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DRAFT OPINION (COM(2023)0637 – C90464/2023 – 2023/0463(COD))

On the proposal for a directive of the European Parliament and of the Council establishing harmonised requirements in the internal market on transparency of interest representation carried out on behalf of third countries and amending Directive (EU) 2019/1937

JURI-PA-759900

Committee on Legal Affairs · Rapporteur: Guy Lavocat

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The draft opinion amends the proposed directive on transparency of interest representation by third countries, extending its scope to indirect influence and requiring registration in each member state where activities occur. It deletes provisions on maximum harmonisation and single registration, increases financial sanctions, and strengthens investigative powers of national authorities.

Committee position. The Committee on Legal Affairs proposes amendments to extend the directive's scope, require registration in each member state, delete maximum harmonisation, and increase sanctions.

Key points

  1. Extends the definition of interest representation activity to include direct or indirect influence, targeting elections or public decisions, and forms like cultural or religious exhibitions, networks, and university or think tank activities.
  2. Requires registration in the national register of each member state where representation activities are performed, not just where the entity is established.
  3. Deletes the provision that entities registered in one member state need not register in others.
  4. Deletes Article 4 on level of harmonisation, allowing member states to maintain or introduce stricter transparency measures.
  5. Changes the definition of interest representation service provider to provider of an activity, and clarifies that activities are provided to promote the third country entity's interests.
  6. Excludes member countries of the European Economic Area from the definition of third country entity.
  7. Deletes the definition of ancillary activity and its exemption from scope.
  8. Requires authorities responsible for national registers to be independent.
  9. Requires member states to make every effort to set up one-stop shops for registration in several national registers.
  10. Gives national authorities inquiry and investigative powers and sufficient resources.
  11. Deletes provisions on cross-border requests for records between supervisory authorities.
  12. Increases maximum financial sanctions to 6% of annual turnover or budget, and EUR 30 000 for natural persons.

Who is affected

  • Entities performing interest representation on behalf of third countries in the EU must register in each member state where they operate.
  • National authorities gain investigative powers and must be independent for register maintenance.
  • Member states with existing transparency mechanisms can keep or strengthen them.

Figures and deadlines

  • 6% of annual worldwide turnover for undertakings, 6% of annual budget for other legal entities, EUR 30 000 for natural persons.