a sustainable way to address HPC needs. Rather, all forms of HPC should be addressed, including the pooling of cloud resources, graphic processor arrays and, in the future, quantum computers as well. On July 26, 2018, Bitkom has published a position paper on the implementation of EuroHPC (https://www.bitkom.org/sites/default/files/file/import/Bitkom-Position-Euro-HPC.pdf, in German). It lists requirements for a successful implementation of the EuroHPC Joint Undertaking. In reference to that publication, the following points should be considered: 1) To precisely specify focal scientific and industrial application sectors that are in line with major European industrial competencies and scientific strengths before the acquisition of hardware, to make sure that the acquisition matches the needs 2) To support the development of HPC software technologies in addition to the hardware developments with an equal focus on both aspects 3) To foster initiatives across the entire supply chain (hardware, software, applications), considering their applicability for real industrial use cases instead of synthetic benchmarks 4) To encourage collaboration with international academic and industrial technology partners 5) To precisely set the goals for the initiative including the definition of appropriate key performance indicators, measuring the scientific and economic impact as a prerequisite to major spending 6) To facilitate the use of EuroHPC resources for the industry, in particular for SMEs 7) To encourage and support the participation of SMEs in the implementation of EuroHPC’s goals 8) To work towards transparency, appropriate consideration of industrial needs and openness in the calls and tenders of the initiative For the next MFF, EuroHPC aims at “deploying a world-class exascale and post-exascale” infrastructure, which is supported by a “leading innovation ecosystem”. We are convinced that such ambitious goals within the next MFF can only be achieved, when adhering to our requirements listed above.
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Meeting with Carl-Christian Buhr (Cabinet of Commissioner Mariya Gabriel)

26 Aug 2019 · Digital Strategy

Meeting with Michael Hager (Cabinet of Vice-President Günther Oettinger)

28 Jun 2019 · digital policy

Meeting with Ann Mettler (Director-General Inspire, Debate, Engage and Accelerate Action)

28 Jun 2019 · Digital Sovereignty

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology) and Bundesverband der Deutschen Industrie e.V.

5 Apr 2019 · Exposure of 5G Infrastructure

Meeting with Maximilian Strotmann (Cabinet of Vice-President Andrus Ansip)

26 Mar 2019 · Governance in digital policy, data, artificial intelligence

Response to Specifications for the provision of cooperative intelligent transport systems (C-ITS)

8 Feb 2019

Background The Commission has recently published a Draft Act for the ‘Delegated Directive Specifi-cations for the provision of cooperative intelligent transport systems (C-ITS)’ for public consultation. In particular, with a view to future autonomous driving and a corresponding traffic control, the delegated act will define how the communication bet¬ween vehicles and with the surrounding infrastructure should be carried out. Bitkom has continuously commented on this important topic and would like to share its views on the current draft Delegated Act: Comments Bitkom supports the Commission's objectives to use a delegated act to optimize the safety, efficiency and environmental impact of future traffic flows through the use of intelligent digital technologies. However, Bitkom would like to point out some important points that should be taken into account in order to ensure a future poof legislation enabled by a technology neutral approach: 1. Safeguarding a technology neutral approach Under the C-ITS Directive (Directive 2010/40 / EU), the envisaged delegated act should not prescribe any single concrete communication technology.* Based on day-1 / day 1.5 use cases, it should rather focus on the communication requirements between participating road users (vehicles, infrastructure, other road users, etc.). With regard to the draft act especially the followings provisions need to be amended to achieve a technology neutral regulation: - The objectives “continuity, compatibility and interoperability” as in particular referenced within Article 33 (3) should be applied in a way, that technology neutrality regarding these objectives can be achieved, for example on use-case or application level. - The annex with the list of 802.11p specifications should be accompanied by a similar list of specifications for LTE-V2X in another annex. Alternatively the list of specifications could be deleted from the act and requirements for communica-tion and interoperability formulated, leaving the concrete specification details to standardisation bodies. 2. Ensuring comprehensive connectivity Care should be taken to ensure that the delegated act does not only refer to short-range communication, but also considers network-based communication. The compatibility of the required communication technologies (for example LTE, LTE-V2X and ETSI ITS-G5) should be ensured. To achieve this goal special attention should be given to amend the following provisions: - Introduce the understanding of “mutual” to the requirement of compatibility and interoperability (refer to article 33) - Extend the definitions of a C-ITS station (Article 5, requirements of an C-ITS sta-tion) by long range communication in OBU’s and RSU’s (in addition to 2nd bullet under 1) 3. Allowing technology innovation The specifications could be set according to the model of the New Legislative Framework through harmonized standards. This would make it easier to adapt to new technical de-velopments without having to amend the regulation. * Some member companies of Bitkom are supporting the draft Delegated Act as it represents a step forward towards enabling mobility. The draft Delegated Act provides legal certainty to ensure interoperability, compatibility and continuity of services. They support the draft Delegated Act regarding technology development as it allows a prompt deployment today while it leaves the door open for further innovation in Europe.
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Meeting with Maximilian Strotmann (Cabinet of Vice-President Andrus Ansip) and Wirtschaftskammer Österreich

11 Jan 2019 · ePrivacy, AI, open data

Meeting with Günther Oettinger (Commissioner)

8 Oct 2018 · MFF and Digital

Response to Fairness in platform-to-business relations

29 Jun 2018

Bitkom appreciates the opportunity to give feedback on the Proposal for a Regulation on Promoting Fairness and Transparency for Users of Online Intermediation Services, voicing the consolidated opinion of its affected members as stated in the attached position paper.
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Response to Targeted revision of EU consumer law directives

21 Jun 2018

Bitkom would like to thank the EU Commission for the opportunity to comment on the recent Proposal of the New Deal for Consumers and would like to give feedback in detail in the attached position paper.
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Response to Review of Regulation on cross-border payments

12 Jun 2018

Please view the attached position paper for the detailed Bitkom position on the proposed review of the regulation on cross-border payments. About Bitkom: Bitkom represents more than 2,500 companies of the digital economy, including 1,700 direct members. Through IT- and communication services only, our members generate a domestic turnover of 190 billion Euros per year, including 50 billion Euros in exports. Members of Bitkom employ more than 2 million people in Germany. Among the mem-bers are 1,000 small and medium-sized businesses, over 400 startups and nearly all global players. They offer a wide range of software technologies, IT-services, and tele-communications or internet services, produce hardware and consumer electronics, operate in the sectors of digital media or are in other ways affiliated to the digital economy. 80 percent of the companies’ headquarters are located in Germany with an additional 8 percent each in the EU and the USA, as well as 4 percent in other regions.
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Response to Fair taxation of the digital economy

16 May 2018

Bewertung des Vorschlags für eine digitale Präsenz Im Grunde genommen geht es bei den Regelungen zur digitalen Präsenz darum, das Besteuerungssubstrat zwischen allen Staaten, in denen ein multinationales Unternehmen Geschäftstätigkeiten entwickelt, neu zu verteilen. Dabei soll der Staat, in dem digitale Leistungen angeboten werden (Marktstaat), zulasten des Sitzstaates eines Unternehmens einen größeren Anteil am Besteuerungssubstrat bekommen. Fraglich ist zum einen, ob hierfür neue Besteuerungstatbestände mit entsprechenden (für Unternehmen bürokratielastigen) Vorgaben für Gewinnermittlung und Gewinnaufteilung geschaffen werden müssen, oder ob nicht eine Verständigung der beteiligten Staaten über die Aufteilung des nach bisherigen Grundsätzen ermittelten Gewinns ausreicht. Zum anderen ist fraglich, ob eine höhere Besteuerung rein digitaler Aktivitäten steuersystematisch gerechtfertigt werden kann. Denn maßgebliche Rechtfertigung für die Erhebung einer Steuer ist die Notwendigkeit, vom Besteuerungsstaat bereit gestellte Infrastruktur für die Unternehmenstätigkeit zu finanzieren. Unternehmen, die nur digital über das Internet oder andere Netze agieren, nehmen aber kaum oder gar nicht Infrastruktur des Marktstaates in Anspruch. Mit der Einführung einer digitalen Präsenz soll die Besteuerung besser berücksichtigen, dass die Nutzer in dem Staat einer digitalen Präsenz durch Bereitstellung ihrer Daten zum Gewinn aus einer digitalen Dienstleistung beitragen. Wertbeitrag und Bedeutung von Nutzerdaten sind jedoch je nach Geschäftsmodell sehr verschieden und für Besteuerungszwecke nicht einheitlich ermittelbar. An diesen Schwierigkeiten einer angemessenen steuerlichen Bewertung ändert auch die Einführung einer digitalen Präsenz und die damit einhergehende Neujustierung der Verrechnungspreisvorgaben nichts. Denn die entsprechenden Vorschläge der EU-Kommission enthalten keine Hinweise oder Kriterien für eine angemessene Bemessung des Wertbeitrages durch Daten. Nicht geklärt sind außerdem die Probleme einer zunehmenden Doppelbesteuerung. Denn neben einer höheren Steuerlast im Staat einer digitalen Präsenz besteht weiterhin im Sitzstaat des Unternehmens, zu dem die digitale Präsenz gehört, ein Steuerzugriff auf den Gewinn des Unternehmens. Überlegungen, wie der Gefahr einer zunehmenden Doppelbesteuerung zu begegnen ist, finden sich jedoch nicht im Vorschlag der Kommission.
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Response to Fair taxation of the digital economy

15 May 2018

Bitkom unterstützt das Anliegen, etwaige Konsequenzen aus der zunehmenden Digitalisierung der Wirtschaft für eine sachgerechte internationale Besteuerung zu ziehen, damit alle Unternehmen auch künftig fair und gleichmäßig besteuert werden. Dieses Ziel wird aber durch eine Sondersteuer auf einige digitale Geschäftsmodelle konterkariert. Die Einführung einer solchen Sondersteuer wirft viele Probleme auf und löst keines. Dies gilt für die Ausgestaltung des vorgesehenen Konzepts, seine Rechtfertigung und den allein auf Europa beschränkten Regelungsansatz. Zunächst kann der vorgeschlagene Besteuerungstatbestand weder eindeutig der Umsatzsteuer noch eindeutig der Ertragsteuer zugeordnet werden. Diese Zwitterstellung führt dazu, dass die Steuer nicht in das System der bestehenden Doppelbesteuerungsabkommen passt. Eine Doppelbesteuerung ist entsprechend vorprogrammiert. Auch ist das Motiv für eine solche Steuer zweifelhaft bzw. zwischenzeitlich entfallen. Ihre geplante Einführung wird u.a. damit begründet, dass US-amerikanische Technologiekonzerne durch das Steuerrecht der USA begünstigt seien und dadurch Wettbewerbsvorteile gegenüber europäischen Unternehmen hätten. Mit der zum 1.1.2018 in Kraft getretenen Steuerreform in den USA wurde diese Begünstigung – wenn sie denn überhaupt je bestanden haben sollte – jedoch aufgehoben. Die neuen Regeln zur Unternehmensbesteuerung in den USA umfassen u.a. eine Hinzurechnungsbesteuerung für bestimmte niedrig besteuerte Auslandseinkünfte (Besteuerung von Global Intangible Low-Taxed Income – GILTI). Des Weiteren trifft eine Sondersteuer für digitale Geschäftsmodelle jedes Unternehmen, das den vorgesehenen Besteuerungstatbestand verwirklicht. Dabei kommt es nicht darauf an, wo das Unternehmen seinen Sitz hat. Es werden also auch europäische Unternehmen getroffen, wenn diese die vorgesehenen Umsatzgrenzen überschreiten. Vielleicht ist die Anzahl der von der Sondersteuer betroffenen europäischen Unternehmen derzeit noch nicht so hoch. Aber Geschäftsmodelle mit Daten entstehen und wachsen aktuell überall in Europa. Eine drohende steuerliche Sonderbelastung führt nicht zu gleichen Wettbewerbsbedingungen für diese Geschäftsmodelle, sondern wirft sie gegenüber Konkurrenten aus anderen Staaten eher wieder zurück, insbesondere, weil die Gewinnmarge junger Unternehmen noch nicht so hoch ist wie die etablierter Unternehmen. Daher sollte das Konzept zumindest die volle Anrechnung der Digitalsteuer auf in Europa gezahlte Ertragsteuern vorsehen und nicht lediglich eine Berücksichtigung der Sondersteuer als Betriebsausgabe. Weit besser wäre, keine neue Sondersteuer in der EU einzuführen, sondern eine international abgestimmte Lösung auf Ebene der OECD zu finden. Der Weg zu einer fairen und gleichmäßigen Besteuerung international tätiger Unternehmen führt nur über die OECD. Nur eine OECD-Lösung lässt die Hoffnung, Doppelbesteuerung internationaler Geschäftsaktivitäten wenigstens zu begrenzen. Zu berücksichtigen ist auch, dass die Vereinbarkeit einer Sondersteuer mit WTO-Regeln noch nicht überprüft wurde. Bei einem Verstoß wären Reaktionen anderer Länder berechtigt und zu erwarten. Letztlich ist schon der Ansatz einer Sondersteuer für digitale Geschäftsmodelle kaum mit dem Ziel vereinbar, Europa bei der Digitalisierung voranzubringen.
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Response to Legislative proposal for an EU framework on crowd and peer to peer finance

9 May 2018

*For more detailed elaboration please view the position paper attached to this feedback* We strongly believe in the benefit of European regulation for crowdfunding services. In many European markets SMEs are traditionally underserved when it comes to accessing finance. While banks turn away from small business loans, credit platforms can connect investors and borrowers. EU-wide regulation will help to create a level playing field and allow platforms to expand within the Single Market. We believe that only a harmonised European set of rules can create robust standards for investor protection and risk management. However, in its current form, the ESCPR does not provide an attractive licensing option for most crowdfunding service providers, in particular not for platforms domiciled in Germany. The ECSPR in its current form will not be attractive for the vast majority of the crowdlending industry, since it does not provide adequate investor protection and impedes the development of the innovative, customer-friendly products which customers expect. It also falls short in terms of customer protection and requirements for risk management and market integrity. We would like to highlight the following issues of the current ECSPR draft: • The ECSPR is drafted for equity-based crowdinvesting and partly unsuitable for the area of crowdlending • The restriction to transferable securities and loans is problematic • The information requirements on individual projects are not suitable for crowdlending • Supervision by ESMA and the legal recourse to the ECJ overlap with national regulators in payment services and result in unnecessary complexity • Relevant topics are neglected, such as risk management and transparency of loan book performance • The regulatory implications on investors and borrowers in Germany need to be clarified We believe that the ECSPR could be a success for all stakeholders if these issues are addressed. To this end, we suggest the following measures: • To clarify that additional national license requirements for investors and borrowers in the context of loan origination do not apply in the context of the ECSPR; • To include minimum requirements for credit platforms in order to ensure professional credit analysis and a professional management of credit risks and operational risks; • That the KIIS requirement (Art 16) is not applied to credit platforms (or crowdlending providers); • That credit platforms are obliged to disclose performance data of the loans they have generated and further information, possibly in the form of a “key information sheet for credit platforms”; • To extent the scope of the ECSPR to all financial assets incl. loan receivables and not just transferable securities; • That the KIIS requirement (Art 16) is not applied to credit platforms (or crowdlending providers); • That credit platforms are obliged to disclose performance data of the loans they have generated and further information, possibly in the form of a “key in-formation sheet for credit platforms”; • To include minimum requirements for credit platforms in order to ensure professional credit analysis and a professional management of credit risks and operational risks; • To align competencies under the ECSPR with the MiFID rules; • To amend Art 9 and leave the rules on payment services to each member state based on the Payment Services Directive; • To allow balance sheet investments for credit platforms if they are fully disclosed and non-discretionary; • To allow investments by employees if they are subject to strict conflicts of interest management and fully disclosed; • We suggest obliging credit platforms to take precautions against business interruptions including business continuity plan and investor protection arrangements in insolvency scenarios; • We suggest including crowdfunding service providers as obliged parties in the national rules for anti-money laundering and counter-terrorism financing.
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Response to Measures to further improve the effectiveness of the fight against illegal content online

29 Mar 2018

On 2018, March 1 the European Commission has published its Recommendation on measures to effectively tackle illegal content online. Bitkom appreciates the opportunaty to give feedback on the Recommendation as well as on the inception impact assessment to further improve the effectiveness of the fight against illegal content online. Please find Bitkom's comments in the attached position paper.
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Response to Energy labelling requirements for computers and computer servers

9 Mar 2018

Estimated savings, complexity & duty cycle Industry would caution on the increase of the estimated energy saving potential. Projecting PC usage and energy consumption growth to 2030 is meaningless; projections involving digital technology further than five years ahead provides no degree of accuracy or certainty. When considering the EU’s own estimated sales figures from PRODCOM it shows a leveling/downward trend in sales numbers for Notebooks (NB) and Desktop (DT) PCs, this is certainly a true reflection of the market over the past few years, we continue to see a declining market in the EU. Further, it’s estimated that implementation of CEC regulation and ENERGY STAR (E*) v7.0 specification will result in approximate energy efficiency improvements in Idle power of 50% for DT/AIO and NB PCs respectively. Future improvement potential will, however, diminish over time with only marginal incremental improvements in energy efficiency. The last stakeholder meeting provided some rough estimates of active usage patterns from ONE E*compliant NB. The conclusions suggest that “estimates around how long PCs are used for vary considerably across different studies even for the same type of PC (e.g. desktop PC)”. No data exists to quantify a creditable estimate of the duty cycle of either NBs or DTs assuming a number of usage patterns. A comprehensive duty cycle and power study assessing the significance of active power is necessary to determine active power as significant, selection of the right workloads will also be a challenge to properly measure active mode power of PCs. Without such a study, proposing an energy label based on active power metric is premature. Bitkom would be interested in providing support to such a study that the EC initiates to assess the usage patterns and characterize a typical duty cycle from various power modes including active, idle (short & long), sleep and off. Consideration on the Energy Label Introducing a PC Energy Label would be a complex exercise, high configurability of PC products based on active performance requires specific analysis. The existing E* label remains a well established and effective scheme for product differentiation. The E* programme serves as a significant global standard for the ICT sector, providing a stable regulatory framework and harmonization of methodologies. Furthermore the E* criteria have proven to be one of the main criteria supporting European GPP. Noting the termination of the EU-US Agreement, the ICT Industry remains committed to the E* criteria development and its continued basis for the PC regulatory review. Scope Industry cannot support a proposal to move tablets from the regulation. There are now a number of “hybrid devices” in the market which combine NB and tablets. Customer acceptance will increase further innovative designs. Legal uncertainty for such devices is a risk if regulated by 2 different regulations with differing requirements. Material Efficiency The IT industry had submitted comments to the draft report "Analysis of material efficiency aspects of PC product group" in February ‘17. Some of these comments have been integrated into the final report, but many proposed measures to improve the material efficiency of PCs still lack practicability and present significant documentation and manufacturing effort with no added value. Namely, the industry is concerned that labelling requirements for product parts (e.g. plastics, batteries) and information requirements on materials (e.g. CRM) will not be effective to improve material recovery rates as state of the art WEEE sorting and recycling processes make no use of the information. Industry questions whether consumers seek technical performance details such as the IP class of a device, or the battery management features. Material efficiency measures should be practicable, consistent and result in quantifiable environmental benefits.
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Response to Review of ecodesign requirements for computers and computer servers

9 Mar 2018

Estimated savings, complexity & duty cycle Industry would caution on the increase of the estimated energy saving potential. Projecting PC usage and energy consumption growth to 2030 is meaningless; projections involving digital technology further than five years ahead provides no degree of accuracy or certainty. When considering the EU’s own estimated sales figures from PRODCOM it shows a leveling/downward trend in sales numbers for Notebooks (NB) and Desktop (DT) PCs, this is certainly a true reflection of the market over the past few years, we continue to see a declining market in the EU. Further, it’s estimated that implementation of CEC regulation and ENERGY STAR (E*) v7.0 specification will result in approximate energy efficiency improvements in Idle power of 50% for DT/AIO and NB PCs respectively. Future improvement potential will, however, diminish over time with only marginal incremental improvements in energy efficiency. The last stakeholder meeting provided some rough estimates of active usage patterns from ONE E*compliant NB. The conclusions suggest that “estimates around how long PCs are used for vary considerably across different studies even for the same type of PC (e.g. desktop PC)”. No data exists to quantify a creditable estimate of the duty cycle of either NBs or DTs assuming a number of usage patterns. A comprehensive duty cycle and power study assessing the significance of active power is necessary to determine active power as significant, selection of the right workloads will also be a challenge to properly measure active mode power of PCs. Without such a study, proposing an energy label based on active power metric is premature. Bitkom would be interested in providing support to such a study that the EC initiates to assess the usage patterns and characterize a typical duty cycle from various power modes including active, idle (short & long), sleep and off. Consideration on the Energy Label Introducing a PC Energy Label would be a complex exercise, high configurability of PC products based on active performance requires specific analysis. The existing E* label remains a well established and effective scheme for product differentiation. The E* programme serves as a significant global standard for the ICT sector, providing a stable regulatory framework and harmonization of methodologies. Furthermore the E* criteria have proven to be one of the main criteria supporting European GPP. Noting the termination of the EU-US Agreement, the ICT Industry remains committed to the E* criteria development and its continued basis for the PC regulatory review. Scope Industry cannot support a proposal to move tablets from the regulation. There are now a number of “hybrid devices” in the market which combine NB and tablets. Customer acceptance will increase further innovative designs. Legal uncertainty for such devices is a risk if regulated by 2 different regulations with differing requirements. Material Efficiency The IT industry had submitted comments to the draft report "Analysis of material efficiency aspects of PC product group" in February ‘17. Some of these comments have been integrated into the final report, but many proposed measures to improve the material efficiency of PCs still lack practicability and present significant documentation and manufacturing effort with no added value. Namely, the industry is concerned that labelling requirements for product parts (e.g. plastics, batteries) and information requirements on materials (e.g. CRM) will not be effective to improve material recovery rates as state of the art WEEE sorting and recycling processes make no use of the information. Industry questions whether consumers seek technical performance details such as the IP class of a device, or the battery management features. Material efficiency measures should be practicable, consistent and result in quantifiable environmental benefits.
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Response to Evaluation of the Low Voltage Directive 2014/35/EU

27 Nov 2017

Bitkom welcomes the opportunity to provide feedback to the evaluation and fitness check of the Low Voltage Directive (2014/35/EU) and to share its views on the Commission’s paper on the roadmap (Ref. Ares(2017)5291384 - 30/10/2017) as follows: The LVD is one of the most essential EU-Directives for our members. The stability of the LVD allows them a foresighted and sustainable product development and planning. The LVD is aligned with the New Legislative Framework. This allows an efficient and coherent application of other Directives in parallel such as the EMC Directive. We neither see a reason nor an indication to revise the well-established LVD. Bitkom does not see any evidence that the current LVD is not achieving its objectives in an efficient, coherent and relevant way. Bitkom is not aware of any new hazards that do not fit into available safety objectives. Additionally, Bitkom doesn`t see any reason to change the existing voltage ratings. Including products with less than 50 VAC or 75 VDC in the scope of the LVD would not have a benefit for the safety & health of the users of electrical equipment. For Products operated below the voltage limits of LVD, safety requirements are covered by GPSD (where harmonized standards for safety exist) and increasingly by RED in case of radio equipment (where harmonized standards for safety are expected soon). Therefore, Bitkom does not see a lack of safety regulations for products placed on the Union market. When it comes to safety requirements, the LVD is coherent with the Machinery Directive and the Radio Equipment Directive. Safety requirements are not part of the Electromag-netic Compatibility Directive and the Eco-Design-Regulation, so coherence is unproblematic in this regard. Inconsistencies regarding the scope might be based on formulations in other Directives. Bitkom also does not see an unclear demarcation between the LVD and the MD with regard to the definition of industrial printers. If such unclear demarcation exist, guidelines would be more appropriate to address this issue rather a revision of the LVD. The Machinery Directive Guide can be used as a tool to answer potential open questions. Bitkom thinks that the LVD is also fit for future. The mentioned technological progress and in particular the digitalisation of the electrical devices and household appliances and the integration of the so-called Internet of Things does not introduce new hazards on product level that would not fit into the available safety objectives of the LVD. Bitkom does not see that an increased number of safeguard clause notifications and ob-jections to harmonised standards might indicate the need for a revision of the scope, the safety objectives and their links with the related procedures of the LVD. The safeguard clause notifications reflect the failure of products to meet the safety objectives of the LVD, not any failing of the LVD itself. This may indicate a need to strengthen market surveillance, not a need to revise the LVD. The provided numbers, which are extremely low in relation to the enormous number of products on the EU market, and indeed also in relation to the wide scope of the LVD (reflected by the large number of harmonized stand-ards), rather proves the opposite. The LVD is effective in achieving its safety objectives. The objections to harmonised standards reflect the possible inadequacy of the standards to fulfil the requirements of the LVD, not any inadequacies in the LVD itself. This does not indicate a need to revise the scope or safety objectives of the LVD. Bitkom objects the need of addressing the safety requirements for after-sales services in the LVD. This would lead to a fundamental change of the New Legislative Framework and all related Directives.
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Response to Legislative proposal for an EU framework on crowd and peer to peer finance

24 Nov 2017

Bitkom, the German digital association, supports the EU Commission's plan to develop an EU-wide framework. This framework must be proportionate. It must also promote the growth of this young industry. We believe that this would benefit small businesses and the economy in general. A single EU-wide framework would make it easier for platforms to build a scalable and consistent solution and customer experience. In the United Kingdom, it could be seen that the introduction of a tailor-made regulatory framework for peer-to-peer loans has contributed to the introduction and maintenance of high standards in this sector. It has also created jobs and contributed to economic growth. To obtain the expected impact on the economy and society, however, it would be important that – whilst bringing forward sufficient standards to ensure investor protection and sector integrity – any such regime is sufficiently tailored to the requirements of platform businesses that are operating or that will commence operations. We believe it is extremely important that the differences between credit and equity fi-nancing platforms should be reflected in all legislative proposals. There is clearly a place for both equity and loan funding for small and medium sized businesses, but – due to the differences in the nature, purpose and risk profile of these funding methods – we strongly believe that complementary but distinct regimes are necessary.
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Meeting with Maximilian Strotmann (Cabinet of Vice-President Andrus Ansip)

30 Jun 2017 · DSM mid-term review

Response to Ecodesign requirements for electronic displays

17 Jan 2017

The draft regulation “Ecodesign requirements for electronic displays” (Lot 5) published by the European Commission on December 21, 2016 not only repeals regulation 642/2009 and adopts new energy efficiency, resource efficiency and information requirements, but also substantially broadens the scope of the regulation to any products with a display larger than 1 square diameter (preamble item 11 and 14). As a result and according to this definition, this draft regulation also amends Regulation 617/2013 “Ecodesign requirements for computers and computer servers” (Lot 3) and Regulation 1275/2008 “Ecodesign requirements for stand-by and off mode electric power consumption” as the new Lot 5 resource efficiency and information requirements are applicable to e.g. Lot 3 products, including portable computers and all-in-one computers. Better Regulation is a priority of Commission President Juncker and his team. In the Better Regulation Guidelines (9 July 2015), the European Commission stated that it believes in the importance of “working to ensure that political decisions are prepared in an open, transparent manner, informed by the best available evidence and backed by the comprehensive involvement of stakeholders.” The process of preparing the Lot 5 draft regulation has regrettably not been up to this standard. BITKOM objects to this draft regulation due to its lack of adherence to the European Commission’s Better Regulation commitments, namely: 1) inadequate impact assessment of the scope expansion; 2) insufficient stakeholder consultation; and 3) double regulation. 1. The European Commission should follow the procedures outlined in Directive 2009/125/EC and not regulate products without prior scientific impact assessment. According to Article 15 of Directive 2009/125/EC an implementing measure should be prepared by an assessment to evaluate the impact on the environment, innovation, market access and costs and benefits. In preparation for this draft regulation, the European Commission assessed televisions and computer displays, but did not carry out an impact assessment on all products with a display larger than 1 square diameter (e.g. Lot 3 products). This draft regulation is therefore not based on the procedural requirements of Directive 2009/125/EC and the extension of product scope cannot be substantiated by a scientific impact assessment. 2. A previous draft of the Lot 5 regulation published for a consultation forum in December 2014 was significantly less extensive in terms of the scope of products covered by the regulation and the proposed resource efficiency requirements. The extension of scope in this final draft regulation is a significant deviation from the draft published in December 2014, which explicitly excluded “any display integrated into battery-powered products designed for mobility and primarily powered by an internal battery” from the scope of the regulation. The industry did not have an opportunity to prepare for, comment on and assess the impact of the extension of scope of the Lot 5 regulation to Lot 3 products. 3. Products should not be regulated in multiple implementing measures and all requirements (energy efficiency, resource efficiency and information requirements) should be incorporated into their product specific regulations (e.g. a portable computer should be regulated by Lot 3 for all requirements, instead of Lot 3 for energy efficiency and Lot 5 for resource efficiency and information requirements). Products covered by a Voluntary Agreement shall be also out of scope of this regulation. Bit strongly calls upon the European Commission to limit the scope of this final draft regulation to televisions and computer displays i.e. products that were assessed in the regulatory process (see 2.). BITKOM asks the European Commission to amend the scope and content of this draft regulation accordingly, respect the regulatory process outlined in Directive 2009/125/EC and avoid double regulation.
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Meeting with Michael Hager (Digital Economy)

16 Sept 2016 · DSM

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8 Sept 2016 · Dual use

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