Special Report No 5/2005: Interpretation expenditure incurred by the Parliament, the Commission and the Council, together with the institutions’ replies
Date: 2005-09-22
Institutions: European Court of Auditors
Subjects: Council of the European Union, European Commission, European Court of Auditors, European Parliament, administrative expenditure (EU), interinstitutional relations (EU), management accounting, report

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I

(Information)

COURT OF AUDITORS

SPECIAL REPORT No 5/2005

Interpretation expenditure incurred by the Parliament, the Commission
and the Council, together with the institutions’ replies

(pursuant to Article 248(4), second subparagraph, EC)

(2005/C 291/01)

TABLE OF CONTENTS

EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

THE AUDIT OBJECTIVE AND SCOPE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

OBSERVATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

The procedures applied to avoid providing interpretation services which exceed the real
needs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Parliament . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Commission . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Council

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

The capacity to provide all the interpretation services needed . . . . . . . . . . . . . . . . . . . . .

The cost of interpretation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Cost calculations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Analysis of the cost of interpretation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Other questions affecting the cost of interpretation . . . . . . . . . . . . . . . . . . . . . . . . .

Specific observations concerning the expenditure for freelance interpretation . . . .

The quality of interpretation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Parliament . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Commission and Council

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

CONCLUSIONS AND RECOMMENDATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

The procedures applied to avoid providing interpretation services which exceed the real
needs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

The capacity to provide all the interpretation services needed . . . . . . . . . . . . . . . . . . . . .

The cost of interpretation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Paragraph

Page

I-VIII

1-12

13-14

15-81

15-29

16-21

22-24

25-29

30-32

33-71

33-38

39-41

42-58

59-71

72-81

72

73-81

82-95

82

83-84

85-92

3

4

5

5

5

6

6

7

7

8

8

10

10

12

14

14

14

15

15

15

15

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The quality of interpretation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

93

Possible developments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

94-95

ANNEX I: The specific provisions applying at the Parliament, the Commission and the Council . . . . . . . . . .

ANNEX II: The cost calculation method developed by the Court . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

The institutions’ replies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

15

16

17

18

19

Paragraph

Page

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EXECUTIVE SUMMARY

I.
Twenty-one languages have the status of official and working languages of the European institutions.
The institutions which, because of the nature of their activities, need the largest volume of interpretation ser-
vices are the Parliament, the Commission and the Council. The Parliament has its own interpretation depart-
ment. The interpretation needs of the Council and the Commission are catered for by the Directorate-General
for Interpretation of the Commission (DG Interpretation).

II.
Because of the uneven spread of demand over the year the European institutions employ not only per-
manent staff interpreters (officials), but also freelance interpreters recruited as auxiliary staff (called ACIs: Aux-
iliary Conference Interpreters).

III.
The purpose of the Court’s audit was to assess the soundness of the financial management of inter-
pretation services at the Parliament, the Commission and the Council. In particular, the audit aimed to estab-
lish whether these institutions have adequate tools and procedures to ensure that:

— the interpretation services provided do not exceed the real needs,

— all the interpretation services needed can be provided,

— interpretation services are provided at the lowest possible cost,

— interpretation is of high quality.

IV.
The audit has shown that the quality of interpretation mostly meets needs and expectations, but that
a number of measures need to be taken to reduce cost and to avoid the provision of interpretation that was
requested but not used.

V.
The institutions have adopted differing approaches in responding to requests for interpretation.
Whereas the DG Interpretation examines, together with the requesting Commission DGs, which interpreta-
tion services are really needed and decides which requests are to be met, there is no such examination at the
Parliament, where all requests which formally comply with the rules are accepted as far as resources are avail-
able. In 2004 the Council adopted a new procedure providing clear incentives to limit interpretation requests.

VI.
A calculation made by the Court shows that in 2003 the total cost of interpretation was around 57 mil-
lion euro at the Parliament and around 106 million euro at the Commission, the Council, the Committees and
some agencies. The average cost per interpreter of an interpretation day was 1 476 euro at the Parliament and
1 046 euro at the Commission and the Council.

VII.
While the institutions have been successful in limiting the interpretation, further savings could be
made if late cancellations, last-minute meeting requests, unequal distribution of meetings over the course of
the week and the year, and high travel costs for ACIs were avoided. As these elements are largely beyond the
control of the interpretation departments, savings could only be achieved by more forethought on the part of
the meeting organisers.

VIII.
Session reports indicating which languages have been used during the meetings are a very useful tool
for assessing whether the interpretation arrangements provided correspond to the needs of the meeting par-
ticipants, but they are not prepared in a significant number of cases. Providing a statement of the cost of can-
celled meetings to the meeting organisers, as the Council does, is good practice which should be extended to
the other institutions.

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INTRODUCTION

The Council has only a small Conferences Unit that orga-
7.
nises the meetings and orders interpretation services from the DG
Interpretation.

1.
According to Article 290 of the Treaty establishing the
European Community the Council is empowered to determine
unanimously the rules governing the languages of the institutions
of the Community.

Under Regulation No 1, updated after every accession of
2.
States to the European Union, the Council has given 21 languages
(Czech, Danish, Dutch, English, Estonian, Finnish, French, Ger-
man, Greek, Hungarian, Irish, Italian, Latvian, Lithuanian, Malt-
ese, Polish, Portuguese, Slovak, Slovenian, Spanish and Swedish)
the status of official languages and working languages of the
institutions (1).

Based on Regulation No 1 interpretation services are nec-

3.
essary when various working languages are used at a meeting.

The institutions which, because of the nature of their
4.
activities, have to provide the largest volume of interpretation ser-
vices are the Parliament, the Commission and the Council. In
2003 the total cost of interpretation was around 57 million euro
for the Parliament and around 106 million euro for the Commis-
sion, the Council, the Committees and some agencies.

5.
The Parliament’s Directorate for Interpretation provides
for all the interpretation needs of the Parliament itself (for meet-
ings held in Brussels, Strasbourg or elsewhere), the Ombudsman,
the Commission in Luxembourg and the Court of Auditors. Since
the completion of the audit the Parliament also provides interpre-
tation to the Committee of the Regions on certain days.

6.
The Commission’s Directorate-General for Interpretation
(DG Interpretation) covers the interpretation needs of the Com-
mission (about 40 % of the interpretation days provided) —
except for meetings taking place in Luxembourg — the Council
(more than 50 % of the interpretation days provided), the Euro-
pean Economic and Social Committee, the Committee of the
Regions, the European Investment Bank and some European
agencies.

(1) Council Regulation No 1 of 15 April 1958 determining the languages
to be used by the European Economic Community (OJ 17, 6.10.1958,
p. 385/58), as amended.

Because of the uneven spread of demand over the year,
8.
depending on the frequency of meetings and the language com-
binations requested, the European institutions employ not only
permanent staff interpreters (officials) (2) but also freelance inter-
preters recruited as auxiliary staff (called ACIs (3): Auxiliary Con-
ference Interpreters). Working conditions, remuneration and
reimbursement of expenses are governed, for ACIs, by the ‘Con-
ditions of employment of other servants of the European Com-
munities’ and by an Agreement signed between the largest pro-
fessional organisation of
International
Association of Conference Interpreters (IACI), and the three EU
institutions employing interpreters (i.e. the Commission, the Par-
liament and the Court of Justice); permanent staff interpreters are
governed by the Staff Regulations (4).

interpreters,

the

9.
In 2003 a total of about 150 000 interpretation days was
provided to the European institutions. The Council accounted for
approximately 39 % of this total, the Commission in Brussels
26 %, the Commission in Luxembourg 4 % and the Parliament
21 %. The other European institutions and bodies (the Court of
Justice, the Court of Auditors, the European Economic and Social
Committee, the Committee of the Regions, the European Invest-
ment Bank, the agencies, etc.) account for the remaining 10 %.
On the providers’ side, the DG Interpretation represents about
70 %, the Parliament 27 % (5) and the Court of Justice 3 % of the
interpretation services supplied.

(2) Before the May 2004 EU enlargement,

the DG Interpretation
employed nearly 500 staff interpreters, the Parliament over 200 and
the Court of Justice 33.

(3) Freelance interpreters are also known under the French acronym AIC

(Auxiliaire Interprète de Conférence).

(4) The Staff Regulations of officials of the European Communities and
the Conditions of employment of other servants of the European
Communities are laid down in Council Regulation (EEC, Euratom,
ECSC) No 259/68 (OJ L 56, 4.3.1968, p. 1), last amended by Regula-
tion (EC, Euratom) No 723/2004 (OJ L 124, 27.4.2004, p. 1).

(5) For statistical purposes, the DG Interpretation defines an interpreter
day as two half-days during which an interpreter really did at least
some interpretation (i.e. excluding travelling and all other activities).
Because the DG Interpretation, the Parliament and the Court of Jus-
tice use different methods to calculate the number of interpreter days
provided, the auditors have adjusted the figures for the other institu-
tions to make them comparable with the DG Interpretation’s figures
in order to calculate the share of each institution in the total consump-
tion and to calculate the cost per interpretation day.

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The volume of interpreter/days provided to EU institutions (index 1998 = 100) (1),
including the languages of the new Member States

Table 1

Council

Commission

Other DG
Interpretation

Total DG
Interpretation

Parliament

Total

1998

100

100

100

100

100

100

1999

96,8

101,5

2000

96,3

100,4

2001

105,6

94,7

95,2

102,7

112,3

98,5

85,0

93,8

98,5

92,7

96,5

101,8

97,8

100,4

2002

109,1

85,8

91,0

98,2

97,7

98,0

2003

103,9

85,1

88,8

95,0

97,2

95,8

2004

89,9

85,1

95,8

88,9

103,1

93,9

(1) To facilitate comparison, 1998 was chosen as the base year because 1998 and 2003 are both years preceding a year of Parliamentary
elections and a renewal of the Commission. Moreover, both years had the same number of official languages (11), as the penultimate EU
enlargement took place in 1995.

Table 1 shows that in recent years the EU institutions
10.
managed to reduce the use of the interpretation services provided
to them. The Council was the only one of the three largest insti-
tutions where the number of
interpretation days increased
between 1998 and 2003, but the new ‘on request’ system intro-
duced as from 1 May 2004 appears to have reversed that trend
(see paragraph 27). However, 2004 was a transitional year and
may therefore not be representative.

11.
The evolution in the use of interpretation services at the
Council between 1998 and 2003 is explained not only by the
increasing number of meetings, but also by the increasing num-
ber of active and passive languages (1) used for meetings at that
institution.

Article 6 of Regulation No 1 states that ‘the institutions
12.
of the Community may stipulate in their rules of procedure which
of the languages are to be used in specific cases’. This provision
makes it possible to tailor language arrangements to the specific
needs of each institution. The institutions have made use of this
possibility to differing degrees, as shown in Annex I.

interpretation service). In particular, the audit aimed to establish
whether the institutions audited have adequate tools and proce-
dures which ensure that:

— the interpretation services provided do not exceed the real

needs,

— all the interpretation services needed can be provided,

— interpretation services are provided at the lowest possible

cost,

— interpretation is of a high quality.

14.
The audit covered expenditure during the 2003 financial
year, but changes occurring in 2004 as a consequence of the most
recent enlargement of the European Union have also been taken
into consideration.

OBSERVATIONS

THE AUDIT OBJECTIVE AND SCOPE

The procedures applied to avoid providing interpretation
services which exceed the real needs

The objective of the Court’s audit was to assess the
13.
soundness of the financial management of interpretation services
at the Parliament, the Commission and the Council. The audit
covered 97 % of the supply of interpretation services (i.e. all sup-
Justice, which has its own
plies, except

for the Court of

(1) Active languages are languages into which interpretation is provided.
Passive languages are the languages which can be spoken at the meet-
ing. If the number of active and passive languages is not the same, the
meeting has an asymmetric language configuration. Example: a 7/6
configuration is a configuration with 7 passive and 6 active languages.

The actual use of languages at meetings shows that on
15.
occasions the interpretation services provided exceed the real
interpretation needs (certain participants might prefer using,
instead of their mother tongue, another more widely known offi-
cial language; expected participants might be absent, making cer-
tain specific interpretation arrangements superfluous). The Court
examined the extent to which the institutions audited have appro-
priate procedures in place in order to forecast as precisely as pos-
sible the expected use of languages and to monitor actual use, so
as to dissuade meeting organisers from requesting interpretation
services exceeding such forecasts.

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Parliament

secretariat of the meeting concerned. In practice, this procedure
has applied since September 2004 to committee and delegation
meetings.

16.
The rules of procedure (see Annex I), which state that
each of its Members has the possibility of speaking in the official
language of his/her choice and that interpretation is provided into
the other official languages, oblige the Parliament to make large
interpretation resources available.

The resources provided in compliance with the Rules of
21.
Procedure exceed the real needs if, at a given meeting, not all the
supposed official languages are used. The Parliament has never
carried out a survey to assess the frequency and the consequences
of such cases.

17.
In order to organise and control the provision of inter-
pretation services, the Bureau of the European Parliament adopted
in 1999 a ‘Code of Conduct on Multilingualism’, updated in 2004.
The basic principles inspiring this code are that, while respecting
the equal rights of the Members, the costs of multilingualism
should be kept within acceptable budgetary limits, resources used
more effectively and the users of language facilities should be
made aware of the necessity for responsible use of language facili-
ties, based on real needs.

Commission

18.
Interpretation may be requested from the Parliament’s
Directorate for Interpretation only for the categories of meetings
listed in the Code of Conduct (Parliament’s plenary sessions, Par-
liament’s governing bodies, committees, delegations, etc.). Inter-
pretation is not available to Members acting individually or to
outside bodies, but exceptions may be authorised by the Bureau.
The Directorate for Interpretation provides the requested inter-
pretation service according to the priorities and within the limits
set in the Code of Conduct.

19.
The Code of Conduct, as updated in 2004, states that
every parliamentary body needing interpretation services (‘user’ in
the wording of the Code) should draw up and regularly update an
‘interpretation language profile’ based on the languages requested
and actually used by its Members. This is a very useful tool for
ensuring that requests correspond to real needs. However, as no
obligation exists for Members of the European Parliament (MEPs)
to confirm their presence at a meeting in advance, the ‘interpre-
tation language profile’ is not sufficient to prevent the provision
of unnecessary interpretation, if MEPs for which specific interpre-
tation services had been planned do not actually attend.

20.
According to the Code of Conduct, at the end of each
meeting the head of the team of interpreters is required, in agree-
ment with the secretariat of the meeting, to draw up for the Direc-
tor of Interpretation a list of the interpretation facilities requested
but not used. A copy of that list has to be forwarded to the

In each Directorate-General (DG) an administrative unit
22.
centralises the requests for interpretation support at specific meet-
ings and transfers them electronically to the DG Interpretation,
through the DOR (Demande d’Organisation de Réunion) system.
Each DG proposes a desired language configuration and ranks the
meetings requested for the same day by order of priority. At inter-
nal weekly ‘arbitration’ meetings, the DG Interpretation decides
which requests can be met, taking into account the availability of
interpreters and meeting rooms. At further coordination meet-
ings, specific language configurations are assigned to each of the
meetings scheduled to take place six weeks later. The number of
active and/or passive languages assigned by the DG Interpretation
is often lower than the number initially requested and is the result
of negotiations between the DG Interpretation and the DG orga-
nising the meeting.

23.
At the DG Interpretation, the interpretation team leader
is required to draft a session report (rapport de séance), in which
he/she indicates what languages have been used during the meet-
ing. In 2004 such reports were drawn up in 82,5 % of the
8 107 meetings with interpretation. In 17,7 % of the reports the
team leaders stated that passive interpretation had been requested
and provided in excess of the real needs, for one or more of the
following reasons: certain national delegations did not speak their
official languages, did not speak at all, or were absent. Non-use of
active interpretation requested and provided was mentioned in
7,2 % of the reports. These occurrences result in at least (1)
1 750 interpreter days paid but not used, costing between
1,5 and 2 million euro.

(1) Based on the prudent hypothesis that the problem affected only one
delegation. The average cost of an interpreter day is shown in Table 4.

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Although the current procedures giving the DG Interpre-
24.
tation the final word in deciding between conflicting requests
from different DGs contain the demand, it is difficult for an inter-
pretation service to decide which meetings are more urgent or
more important. Other international
institutions have imple-
mented systems that are more resource-management oriented:

— the Council of Europe has introduced a system of internal

billing,

— Unesco applies a quota system, whereby the interpretation
days exceeding the quota are charged back to the meeting
requester.

Among the European Union institutions, the Council has adopted
the system mentioned in paragraph 27, which increases the cost
awareness of national delegations. Under the new Activity Based
Management system similar arrangements could be considered by
the DG Interpretation.

Council

Procedures applied before the 2004 enlargement of the European
Union

25.
The nomenclature used before the enlargement to deter-
mine the language configuration provided for each meeting was
based on tradition and was not regularly updated. There was no
procedure to verify whether those attending meetings really
needed interpretation into their mother tongue or whether they
really expressed themselves in their own language.

26.
An excess of languages on offer was shown by a 2001
survey of 799 Council and Commission delegates (1). Although
73 % of the delegates stated that they had the possibility of
expressing themselves in their mother tongue, only 59 % of them
said they had actually spoken that language. This would often
have been the case of delegates who have as their mother tongue
a not much diffused language and who are fluent in a more widely
known official language. It is improbable that delegates who
spoke an official language needed interpretation into their mother
tongue from an official language which they used. It is therefore
reasonable to consider that the languages for which interpreta-
tion is needed are the languages actually spoken at a meeting.

(1) Algoé Consultants, Evaluation de la qualité des prestations fournies par le

SCIC en matière d’interprétation, Lyon-Ecully, 26 June 2001.

Procedures for the period after the enlargement

27.
Decision No 56/04 of the Secretary-General of the Coun-
cil (2) governing the language arrangements for the period after
the enlargement has substantially changed the use of interpreta-
tion services. The new system adapts the language arrangements
to the real needs of the delegations, increases their cost awareness
and gives Member States an incentive to cut down on unneces-
sary interpretation requests, with a consequent reduction of inter-
pretation costs.

As of 1 July 2004, interpretation is no longer provided
28.
for the meetings of 25 preparatory bodies (committees, groups
and working parties). As a result, the average number of meet-
ings with interpretation held at the Council has decreased from
13 to 11 per day. The full 20/20 language configuration is
financed by the Council’s budget for meetings of the Council, the
European Council and a maximum of 20 preparatory bodies.

29.
For other preparatory bodies, active or passive interpre-
tation is only provided if requested by the national delegations.
To cover these costs, delegations can draw on a financial alloca-
tion of 2 million euro per language. 66 % of any unused amount
is transferred to the amount of the budget appropriations for del-
egates’ travel expenses allocated to the Member State concerned.
National delegations have the possibility of adapting their requests
every six months, with two months’ notice. As a result, during
2004 one or more languages were dropped from the language
arrangements for a number of preparatory bodies.

The capacity to provide all the interpretation services needed

for

Requests

interpretation concerning

30.
the pre-
enlargement official languages can generally be met. The situa-
tion is different for the new official languages, because of an insuf-
ficient number of interpreters satisfying the specific linguistic
needs (3) of the European Union.

(2) Decision of the Secretary-General of the Council/High Representative
for the Common Foreign and Security Policy No 56/04 of 7 April
2004 concerning interpretation for the European Council, the Coun-
cil and its preparatory bodies, SN 1327/04 REV 1.

(3) To ensure high quality interpretation, EU interpreters are, in principle,
requested to provide interpretation only into their mother tongue. The
high number of working languages makes it very difficult to find inter-
preters for all language combinations.

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The European Personnel Selection Office’s (EPSO) com-
31.
petitions for the recruitment of interpreters for the new official
languages were not finalised until after the date of the enlarge-
ment. There were no successful candidates for Maltese and the
number of successful candidates for the other official languages
was not sufficient to cover the needs of the EU interpretation
services.

32.
Difficulties arose in 2004 at the Council, where demand
for interpretation into some new official languages was even
higher than for the other official languages. The DG Interpreta-
tion was not able to meet 37 % of the requests for meetings tak-
ing place from May to December 2004.

The cost of interpretation

Cost calculations

for an interpreter ‘Being Made Available’

Each year the DG interpretation calculates an average
35.
cost
(hereinafter:
BMA) (1) for a full day or for half a day. This calculation is used as
a basis for charging interpretation services to institutions and
bodies (interinstitutional billing) to which the DG Interpretation
provides interpretation services. As cancelled interpretation
orders are also considered as BMA, this concept measures the cost
of the interpretation services made available but not the cost of
the interpretation services actually used. Moreover, the cost per
BMA calculated by the DG Interpretation does not take into
account all overhead costs or pension contributions for perma-
nent staff. As all staff pensions are paid from the Commission
budget, this method seems appropriate for interinstitutional price
setting, but underestimates the full cost per BMA. The same goes
for Community tax on the remuneration of permanent and
freelance interpreters, which ought to be deducted from the cost,
as it is revenue for the EU budget.

Cost calculations made by the audited institutions

33.
In order to manage expenditure in accordance with the
principles of sound financial management — economy, efficiency
and effectiveness — it is necessary to know the full cost of ser-
vices provided to serve as a basis for a rational allocation of
resources.

Cost calculations made by the Court of Auditors

36.
The Court has developed the method described in
Annex II for estimating the total cost of interpretation and the full
cost per interpretation day performed by ACIs and by permanent
staff. The same method was used to calculate the cost to both the
Parliament and the DG Interpretation.

34.
The Parliament has no estimates of the average full daily
cost of ACIs and permanent interpreters. It calculates the direct
cost
travel
(essentially remuneration and reimbursement of
expenses) only of interpretation services provided by ACIs and
does not update its calculations on a regular basis.

37.
follows:

The results of the auditors’ calculations for 2003 are as

Table 2

The cost of an interpretation day provided by a permanent interpreter

Parliament

DG Interpretation
(Commission + Council)

before tax and pension

after tax and pension

before tax and pension

after tax and pension

(euro)

Direct cost (1)

Indirect cost (2)

Full cost

1 205

220

1 425

1 232

227

1 459

942

227

1 169

970

232

1 202

(1) Direct costs are the remunerations of staff interpreters and ACIs, including travel and subsistence allowances.
(2)

Indirect costs are defined here as all other costs related to the interpretation activity: remunerations of management and staff responsible
for planning, finance, human resources management and other administrative tasks, training, IT and office costs, etc.

(1) This is a translation of the French term mise à disposition (MAD) used
at the DG Interpretation. All interpreters ordered and not cancelled at
least six working days before the meeting are invoiced as BMA.

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Table 3

The cost of an interpretation day provided by an ACI

Parliament

DG Interpretation
(Commission + Council)

before tax

after tax

before tax

after tax

Direct cost

Indirect cost

1 390

245

Full cost

1 635

839

168

1 007

744

171

915

1 250

245

1 495

Table 4

The weighted average and total cost of interpretation provided by permanent interpreters and ACIs

(euro)

(euro)

Cost per interpretation
day per interpreter

Direct cost

Indirect cost

Full cost per interpre-
tation day (1)

Total number of inter-
pretation days
(harmonised method)

Total cost of
interpretation

Total number of BMA
calculated by the DG
Interpretation

Full cost per BMA

Parliament

DG Interpretation
(Commission + Council)

before tax and pension

after tax and pension

before tax and pension

after tax and pension

1 292

232

1 523

1 240

236

1 476

886

195

847

199

1 081

1 046

38 803

38 803

101 331

101 331

59,1 mio

57,2 mio

109,5 mio

106,0 mio

n/a

n/a

n/a

n/a

147 751

147 751

742

718

(1) The figures for the average full cost per interpretation day in 2003 (1 081 euro before tax and pension or 1 046 euro after tax and pen-
sion) are much higher than the cost per BMA because they include more overhead costs than those considered by the DG Interpretation
and take account only of full interpretation days (or two half-days) for meetings which actually took place, whilst, as set out in para-
graph 35, cancelled meetings and half-day meetings also count for the calculation of the cost per BMA as such meetings are charged to
the meeting organisers.

At an average cost per interpretation day after tax and
38.
pension contributions of 1 476 euro at
the Parliament and
1 046 euro at the DG Interpretation, a full-day meeting with full
interpretation coverage cost about 40 000 and 34 500 euro respec-
tively before enlargement (11/11 coverage with 3 interpreters per
language booth or 33 interpreters in total) and about 88 500 and
63 000 euro respectively after enlargement (20/20 coverage with
3 interpreters per language booth or 60 interpreters in total).

Where there are 4 interpreters per booth, which is not uncommon
for meetings at the Parliament, the interpretation cost for a one-
day meeting can amount to 118 000 euro (or 84 000 euro if the
interpretation is provided by DG Interpretation). A meeting with a
small 3/3 regime (English, French and German as passive and active
languages, with 6 interpreters in total) costs just 8 900 euro at the
Parliament and 6 300 euro at DG Interpretation. This illustrates the
importance of basing requests for interpretation on real needs.

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Analysis of the cost of interpretation

Other questions affecting the cost of interpretation

Parliament

39.
Although the remuneration system of permanent and
freelance interpreters is the same for both institutions, the Parlia-
ment’s cost per interpretation day is much higher than at the DG
Interpretation. The Court found that this difference is mainly due
to a number of constraints on which the management has little
influence, namely:

(a) Unlike in Brussels, there are very few local (1) freelance inter-
preters in Strasbourg. This increases freelancers’ travel and
hotel expenses. In 2003, these costs represented 22 % of all
payments to ACIs. Two thirds of the ACIs hired by the Euro-
pean Parliament in 2003 were non-local, as against less than
40 % of those hired by the DG Interpretation.

(b) As all staff interpreters are based in Brussels and 12 plenary
session weeks a year are held in Strasbourg, the Parliament
total travel costs for permanent staff are much higher than at
the Commission.

(c) Shorter working weeks with relatively little parliamentary
activity on Mondays, Thursday afternoons and especially on
Fridays, and a much higher demand for interpretation ser-
vices during plenary session weeks in Strasbourg than dur-
ing weeks in Brussels where only committee or political
group meetings take place mean that many permanent inter-
preters spend up to 32 days a year without an assignment.

(d) Late-evening or night meetings are frequent at the Parlia-
ment. The consequence is that the interpreters have a right
to paid rest for the next morning or day and other interpret-
ers must be recruited. At the Commission, and to a lesser
extent at the Council, these kinds of meetings are exceptional.

The DG Interpretation

The ACIs hired by the DG Interpretation generally cost
40.
significantly less than permanent staff (see also paragraphs 59
to 62). As the number of interpretation days provided by perma-
nent staff dropped by 4 % from 2002 to 2003 the cost difference
between both categories of interpreters inevitably increased in
2003.

41.
Most ACIs hired by the DG Interpretation are local or
near-local (55 % of the contract days of ACIs in 2003 and 59 %
in 2004) requiring little or no hotel and travel costs and allow-
ances. As they are remunerated only for the days for which they
have been contracted, local freelancers cost less than permanent
interpreters. Non-local ACIs, on the other hand, are more expen-
sive, as a study carried out on behalf of the Commission shows (2).

(1) Local ACIs have their declared professional domicile within less than

60 kilometres from the meeting venue.

(2) PriceWaterhouseCoopers, Etude sur le coût total des interprètes fonction-

naires et des interprètes A.I.C., 5 October 2001.

Parliament

Late requests and cancellations

42.
Providing interpretation services at short notice is par-
ticularly costly, as travel expenses may have to be paid to ACIs for
a short work assignment (for example, a single meeting), whereas
requests made sufficiently in advance make it possible to plan the
employment of freelance interpreters for a longer period (for
example, a full week in which various meetings are held).

The audit showed that, in 2003, in a large number of
43.
cases the deadlines set by the Code of Conduct were not respected:
853 requests (an average of 17 per week) and 650 cancellations
(13 a week on average) were made after the deadline.

Late cancellation of meetings, although sometimes
44.
unavoidable, causes a waste of financial resources if the interpret-
ers assigned cannot be switched to other meetings. If the inter-
preters used are ACIs, their remuneration is a pure loss for the
institution; if they are officials, they could have been employed for
other meetings for which ACIs had been recruited on the assump-
tion that permanent staff were not available. The ‘GERI’ (acronym
for Gestion des Réunions et des Interprètes) computer system used at
the Parliament in 2003 makes it possible to determine the num-
ber of half-days of interpretation requested and made available,
but not needed due to the cancellation of meetings (3). In 2003,
this totalled 6 298 half-days (2 864 half-days for permanent staff
and 3 434 half-days for ACIs). This corresponds to about 8 % of
the interpretation days performed and 7,5 % of those requested.
As a result, about 4 million euro was spent on services made
available but not used. Better planning could have allowed the
staff interpreters assigned to the cancelled meetings to replace
ACIs employed for other meetings (on this question see also
paragraph 47).

(3) In ‘GERI’ the unit of measurement of the employment of interpreters
is the ‘half-day’. When a meeting is cancelled in GERI, the interpreta-
tion half-days allocated to that meeting are automatically shown as
‘suspended half-days’ (demi-journée suspendue) for each interpreter
booked for the meeting. Should the available interpreter be reassigned
to another meeting, then the ‘suspended’ code is replaced by the code
of the new meeting. Hence, the sum of all the ‘demi-journées suspen-
dues’ in GERI is the ‘net loss in interpretation resources’ expressed in
half-days.

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Commission

Council

Cancellation or short duration of meetings

Cancellation of meetings

The late cancellation and the short duration of meetings,
45.
together with DG Interpretation’s need to hold a few interpreters
per language in reserve, so as to cover last-minute meetings or
unforeseen absences of interpreters, are the main reasons behind
the high number of cases of so-called ‘implicit or explicit stand-by
duty’ (1), i.e. interpreters who are present but have to be put on
stand-by because their services are not needed. In 2003, perma-
nent interpreters spent on average 33 days on ‘implicit stand-by
duty’. A high number of cases of ‘implicit stand-by duty’ (about
130 interpreters per day, corresponding, in 2003, to more than a
quarter of the number of the staff interpreters) occur in August
when very few meetings take place. As a result, a total of 15 000
interpreter days, corresponding to around 15 % of the working
days of the staff interpreters, were not used. ACIs had a total of
more than 6 000 days of ‘implicit stand-by duty’. The total cost
of ‘implicit stand-by duty’ in 2003, at an average cost of 865 euro
per day, available for interpretation (2), can be estimated at about
18 million euro. While a significant portion of the standby costs
may be unavoidable under the current working arrangements,
every effort should be made to reduce those costs.

In 2003, 15 % of the interpreter days requested by Com-
46.
mission departments were cancelled, but no figures are available
for the number of cases in which no resources were lost because
the interpreters booked for the cancelled meetings could be
assigned to other meetings.

47.
In 2003, there were nine working days on which at least
100 permanent interpreters (or more than 20 % of the total num-
ber of permanent interpreters) assigned to cancelled meetings
were on ‘implicit stand-by duty’ whilst at the same time more
than 100 ACIs had been recruited.

48.
Meetings lasting a very short time result in a kind of
‘implicit stand-by duty’, as interpretation is needed only for a
small part of the interpreter day or half-day booked. One reason
for very short meetings is that some working parties, whose meet-
ings are scheduled at regular intervals, meet even when they have
very few, non-urgent points on the agenda.

(1) ‘Implicit’ stand-by duty differs from ‘explicit’ stand-by duty in that the
latter corresponds to reserve teams included in the planning to replace
absent interpreters. According to the established working conditions
(‘Provisions applicable to staff interpreters’, SCIC (87)25), interpreters
can be assigned to meetings for a maximum of 18 sessions (half-days
of 3,5 hours) per period of two weeks.

(2) The average cost per day available for interpretation is calculated as
the total cost of the DG Interpretation after tax and pension calculated
above (106 million euro) divided by the sum of interpreter days
(101 000) and implicit stand-by duties (21 000).

49.
In 2003, according to the Council’s own estimates, more
than 5 % of the Council’s interpretation expenditure (2,4 out of
45,7 million euro) represented payments for cancelled meetings,
where the interpreters could not be employed by the Council for
other meetings held on the same day. This corresponds to a net
yearly waste of almost 4 000 interpreter days.

Meetings invoiced at higher rates

50.
Late requests for new meetings or for the addition of one
or more languages, made fewer than six working days before the
meeting, were invoiced in 2003 at the rate of 835 euro, that is
about one third more than the normal rate of 632 euro. In 2003,
these late requests corresponded to about 3 % of the total amount
invoiced to the Council.

51.
It is important to make meeting organisers aware of the
high cost of cancellations and late requests. The statement of the
cost of cancelled meetings sent at the end of each month to the
Head of the central coordination unit of the Member State hold-
ing the rotating Council Presidency can be regarded as an example
of good practice if exploited for management purposes.

The interinstitutional billing system of the DG Interpretation

52.
In order that the DG Interpretation recovers the costs of
the interpretation services provided to other institutions (costs
that are to be charged to the administrative budget of these insti-
tutions) an interinstitutional billing system has been set up, based
on ‘service level agreements’ between the DG Interpretation and
the institutions concerned.

53.
In 2003 the DG Interpretation invoiced the Council at a
basic rate of 632 euro per day or 369 euro per half-day for inter-
preters ordered at least six weeks in advance for meetings held in
Brussels. Higher rates were applied to missions and late orders.

The following points were noted with respect to the cur-

54.
rent billing:

(a) The price structure is not based on the real cost of each type
of request (timely requests, late requests, requests withdrawn,
requests for languages with higher ACI travel costs, etc.).

(b) For the DG Interpretation revenue standard rates based on an
estimated level of activity are used. Most of the costs borne
by the DG Interpretation are fixed costs (only the cost of the
ACIs is entirely variable). As a result, if the volume or the
composition of the actual demand for interpretation services
is different from that forecast, the DG Interpretation incurs
either a deficit or a surplus.

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(c) The price does not incorporate the full cost of the interpre-
tation services, because, as mentioned in paragraph 35, it
does not include all overheads.

(d) The limitation of the number of interpreters and meetings
per day specified in the Service Level Agreement prevents
high peaks in demand, but does not prevent troughs (early
January, August, etc.).

(e) The lack of a link between the computer systems of the
Council and the DG Interpretation makes the billing labour
intensive and error prone. The downward corrections made
to the 2002-2003 DG Interpretation invoices sent to the
Council amounted to almost 6 % of the amount initially
invoiced.

The interinstitutional cooperation

55.
Based on the work of the Interinstitutional Committee on
Translation and Interpretation (ICTI) and the ‘Chêne Report’ (1) of
2002, considerable progress was made towards more coopera-
tion between the EU institutions in the area of interpretation. The
main achievements include:

— joint competitions for staff interpreters organised by EPSO,

— a joint selection procedure and a joint list of accredited ACIs,

— a common system and unit for payments to ACIs (since

October 2004),

— an exchange of interpreters for the new languages, who are

in short supply.

56.
Further savings and efficiency gains could be made in
several other areas, but enhanced cooperation is hampered by the
current organisation involving three independent interpretation
service providers (the DG Interpretation, the Parliament and the
Court of Justice).

election period (from 10 May to 2 July 2004), dozens of per-
manent Parliament interpreters, especially from the smaller
languages, had no task assignment. At the same time, the DG
Interpretation hired on average 253 ACIs per day, resulting
in significant costs charged to budget appropriations (more
than 900 euro per day and per interpreter).

(c) The current organisation makes it more difficult to reduce
travel costs by taking advantage of the presence of non-local
ACIs already contracted by the other institution for adjacent
days.

(d) Further economies of scale in human resources, financial,
operational and IT management and the integration of IT
systems could be achieved through a common organisation.

58.
It should therefore be analysed whether the abovemen-
tioned problems could be solved by creating one single interin-
stitutional office or agency providing interpretation services to all
EU institutions or by improving the interinstitutional coopera-
tion. Centralising the provision of interpretation services would
be compatible with the autonomy of each institution, as proven
by the fact that the Council has relied on the Commission for the
provision of interpretation for years, without any noteworthy dis-
ruptions. The Service Level Agreement signed between the Coun-
cil and the DG Interpretation shows that it is perfectly feasible to
guarantee the client institution an agreed number of interpreters
per day.

Specific observations concerning the expenditure for
freelance interpretation

The optimal ratio of permanent to freelance interpreters

57.
The division of labour between the Parliament and the
Commission (the DG Interpretation) is not efficient for the fol-
lowing reasons:

The DG Interpretation

(a) Both institutions are competing to recruit ACIs for meetings

in Brussels.

(b) The institutions do not systematically communicate their
availability or need of resources to each other. The DG Inter-
pretation recruits ACIs on days on which the Parliament still
has permanent interpreters without any task assignment.
Where meetings are cancelled or interpreters are only needed
for half a day or less, the separate organisational structures
combined with the lack of information flowing between both
institutions make it almost impossible for the other institu-
tion to use these resources. During the European Parliament

(1) Report of the ad hoc Working Group of the CITI, Synergies et écono-
mies d’échelle susceptibles d’être obtenues grâce à la coopération entre les ser-
vices d’interprétation et de traduction des institutions et des organes commu-
nautaires, Brussels, 22.4.2002.

The appropriateness of employing ACIs instead of per-
59.
manent staff depends on a large number of factors such as the
way in which meetings are spread out over the year and the week,
the availability of local freelance interpreters or the distance
between the professional domicile of the interpreter and the
meeting venue. The Court considers that the results of the study
already mentioned made on behalf of the DG Interpretation (2)
are generally valid. They indicate, as a global optimal ratio, 51 %
of interpretation days to be performed by permanent interpret-
ers. The share of interpretation days performed by permanent
interpreters dropped from 53 % in 2000 to 46 % in 2002
and 2003, but went up to 50 % in 2004.

(2) PriceWaterhouseCoopers, Etude sur le coût total des interprètes fonction-

naires et des interprètes A.I.C., 5 October 2001.

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However, an overall target ratio of 51:49 is not suitable
60.
for all languages. The DG Interpretation has not calculated the
optimal ratio for each language. For example, the ratio of Dutch-
speaking freelancers (54 % in 2003) should be higher, as many
‘locals’ (ACIs living in or around Brussels) and not so costly ‘non-
local’ (ACIs living not far from Brussels) freelancers are available.

According to Article 10 of the Commission rules imple-
64.
menting the Agreement between the IACI and the EU institu-
tions (2), an ACI is entitled to the reimbursement, on presentation
of supporting documents, of an exchangeable and reimbursable
IATA ticket at the lowest rate that is not subject to quotas. The
implementing rules applicable to the ACIs working for the
Luxembourg-based EU institutions (3) contain a similar clause.

61.
On the other hand, more permanent interpreters might
be recruited, for example, for Portuguese and Greek, as travel
costs for Greek and Portuguese ACIs are above the average for all
the ACIs. For these languages, the reliance on ACIs is relatively
high (respectively 59 % and 67 % of the interpretation days in
2003), permanent interpreters have one of the highest workloads
of all languages (116 and 108 days respectively, against 104 on
average in 2003) and the percentage of local ACIs is the lowest
(only 30 % for Portuguese and 42 % for Greek against an average
of 56 % in 2003).

65.
The Agreement should be changed to ensure that an ACI
is generally paid no more than the amount corresponding to the
cost of a ticket with restrictions (i.e. a ticket at the lowest rate).
This amount should, however, also be paid in the event of no
show due to illness, cancellation of the meeting or any other rea-
son beyond the ACI’s control.

Parliament

Parliament

The Parliament has not made any specific calculation in
62.
order to establish the optimal proportion of freelancers and per-
manent interpreters. In 2003, 57 % of the interpreter days were
provided by ACIs. Notwithstanding the higher cost, a higher per-
centage of freelance interpretation than at the DG Interpretation
seems justified because of more uneven demand. However, the
five languages with the highest percentage of freelance interpre-
tation (in decreasing order: Spanish, Italian, English, Finnish
and Swedish) are languages for which the travel costs of ACIs are
above average.

The allowances of ACIs

Reimbursement of travel expenses and daily allowances

63.
The travel costs for ACIs are substantially higher than for
permanent officials. Due to the Agreement, which grants ACIs a
travel allowance, a daily allowance and reimbursement of travel
and hotel costs, ACIs benefit from more favourable travel condi-
tions than their permanent colleagues. For meetings held outside
Brussels, this results in unequal travelling conditions for interpret-
ers of the same level performing the same job. According to IACI
Agreements with other international organisations, ACIs benefit
from the same conditions for reimbursement of travel expenses
as permanent staff of a similar level (1).

(1) Article 15 of the Agreement governing the conditions of employment
of conference interpreters remunerated by the day between the IACI
and the Coordinated Organisations (Accord régissant les conditions
d’emploi des interprètes de conférence rémunérés à la journée entre
l’AIIC et les Organisations coordonnées) stipulates that, save as other-
wise provided and mutually accepted, the rules governing travel
expenses are to be those in force in each Organisation; this is con-
firmed by Article 2 of the Additional Agreement between the IACI and
the Council of Europe, which stipulates that the conditions of travel
and reimbursement of expenses applicable to Council of Europe staff
on duty travel are to apply to interpreters.
Article 13 of the IACI-United Nations Agreement (2000-2005):
‘Except as may be otherwise provided in this Agreement, the travel
rules applicable to the regular staff of the employing organisation on
missions of similar duration shall be applicable to the travel of the
freelance interpreters employed thereby. (…)’.

66.
An examination of a sample of payments made to ACIs
showed that a majority of the ACIs travelling by plane obtained
reimbursement of a business class ticket, without any evidence, in
the file, of the necessity of buying such a ticket.

67.
Contrary to the rules stating that an ACI is not entitled
to a full daily allowance when a permanent official would get only
part of such an allowance, a full daily allowance is granted even
for a period of less than 12 hours (4).

The DG Interpretation

An examination of a sample of 17 payments made to
68.
ACIs who travelled by plane showed that four of them obtained
reimbursement of a business class ticket, without any evidence, in
the file, of the necessity of buying such a ticket.

(2) European Commission, Rules for implementing certain provisions of
the Agreement (Modalités d’application de certaines dispositions de la
Convention).

(3) Provisions for implementing the Rules concerning freelance confer-
ence interpreters working for the Luxembourg-based institutions (Dis-
positions d’application relatives aux Réglementations concernant les
interprètes de conférence free-lance travaillant pour les institutions de
Luxembourg), § III. Travel expenses.

(4) Article 9§2 of the Agreement mentioned in paragraph 8 states that
‘the daily subsistence allowance and supplementary daily allowance
for interpreters who are not staff members of an institution shall be
equal to the mission allowance paid to LA4 and LA8 officials in the
institution which applies the most favourable rate. For interpreters
whose contracts are covered by Article 78 of the CEOS, the rate shall
be that in force in the institution for which they have been recruited’.

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Comparison with other international organisations

69.
The daily fee paid by the European institutions in 2004
at a fixed rate of 483,98 euro per day for experienced interpret-
ers is in line with current market conditions in the private sector.
However, it is lower than the gross average rate paid by other
international organisations, which have also signed Conventions
with the IACI. The much higher volume of employment and the
longer contracts that the EU institutions are able to offer, as well
as the favourable tax treatment (ACIs pay a community tax and
are as a consequence exonerated from national income taxes)
explain the difference.

The effect of the favourable tax treatment is that, in spite
70.
of a lower gross rate, the net amount received by the freelance
interpreter from DG Interpretation and the Parliament is higher
than the net amount earned by working for the private sector or
for other international organisations. This means that the EU
institutions can afford to apply high standards in recruiting ACIs,
but also have to carefully observe the market conditions in order
to avoid overpaying their ACIs.

71.
Contrary to the European institutions, the Organisation
for Economic Cooperation and Development pays a reduced rate
in the case of cancelled meetings, meetings which end early and
general or non-technical meetings (1).

The quality of interpretation

Parliament

Since the fourth quarter of 2003, the DG Interpretation
74.
has requested the meeting organisers to complete a short ques-
tionnaire after each meeting. 94 % of them have declared them-
selves very satisfied or satisfied with the DG Interpretation’s ser-
vices and the quality of interpretation.

75.
This picture was largely confirmed to the auditors by
various Heads of the central coordination unit created by each
Member State holding the rotating Council Presidency (hereafter
called Council Presidency Coordinator) and meeting requesters at
the Commission. The quality of interpretation was almost unani-
mously mentioned as the main strength of the DG Interpretation.

76.
As an aid to ensuring the quality and consistency of inter-
pretation, the DG Interpretation’s interpreters have at their dis-
posal on-line multilingual glossaries for a large number of sub-
jects. Meeting documentation, on the other hand, is often only
available in English and has therefore to be supplemented by the
interpreters themselves through database searches. Quality could
also be further improved through more stable interpretation
teams for successive meetings. This seems particularly appropri-
ate for the most technical meetings.

77.
The helpfulness of the officials of the DG Interpretation
is also considered to be one of the DG Interpretation’s main
strengths. In the event of the interpretation request being partly
or entirely turned down by the DG Interpretation during its
weekly arbitration or coordination meetings, the requested meet-
ing is normally rescheduled to the following week or held with a
reduced language configuration. Any significant delays in the
progress of committees or working groups are said to be
exceptional.

72.
A survey performed by the Court amongst the political
groups did not reveal any complaints about the quality, reliability
or helpfulness of the interpretation service, but the limitation of
interpretation sessions to three and a half hours was considered
too restrictive.

The most frequently mentioned negative point during
78.
the Court’s interviews with Commission and Council clients was,
as in the Parliament, the limitation of interpretation sessions to
three and a half hours.

Commission and Council

The Council has no system for evaluating the quality of

79.
interpretation and measuring the satisfaction of the delegates.

About 1,2 % of the session reports (2) in 2003, and 0,5 %
73.
in 2004, mentioned an informal complaint, mainly concerning
the language arrangements. A 2001 evaluation of the quality of
interpretation services provided by the DG Interpretation con-
ducted by external consultants, including a survey among the del-
egates attending Commission and Council meetings with inter-
pretation, showed that 91 % of these delegates were generally
satisfied or very satisfied with the quality of the DG Interpreta-
tion’s interpretation. The weakest point was considered to be the
knowledge of the issues discussed at the meetings. This problem
seemed to be linked to late distribution or unavailability of the
meeting documents, which the interpreters’ survey pointed out as
the biggest problem. More than half of the interpreters were dis-
satisfied with the documentation. Particularly the unavailability of
the documentation in their active language was considered to be
a problem.

(1) See ‘Terms and conditions of employment of free-lance interpreters at

the OECD in 2003’.

(2) See paragraph 23.

80.
The 2002-2003 Council Presidency Coordinators inter-
viewed by the Court’s auditors almost unanimously mentioned
the quality of interpretation as the main strength of the DG Inter-
pretation. Official complaints on the part of meeting organisers
or delegations are exceptional. In both 2002 and 2003 the DG
Interpretation received only four or five such complaints, of
which each year only two were linked to the quality of the
interpretation.

81.
Council Presidency Coordinators also consider that the
required six weeks’ advance notice imposed by the DG Interpre-
tation is too long and inevitably entails a large number of changes.
It was also suggested that clearer and more detailed written
instructions addressed by the Secretariat-General to the Council
Presidency Coordinator and to the meeting organisers would
make it possible to improve the planning of meetings and to
avoid the frequent cancellation of meetings especially during the
first weeks of a new presidency.

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CONCLUSIONS AND RECOMMENDATIONS

The procedures applied to avoid providing interpretation
services which exceed the real needs

82.
The audit found that the institutions have managed
to contain expenditure on interpretation over the past five years
despite an increase in the number of official languages from 11
to 20 in May 2004. Systems to ensure that interpretation is only
provided when there is a real need have been set up by the Com-
mission and the Council. The best practices observed in these
institutions should be extended to the Parliament (paragraphs 15
to 29).

The capacity to provide all the interpretation services needed

83.
The needs for interpretation concerning the official lan-
guages prior to enlargement are generally met, but an insufficient
number of interpreters is available to interpret from the new offi-
cial languages or into the new official languages (paragraphs 30
to 32).

84.
The increase in the number of working languages raises
practical and financial problems that can only be overcome by
controlling the demand for interpretation services and the related
costs. The accession of small countries creates a huge increase in
demand in small interpretation markets, where supply is rather
limited, making it increasingly difficult to meet all requests for
interpretation. The EPSO competitions organised to select staff
interpreters for the new languages were not finished until after the
date of the enlargement and did not provide enough successful
candidates to cover the needs of the EU interpretation services
(paragraphs 30 and 31).

The cost of interpretation

85.
Around 80 % of the cost of interpretation is accounted
for by the remuneration of the interpreters. Additional costs relate
to management, administration, training, information technol-
ogy, etc. The Court estimates that in 2003 the full cost of the
interpretation services provided by the Parliament and by the DG
Interpretation was around 57 and 106 million euro respectively.
Including the Court of Justice, the total cost of interpretation of
the EU institutions before the enlargement of the Union can be
estimated at about 170 million euro. The cost of an interpreta-
tion day at the Parliament is much higher than at the DG Inter-
pretation, mainly because of the way in which the Parliament’s
meetings are organised (paragraphs 33 to 41 and Annex II).

86.
Despite the measures taken to contain and reduce inter-
pretation costs, there is still the potential for further savings
through better management of meetings, in particular by ensur-
ing that last-minute changes and cancellations are kept to a mini-
mum (paragraphs 42 to 51).

Furthermore, the institutions should review their policy
87.
for the level of reserve interpretation resources kept on standby,
in order to minimise the costs involved (paragraph 45).

As shown in paragraphs 44 and 49, in 2003 at the Par-
88.
liament and the Council over 6 million euro was spent for inter-
pretation services requested but not used because of the cancel-
lation of meetings. Meetings were cancelled also at
the
Commission, but, for the reason set out in paragraph 46, the cost
of the cancellations cannot be estimated.

89.
The Commission provides interpretation services to itself
and the Council and other institutions through DG Interpretation.
Interpretation costs are billed to the other institutions — which
represents an effective resource management tool — but the
Court found that the billing rate does not take account of the full
costs. While this has no net effect on the EU budget, it could
result in inappropriate management decisions concerning the use
of available resources.

90.
Cost savings could also be achieved through a stricter
application of the Agreement with the IACI, a further integration
of computer systems and closer interinstitutional cooperation.

As to the Agreement with the IACI, consideration should
91.
be given to the possibility of negotiating an agreement to let them
benefit from the same arrangements as exist for permanent staff.
The example of the United Nations shows that a centralisation of
travel arrangements for freelance interpreters is feasible (1). Con-
sultations with the IACI could be started on the basis of Article 19
of the Agreement, with a view to amending the Agreement on
this point (paragraphs 63 to 71). Consideration should also be
given to the possibility of negociating special fares for ACIs with
travel agencies, air companies, hotels, etc.

92.
The general policy of providing interpretation either by
permanent staff or by ACIs is not clear-cut, but depends on a
large number of factors: the way in which meetings are spread out
over the year and the week, the availability of local freelance inter-
preters, the required language combinations, the distance between
the professional domicile of the interpreter and the meeting
venue, etc. Local ACIs generally cost less than staff interpreters,
whereas non-local ACIs are on average more expensive (para-
graphs 39 to 41).

The quality of interpretation

93.
The users are generally satisfied with the quality of the
interpretation services provided (paragraphs 72 to 75), although
many users have called for greater flexibility in the time limits
established for meetings.

(1) See also Article 14 of the IACI — United Nations Agreement (2000-
2005): ‘When an organisation offers the interpreter a contract it shall
endeavour to inform him of the arrangements it intends to make for
transportation. If the interpreter accepts the contract, he shall accept
whatever travel arrangements are made, unless his professional obli-
gations prior to and subsequent to his contract are such as to render
impractical, in the opinion of the organisation, participation in such
arrangements. (…)’.

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Possible developments

94.
An independent evaluation should be made of the pos-
sible benefits of creating one single interinstitutional office pro-
viding interpretation services to all EU institutions, compared
with those from an increased interinstitutional cooperation
(paragraph 58).

Each enlargement of the European Union has led to an
95.
increase in the number of working languages and the complexity
of demands for interpretation services. This report shows that,
without calling into question the principle of multilingualism, the
institutions have been able to take pragmatic steps to limit
and control interpretation costs. The Court recommends that the
institutions should continue such efforts.

This Report was adopted by the Court of Auditors in Luxembourg at its meeting of 22 Septem-
ber 2005.

For the Court of Auditors
Hubert WEBER
President

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ANNEX I

The specific provisions applying at the Parliament, the Commission
and the Council

Parliament

1.
According to Rule 138 of the Parliament’s Rules of Procedure, all Members have the right to speak in Parliament in
the official language of their choice. Speeches delivered in one of the official languages are simultaneously interpreted into
the other official languages. The same Rule also states that in committee and delegation meetings interpretation is provided
from and into the official languages used and requested by the members of each committee or delegation. In practice, for all
plenary sessions and a number of meetings of large political groups, interpretation is provided from and into all official EU
languages (11 active and passive languages before enlargement, 19 after enlargement because of insufficient availability of
Maltese interpreters). For parliamentary committee meetings, interpretation is provided for the languages of all committee
members.

Commission

As far as the use of languages is concerned, the Commission’s Rules of Procedure (1) and their implementing rules (2)
2.
allow more flexibility. For meetings of the European Commission itself, there is interpretation in just three languages (English,
French and German). For ‘Comitology Committees’ (3), the number of languages differs from one Committee to another, tak-
ing into account the requests of the national delegates. In most cases, these committee meetings are held with interpretation
into between three and seven languages.

Council

3.
Pursuant to Regulation No 1 and Article 14 of the Council’s Rules of Procedure, full interpretation (11 active and
passive languages before enlargement, 20 languages after enlargement) is provided for Ministers’ meetings. Coreper (the
Committee of Permanent Representatives) meetings are held with only three active and passive languages (English, French
and German). For the numerous other preparatory bodies (committees, groups, working parties), a particular language con-
figuration is agreed at the time each body is set up. The language configurations for each body are listed by the General Sec-
retariat of the Council in a specific nomenclature.

4.
When receiving meeting requests from the Council’s Presidency, the Conference Unit of the General Secretariat of
the Council automatically assigns a language configuration to each meeting request according to the nomenclature. All
requests for meetings with interpretation are met by the DG Interpretation as long as the total number of meetings with
interpretation and the number of interpreters per day do not exceed the ceilings set in a ‘Service Level Agreement’ (SLA),
concluded between the Commission (the DG Interpretation) and the Council in December 2002 in order to formalise the
main obligations of both parties.

(1) Rules of Procedure of the Commission, C(2000) 3614 (OJ L 308, 8.12.2000, p. 26).
(2) Rules to give effect to the Rules of Procedures of the Commission, C(2001) 1.
(3) Advisory Committees, Management Committees and Regulatory Committees governed by Council Decision 1999/468/EC of 28 June
1999 laying down the procedures for the exercise of implementing powers conferred on the Commission (OJ L 184, 17.7.1999, p. 23)
replacing Decision 87/373/EEC (OJ L 197, 18.7.1987, p. 33).

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ANNEX II

The cost calculation method developed by the Court

1.
The full budgetary cost (cost before tax and pension) to the DG Interpretation, as calculated by the Court’s auditors,
is equal to the full cost used by the DG Interpretation to set the interinstitutional billing rates plus the overhead costs not
included in the DG Interpretation calculations (cost of senior management and support staff involved in activities concern-
ing budgetary and financial matters, human resources management and general administration).

2.
By deducting the Community tax paid by staff interpreters and ACIs from the ‘cost before tax and pension’ and by
adding the fictitious employer’s pension contributions for staff interpreters (which are equal to twice the contribution paid
by the official) (1), the cost to the Community budget is obtained (cost after tax and pension). For ACIs the full budgetary
cost already includes the pension contributions paid by both the ACI and the EU institutions to an external body.

(1) According to Article 83(2) of the Staff Regulations a contribution corresponding to one third of the cost of financing the pension scheme
is deducted monthly from the salaries of officials. In consequence, the ‘employer’s contribution’ is twice the official’s contribution.

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EUROPEAN PARLIAMENT’S REPLIES

Within the Interpretation Directorate,

the Meetings
V.
and Conferences Unit checks whether requests for meetings
accord with the rules in force before agreeing to providing inter-
preting services.

VII.
The European Parliament stresses that, as a political insti-
tution, it must be capable of responding rapidly to political situ-
ations which by definition are in certain cases impossible to
schedule. A code of conduct was adopted in 1999 and updated
in 2004 in order to establish rules to provide a better framework
for the provision of interpreting services.

While many meetings organised at the other two institutions
referred to in this report may not require interpretation services,
parliamentary meetings generally do (1).

VIII.
Session reports exist for meetings of committees and
delegations; they will be extended to other types of meetings,
including those of the political groups.

Regular drafting of periodic reports to cultivate awareness among
users has suffered on account of technical difficulties. The admin-
istration undertakes to improve the situation as from September
2005.

Even if Members were required to confirm in advance
19.
that they would be attending a particular meeting, numerous dif-
ficulties would be encountered in attempting to respect the lan-
guage profile of a meeting, including the obligation to cover lan-
guage needs
attendance of Ministers,
Commissioners and invited experts at meetings.

arising from the

20 and 21.
The interpreting services regularly check with
user services the need for the resources requested; since Septem-
ber 2004, in order to ensure optimal use of resources, they have
also been making use of the reports drawn up after committee
and delegation meetings, and they will shortly also start to use
those drawn up after political group meetings.

(1) Rule 138 of the Rules of Procedure of the European Parliament reads:
‘1. All documents of Parliament shall be drawn up in the official languages.
2. All Members shall have the right to speak in Parliament in the official
language of their choice. Speeches delivered in one of the official languages
shall be simultaneously interpreted into the other official languages and into
any other language the Bureau may consider necessary.
3.
Interpretation shall be provided in committee and delegation meetings
from and into the official languages used and requested by the members and
substitutes of that committee or delegation.
4. At committee and delegation meetings away from the usual places of
work interpretation shall be provided from and into the languages of those
members who have confirmed that they will attend the meeting. These
arrangements may exceptionally be made more flexible where the members of
the committee or delegation so agree. In the event of disagreement, the Bureau
shall decide.’

User services (committees and delegations) keep the language
profiles of their meetings up to date in order to enable the Inter-
pretation Directorate to make optimal use of resources. This
information will be periodically forwarded to Parliament’s Bureau
so that it can, if appropriate, decide on any changes that may be
necessary.

30.
The EP notes (Rule 139 of the Rules of Procedure) the
fact that cover of the new official languages introduced at the time
of the most recent enlargement is as yet incomplete, because of
the lack of qualified personnel, whose training is a matter for the
Member States.

31.
Although the competition organised by EPSO to recruit
Maltese interpreters was unsuccessful, Maltese is covered at part-
sessions in Strasbourg by recruiting freelance interpreters;
in
2006 it will also be covered at part-sessions in Brussels thanks to
the availability of Maltese interpreters from a training programme
financed by the institutions.

The EP’s administration records the direct cost of
33 and 34.
interpreting services provided by freelance interpreters in accor-
dance with the rules in force, and regularly updates the average
cost of a day’s interpretation provided by a freelance.

It undertakes to study and possibly adopt the method of calcula-
tion proposed by the Court in order to improve knowledge of the
overall cost of the services provided, including those provided by
staff interpreters, and to make available the necessary resources
for management of these data.

38.
The difference observed between the costs of an interpre-
tation day at the EP and DG Interpretation is explained well in the
following point 39, where the Court indicates the specific con-
straints which characterise the EP’s work.

The excessive concentration of meetings in one part of
39.
the week or day (point 39(c)) is mainly attributable to the need for
political groups to respect deadlines for tabling amendments
before their written translation. The introduction of nine new lan-
guages has made it necessary to bring this deadline forward from
the Thursday morning to the Wednesday evening before a part-
session, the corollary of which is a concentration of meetings on
Wednesday.

The interpretation services are aware of the need to improve the
use of resources, and have therefore increased interinstitutional
cooperation to mutually make permanent staff interpreters avail-
able, and hope to increase this practice, particularly during peri-
ods when there is little work at Parliament.

In 2004, the departments responsible for organising parliamen-
tary committee and delegation meetings succeeded in increasing
the number of meetings scheduled for Thursday afternoons.

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Meetings are held at late hours at the EP (point 39(d)) as a result
of decisions taken by the political bodies on the organisation of
work; most are accounted for by meetings held during Strasbourg
and Brussels part-sessions, certain meetings of the Committee on
Budgets during the budget adoption period and certain meetings
of conciliation committees. They represent a very small propor-
tion of the total volume of work and are an integral part of the
work pattern proper to the parliamentary institution of the
25 Member States.

The EP welcomes the progress made in interinstitutional
55.
cooperation in the field of interpreting. This is not confined to the
recommendations made in the ‘Chêne report’: in particular, it also
includes ad hoc exchanges of permanent staff interpreters work-
ing in the old official languages.

Certain differences between the institutions as regards the work-
ing conditions of interpreters still hamper exchanges of staff inter-
preters. This subject is under consideration.

The high cost of providing interpretation services at short
42.
notice reflects the organisational flexibility required within the EP.

As indicated in the reply to point VII above, meetings may be
requested at short notice as Parliament is called upon to respond
to political events.

The late cancellation of meetings to which interpreters
43.
have been assigned and the scope for perfecting the planning of
work are cost factors which the administration regularly draws to
the attention of users. It has been decided that their awareness
should be fostered more by regularly informing them of the cost
of these late cancellations. However, the figures quoted by the
Court should be placed in perspective in order to avoid any mis-
understanding. Many meetings consist of a series of sub-meetings
held in the course of a single day (coordinators, chairman
and vice-chairmen, working groups, etc.): the cancellation of one
or more of these sub-meetings does not have any budgetary
implications if the interpreters have worked during other sub-
meetings. Moreover, the figures for cancellations of meetings also
include ‘technical’ cancellations which do not have any impact on
the interpretation budget because they merely entail rescheduling
the same meeting which has already been requested while alter-
ing the timing, meeting room, place of work or languages
requested.

In managing interpretation, it is necessary to reconcile
44.
the budgetary approach, which focuses on payments to freelances
(freelances are paid a fixed daily amount, even if they work only
during one brief meeting), and the timetabling of Parliament’s
work, where half-day slots or even shorter periods apply. Conse-
quently, the budgetary impact of interpretation costs is only lim-
ited, or even non-existent, when a ‘sub-meeting’ or working group
meeting is cancelled but the interpreters concerned have worked
during other meetings the same day (on average, it is possible for
70 % of interpreters who become available because of cancella-
tion of a meeting to be reassigned to other meetings). This being
so, Parliament estimates that the cost of interpretation services
scheduled but not used in 2003 amounted to less than 5 % of all
the interpreting resources mobilised (56 298 interpreter days), or
just over half the percentage and cost mentioned by the Court.

56.
Irrespective of the savings and gains in efficiency which
might be possible, it should be noted that the existence of three
interpretation services corresponds to the particular characters
and specific needs of these institutions.

The calendars of work of the institutions could be harmonised
more in order to improve the efficiency and availability of the
interpreting service, particularly in the case of the enlargement
languages.

The concept of competition is not in any way applicable
57.
to pay, which is set at the same level for all the EU institutions by
agreement with the profession.

The Secretaries-General of the institutions, being aware of the
need to make better use of the human resources available (see
point 57(b)), have very significantly stepped up interinstitutional
cooperation and have initiated a programme of mutual provision
of staff interpreters; they are determined to increase cooperation
in this field.

Joint management of the list of freelance interpreters and greater
consultation between scheduling departments is already making
it possible to share travel expenses (point 57(c)) to an extent
which could undoubtedly still be improved.

58.
The European Parliament’s political and operational
autonomy could not be reconciled with an organisational prac-
tice whereby the EP would have to submit its requests for official
meetings for administrative arbitration, which would become
unavoidable in connection with the management of the resources
available, and in sum would make the holding of Parliament’s
meetings subject to such technical arbitration. Thus the European
Parliament cannot endorse the idea of setting up a single agency
the
responsible for providing interpretation services to all
institutions.

Incidentally, the conclusions of the ‘Chêne report’, formulated in
2002 for the Secretaries-General of the institutions after a detailed
study, advocated increasing synergy rather than merging services.

Lastly,
in economic terms, the setting-up of a single agency
responsible for providing interpreting services to all the institu-
tions would not reduce the additional costs arising from the
organisation of the EP’s meetings (costs of missions to Strasbourg,
more missions, objective factors which the Court describes as
being justified). Nor would it make it possible to reduce the short-
age of qualified interpreters for certain languages.

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The European Parliament has always aimed for a 50/50
62.
ratio between freelance interpreters (ACIs) and permanent staff
interpreters; this ratio is of course favourable to ACIs at peak
times, but in 2004 the ratio stabilised at 52 % permanent staff
to 48 % ACIs.

The provisions of the new Staff Regulations currently distinguish
between the daily subsistence allowance and the accommodation
allowance. Renegotiation of the Agreement with the IACI would
make it possible to clarify these provisions.

63.
Particularly since the setting-up of a single department
responsible for all payments to ACIs, the EP’s administration has
sought to verify more carefully the travel expenses incurred by
ACIs.

72.
The duration of interpretation sessions is set at three and
a half hours for customary meetings. However, if the user service
so requests, it can easily be increased to four hours or more, the
teams of interpreters being enlarged for the purpose.

The aim is to apply the lowest rates possible while complying
with the rules in force and as far as possible bringing the pay-
ments into line with the criteria which apply to permanent staff
interpreters.

82.
The best practices observed at the other institutions will
be studied by EP departments which use interpreting services with
the aim of improving the planning of work while respecting the
political imperatives referred to in the reply to point VII.

The EP is willing to renegotiate the Agreement with the IACI.

64 and 65.
The type of plane ticket referred to in Article 10
of the rules implementing the Agreement currently in force (an
exchangeable and reimbursable IATA ticket at the lowest rate that
is not subject to quotas) does not correspond to a ticket ‘subject
to restrictions’ [the phrase used in the French text of the Court of
Auditors’ preliminary observations where the English version has
‘subject to quotas’ — translator’s note].

If appropriate, however, Parliament’s administration agrees to
reimburse travel expenses on the basis of a reduced rate subject
to restrictions, undertaking to reimburse interpreters for any pen-
alty incurred for reasons arising from their work for Parliament.

The administration encourages ACIs to use this formula, and to
systematically call upon the services of the travel agency con-
tracted to the EP, which is instructed to apply the negotiated rates
or the best available rates.

In certain cases and on certain lines (e.g. Brussels-Strasbourg dur-
ing the EP’s part-sessions), no exchangeable ticket is available at
less than business class rate.

In cooperation with the new single department respon-
66.
sible for paying ACIs which was set up in October 2004, the EP’s
administration has established a unit to monitor expenses arising
from the commitments of ACIs.

83 and 84.
The cover of needs for interpretation concerning
the new official languages is progressing in step with the consid-
erable efforts which the institutions are making to find new inter-
preters and to provide supplementary training. However, the new
Member States have a prime role to play in training linguists.

85 and 86.
Full multilingualism, which the EP desires, entails
substantial costs, which can be controlled better on the basis of
the type of organisation of parliamentary work and optimal plan-
ning of meetings. These costs also arise from political decisions
relating to the organisation of work (calendars and places of
work).

87.
The EP’s Interpretation Directorate pursues a minimalist
policy on reserve interpretation teams. Only one reserve team per
day is programmed, and that only on days of peak work; in the
end, the reserve team is always used, either fully or in large part.

88.

See Parliament’s reply to point 44.

90 and 91.
The EP’s administration is currently in the pro-
cess of applying the Agreement with the IACI more strictly,
increasing the integration of IT systems and intensifying interin-
stitutional cooperation; it undertakes to continue these efforts.

The EP is open to the possibility of renegotiating the Agreement.

67.
It is true that Parliament has always applied Article 9(2)
of the Agreement with the profession, considering that its pur-
pose was to ensure that the same scales were applicable, rather
than the rules on payment of fractions of daily allowances.

92.
The EP considers that it should have a body of staff inter-
preters to guarantee the EP’s independence and autonomy in this
respect.

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Ad hoc use of freelance interpreters as needs dictate makes it pos-
sible to cope with peaks of work while keeping the budget under
control.

A 50/50 ratio seems a reasonable compromise between
autonomy and flexibility of the service.

93.
The duration of meetings is decided by the political and
parliamentary bodies; it may exceed the duration laid down by
agreement, namely three and a half hours, as mentioned at 72.

The interpreting service is required to comply with all requests
which accord with the rules; to this end it assigns interpreters to
meetings in accordance with the rules in force concerning work-
ing conditions.

It is up to the EP’s political authority to determine
94.
whether it wishes to have its own autonomous interpreting ser-
vice, albeit involved in extensive interinstitutional cooperation, or
whether it prefers to work towards the establishment of a single
agency to provide interpreting services to all the institutions.

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REPLIES BY THE COUNCIL

The General Secretariat of the Council welcomes the European Court of Auditors’ report on interpretation
expenditure of the EU institutions, which could serve as a basis for further rationalisation of the use of inter-
pretation facilities in the future.

Remarks on some individual points of the report

10 and 11.
Table 1 and following analyses in points 10
and 11 do not give a full explanation on the increase of

interpreter days in the Council between 1998 and 2002 (+ 9 %).
The main reason for this increase is the significant growth of the
Council’s activities and the number of meetings (+ 39 %) held
within the Council during that period (see Table 1).

The volume of interpreter days provided to the Council, including the languages of the new Member States,
compared to the number of meetings (index 1998 = 100)

Table 1

Council meetings

Interpreter days provided for the Council

1998

1999

2000

2001

2002

2003

100

100

105,8

112,2

96,8

96,3

132,7

105,6

139

109,1

135,8

103,9

2004

124,8

89,9

As for the decrease of – 13 % in interpretation days in the Coun-
cil in 2004, it should be noted that the number of meetings went
down by – 8 % in 2004. Moreover the following factors must be
taken into account:

— Since 1 May 2004 there have been fewer meetings with inter-

pretation based on SG/HR decision No 56/04.

— The old Member States (former EU-15) made fewer requests

for interpretation in 2004 than before.

— DG Interpretation could not provide all the requested inter-

pretation for the new languages.

It should be added that the Council’s budget also finances

28.
50 % of the Coreper meetings’ interpretation expenditure.

35.
The fact that the definition of the ‘MAD’ is not clear and
has frequently changed over the years makes every analysis based
on this concept highly questionable.

49.
It should be mentioned that even if the Council cancels a
meeting for which interpretation has been booked and has to be
paid, it does not mean that the interpreters would stay idle.
According to the Council’s experience, DG Interpretation can and
has assigned some of these interpreters to other meetings held in
the Commission or
serviced by
DG Interpretation.

institutions

in other

94.
The General Secretariat of the Council supports the idea
of carrying out an independent evaluation on the possible ben-
efits of creating one single interinstitutional office providing inter-
pretation services to all EU institutions.

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THE COMMISSION’S REPLIES

EXECUTIVE SUMMARY

INTRODUCTION

I.
DG Interpretation ensures multilingual communication,
which is at the core of Community decision making. It ensures
equal linguistic treatment of all Member States, giving each of
them the possibility to use its official language(s) when address-
ing the institutions. It also sustains multilingualism in the Union,
which has become a sensitive political matter. Matching real
needs, high quality, availability and cost-effectiveness are the
guiding principles followed by the Commission for the provision
of interpretation.

6.
The Commission would point out that for a number of
years it has been supplying direct to the countries exercising the
presidency of the Council of the Union, at their request and at
their expense, teams of interpreters for meetings organised by the
presidency outside the framework agreed between the presidency
and the Council. Over time these meetings have come to consti-
tute a sizeable part of DG Interpretation’s work.

II.
Whilst taking into account the principle of satisfying real
needs in a cost-effective manner, the Commission is bound to
ensure the availability of interpreters of the highest quality, whose
services are required by the political nature of the activities of the
European Union. DG Interpretation employs staff interpreters to
guarantee the availability and continuity of interpretation services
with the high quality needed by the institutions. When demand
for interpretation exceeds what DG Interpretation can offer,
freelance interpreters (AIC) of the same quality are hired.

8.
DG Interpretation employs staff interpreters (officials) to
guarantee the availability and continuity of interpretation services
with the high quality needed by the institutions it serves. Staff
interpreters also play a vital role in areas like training and selec-
tion, not to mention quality control. Availability of staff interpret-
ers also allows the assignment of stable teams to high level, politi-
cally sensitive or very specific technical meetings, this being a very
important factor to ensure quality interpretation is delivered on
these occasions.

V.
As a matter of principle the DG Interpretation of the Com-
mission takes great care in examining the requests for interpreta-
tion and makes available to the other services information about
the languages not used in any given meeting. It also coordinates
with Commission services to provide only those languages that
are needed, in so far as this can be foreseen.

VI.
The average figure of 1 046 euro per interpreter day is a
global amount that includes expenses such as training to staff
interpreters, support to national training institutions, in-house
and external awareness raising and advice on defining policies on
the technical aspects of multilingual communication.

In May 2004 the Council of Ministers introduced an
10.
interpretation ‘on request’ system that has had a general effect of
decreasing the amount of interpretation requested. This trend is
confirmed for the four first months of 2005, as the total output
equals that of the same period in 2004, whereas the number of
languages into which and from which interpretation is requested
rose from 11 to 20. However, inherent to this system is a higher
risk of peaks and troughs which makes it difficult to ensure an
optimised use of resources. Also, the implications of this system
on the availability of interpretation must be closely monitored, as
a stable minimum level of activity is needed to ensure that the
necessary staffing levels and quality can be retained to meet
demand during peak periods.

THE AUDIT OBJECTIVE AND SCOPE

Session reports include details on the use of languages
VIII.
in any given meeting and they are produced in 82,5 % of the
meetings serviced by DG Interpretation. DG Interpretation
focuses on drawing the attention of Directorates-General, who
repeatedly ask for languages that subsequently are not used, to the
waste of resources that this involves.

13.
In order to keep AIC travel costs as low as possible, six
weeks’ advance planning of meetings is necessary, but this may
result in a number of cancellations as this advance notice period
is perceived as too long by many Delegations.

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In case of cancellation of a meeting, interpreters are, to the extent
possible, immediately re-allocated to other meetings. A new sys-
tem based on the counting of interpretation sessions, which DG
Interpretation is eager to implement, would take due account of
cancellations and give a clearer view of the cost of both requests
and cancellations.

The ‘on request’ system adopted by the Council does not totally
guarantee stability in demand and makes it less predictable. DG
Interpretation provides in principle a fixed number of interpreta-
tion days to the Council.

OBSERVATIONS

15.
The Commission adopted procedures based on the prin-
ciple of satisfying ‘real needs’ in 1984 and confirmed in 2002,
making a distinction between political and technical meetings.
DG Interpretation actively monitors language use in meetings by
requiring the lead interpreter to fill in a session report and by sys-
tematically informing meeting organisers about the languages
requested but not used, as an incentive towards a real needs
policy. The non-use of a language depends on how a meeting
evolves and on other parameters beyond the control of both the
interpretation services and the meeting organisers. For requests
from other institutions, DG Interpretation is not in a position to
decide whether a language is necessary, nor can it anticipate
which languages will actually be spoken or listened to.

23.
DG Interpretation makes its best efforts to provide the
requested languages and has no power to influence language
regimes decided for political reasons. Non-use of a language can-
not be anticipated. Delegates may use a language other than their
mother tongue due to unforeseen situations in the meeting, or
simply decide not to speak at all whilst still listening to interpre-
tation. However, in case a booth proves not to be necessary, the
interpreter in charge contacts the Planning who will then remove
that active language and re-allocate the interpreters where pos-
sible. The quote ‘1 750 interpreter days paid but not used’ does
not take into account the re-assignment of interpreters nor that a
Delegation may be listening to interpretation without taking the
floor.

24.
The Commission has carefully examined the possibility
of introducing an internal billing system for Commission DGs
and has concluded that the administrative burden entailed would
be disproportionate to any possible benefits. Institutions such as
the Council of Europe and Unesco are different in scale from the
Commission and the volume of interpretation and the number of
their working languages, for which interpreters are not in short
supply, represent only a fraction of the Commission’s interpreta-
tion activity.

Through a weekly negotiation process, DG Interpretation takes
into account a priority ranking drawn up by each DG as well as
the total available resources within a broader timescale than the
date for which the meeting is requested and proposes alternatives
in order to strike a balance between political needs and optimum
use of resources.

DG Interpretation is currently testing, with its clients, a new sys-
tem for calculating the provision of interpretation based on ses-
sions, which is closer to reality, because it is linked to the actual
resources used, and thus, should help to reduce the level of man-
agement risks. This new system, when applied, will make avail-
able to clients more accurate forecasts and data on their use of
interpretation and the cost thereof.

26.
Member States are entitled to request and receive the
interpretation they require and their delegations often consist of
more than one person. Each delegate may have a different capac-
ity of expressing himself or of understanding other languages and
will thus use interpretation differently (e.g. some delegates may
listen directly to English, but still prefer to speak their own lan-
guage or speak English but listen to interpretation into their own
language). For this reason it is difficult to say if a language can be
considered not necessary because it was not spoken.

31.
The competitions for interpreters in connection with
enlargement were advertised in early April 2003, 13 months
before enlargement, and were completed between March and
November 2004, depending on the language (the competition for
Maltese was completed in December 2003, but without any suc-
cessful candidates).

For some of these new languages, one of the main reasons for the
inadequate number of successful candidates was the shortage of
interpreters trained to the internationally recognised standards.

35.
The Commission is aware of some shortcomings of the
BMA (mise à disposition, MAD) system used for billing its client
institutions, bodies and agencies. For this reason it has prepared a
new system to measure the amount of interpretation provided
through the concept of ‘interpretation sessions’. This new system
is much closer to reality and the Commission is ready to intro-
duce billing based on it. This includes features allowing the insti-
tutions to forecast more accurately the cost of a meeting as soon
as it is requested. This concept was already presented to the Coun-
cil, the EESC and the CoR in 2004 and simulations are being run
in parallel with the existing BMA system, with a view to formally
run the new sessions-based system in 2006.

C 291/26

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Official Journal of the European Union

23.11.2005

The figure of 1 046 euros per average interpreter
37 and 38.
day calculated for DG Interpretation is a global amount that
includes expenses such as training and support to educational
schemes, in-house and external awareness raising and advice on
the technical aspects of multilingual communication. DG Inter-
pretation aims at providing interpretation as requested in order to
facilitate the decision making process within the European
institutions.

40.
In 2003, many staff interpreters were involved in the
preparations for enlargement: they were attending training for the
new languages, providing assistance to various training programs
in universities in the accession countries and sitting on competi-
tion juries or freelance tests. In addition two extraordinary sum-
mits in preparation of enlargement led to the cancellation of all
other meetings in the Council during the periods concerned. Two
strike days in 2003 accounted for about 1 % of the drop in the
occupation level of staff interpreters.

45.
Due to the political nature of the activity of the institu-
tions, and to the fact that the availability and continuity of the
interpretation services must be guaranteed, DG Interpretation is
obliged to maintain a limited quantity of reserve interpreters. It
would be a false economy not to have a reserve, as the impossi-
bility of replacing a missing interpreter and thus ensuring the nec-
essary linguistic coverage with all the relays needed to make it
work would mean the whole interpretation team could not func-
tion. Since the unavailability of one interpreter might mean the
cancellation of a whole meeting, recourse to a reserve is to be
considered as a reasonable risk management measure. Moreover,
linked to the nature of interpretation itself, and in order to secure
a high level of quality, DG Interpretation is bound by an Agree-
ment on Working Conditions which limits the number of work-
ing ‘sessions’ an interpreter is allowed to work and provides for
limited standby arrangements. Two more aspects also need to be
taken into account when considering standby duty:

— It is often difficult to reassign for the remaining half day staff
interpreters who under the Staff Regulations are entitled to
work half time on any given day.

— The Staff Regulations do not allow the institutions to insist
that statutory staff take leave at a specific point of time such
as periods of decreased activity.

DG Interpretation already has an active policy of encouraging
leave during decreased activity periods and also concentrates
training at these times. The Commission will continue its endeav-
ours to further reduce implicit standby duty costs. However,
either for the reasons given above or because of late cancellations
of meetings by other institutions, there is limited scope for real
savings in this area.

The fact that there were nine working days on which at
47.
least 100 permanent interpreters were on implicit stand-by is
merely an illustration of changes to planned agenda at short
notice corresponding to exceptional circumstances: the European
Council Extraordinary Summits, which caused the cancellation of
all other Council meetings and two days of strike. Contracts of
AICs cannot be cancelled within 60 days of the start of the con-
tract, but to limit costs, these contracts are converted to local con-
tracts. Staff interpreters whose meetings are cancelled are put on
stand-by.

Interpretation services cannot determine the pace of
48.
meetings nor the content of agendas. Delegates meet when they
think it is appropriate and the interpretation services provide
interpretation as requested.

54.

(a) The price system of DG Interpretation is based on a flat rate
modulated to each type of request; meetings booked at short
notice, late meetings, meetings held on weekends or public
holidays costing more. Cancelled meetings are also billed. It
is not politically acceptable to have different prices for dif-
ferent languages as this undermines the principle of equality
embedded in the Treaty.

(b) The Commission incurs a deficit because the client institu-
tions have historically paid less than the full price requested
by DG Interpretation. The Commission is also aware of some
shortcomings of the BMA (MAD, mise à disposition) system.
For this reason it has prepared a new system for measuring
the volume of interpretation provided and will soon be ready
to introduce a new billing system based on sessions. This sys-
tem is closer to reality and includes features allowing sound
forecasts about the cost of a meeting as soon as it is requested.
Simulations have been made and the system was presented
to the Council, the EESC and the CoR in 2004. The two bill-
ing systems are being run in parallel in 2005 with the aim of
applying session billing to the institutions in 2006.

(c) The price applied by DG Interpretation is suitable for inter-
institutional billing but is not intended to express its full
costs.

46.
The Commission can retrieve information about cancel-
lations and would be able to show the reallocation of interpreters
but as this is an ongoing process such tracking would be time-
consuming with any likely benefits being outweighed by the
costs.

(d) The Service Level Agreement agreed with the institutional cli-
ents corresponds to the logistics and resources available for
meetings but it does not prevent troughs because demand is
determined by each institution in the light of their planning
and political agenda, which to date the Commission’s inter-
pretation services have no means of influencing.

23.11.2005

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Official Journal of the European Union

C 291/27

(e) Even though the introduction of the new billing system
would make the billing exercise less labour intensive, DG
Interpretation is aware that maximum efficiency in the man-
agement of interpretation resources can only be achieved by
linking the computer systems between institutions and will
continue working in this direction. For reasons of security
and differences in the architecture of corporate systems,
establishing IT links between institutions takes time.

(c) The current organisation already allows for reduced travel
costs on a case-by-case basis by taking advantage of the pres-
ence of non local AICs already contracted by the other insti-
tution for adjacent days. Full IT communication between
institutions on the availability and global management of
freelance interpreters is expected to be operational in Sep-
tember 2005.

The Commission welcomes the progress interpretation
55.
services made in the area of
interinstitutional cooperation.
Achievements go further than the recommendations of the ‘Chêne
report’, and include areas such as training and more recently, to a
limited extent, the exchange of permanent resources.

(d)

Joint management of freelances, including selection, accredi-
tation, quality control and payment will be fully operational
when on line communication of the IT systems of the differ-
ent institutions will be opened up in September 2005, fol-
lowing the ongoing test phase.

— (4th indent) Different working conditions applying to inter-
preters in the different institutions still prevent an optimal
rate of exchange. However, for the last years the services have
been working to make progress in every area of interinstitu-
tional cooperation.

56.
Real progress has been made in interinstitutional coop-
eration. The different services continue adapting to the possible
extent the way they function, to bring progress in areas like the
reciprocal use of permanent resources and by sharing the work in
periods of intense activity. However, there is still ground to
develop and consolidate the cooperation highlighted in the 2002
report by an interinstitutional working group chaired by Mr
Claude Chêne without calling to question the political autonomy
of each institution.

58.
The creation of a single interinstitutional service provid-
ing interpretation to all EU institutions would require a decision,
between institutions, at political level. The Commission believes
that deepening interinstitutional cooperation could bring econo-
mies of scale and savings without calling into question the
autonomy of the institutions in matters of budget, staff and the
capacity to adapt priorities to the political agenda. To launch an
evaluation of the advantages of a single interpretation service
compared to improvements in interinstitutional cooperation it
would be necessary to have a clear signal from the other institu-
tions of their willingness to pursue such a course rather than con-
tinue with progress on interinstitutional cooperation. Indeed,
enormous efforts and significant resources have already led to
merging the payment offices, to creating a common list of accred-
ited freelances and holding joint competitions and accreditation
tests. These efforts should be consolidated and strengthened and
the results analysed: detailed analysis of benefits and savings is
necessary before a decision on further developments is taken.

57.

(a) Competition among interpretation services to recruit AIC is
limited by the Agreement with IACI, which is applied by all
the institutions. Improvement of coordination of recruiting
services is however a clear goal at this stage of the develop-
ment of interinstitutional cooperation.

Variations in the number of requests for interpretation
59.
makes the average ratio between staff interpreters and freelances
hired for interpretation services varying from one year to another.
In the run-up to enlargement, for example, the number of staff
interpreters on interpreting assignments was reduced because a
certain number were already present in the accession States to
help prepare for enlargement. A further number of staff were sit-
ting in the evaluation panel of accreditation tests for the new lan-
guages. For those languages, it must be remembered that inter-
pretation services rely for the time being very significantly on
accredited freelances, increasing the overall share of the latter
since 1 May 2004.

(b)

Interpretation services are working to improve communica-
tion systems between the institutions despite the difficulties
linked to security and different corporate IT architecture.
Important progress is expected to take place in 2005. An
interinstitutional policy for the exchange of staff interpreters
has not yet been established due to different working condi-
tions and other staff related provisions, but the services are
working with a view to overcoming these difficulties. How-
ever, ensuring a guaranteed level of service can only be
achieved through binding, not ad hoc decisions.

60.
A change in ratios cannot take place overnight. However,
planning is possible in the long term. The issue of language com-
binations prevents interpretation services from applying strict
ratios, as interpreters vary in the number of languages they know,
and very often, staff interpreters have a wider language combina-
tion than freelances. Staff interpreters are also needed to main-
tain quality control, continuity in meetings and confidentiality at
politically sensitive meetings.

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Official Journal of the European Union

23.11.2005

A competition for Greek was organised in 2003 and a
61.
Portuguese one is foreseen in 2006. The share between local and
non-local freelance has changed with the introduction of the ‘on
request’ system by the Council. More local freelances are now
employed as the non-locals have changed their professional
domicile to Brussels, thereby allowing a large reduction of cost.

63.
Higher travel costs for AIC result from the obligation of
the Commission to apply strictly the conditions of the Agreement
and to respect the conditions by which it is bound to reimburse
the cost of travel. AICs are encouraged to take the cheapest pos-
sible tickets through the issuing of information about travel
prices, whilst staff interpreters can benefit from the corporate
booking rates and restricted fares.

DG Interpretation is bound to respect the terms of the
68.
Agreement and its modalities, which do not require an AIC to
prove that he bought the cheapest ticket available. When the
terms of the Agreement are respected, DG Interpretation has to
pay the ticket. The commercial policy of the airline also has an
impact on the cost of tickets.

DG Interpretation does not have the flexibility of observ-
70.
ing market conditions since it is bound by the terms of the Agree-
ment. High standards in recruiting AICs are indeed applied and
quality secured by respecting the Agreement on working condi-
tions for interpreters. The quality of AICs is reported on fre-
quently and all have passed an accreditation test to be on the
interinstitutional freelance list. Language training is also available
for them during low activity periods.

71.
The existing Agreement does not foresee the possibility
of paying less in the case of cancelled meetings. However, the
Commission pays less for its AICs than other international
institutions.

73.
DG Interpretation is aware of the very high satisfaction
rate with regard to the quality of the interpretation services it pro-
vides. It strives to maintain its reputation for quality through, for
example, thematic training. Moreover, a study on better docu-
mentation is being carried out by an external company with a
view to improving the provision of documentation to interpret-
ers ahead of meetings. A final report on this subject is expected
in 2005.

76.
There is a definite policy of keeping teams unchanged for
assignments to difficult meetings, although unforeseen events or
the availability of specific resources does not always make this
possible.

A ‘volontariat’ scheme is in place (interpreters may express an
interest for specific meetings) and attention is paid to maintain-
ing stable teams.

Interpretation is a highly specialised profession requiring
78.
a high level of concentration. In order to guarantee quality, spe-
cific working conditions are necessary. The limitations which
exist, i.e. a maximum of 4 hours of work in the morning, a com-
pulsory 90 minutes lunch break and the end of the normal work-
day at 18.30, are measures in place to ensure that the quality of
interpretation is guaranteed over time. However, extensions
to continue beyond 18.30 can be agreed by simple advance
request by the meeting organisers.

81.
In order to secure the best quality/price ratio, a six weeks’
advance notice is considered by the Commission to be a reason-
able timescale to allow for proper forecasting, good planning and
management of resources. This may generate difficulties for other
institutions, but DG Interpretation attempts to address any prob-
lems on a case by case basis. Late requests generate higher costs.

CONCLUSIONS AND RECOMMENDATIONS

The Commission acknowledges that its efforts to contain
five years are

82.
expenditure on interpretation over the past
recognised.

83.
Enlargement is a process which requires advance plan-
ning. Although DG Interpretation has made numerous awareness
raising actions in all the new Member States well in advance and
provided considerable assistance to set up and manage conference
interpreting training courses, there remains a shortage of inter-
preters in particular for some of the new languages. However, the
Commission cannot take over the prime responsibility of Mem-
ber States to provide interpretation qualifications and guarantee
the supply of a number of suitably qualified interpreters.

84.
The competitions for interpreters in connection with
enlargement were advertised in early April 2003, 13 months
before enlargement, and were completed between March and
November 2004, depending on the language (the competition for
Maltese was completed in December 2003, but without any suc-
cessful candidates).

For some of these new languages, one of the main reasons for the
inadequate number of successful candidates was the shortage of
interpreters trained to the internationally recognised standards.

86.
The interpretation services provide quality interpretation
as and when requested. They take action upon cancellation of
meetings by the organisers by reallocating those interpreters that
became free to other meetings. The Commission considers that a
six weeks’ advance notice is a reasonable timescale to allow for
proper forecasting, good planning and management of resources.
This may sometimes generate difficulties for other institutions,
but DG Interpretation addresses any problems on a case-by-case
basis.

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Official Journal of the European Union

C 291/29

A limited reserve of

interpretation resources is on
87.
stand-by as a risk-management policy to avoid cancellation costs
and to allow DG Interpretation to cope with the requirement for
quality, availability and continuity to which the DG is bound.
Regarding the political nature of the institutions it serves, being
unable to respect these requirements would render redundant the
mission of the DG.

88.
It would be possible for DG Interpretation to retrieve
information about cancellations and show reallocation of inter-
preters but this being an ongoing process, it would be time-
consuming to do this extensive tracking work. The cost in terms
of extra staff would negate any derived benefits.

It is acknowledged that the billing rate, although suitable
89.
for the purposes of interinstitutional billing, is lower than what
would be required to take into account the full costs, because the
agreed rate results from a negotiation between DG Interpretation
and its institutional customers. Moreover, DG Interpretation
could not withdraw the provision of interpretation because of a
failure to agree on a billing rate.

90.
As regards the Commission, the Agreement with the
IACI is strictly applied and no further savings can be achieved in
the present conditions. The Commission believes further savings
can only be achieved by renegotiating the Agreement. Further
integration of computer systems and closer interinstitutional
cooperation have been under way since 2002 and will continue
amongst the highest priorities of the Commission in the area of
conference interpretation.

91.
The Commission agrees that consideration should be
given to renegotiate the Agreement with the IACI, with a view to
applying similar travel arrangements to freelance interpreters as
to permanent staff. However, concerning special contracts with
travel agencies, air companies or hotels, DG Interpretation deems
that it is not efficient to duplicate the approach already taken by
the Personnel and Administration DG. The possibility to renego-
tiate the agreement could also provide further gains if consider-
ation is taken to bringing the remuneration structure of AIC into
line with the philosophy put in place for permanent staff by the
Reform of the Administration as well as to the new reality of an
enlarged Union. Renegotiating the IACI Agreement requires the
agreement of all the EU institutions involved.

Interpretation is a highly specialised profession requiring
93.
a high level of preparation and concentration. In order to guar-
antee a level of quality that satisfies the users, specific working
conditions are necessary. The limitations which exist in the Agree-
ment on working conditions ensure that the quality of interpre-
tation is guaranteed over time. It should be recalled that exten-
sions can be agreed by simple request
from the meeting
organisers; a change of teams or other arrangements are then
made.

94.
The creation of a single interinstitutional service provid-
ing interpretation to all EU institutions would require a decision
at political level. The Commission believes that deepening inter-
institutional cooperation could bring economies of scale and sav-
ings without calling into question the autonomy of the institu-
tions in matters of budget, staff and the capacity to adapt priorities
to the political agenda. To launch an evaluation of the advantages
of a single interpretation service compared to improvements in
interinstitutional cooperation, it would be necessary to have a
clear signal from the other institutions of their willingness to pur-
sue such a course rather than continue with progress on interin-
stitutional cooperation. Indeed, enormous efforts and significant
resources have already led to merging the payment offices, to cre-
ating a common list of accredited freelances and holding joint
competitions and accreditation tests. These efforts should be con-
solidated and strengthened and the results analysed: detailed
analysis of benefits and savings is necessary before a decision on
further developments is taken.

The Commission agrees to continue its efforts to give a
95.
positive answer to the challenge of multilingualism, whilst keep-
ing interpretation costs under control. This could be achieved
through the consolidation of interinstitutional cooperation, es-
pecially in terms of the use of permanent staff, and by exploring
the possibilities to simplify and consolidate the terms of travel
and remuneration of freelance interpreters, through a renegotia-
tion of the Agreement with the IACI. Only after progress in these
areas is consolidated and the institutions have a clearly defined
political approach to their autonomy in interpretation matters, is
it worth considering the launching of an independent study on
the advantages of setting up a single interinstitutional office.