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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-769946

Committee on Legal Affairs · Rapporteur: Pascale Piera

✦ In short · AI summary of this text, generated 5 Sept 2026

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This draft opinion proposes amendments to the directive on transparency of interest representation by third countries, aiming to ensure minimum harmonisation, remove the European Interest Representation Number, strengthen national authorities' powers, and allow criminal sanctions.

Committee position. The Committee on Legal Affairs proposes amendments to the Commission's proposal to ensure minimum harmonisation, remove the EIRN, strengthen national authorities' powers, and allow criminal sanctions.

Key points

  1. Changes the level of harmonisation to a minimum, allowing Member States to adopt or maintain more stringent provisions for a higher level of transparency.
  2. Removes the unique European Interest Representation Number (EIRN) system; entities register in each Member State where they operate.
  3. Deletes provisions on ancillary activities and the definition of ancillary activity.
  4. Requires entities to keep records for at least 4 years and to draw up reports on a quarterly basis.
  5. Allows Member States to use existing national registers and requires entities to register in each Member State where they operate.
  6. Removes the requirement for entities not established in the Union to register in the Member State of their legal representative.
  7. Requires entities to submit at least the information set out in Annex I for registration, and removes the option to request non-publication.
  8. Replaces strict deadlines for registration and removal with a 'reasonable period of time'.
  9. Strengthens supervisory authorities' investigatory powers by removing conditions and thresholds for requesting information.
  10. Simplifies sanctions by allowing Member States to establish criminal sanctions and removing detailed rules on administrative fines.

Who is affected

  • Entities carrying out interest representation on behalf of third countries: must register in each Member State where they operate and keep records for at least 4 years.
  • Member States: may keep or adopt stricter transparency rules and may establish criminal sanctions.
  • National authorities: have more flexible deadlines and stronger investigatory powers.

Figures and deadlines

  • Records must be kept for at least 4 years after the activity ceases.
  • Reports must be drawn up on a quarterly basis.