Accountancy Europe is pleased to provide its input to the European Commission’s (EC) Call for Evidence gathering stakeholder input for the upcoming digital omnibus initiative. Overall, Accountancy Europe supports the Commission’s simplification efforts for the purpose of streamlining compliance, removing duplicate or redundant reporting obligations, and ensuring that policy goals are achieved in a smarter way.
In December 2024 Accountancy Europe published 10 principles for policy-makers to follow when simplifying legislation. These remain highly relevant today, and in pursuing its digital simplification initiative, we urge the Commission to:
- Clearly define the scope and objectives of the simplification measures
- Focus on practical measures that achieve concrete simplification for businesses, and avoid political solutions that risk adding further complexity and uncertainty
- Address specific challenges faced by SMEs
- Engage with stakeholders – including Accountancy Europe and the accountancy profession – early, meaningfully and effectively
For the digitalisation simplification specifically, we would underline a few specific principles:
- Digitalisation, automation and AI are too important to leave it to the markets alone to create confidence in their suitable functioning and to properly protect businesses and citizens
- Lack of minimum regulatory intervention may lead to the greater use of non-European service providers and ICT providers which, under the current geopolitical circumstances, may be particularly risky, undermine Europe’s digital safety and further reinforce unsustainable dependencies
- Digital simplification should not constitute point blank deregulation, as this leaves it to other jurisdictions and centralised market forces to determine the rules of the game alone
- The Commission must re-affirm continued need for crucial and strategic EU legislation such as the AI Act, even if specific simplification and compliance reduction measures are undertaken as part of these
- Transparency of algorithms is necessary, as only transparency can build trust among and adequately protect businesses and citizens
- Rolling out of further standards that are needed for the basic operationalisation and enforcement of legislation is necessary. For example, as part of the AI Act the expected further standards on national supervisory authorities is key to ensuring the legislation’s functioning
- On the other hand, the Commission should avoid unnecessary extension of existing legislation. For example, in the Digital Operational Resilience Act (DORA), there are review clauses for 2026 that could lead to a potential expansion of the legislation’s scope that should be avoided, as this would not lead to simplification nor ensure certainty
We look forward to contributing to relevant, specific Commission initiatives in this space.
