Special Report No 9/2006 concerning translation expenditure incurred by the Commission, the Parliament and the Council together with the institutions’ replies
Date: 2006-07-06
Institutions: European Court of Auditors
Subjects: Council of the European Union, European Commission, European Parliament, audit, cost-effectiveness analysis, operational expenditure (EU), translation

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I

(Information)

COURT OF AUDITORS

SPECIAL REPORT No 9/2006

concerning translation expenditure incurred by the Commission, the
Parliament and the Council together with the Institutions’ replies

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

(2006/C 284/01)

TABLE OF CONTENTS

Paragraph

Page

ABBREVIATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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

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

Legal framework . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Organisation of the translation services of the EU institutions . . . . . . . . . . . . . . . . . . . . .

Audit scope and approach . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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

The procedures applied to ensure that translation demands are met and unnecessary trans-
lations are avoided . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Internal guidelines governing translation requests . . . . . . . . . . . . . . . . . . . . . . . . . .

The capacity to meet translation demand . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

The evolution of the number of pages translated . . . . . . . . . . . . . . . . . . . . . . . . . . .

Practical measures taken by the institutions to contain translation volume . . . . . . .

Quality control

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

The controls to ensure translations are of adequate quality . . . . . . . . . . . . . . . . . . .

Timeliness and other elements of client satisfaction . . . . . . . . . . . . . . . . . . . . . . . . .

The cost and the efficiency of translations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

The cost of translation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

The efficiency of the translation process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

I-IX

1-11

2-3

4-8

9-11

12-95

12-36

13-18

19-23

24-26

27-36

37-46

37-43

44-46

47-95

47-52

53-95

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

96-109

The procedures applied to ensure that translation demands are met and unnecessary trans-
lations are avoided . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

The procedures applied to ensure that translations are timely and of adequate quality for
their purpose . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

96-98

99-101

The cost and the efficiency of translation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

102-109

3

4

5

5

5

6

6

6

6

7

7

9

9

9

10

10

10

13

18

18

19

19

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Paragraph

Page

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

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

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

1-12

1-6

7-10

Council

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

11-12

ANNEX II: The method developed by the Court to estimate translation cost . . . . . . . . . . . . . .

1-9

Institutions’ replies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

21

21

21

22

24

25

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CIEQ

Interinstitutional Committee for the Evaluation of External Translations

ABBREVIATIONS

CRE

DG

Compte rendu in extenso (detailed record of the debates at the Parliament’s plenary sessions)

Directorate-General

DG A III

Directorate A III (Translation and document production) of the Secretariat-General of the Council

DGT

EP

Directorate General for Translation of the Commission

European Parliament

EPSO

European Personnel Selection Office

EU-15 languages Official languages of the 15 EU Member States prior to enlargement

EU-10 languages Official languages of the 10 enlargement countries

FTE

ICTI

ISC

MEP

OJ

SGC

Full-time equivalent (a measurement equal to one staff member working a full-time work schedule
for one year)

Interinstitutional Committee for Translation and Interpretation

Inter-Service Consultation (consultation between Commission Directorates-General)

Member of European Parliament

Official Journal of the European Union

Secretariat-General of the Council

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EXECUTIVE SUMMARY

I.
Twenty-one languages have the status of official and working languages of the European institutions.
Each EU institution has its own translation service. The institutions which, on account of their activities, have
to provide the largest volume of translations are the Commission, the Parliament and the Council. Because of
the uneven spread of demand over the year or temporary insufficient internal capacity for the EU-10 languages,
the European institutions need freelance translators in addition to their staff translators.

II.
The objective of the audit was to assess the extent to which the Commission, the Parliament and the
Council manage their translation resources and expenditure efficiently and effectively. The Court addressed
three questions:

— Is translation demand met and are there adequate procedures to avoid unnecessary translations?

— Are translations timely and of adequate quality for their purpose?

— Were the institutions able to keep the cost of translations under control?

III.
The audit has shown that the institutions have adopted different approaches when responding to ris-
ing translation demand. Both the Commission and the Council have taken adequate measures to reduce the
number of documents translated into all languages. A significant part of all translation requests is, however,
not governed by the translation guidelines adopted by each institution, and none of the institutions has a clear
and coherent procedure for requesting translations.

The three translation services audited generally manage to deliver translations into the EU-15 languages
IV.
on time and with the required quality. However, in 2004 there were significant problems for the EU-10
languages.

V.
None of the translation services has a tool for measuring client satisfaction or procedures for com-
plaints about quality. Only the Commission has guidelines for quality control. Quality indicators, such as the
number of errors found per page, are available at the Parliament but not at the Commission or the Council.

VI.
With the exception of the Commission for 2002, none of the institutions had calculated their total
translation cost or the average cost per page translated. A calculation made by the Court shows that in 2003
the full cost of translation was about 100 million euro each for the Parliament and for the Council and 215 mil-
lion euro for the Commission. Following the increase in the number of languages after the May 2004 EU
enlargement, the cost of translation has risen to approximately 128 million euro for the Parliament, 126 mil-
lion euro for the Council and 257 million euro for the Commission in 2005. The average cost per page in 2003
was 150 euro at the Parliament and at the Commission, and 254 euro at the Council. In 2005, the average
cost per page rose to 194 euro at the Commission and 276 euro at the Council, but dropped to 119 euro at
the Parliament. Internal translation is more expensive than freelance translation, but comparison is difficult as
texts translated externally are of a different nature and the quality of internal translation is recognised to be
higher.

VII.
While the Commission and the Council have been successful in reducing demand for translations into
the EU-15 languages this has also resulted in overcapacity and below-average productivity. The Court, how-
ever, noted significant differences in the productivity and the outsourcing percentages of the different lan-
guage units of the different institutions.

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Since 1995 the EU translation services have increased cooperation in certain areas such as recruit-
VIII.
ment, the creation of a terminology database, procurement of IT tools etc. The Court considers that savings
could be achieved by further increasing interinstitutional cooperation, in particular by ensuring that spare
capacity in one institution is made available to other institutions in order to reduce their outsourcing to
freelance translators. However, lack of forecasts and insufficient communication of available translation capac-
ity make it difficult for the institutions to take full advantage of temporarily available capacity at other
institutions.

While advanced IT tools are available at the audited translation services, they are not used in a con-
IX.
sistent manner. At the Parliament the actual use of IT tools thus varies widely from one translation unit to
another. For the EU-15 languages in 2004, there was only a marginal use of the tools at the Council whereas
no information was available on the level of use at the Commission during the audit period. The efficiency and
the harmonisation of the translations could be improved by increased use of computer tools, better planning,
stricter adherence to deadlines for requesting translations and closer supervision of outsourcing decisions in
order to avoid the use of freelance translators while staff translators are available. Furthermore, consistent
monitoring through the use of performance indicators and procedures for ensuring adequate management
information should be implemented.

INTRODUCTION

1.
The European Union functions in a multilingual environ-
ment with equal treatment of the languages of its Member States.
The European Community institutions employ nationals from all
Member States with varying degrees of knowledge of languages.
For practical reasons the languages most frequently used within
the institutions are reduced in number (1), but documentation
received from, and sent to, Member States is in their official lan-
guages. The translation of incoming and outgoing documents is
therefore vital to the sound running of the institutions, and for
communicating with Member States and their citizens.

Legal framework

2.
Pursuant to Article 290 of the Treaty establishing the
European Community and Council Regulation No 1/1958 (2),
updated after each enlargement, 21 languages have been given
the status of official and working languages of the institutions (3).
This Regulation later establishes the language regimes applying to
some broad categories of EU documents (4), but also authorises

(1) Generally English, French and German.
(2) 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.

(3) Spanish, Czech, Danish, German, Estonian, Greek, English, French,
Irish, Italian, Latvian, Lithuanian, Hungarian, Maltese, Dutch, Polish,
Portuguese, Slovak, Slovene, Finnish, Swedish. Since 18 June 2005
Irish has been the 21st official EU language, although certain effects
of Council Regulation (EC) No 920/2005 (OJ L 156, 18.6.2005, p. 3)
have been postponed until 1 January 2007.
In particular, documents published in the Official Journal of the Euro-
pean Union (19, 20 or 21 official languages, due to derogations con-
cerning the use of Maltese and Irish) and documents sent to a Mem-
ber State or to a person subject to the jurisdiction of that Member
State (language of the State concerned).

(4)

the institutions to stipulate in their Rules of Procedure which lan-
guages are to be used in specific cases. This provision makes it
possible to tailor language arrangements to the specific needs of
each institution (see Annex I).

In addition to their Rules of Procedure, each institution
3.
adopts practical guidelines covering the types of documents to be
translated, the number of languages, the length of the originals
and the deadlines (see also Annex I).

Organisation of the translation services of the EU institutions

4.
the
Each Institution has its own translation service:
Directorate-General for Translation and Publishing at the Parlia-
ment, the Directorate-General for Translation at the Commission
(hereafter DGT) and Directorate A III (Translation and document
production) at the Council (hereafter DG A III). The Court of Jus-
tice and the Court of Auditors, as well as the European Economic
and Social Committee and the Committee of the Regions, also
have their own translation services. The translation needs of
the agencies are covered by the Translation Centre in
Luxembourg (5).

5.
In 2005, the Commission employed about 1 450 staff
translators (and about 600 support staff), the Parliament about
550 translators (and about 380 support staff) and the Council
660 translators (and about 330 support staff). There is an uneven
spread of demand for translations over the year, and some Euro-
pean institutions limit costs or meet peak demand through the
use of
selected through tendering
procedures.

translators

freelance

(5) The Translation centre in Luxembourg mainly relies on translation by
freelance translators. The centre employs about 80 (in 2004) staff
translators, who are mainly occupied with revision of freelance trans-
lations for the agencies and to a limited extent with translation tasks
for other institutions.

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The organisational structure of the EU translation services
6.
includes translation units comprising translators and secretaries
(one unit per language at the Parliament and the Council; one
department per language at the Commission (6)), a planning unit,
a freelance unit and various other support units (information
technology, resources management, etc).

— Are translations timely and of adequate quality for their

purpose?

— Were the institutions able to keep the cost of translations

under control?

7.
In 2005, the EU institutions producing the largest vol-
ume of translations were the Commission (1 324 000 pages (7)),
the
and the Council
(457 000 pages (9)). Together they represent about 70 % of the
total EU translation volume.

(1 080 000 pages (8))

Parliament

The translation needs of the institutions are met in differ-

8.
ent ways:

11.
The audit principally covered 2003 and 2004, but
changes occurring in 2005 as a consequence of enlargement were
also taken into consideration. The audit was based on an exami-
nation of existing rules and procedures, testing of the reliability
of the production statistics, calculation of costs and productivity
and the undertaking of a client satisfaction survey within major
user services.

(a) by the translation service which either translates the docu-

ment in-house or

OBSERVATIONS

(b) outsources the work to freelance translators;

(c) by direct recourse to freelance translators not necessarily
with the involvement of the translation service (hereafter
called direct outsourcing);

(d)

through translation by administrative staff of the Directorate-
General (hereafter DG) concerned (grey translations).

The procedures applied to ensure that translation demands are
met and unnecessary translations are avoided

12.
To ensure efficient use of resources, only translations that
are necessary and of sufficient priority for the effective function-
ing of the institutions should be undertaken. Clear guidelines are
necessary to establish the criteria for texts for which translation
can be requested. The Court examined the extent to which these
guidelines exist, their quality and how they are applied.

Audit scope and approach

Internal guidelines governing translation requests

9.
The objective of the audit was to assess the extent to which
the Commission, the Parliament and the Council manage their
translation resources and expenditure efficiently and effectively.

10.

This was done by addressing three questions:

— Is translation demand met and are there adequate procedures

to avoid unnecessary translations?

(6) Each department consists of between three and six units, specialised

by policies (or domain); 77 units in total.

(7) This figure includes outsourcing ordered by DGT, but not by other
DGs for which no reliable and exhaustive figures are available.
(8) Harmonised definition: 1 500 printed original text characters (source
language), without blanks. For modified versions of existing texts,
DGT counts the number of modified characters and multiplies this
number by a certain percentage (50 % for internal translation
and 30 % for freelance translation) in order to account for the addi-
tional work of integrating the modified parts into the original text.
The Parliament uses a slightly different method, counting the num-
ber of characters of the whole modified paragraph, without adding
50 %. The resulting number of pages of each document is rounded
up to the unit.

(9) The official production figures of the Council were adapted by the
Court to make them comparable to those of the other institutions.

None of

13.
the institutions has established consistent
and clear procedures defining who can request a translation,
which types of documents should be translated (when and into
which languages), criteria for authorising non-mandatory trans-
lations and procedures for monitoring the enforcement of ‘trans-
lation policy’.

14.
The guidelines established by the three institutions only
indicate the types of documents for which translation is manda-
tory (either into all languages or into some languages). With the
exception of the Council’s ‘non-core’ documents (10), for which a
decision not to translate them into the EU-10 languages was taken
in 2003, it is unclear which documents should not be accepted
for translation.

15.
More than a few thousand persons at the Commission,
800 at the Parliament and most Council administrative staff have
been granted access to the system for making translation requests.
This — together with insufficient guidelines — increases the risk
that low priority or unnecessary translations may be requested.

(10) See Annex I, footnote 9.

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In some Commission DGs translation requests are autho-
16.
rised by the Head of a coordinating unit. In other Commission
DGs and in some Parliament and Council DGs translation requests
are authorised at unit level or sent directly to the planning unit of
the translation service without prior authorisation or supervision.
In such cases, the planning unit of the translation service is the
only real filter for identifying and refusing requests for transla-
tions which are low priority for the institution (11). However, they
have only a limited basis on which to make such judgements.

17.
The Parliament’s ‘Code of Conduct on multilingualism’
(see Annex I) only ‘lays down implementing arrangements, in par-
ticular the priorities to be observed in cases where language
resources are not sufficient to provide all the facilities requested’.
It is stated that ‘each user is competent to define its language
needs’ (Article 1(1) and (5)). Consequently, if the request does not
violate the Code of Conduct, the planning unit does not question
the need to translate or the number of target languages requested,
even if it is clear that operational deadlines cannot be complied
with (and the translation is therefore unlikely to be used).

18.
The planning units of the Commission and the Council
may, after consultation with the translation requestor, refuse
requests which do not comply with the internal rules, or which
are considered premature or not needed. Between 5 % and 10 %
of the translation requests were refused in 2003 and 2004. Unless
a requestor complained the authorisations given by the planning
unit’s operational staff at the Commission and the Council were
not checked by management, not even on a sample basis. The
acceptance of translation requests often depended more on the
availability of translation capacity than on actual needs.

The capacity to meet translation demand

19.
Since enlargement, requests for translations concerning
the EU-15 languages could generally be met by the institutions.
The situation was different for the EU-10 languages, because of an
insufficient number of translators from the new Member States.
The first set of interinstitutional EPSO competitions for assistant
translators for the EU-10 languages was not concluded before
enlargement and did not result in a sufficient number of success-
ful candidates.

20.
While the Parliament was more successful in preparing
for translation into the EU-10 after the enlargement, none of the
institutions was able to meet its targets for recruitment of staff
translators and support staff for the new language units. By
December 2004 the Commission’s DGT had only recruited
between 25 and 38 translators and support staff per EU-10 unit,

(11) In its preliminary draft budget for 2006, the Commission states that
‘non core documents can be assessed against real needs in accordance
with the Decision of 26 May 2004 on the supply and demand for
translation (SEC(2004) 638)’.

compared to a target of 90. As new EPSO competitions were only
launched in May 2005, the scarcity of staff translators for the
EU-10 languages is expected to last until late 2006 (see also
paragraph 74).

21.
Unlike the EU translation services, some large private
translation offices used by the European institutions managed to
translate into and from all the EU-10 languages from 2004. This
was achieved by setting up offices in the new Member States.
While the Commission has made a limited use of translators as
contract staff in its representation offices in the new Member
States, it has decided that this will largely be phased out in 2006
for practical management reasons.

22.
From May 2004 until April 2005, due to these capacity
constraints, only legislative core documents (12) were translated
by the Council into the EU-10 languages. Within the same period
the Parliament only translated from or into the EU-10 languages
rules of general interest, plenary agendas and minutes, as well as
documents put to the vote.

23.
In 2004 very few translators in the EU-15 language units
had sufficient working knowledge of one or more of the EU-10
languages. As a result, translation into the so-called procedural
languages — English, French and German — was mostly under-
taken by non-native speaking translators which further limited
the available capacity for translation into the EU-10 languages.

The evolution of the number of pages translated

24.
The enlargement of the European Union resulted in an
increase from 11 to 20 official languages. This had the potential
to significantly increase the cost and complexity of translation. As
a result, the EU institutions took measures to limit the increase to
a minimum by introducing stricter criteria for translation. The
Court examined the extent to which these measures were success-
ful in controlling translation demand.

25.
Graphic 1 shows that in recent years the institutions have
managed to limit the increase in translation volume (13). Stricter
acceptance criteria introduced by the Council in 2003 and by the
Commission in 2004 halted the rising trend of previous years.
However, the fall in translation volume in all the institutions in
2004 was also caused by the slowdown in legislative activity due
to the parliamentary elections and the renewal of the Commis-
sion as well as a backlog of translations into the EU-10 languages.

(12) See Annex I, footnote 9.
(13) The number of pages translated provides comparable data for all the
institutions but differs slightly from demand because of the requests
turned down by the planning units and time-lags between request
and delivery. The reported figures do not include grey translations or
direct outsourcing, which is particularly significant at the Commis-
sion but for which there are no exhaustive figures available.

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Graphic 1

The translation volume of the Commission, the Parliament and the Council

26.
Table 1 shows that at the Parliament and the Council,
which apply a policy of full multilingualism, the translation vol-
ume is nearly the same for all languages. The lower volume for
the EU-10 languages is due to capacity constraints. Only the
English units face lower demand than the other units, because
about three quarters of the originals are now written in English at
the Council and nearly a half at the Parliament. The Commission,

on the other hand, makes a clear distinction between procedural
languages (English, French and German) and non-procedural lan-
guages, for which demand is significantly lower. Contrary to the
Parliament and the Council, the English units in the Commission
do not face a lower demand than the other units because a large
volume of documents coming from outside the institution have
to be translated into the procedural languages.

Table 1

Translation volume per target language (in thousands of pages)

COMMISSION

PARLIAMENT

COUNCIL

2003

2004

2005

2003

2004

2005

2003

2004

2005

146

174

175

108

2

131

151

146

75

23

128

142

126

56

51

51

63

65

60

1

40

51

53

47

12

53

70

73

66

39

30

34

40

37

< 1

17

33

32

30

5

20

29

28

26

19

Translation into

English

French

German

Other EU-15 languages (average)

EU-10 languages (average)

Source: Court of Auditors.

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Practical measures taken by the institutions to contain
translation volume

Parliament

Commission

32.
A new version of the ‘Code of Conduct on multilingual-
ism’, approved by the Parliament’s Bureau in 2004, limits the size
of documents, but not the number of languages or the types of
documents to be translated.

When preparing for the May 2004 enlargement, the
27.
Commission took specific measures to prevent an increase in
translation volume proportional
to the increase in official
languages.

33.
While documents discussed by the Parliamentary Com-
mittees are in principle translated into all the languages of their
Members and Alternates, some Committees accept a smaller
number of languages.

28.
In May 2004, the Commission issued a Communication
laying down an action plan with the objective of controlling the
volume and cost of translation by limiting the number of lan-
guages into which certain documents would be translated and by
stipulating the maximum length of the texts. Several DGs took
additional measures to reduce translation volume in areas not
covered by the Communication. Some publications are thus no
longer issued in all official languages. For certain documents, only
a summary is translated into all languages.

The Commission has adopted a pragmatic approach to
29.
translation, matching the needs of the requesting DG with the
capacity available. The translation of tendering documents into
the non-procedural languages (14), for instance, is suspended until
a potential tenderer asks for it. The language regimes of the dif-
ferent ‘comitology’ Committees (15) vary according to the needs
of their members: some use a single working language; others
only request documents in a limited number of agreed languages.

30.
In order to dissuade users from requesting a full transla-
tion for basic comprehension purposes, DGT also offers alterna-
tive services, such as written or oral summaries, a translation hot-
line (a simplified system for very short translations) and, for some
language combinations, edited machine translations. However,
the audit showed that clients were insufficiently aware of these
options, which only represent a small share of the total DGT pro-
in 2005, DGT took steps towards
duction. For that reason,
increasing the visibility of the different services available.

The Commission made significant efforts to reduce the
31.
number of consecutive translations of different versions of the
same text. As a rule, Commission documents are translated for
the first time once the Inter-Service Consultation procedure (ISC)
has been completed.

(14) The procedural languages of the Commission are English, French and

German.

(15) Advisory Committees, Management Committees and Regulatory
Committees,
regulated by Council Decision 1999/468/EC of
28 June 1999 laying down the procedures for the exercise of imple-
menting powers conferred on the Commission (OJ L 184, 17.7.1999,
p. 23), replacing Council Decision 87/373/EEC of 13 July 1987,
(OJ L 197, 18.7.1987, p. 33).

Council

The Council also took specific measures to prevent an
34.
unnecessary increase in translation volume while preparing for
the 2004 enlargement. In 2003 it established a list of core docu-
ments (see Annex I) and severely limited the acceptance of non-
core documents.

35.
In addition, it made efforts to reduce the number of con-
secutive translations. Since 2003 the Secretariat General of the
Council (hereafter SGC) only provides translations into all lan-
guages of legislative texts at a limited number of ‘milestone stages’
rather than as previously after each meeting of each preparatory
body. However, DG A III does not monitor the observance of
these rules, or the possibilities for further reducing the number of
successive versions that are translated.

36.
The approaches taken by the different institutions to lim-
iting translation demand are uncoordinated and, as a result,
inconsistent. For example, the Parliament currently translates all
written questions into the EU-15 languages and the Commission’s
answers are only made available in two procedural languages,
plus the language of the MEP who put the question.

Quality control

The controls to ensure translations are of adequate quality

37.
Translations should be accurate, clear and ‘fit for pur-
pose’ (whereby the required quality of the translation depends on
its destination (16)). The Court examined whether there are appro-
priate measures to ensure that the quality of translations meet the
objectives. At the translation service level, the responsibility for
quality control primarily lies with the Heads of Units. At the
Commission, DGT divides all translations into five categories of
‘translation quality types’ (TQT), with a different degree of revi-
sion and/or quality evaluation according to the type of document.
In addition, some Commission DGs, such as DG Competition,
systematically review the translations they receive.

(16) For example, documents destined for publishing or legal texts require
better-quality translations (and thereby more resources) than docu-
ments for internal use.

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On the other hand, the Parliament and the Council do
38.
not allocate translations to quality categories and their quality
control procedures are less structured. As a result, revision prac-
tices vary significantly, although legislative acts are always revised
by lawyer-linguists before publication.

39.
In addition to checks performed by the translation units,
the Directorate for Translation at the Parliament evaluates the
quality of both internal and external
translations through
bi-monthly random checks (which mainly concern linguistic
errors such as spelling or grammar but not the application of cor-
rect terminology etc). This process produces quality indicators,
such as the number of errors found per page, information which
is not available at the Commission or the Council.

40.
None of the translation services has put in place specific
tools to measure users’ satisfaction or formulated procedures for
handling complaints about quality.

The client satisfaction survey carried out by the Court
41.
towards the end of 2004 showed that the quality of translations
into the EU-15 languages, as well as the administrative process-
ing of the translation requests, were generally considered satisfac-
tory. However, some Commission DGs reported some quality
problems with DGT translations into the EU-15 languages, in par-
ticular a lack of precision in technical terms, and the fluctuating
quality of freelance translation. DG A III of the Council also
reported some quality problems with legislative proposals sub-
mitted by the Commission.

Timeliness and other elements of client satisfaction

In 2004 the Commission’s DGT finished about 90 % of
44.
all translations within the agreed deadlines (compared to about
80 % in 2003 and 94 % in 2005). This improvement can in part
be attributed to the decreasing workload. The corresponding fig-
ure at the Parliament for the period May 2004 to July 2005 was
86 %. The SGC has no statistics showing the level of compliance
with the translation deadlines at the Council.

45.
However, certain Commission DGs surveyed during the
Court’s audit reported that the deadlines which are set by DGT are
not always compatible with the legal obligations or operational
needs of the DGs. Therefore, administrators (non-linguists) fre-
quently translate some urgent short documents themselves (grey
translations), and in other cases outsource certain translations
directly to freelance translators (see also paragraphs 54 and 75).
While this represents a pragmatic solution, it also illustrates an
inability to meet demand and considerably increases the difficul-
ties of the Commission in managing its translation function as a
whole.

46.
Council and Commission users of translations also
reported that, because of insufficient capacity for the EU-10 lan-
guages, the deadlines set by the planning units — particularly in
2004 — were too long to meet their needs.

The cost and the efficiency of translations

In contrast, most clients surveyed in 2004, in particular
42.
in the Commission, referred to quality problems for translations
into the EU-10 languages. This was caused by the need to use
mostly external translators — many of whom had little experi-
ence of EU-type translation — and by a lack of internal capacity
to revise freelance translations sufficiently.

The cost of translation

Cost calculations

The quality of translations carried out by freelance trans-
43.
lators is assessed by staff translators and awarded a grading out
of 10. When quality control shows that the quality of a freelance
translation is insufficient, the document is either sent back to the
freelance translator or revised in-depth by a staff translator.
Freelance translations marked 6/10 or less are submitted to the
CIEQ (17), an independent interinstitutional arbitration commit-
tee. In 40 % of the cases submitted by the Commission in 2004,
the CIEQ recommended the termination of the whole contract or
of parts of it.

47.
Activity based budgeting (ABB) is a means to enhance
‘transparency in the management of the budget with reference to
objectives of sound financial management and in particular effi-
ciency and effectiveness’ (18). Being aware of the cost of an activ-
ity is essential for controlling its performance. Article 12(1) of the
Parliament’s Code of Conduct stipulates that ‘translation services
shall inform users every three months, on comparable bases, of
the costs generated by their requests for language facilities’. How-
ever, this stipulation has not been implemented. The SGC has
never estimated the cost of translation.

(17) CIEQ: Comité Interinstitutionnel d’Evaluation de la Qualité des Tra-

(18) See recital 14 of Council Regulation (EC, Euratom) No 1605/2002 of

ductions Externes.

25 June 2002 (OJ L 248, 16.9.2002, p. 1).

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C 284/11

During the period covered by the audit, the Commission
48.
abandoned a costing project. There is, however, an allocation of
translation cost to individual policy areas through the ABB pro-
cess. A flat rate is used which depends on the size of the DG con-
cerned, but it is not based on the actual costs or actual usage.

49.
Despite the importance of such information, the institu-
tions have calculated neither their total translation costs, nor their
cost per page. The Court calculated the full cost of the internal
and external translations managed by the translation services of

the institutions (i.e. excluding direct outsourcing and grey trans-
lations, for which no cost calculation can be made, as no infor-
mation on the amount of time spent by administrative staff on
translation tasks is available). The purpose of the calculation was
to allow a comparison between the institutions included in the
audit, and the costs of freelance translations. A detailed descrip-
tion of the Court’s cost calculation method is set out in Annex II.

The results of the Court calculations for 2003 (19) are

50.
detailed in Tables 2, 3 and 4:

Table 2

Full cost of internal translations

TOTAL COST OF INTERNAL TRANSLATION
(million euro)

AVERAGE COSTS PER PAGE
(euro)

Commis-
sion

Parlia-
ment

Council

3 institu-
tions

Commis-
sion

Parlia-
ment

Council

3 institu-
tions

Staff translators

94,76

40,03

54,58

189,37

85,27

89,87

136,92

96,85

Secretaries

5,46

7,80

11,25

24,51

4,92

17,51

28,22

12,54

Direct cost

100,22

47,83

65,83

213,88

90,19

107,38

165,14

109,39

Management

0,50

0,27

0,52

1,30

0,45

0,62

1,31

0,66

Translation service staff

34,06

10,35

11,42

55,84

30,66

23,25

28,64

28,56

Planning

Building

IT

Other (1)

2,35

22,80

8,31

9,72

0,41

9,14

6,01

3,09

1,25

4,00

2,11

0,92

3,12

2,05

12,50

44,44

20,52

20,52

31,35

22,73

5,39

3,48

19,70

16,28

7,48

8,74

13,49

13,51

10,08

6,93

8,72

8,33

Indirect cost

77,74

29,28

34,54

141,56

69,96

65,72

86,65

72,40

Total cost

177,95

77,11

100,38

355,44

160,15

173,11

251,80

181,78

(1) Human Resources Management, Training, Finance, etc.
Source: Court of Auditors.

(19) In 2004 and 2005, the costs were significantly higher, as explained
in paragraph 53, but these years were characterised by a lower effi-
ciency because of the transition from a system with 11 to one with
21 languages.

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Table 3

Full cost of external translations

TOTAL COST OF EXTERNAL TRANSLATION
(million euro)

AVERAGE COSTS PER PAGE
(euro)

Commis-
sion

Parlia-
ment

Council

3 institu-
tions

Commis-
sion

Parlia-
ment

Council

3 institu-
tions

Staff translators (revision)

Secretaries

Freelance translation

5,85

1,51

11,22

0,00

2,74

8,90

Direct cost

18,58

11,64

Management

Translation service staff

Planning

Freelance unit

Building

IT

Other (1)

0,14

9,32

0,65

2,01

2,29

2,29

1,56

Indirect cost

18,27

Total cost

36,85

0,12

4,54

0,18

1,39

1,75

1,71

0,58

10,27

21,92

(1) Human Resources Management, Training, Finance, etc.
Source: Court of Auditors.

N.A.

N.A.

N.A.

N.A.

N.A.

N.A.

N.A.

N.A.

N.A.

N.A.

N.A.

N.A.

N.A.

5,85

4,25

20,12

30,22

0,26

13,86

0,83

3,40

4,04

4,01

2,15

28,54

58,76

18,36

4,74

35,24

58,34

0,44

0,00

12,70

41,22

53,92

0,56

29,26

21,04

2,03

6,32

7,18

7,20

4,91

0,83

6,44

8,10

7,94

2,69

57,34

47,60

115,68

101,54

N.A.

N.A.

N.A.

N.A.

N.A.

N.A.

N.A.

N.A.

N.A.

N.A.

N.A.

N.A.

N.A.

10,95

7,95

37,65

56,55

0,49

25,94

1,55

6,37

7,55

7,50

4,02

53,41

109,97

Table 4

Estimated full cost of translation; internal and external translation

TOTAL TRANSLATION COSTS
(million euro)

AVERAGE COSTS PER PAGE
(euro)

Staff translators

Secretaries

Freelance Translators

Commis-
sion

100,61

6,97

11,22

Parlia-
ment

40,03

10,54

8,90

Council

3 institu-
tions

Commis-
sion

Parlia-
ment

Council

3 institu-
tions

54,58

195,22

70,37

60,54

136,92

11,25

0,00

28,76

20,12

4,88

7,85

15,94

13,45

28,22

0,00

Direct cost

118,80

59,47

65,83

244,10

83,09

89,93

165,14

Management

0,64

0,40

0,52

1,56

0,45

0,60

1,31

Translation service staff

43,38

14,90

11,42

69,70

30,34

22,53

28,64

Planning

Freelance unit

Building

IT

Other (1)

Indirect cost

2,99

2,01

25,09

10,60

11,28

96,00

Total cost

214,80

0,59

1,39

1,25

0,00

10,89

12,50

5,39

3,48

7,72

3,67

39,55

99,02

(1) Human Resources Management, Training, Finance, etc.
Source: Court of Auditors.

4,83

3,40

48,47

23,71

18,42

2,09

1,41

17,55

7,41

7,89

0,89

2,10

16,47

11,68

5,55

3,12

0,00

31,35

13,51

8,72

34,54

170,09

67,14

59,81

86,65

68,32

100,38

414,19

150,24

149,74

251,80

166,37

78,41

11,55

8,08

98,05

0,63

27,99

1,94

1,37

19,47

9,52

7,40

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C 284/13

Cost analysis

51.
Costs per page are calculated ex post, and are only valid
for the volume of demand and production of 2003. As most of
the translation costs are fixed costs (87 % at the EP, 91 % at DGT
and 97 % at the SGC), years of low demand will naturally result
in a higher cost per page. In 2004, the Commission translation
volume for the EU-15 languages dropped by almost 25 %, which
resulted in a drop in productivity of 20 %, because the reduction
of freelance translation was insufficient to fully occupy staff trans-
lators. In 2003, the cost per page translated internally by the
Commission and the Parliament was comparable while the Coun-
cil’s cost per page was significantly higher, largely due to lower
productivity and higher costs of secretarial support and buildings.
Because the Council has sufficient permanent staff to avoid the
use of freelance translation for the EU-15 languages, the gap was
even larger at the level of the total cost per page.

52.
For 2003 the estimated full cost per page of external
translation was 35 % lower than the cost of internal translation
at the Parliament (100 euro versus 154 euro) and 25 % lower at
the Commission (120 euro versus 160 euro). However, these data
do not take into account the different natures of internal and
external translations, with the former involving more demanding
and time-consuming priority texts such as legislation and docu-
ments for publication. Staff translators are also involved in other
language-related duties meaning that their time is not entirely
devoted to translations (see paragraph 76). For both the EU-15
and EU-10 languages, freelance prices paid by the Parliament are
on average 12 % higher than the prices paid by DGT (20).

(f)

translations carried out in full or in part which were not
needed due to subsequent changes made to the original
(European Parliament, Commission and SGC).

54.
Moreover, the Commission neither monitors nor has any
information on the volume of grey translations or documents
translated by direct outsourcing by client DGs (see also para-
graphs 45 and 75).

55.
The procedures, organisation and working methods of
the translation services are affected by specific constraints, such
as urgent requests in particular at the Council, legal texts and the
working agenda of the institutions. Table 5shows the translation
volume for which there is a very short deadline (less than 24 or
between 24-72 hours).

Table 5

The applicable translation deadline

Commission

Parliament

Council

Lead time
(in hours)

< 24 24-72

< 24

24-72

< 24

24-72

3 %

7 %

19 %

30 % 40 %

22 %

Source:

ICTI (Interinstitutional Committee for Translation and Interpretation).

The efficiency of the translation process

Forecasts of demand

The activity-based approach to managing human and
53.
financial resources requires the setting of objectives, the planning
of activities and the monitoring of output and performance
against targets, measured though indicators. The institutions,
however, do not produce sufficient indicators and management
information to monitor:

(a)

rejected requests and the total number of requests (European
Parliament),

(b) adherence to tabling deadlines (SGC),

(c)

infringements of the Code of Conduct (European Parliament),

(d)

translated pages per requesting entity/language combination
(European Parliament),

(e)

‘core’ documents for which translation is mandatory (Euro-
pean Parliament & SGC),

(20) For the new languages, the price difference ranges from 15 % for
Lithuanian to 38 % for Latvian. The average price difference is about
12 % (see Table 4) which is partly explained by the different contrac-
tual conditions. In particular the Parliament’s contractor is obliged to
accept translations and has to work within very short deadlines in the
case of the translation of written questions.

56.
Accurate forecasting of demand is particularly important
for ensuring maximum use of internal resources. In the short
term, despite the apparently lower cost of external translations,
outsourcing does not always save money. As internal translation
costs are mainly fixed costs (see paragraphs 51 and 52), so the
marginal (or extra) cost of, say, an additional page of internal
translation is very low whereas the marginal cost of a page of
external translation is considerable. Therefore, recourse to exter-
nal translation should ideally be limited to cases where internal
capacity is not available. This requires a good system for forecast-
ing demand.

57.
Although the Parliament’s Code of Conduct states that
‘on the basis of their work programmes, the secretariats of the
committees, delegations and political groups shall draw up
monthly translation forecasts indicating for each document the
probable source language, the likely date of submission and the
number of pages to be translated’, no such forecasts are sent to
Planning.

58.
In 2003 and 2004 most Commission DGs did not sys-
tematically provide DGT with their translation forecast for a given
period, and at the Council only a few DGs regularly informed DG
A III of a forecast of translation needs.

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In practice, the main sources of information about future
59.
workload are the work programmes of the institutions and the
provisional agendas of the institutions’ meetings, which give only
a rough indication of translation needs and are thus inadequate
for detailed planning.

Adherence to tabling deadlines

The Parliament’s 2004 Code of Conduct prescribes a gen-
60.
eral tabling deadline (21) of 10 days. However, this deadline was
only observed by the users of translation in about half of the cases
during its first year of application. Most translations can thus only
be provided shortly before the meetings.

61.
In 1998, Council DG A III set tabling deadlines (10 work-
ing days for working group documents and five working days for
Coreper documents). Because of time pressure inherent in the
Council’s functions, these deadlines are rarely observed. Most Par-
liament and Council translations are only provided shortly before
the meetings.

62.
The Commission has not imposed tabling deadlines, but
DGT’s planning unit regularly renegotiates deadlines with the
users if the requested deadline is not feasible.

Planning

The Court’s calculation of the full cost of translation in
63.
2003 estimates the three institutions cost of planning at about
4,8 million euro, representing around 1 % of total translation
costs (see Table 2). Planning is another instrument to achieve the
most effective use of internal resources (see paragraph 56).

64.
Inter alia, due to very short translation deadlines, see Table
5, Heads of units at the Council and the Parliament have little
scope for long or mid-term planning or the potential to smooth
out the workload.

65.
The Council’s planning system is based on the number of
printed pages of the tabled document. This is not a reliable tool
for forecasting translation time, as it often does not reflect the
translation work actually required (22).

The computer system at the Parliament allows the plan-
66.
ning units to check the number of translated pages to be finalised
per day. This provides a general indication of the capacity avail-
able per language unit, but does not provide up-to-date informa-
tion on the available internal capacity of each unit for a given
period, taking into account the availability of translators (leave,
training, etc.).

(21) A tabling deadline is the minimum incompressible time allocated to

a translation service to issue a requested translation.

(22) The volume of work necessary to translate a document depends on a
number of factors including the number of words that need to be
translated (pages may contain texts of different length; only the
amendments to a previously translated text need translation, etc.), the
technical difficulty of the document and the availability of translated
source or reference text.

Efficient use of internal and external resources

Pre-processing

67.
In order to avoid the re-translation of texts previously
translated, users are required by the translation services to indi-
cate references to existing similar translated documents and/or to
show changes made to the previous version of a document
already translated. However, as these indications are often omit-
ted or incomplete, the planning units are obliged to search data-
bases for them. The codification of requests and of translated texts
is not precise enough to optimise such searches. The situation is
particularly difficult at the Parliament, where documents are scat-
tered over various databases and networks, and translation ser-
vices do not have a comprehensive collection of translated texts.

The translation units’ working methods

The Heads of Unit are responsible for assigning jobs to
68.
their staff translators. The language units are each organised dif-
ferently, some by groups of specialised translators, others follow-
ing a ‘first come, first served’ approach. The Commission DGT
and Council DG A III each have centrally developed tools show-
ing the availability of individual translators. However, these tools
are not used systematically by all language units. The Parliament
does not have such tools. Some Heads of Division use spread-
sheets, others allocate work manually.

69.
All translation units consist of both translators and sup-
port staff. The latter are responsible for searching references, typ-
ing, formatting, archiving, etc. … The Council (23) and the Parlia-
ment employ about one secretary for two translators whereas the
Commission employs only one secretary for four or five
translators.

70.
Despite the fact that the three institutions have declared
policies encouraging the use of modern technology and spent
23,7 million euro on IT-tools in 2003 (full costs including
licences, see Table 4), in practice each translator, with the tacit
agreement of his Head of Unit, can decide on the use of computer-
assisted translation (Translator’s Workbench), research tools (such
as Euramis, IATE, etc.) and voice recognition software (as opposed
to typing). At the Parliament, the percentage of translators and
support staff using these tools varies widely from one unit to
another (from 10 % to 90 %). Only a marginal use of IT tools is
made at the Council. The Commission has the most advanced IT
tools of the three institutions but no information is available as
to the level of use.

(23) After deduction of the time spent by secretaries on activities unre-

lated to the translation process.

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Since 2003, about 100 of the 1 100 Commission trans-
71.
lators have been involved in teleworking. According to DGT’s
evaluation report (24), the current formula allows net annual cost
savings of about 10 000 euro per translator, mainly thanks to
higher productivity. At the Parliament, 26 out of 430 translators
are involved in teleworking and the Council has also launched
two pilot projects in this field.

Outsourcing

72.
Both the Commission and the Parliament have a policy
of always using internal translation for legislative texts (for qual-
ity reasons), as well as urgent, confidential and short documents
(for practical reasons). As nearly all the translation work at the
Council belongs to these categories, translations at the Council
are mostly internal.

73.
The decision to outsource to freelance translators is in
principle taken by the Heads of the translation units (except for
direct outsourcing as mentioned below), taking into account the
type of translation and the available internal capacity. At the
Commission and the Parliament a clear, positive correlation
between workload and outsourcing percentage was noted for
most language units in 2004. However, the audit showed that
two Commission DGT units had high outsourcing percentages in
2004, although their workload was below-average (due to a

delayed reaction to the drop in workload compared to 2003)
indicating an under-utilisation of internal capacity. The Parlia-
ment’s French translation division had the second lowest work-
load in 2005, but the second highest outsourcing percentage.
These situations have not triggered remedial management action.

74.
Both the Parliament and the Commission automatically
outsource some translation jobs without checking whether inter-
nal capacity is available for some or all languages. In 2003-2004
both institutions established the objective of increasing the per-
centage of translation work sent to freelance translators to respec-
tively 30 % and 40 %, in order to cope with anticipated increases
in overall demand and taking into account the lower cost of
freelance translation (compared with recruiting additional full-
time translators). Because of the structural drop in demand in
2004 the Commission DGT suspended this target and the Parlia-
ment gave instructions not to send translations other than CRE to
freelance translators during the election period (25). Whilst the
overall workload per EU-15 language unit was about 20 % lower
in 2004 compared to 2003, the Parliament’s outsourcing percent-
age hardly changed (32,5 % in 2003 and 32 % in 2004) (see
Table 6). The difference in the outsourcing percentages for the
EU-10, from 2004 to 2005, at the Parliament, the Commission
and the Council, is mainly due to the fact that the Parliament, in
2004, had been more successful in recruiting staff translators for
the EU-10 languages than the other institutions. Due to a legisla-
tive slowdown in 2004 and the lower translation volume, the Par-
liament was able to translate a larger percentage of the transla-
tion tasks
also
paragraphs 20 and 25).

in the EU-10 languages

in-house

(see

Table 6

Outsourcing percentages in 2003, 2004 and 2005

Outsourcing percentage

2003

2004

2005

2003

2004

2005

2003

2004

2005

Commission

Parliament

Council

All languages

EU-15 languages

EU-10 languages

Source: Court of Auditors.

22 %

21 %

N.A.

23 %

16 %

60 %

20 %

33 %

30 %

10 % 32,5 %

32 %

37 %

41 %

20 %

36 %

33 %

43 %

0 %

0 %

N.A.

1 %

0 %

8 %

2 %

0 %

5 %

75.
While direct outsourcing by client DGs is marginal at the
Council and the Parliament (26), the audit has shown that several
hundreds of thousands of pages were outsourced directly by
Commission DGs during the 2003 to2004 period with no super-
vision from DGT (see also paragraphs 45 and 54).

Productivity

(24) European Commission, DGT, Translation Directorate, Evaluation
Report of the Telework Pilot Project in the Translation Service, Brus-
sels, 6 October 2003.

(25) CRE = ‘Compte rendu in extenso’: a detailed record of the debates,
representing about 18 % of the Parliament translation volume in
2003 to 2005.

(26) The EP’s political groups sometimes contract freelance translators
directly if the planning unit rejects their requests (exceeding their
weekly quota of 15 pages).

The productivity of the three institutions audited from
76.
2000 to 2005 was reviewed for the purpose of comparing per-
formances between institutions over time. The calculation of pro-
ductivity used the concept of ‘full time equivalent’ (FTE), accord-
ing to which the time considered as time used for translation is
the time during which translators are effectively available for
office work. Since in many cases this time includes activities other
than translation (training, management, quality control, proof-
reading of documents produced by other services etc.), the pro-
ductivity based on FTE is a broad indicator only. Comparisons
between institutions and between language units within a given

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institution should be considered with caution. Care should also be
taken to identify the reasons for the differences noted and pos-
sible constraints should be analysed in order to assess whether
management can act directly.

77.
Productivity, defined as the number of standard pages
translated internally per internal translator FTE, fluctuates widely
from one language division to another and from one institution
to another. The productivity of the EU-10 language units in all the
institutions is generally lower because of higher training needs,
lack of experience, smaller translation memories (limiting the use
of computer translation) and more time devoted to the revision
of external translations.

The productivity of the EU translation services is much
78.
lower than in the private sector (27). The higher productivity in
the private sector is mainly due to the nature of the texts (few leg-
islative texts), as well as the widespread use of IT tools. Despite
texts of a lower degree of complexity, freelance translations are
perceived to have a lower quality and need a higher level of revi-
sion than documents translated internally. A number of contracts
with external bureaux have thus been cancelled due to the inad-
equate quality of the translations (see paragraph 43). However, in
the absence of spare internal capacity, the higher productivity,
combined with lower salaries, makes freelance translation signifi-
cantly less costly than employing additional in-house translators,
even when indirect costs (planning, tendering, payment, quality
control, etc. …) are included (see Table 7).

Table 7

Average number of pages translated per translator (FTE)

Commission (per year)

Commission (per day)

Parliament (per year)

Council (1) (per year)

(1) Council: until 2004 (included) EU-15 languages only.
Source: Court of Auditors.

2000

2001

2002

2003

2004

2005

915

5,2

902

5,2

909

5,1

1 054

5,7

1 092

1 195

1 062

1 031

602

653

772

707

917

5,0

858

648

797

4,5

1 226

669

Commission

79.
The productivity of DGT, which, in most years, was
slightly lower than at the Parliament, can to some extent be
explained by the Commission’s role as initiator in the legislative
process. This implies a higher revision rate and a lead role in the
development of terminology and databases, from which other
institutions also benefit. Furthermore, Commission translation
staff provide other language-related functions not reflected in
translation output per day.

81.
Even after the DGT’s introduction of a so-called ‘flexibil-
ity mechanism’, allowing the transfer of translation jobs within
the same language department from units which are temporarily
facing an above-average workload to other units, significant pro-
ductivity differences between units still exist (28). The main expla-
nation for these differences is variation in demand for translations
of texts relating to various policy areas which determine the com-
petences of the language units. The differences in productivity
between DGT units have widened further since enlargement. The
productivity of the most productive unit in 2005 is double the
productivity of the least productive unit.

80.
From 2003 to 2005, average productivity for the EU-15
languages dropped by more than 20 %. For most of the non-
procedural EU-15 languages, productivity fell below four pages a
day. This drop is due to the fall
in workload for the non-
procedural languages which has caused overcapacity. The over-
capacity should be considered in the light of the level of direct
outsourcing taking place without any supervision by DGT (see
paragraph 75).

(27) See also PriceWaterhouseCoopers, Comité Economique et Social
(CES) & Comité des Régions (CdR), ‘Analyse comparative de la pro-
ductivité des départements de
institutions
européennes’, Bruxelles, 4 août 2000, p. 24: ‘Il est à noter que la pro-
ductivité d’un traducteur d’un établissement privé tourne aux envi-
rons de 8 à 10 pages par jour sans tenir compte de la production via
“Translation Memory” (une page correspondant à 350 mots)’
(350 words = 2 100 characters = 1,4 standard pages).

traduction des

(28) Within the English department, for instance, the productivity in the
first half of 2004 of the busiest unit was 65 % higher than the pro-
ductivity of the unit with the lowest workload.

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Parliament

82.
During the last five years the Parliament has reduced the
number of translators by an average of more than five FTE (or
15 %) per language.

The productivity of the English and French translation
83.
units at the EP is systematically below average (by 5 to 20 %,
depending on the year) whereas productivity differences among
the other EU-15 languages are limited to 10 %. This is explained
by the French unit’s higher-than-average number of translators
coupled with an above-average outsourcing of translations. For
the English unit there is a lower need for translations as most
internal documents are drafted in English. Outsourcing levels and
overcapacities are factors open to management decisions.

Some institutions have no performance indicators and

88.
no statistics on:

(a)

(b)

the actual time spent, versus the standard or estimated time,
on the translation of a specific document (European Parlia-
ment, Commission and SGC);

the number of pages revised (Commision and SGC) and the
time spent on revision (European Parliament, Commission
and SGC);

(c)

the production and productivity of individual translators
(SGC);

(d)

the volume of translations outsourced automatically by the
planning units and those outsourced by the translation units
(European Parliament and Commission);

Council

(e)

failure to observe delivery deadlines (SGC);

84.
The Council’s productivity was systematically lower than
that of the Commission and the Parliament. This can be ascribed
to a combination of a high share of legislative documents requir-
ing particular attention, highly fluctuating demand (a daily work-
load from less than 1 000 to more than 7 000 pages in 2003).

(f)

the impact of IT translation tools on productivity (European
Parliament, Commission and SGC);

(g) crossed data, such as the correlation between workload and
outsourcing (European Parliament, Commission and SGC)
(see paragraphs 73 and 83).

85.
In order to deal with its problem of overcapacity, DG A
III has adopted a long-term action plan to reduce the number of
translators and secretaries in the EU-15 language units from about
50 FTE in 2002 to 25 FTE in 2015 (29). However, the full effect
of the plan is a long-term process because the Council maintains
that there are limited possibilities of internal redeployment and
low interinstitutional mobility.

89.
The production and productivity statistics for the vari-
ous translation services of the European institutions include text
segments translated automatically, in particular by the Transla-
tors’ Workbench (TWB) system. More refined calculation systems
are used by private translation companies in order to calculate the
real workload and the productivity of individual translators.

86.
The differences between the language unit’s productivity
are smaller at the Council (and the Parliament) than at the Com-
mission (with the exception of the low productivity of the English
unit at DG A III which is about 20 to 40 % lower than the pro-
ductivity of the other units in 2003 to 2005). The editing of origi-
nals and the role of English as the main pivot language for trans-
lations of
from the EU-10 languages, which raise
considerable terminological difficulties, might to some extent
explain this apparent low productivity.

texts

Monitoring of
indicators

the translation process using performance

90.
Unlike the other institutions, which only consider the
amended parts of the text, the Council calculates its production
on the basis of the printed pages (see also paragraph 65). As a
result, the Council’s production statistics overstate the actual
number of pages translated by more than 50 %. Following the
Court’s audit, DG A III adopted a method similar to the one used
by the other institutions.

Interinstitutional cooperation

The creation of the ICTI in 1995 has gradually allowed

91.
the EU translation services to cooperate in certain areas.

92.

The main achievements so far are:

87.
The institutions’ main translation statistics are produced
centrally and focus on the volume of translations per unit. These
statistics are regularly used by management and resources units,
but their use for daily monitoring purposes by the Heads of the
translation units varies widely and some Heads of Unit have
developed their own tools.

(a)

the creation of a common terminology database and trans-
lation memory;

(b) an inter-institutional call for tenders for freelance translation

from and into the EU-10 languages (30);

(29) DGMA, Plan d’action pour la modernisation administrative du SGC

(30) However, the Commission made almost no use of the list and orga-

(PAMA), 30 May 2002, section 11: Réforme de la DG A III.

nised its own call for tenders.

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(c) a joint tendering procedure for the acquisition of voice rec-

ognition software and other multilingual tools;

(d) a joint committee for the evaluation of outsourced transla-

tions (CIEQ);

ing rules established by the three institutions prescribe manda-
tory translation for certain types of documents. There is, however,
a large area for which no commonly accepted criteria exist and
where documents are dealt with on a case-by-case basis depend-
ing mainly on availability of resources (see paragraphs 13 to 18).

(e) a limited exchange of translators and of translation workload.

The Court’s analysis of the nature and the timing of sup-
93.
ply and demand shows that whereas all institutions face structural
difficulties in providing a sufficient volume of translations of an
acceptable quality into the EU-10 languages, there are clear dif-
ferences as far as the EU-15 languages are concerned. English
translators, for instance, face the highest workload of all lan-
guages at the Commission DGT (see paragraph 86), but the low-
est at the Council and the Parliament. As Council and Parliament
work with very short delivery deadlines and widely fluctuating
demands, they also have temporary spare capacity during some
periods (see paragraph 84).

94.
In line with the conclusions of the task force on work-
load balancing, a pilot project was initiated on 1 January 2005.
In 2005, 3 763 pages (or 63 % of the requested volume) were
translated by one of the participating institutions at the request of
another institution. This corresponds to just 0,2 % of the total
workload of all the institutions involved, while more than 20 %
of the same workload is allocated to freelance translation. The
savings can be estimated at 150 000 euro (31). As the total spare
capacity is much higher than the capacity made available to other
institutions in the framework of the pilot project, the potential
savings are higher.

95.
It is, however, a weakness in the current system of work-
load balancing that documents which are normally outsourced
and translations into the EU-10 languages are excluded from the
system. In addition, the institutions do not sufficiently inform
each other of the spare capacity available and have no real incen-
tive or obligation to accept a translation request just from another
institution. Had the Commission’s DGT’s internal translators of
the EU-15 non-procedural language units reached the same pro-
ductivity in 2005 as in 2003, they would have translated at least
10 000 pages more for each of the EU-15 languages. In 2005, the
Parliament and several Commission DGs outsourced a similar
number of pages of non-urgent documents in the same languages
which could have been translated by another institution. Total
payments of about 11 million euro for freelance translations
could thus have been avoided (32).

CONCLUSIONS AND RECOMMENDATIONS

The procedures applied to ensure that translation demands are
met and unnecessary translations are avoided

None of the institutions has consistent and clear proce-
96.
dures for requesting or authorising translations. The implement-

(31) At a variable cost of 40 euro per page.
(32) Taking into account only the variable costs of freelance translation,

estimated at 40 euro per page.

Recommendation: In view of the necessity to set priorities and
restrictions in order to match a steadily growing demand for trans-
lations, the institutions should streamline their procedures. This
should include control of the size of documents, a further differen-
tiation of texts according to their nature and purpose and the adop-
tion of a fit-for-purpose approach for authorised texts for transla-
tion.

97.
The audit showed that translation needs in the EU-15
languages can generally be met. However, the accession of small
countries has created a large increase in demand in small transla-
tion markets, where supply is rather limited. The difficulties
encountered with the launching of EPSO competitions to select
staff translators for the EU-10 languages have meant a shortage
of translators from the new Member States. As a result, during the
first year after enlargement, the institutions were not capable of
satisfying translation needs for the new languages (see para-
graphs 19 to 23).

Recommendation: There is still a need to considerably increase the
internal capacity of the institutions for the EU-10 languages. The
Commission should organise a critical review of EPSO’s failure to
recruit the needed staff translators in time. This should lead to an
action plan designed to increase awareness and foster interest in the
Community’s translation activity in the EU-10 Member States and
other Candidate Countries.

98.
Generally the institutions managed to contain expendi-
ture on translation despite an increase in the number of official
languages from 11 to 21 (including Irish) since May 2004 (see
paragraphs 25 to 36). While the Commission and the Council
took significant measures to reduce the number of documents to
be translated into all languages, the Parliament has been less
ambitious in the reduction of translation volume by limiting only
the size of documents for translation but not the number and
types of documents (see paragraph 32).

Recommendation: The translation services could enter into Service
Level Agreements with their users, establishing more stringent guide-
lines on the type of documents requiring translation, the required
language versions, the stage at which a translation should be initi-
ated, the total number of pages per year, the recourse to automated
translation etc. Some coordination by the institutions might also
prevent inconsistencies in their respective approaches.

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The procedures applied to ensure that translations are timely
and of adequate quality for their purpose

99.
The three institutions generally managed to deliver trans-
lations into the EU-15 languages on time and with the required
quality (see paragraphs 41 and 44). The situation was, however,
different for the EU-10 languages, because of an insufficient num-
ber of translators. At the Commission and at the Council the
internal capacity for the EU-10 languages in 2004 was not even
sufficient to revise freelance translations and most clients consid-
ered the quality of the translations unsatisfactory (see para-
graph 42). None of the translation services measures users’
satisfaction.

Recommendation: The institutions should conduct regular satis-
faction surveys among the various users of translation services includ-
ing the application of deadlines. Such surveys could be used as input
to action plans for the improvement of service quality and produc-
tivity.

100.
The Parliament and the Council have no precise guide-
lines on quality control, and revision practices vary significantly.
However, the institutions generally perform adequate controls in
order to identify poor quality translations (see paragraphs 37
to 43). While the Directorate for Translation at the Parliament
evaluates the quality of both internal and external translations
through bi-monthly random checks and quality indicators, no
such control or performance indicators are produced by the other
institutions.

Recommendation: In addition to the systematic quality control
performed on outsourced translations and to the supervision exer-
cised by each Head of Unit, it would be advisable to perform regular
random quality checks in each language section. This, combined with
users’ satisfaction surveys, could form the basis for qualitative per-
formance indicators.

101.
Some Commission DGs reported that they had to rely
on ‘grey translations’ or direct outsourcing as DGT could not pro-
vide certain translations within the required deadlines The volume
of these translations is not clear and the cost is not included in the
Court’s calculations as the amount of time spent by administra-
tive staff on grey translations is not available (see paragraphs 45,
54 and 75).

Recommendation: The level of direct outsourcing and ‘grey trans-
lations’ should be monitored by the translation services in order to
take this translation volume into consideration during the planning.

full cost for translation for the three institutions at 414 mil-
lion euro before enlargement (see Table 4) and 511 million after
enlargement. The average cost per page in 2003 was 150 euro at
the Commission and at the Parliament, and 254 euro at the
Council. In 2005, the average cost per page has risen to 194 euro
at the Commission and 276 euro at the Council, but has dropped
to 119 euro at the Parliament.

103.
Internal translation is more expensive than freelance
translation, but comparison is made difficult by the different
nature of the texts translated, the higher perceived quality of inter-
nal translation, short deadlines applied to internal translations for
certain documents due to working methods, particularly at the
Parliament and Council and the revision required for external
translations (see paragraph 52).

Recommendation: Being aware of the cost of an activity is essen-
tial for controlling its expenditure. Procedures to ensure adequate
management information on costs should thus be implemented.

Due to a large decrease in the workload, the productiv-
104.
ity of most EU-15 language translation units dropped signifi-
cantly in 2004 and consequently the average cost per page rose
(see paragraphs 51 and 76 to 86). Because of the measures taken
to reduce the translation demand, the Commission and the Coun-
cil have had spare capacity since 2004 for the EU-15 non-
procedural languages.

105.
The audit showed that the planning units of the three
translation services are currently more involved in work alloca-
tion than in establishing translation forecasts in order to plan the
workload and smooth the peaks of activity (see paragraphs 56
to 59, 63 to 66 and 91 to 95).

106.
The adjustment of workload is a key issue. A reduction
in the translation volume results in a transitional period of over-
capacity, lower productivity and a higher average translation cost.
However, the Court noted that some units had both low produc-
tivity figures and above average outsourcing percentages (see
paragraphs 73 and 74). The lack of workload forecasts (planning)
makes it more difficult for the institutions to take full advantage
of temporarily available capacity at other institutions (see para-
graphs 91 to 95, as well as paragraphs 56 to 66).

The cost and the efficiency of translation

102.
With the exception of the Commission for 2002, the
institutions have calculated neither their total translation costs
nor their average cost per page. The Court estimates the annual

107.
In 2005, the Parliament and Commission DGs (other
than DGT) outsourced a large number of pages that could have
been translated internally by another institution. The Court thus
estimates that total payments of about 11 million euro to
freelance translators could have been saved (see paragraph 95).

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Recommendation: More emphasis should be placed on the pro-
cesses of management and planning in order to smooth the peaks
and troughs in the translation workload and facilitate more effective
interinstitutional cooperation. Regular and reliable forecasts of future
translation tasks should be sent to the planning units and the insti-
tutions should inform each other of available internal capacity.
Spare internal capacity should be used to reduce the level of outsourc-
ing by Commission DGs (other than DGT) and by other institutions
by extending the pilot exercise initiated in January 2005 on
interinstitutional cooperation. A system of interinstitutional billing
for translation could give institutions with temporary or structural
spare capacity an incentive to cooperate with other institutions.
At the Council, further efforts should be made to adjust to the struc-
tural overcapacity. The possibility of redeployment outside the trans-
lation services or the application of other provisions of the Staff
Regulations should be considered as the existing action plan only
expects to resolve the present overcapacity by 2015.

108.
Even though the institutions have invested in advanced
modern technology, it is not used in a systematic manner (see
paragraphs 68 to 70).

Recommendation: The efficiency of the translation process could be
improved through:

— a reduction of secretarial support at the Council and the Par-

liament,

— harmonised working methods based on best practices,

— further integration and more intensive use of computer tools,

— an increased use of teleworking.

109.
The translation services do not produce sufficient man-
agement information to follow up on the translation costs such
as the actual time spent on translation and revision, detailed pro-
ductivity figures, outsourcing level etc. (see paragraph 88).

Recommendation: In order to use productivity as a management
indicator, the institutions should develop systems which better reflect
all the activities of staff translators (including time spent learning
new languages). In order to enable a better use of resources, efforts
should be made in all institutions to develop relevant qualitative and
quantitative performance indicators.

This Report was adopted by the Court of Auditors in Luxembourg at its meeting of 6 July 2006.

For the Court of Auditors
Hubert WEBER
President

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THE PROVISIONS APPLYING AT THE COMMISSION, THE PARLIAMENT AND THE COUNCIL

ANNEX I

Commission

The Rules of Procedure of the Commission (1) specify that all acts adopted by the Commission shall be attached to a
1.
‘summary note’ (in the oral procedure) or ‘day note’ (in the written, empowerment or delegation procedure) (2), in the authen-
tic language or languages, i.e. in the official languages of the Communities in the case of instruments of general application
and the language or languages of those to whom they are addressed in other cases (Article 18 of the Rules of Procedure).

2.
Although ‘comitology’ Committees come under the Commission itself (3) and Council Regulation (EEC) No 1/1958
of 15 April 1958 applies to their work (4), an explicit reference to the language regime was deliberately not introduced in
the Standard Rules of Procedure (5), so as to allow each committee to find pragmatic solutions tailored to its real needs.
Documents that would, in any case, be translated at a later stage (in particular, draft measures whose final version must be
published in the OJ) are in principle already translated for committee meetings.

3.
A note from the Secretariat-General (6) issued in June 2004 specifies that ‘for those implementing measures which
are addressed to a reduced number of Member States only, a translation in the corresponding languages would be sufficient,
together with a communication published in the Official Journal of the European Union announcing the adoption of the deci-
sion and informing the reader of the website on which it is accessible. Full translation is required only if the publication in
the Official Journal of the European Union is a legal precondition for their coming into force (i.e. for regulations, directives and
decisions of the EP and the Council adopted in codecision and Commission regulations and directives addressed to all Mem-
ber States, but not for Commission decisions).’

4.
The May 2004 Communication distinguishes between documents resulting from legal obligations (subdivided into
nine categories) and documents of political importance (subdivided into 11 categories). The translation of certain categories
of documents, such as publications other than the Official Journal ofthe European Union, is not covered by the Communica-
tion and must be decided on a case-by-case basis through dialogue between the requesting DG and DGT (7).

5.
The main categories of documents translated into all languages are: legislative proposals, explanatory memoranda,
reports required by legal texts, announcements of State aid and antitrust procedures published in the Official Journal, as well
as the subsequent final decisions published in the Official Journal, anti-dumping decisions, Communications of the Com-
mission (including white and green papers), calls for tenders or for manifestation of interest and press communiqués.

6.
Other documents are only translated into the procedural languages (English, French and German) (in particular com-
munications to the Commission, follow-up reports of Council decisions and Commission proposals), or into the language
of the addressee (i.e. letters to permanent representations, replies to individual requests and financing proposals). Technical
annexes are translated into no more than three languages, or are not translated at all, depending on the ‘real needs’. Replies
to written parliamentary questions are translated into the language of the Member of European Parliament who has asked
the question and into one procedural language.

Parliament

7.
Pursuant to Rule 138 of the Parliament’s Rules of Procedure, ‘all documents of the Parliament shall be drawn up in
the official languages’. Article 150 states that ‘amendments shall be put to the vote only after they have been printed and
distributed in all the official languages, unless Parliament decides otherwise. Parliament may not decide otherwise if at least
37 members object.’

(1) Rules of Procedure of the Commission, C(2000) 3614 (OJ L 308, 8.12.2000, p. 26).
(2)

These notes record all decisions adopted by the Commission during the meeting (summary note in the oral procedure) or during the day
(day note for the other procedures).
Judgment of the Court of First Instance, of 19 July 1999, Case T-188/97, Rothmans International BV versus Commission.
European Commission, Note of the Secretary-General for the attention of Directors-General and Heads of Services, SEC(2003) 795,
10 July 2003.
Standard Rules of Procedure — Council Decision 1999/468/EC — Rules of procedure for the … committee (OJ C 38, 6.2.2001, p. 3).
European Commission, Secretariat-General, Task Force Future of the Union and institutional questions, Director, Note for the attention of
Mr Madelin, Director General of DG SANCO, 23 June 2004, TFAU/2 — RH — nb (2004) D/6980 5/1208 — A/DOS 6242).
The 20 categories of the May 2004 Communication covered 64 % of the translations in 2004 and 72 % in 2005 versus 34 % in 2003.
The main categories in 2005 are: legislative proposals and autonomous acts (36 %), State aids and competition procedures (10 %), com-
munications from the Commission (7 %) and tendering procedures (6 %) and web pages (4 %).

(3)
(4)

(5)
(6)

(7)

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On 19 April 2004 the Bureau of the European Parliament adopted a Code of Conduct which entered into force on
8.
1 May 2004 and replaced a similar Code of Conduct of 8 February 1999. Article 1(2) of the Code of Conduct states the
following: ‘Language facilities in Parliament shall be managed on the basis of the principles governing “controlled full mul-
tilingualism”. Accordingly, the right of Members to use in Parliament the official language of their choice, pursuant to Par-
liament’s Rules of Procedure, shall be fully respected. The resources to be devoted to multilingualism shall be controlled by
means of management on the basis of users’ real needs, measures to make users more aware of their responsibilities and
more effective planning of requests for language facilities.’

9.
The documents with the highest number of target languages are amendments, draft opinions and draft reports. For
all the other document types, target languages range from one (mainly English) to four. Table 8, drawn up for the purpose
of the audit, gives an overview of the types of documents which are translated at the Parliament.

Table 8

Types of documents translated by the European Parliament

Figures from 1 January 2003 till 31 May 2004

Document
type

% of
translation

Mandatory into all
languages

Non-mandatory into all
languages

Compte rendu

Amendment

Miscellaneous (‘Divers’)

Draft reports

Rapport révisé

Written questions

Procès-verbal

Communications to the Members

Working Documents

Notes

Draft opinions

Resolutions

Letter

Agenda

12 other specific categories representing
each maximum 1 % of the total translation
volume

Source: Court of Auditors.

CR

AM

DV

PR

RR

QE

PV

CM

DT

NT

PA

RE

LT

OJ

19,3 %

17,6 %

15,1 %

9,8 %

7,3 %

5,9 %

5,2 %

4,2 %

3,2 %

2,3 %

2,2 %

1,7 %

1,2 %

1,1 %

3,9 %

×

×

×

×

×

×

×

×

×

×

×

×

×

×

×

×

10.
A document published in the Official Journal of the European Union or voted on in plenary will always have to be
translated into all official languages, whereas translation of working documents can be restricted to the language needs of
the readers.

Council

Pursuant to Regulation No 1 and Article 14 of the Council’s Rules of Procedure (8), translation into all official lan-
11.
guages is required for documents discussed at ministerial meetings, except as otherwise decided unanimously by the Coun-
cil on grounds of urgency. Any member of the Council may oppose discussion if translations are not available.

(8) Council Decision of 22 March 2004 adopting the Council’s Rules of Procedure (2004/338/EC, Euratom) (OJ L 106, 15.4.2004, p. 22).

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The Annex to the Guide for producing documents for the Council and its preparatory bodies lists the ‘core documents’ which
12.
have to be translated into all languages (9). As stated in the guide, documents that are not on this list may not be translated
into the EU-10 languages. These documents may be translated into the EU-15 languages, on a selective basis, if the volume
of work of DG A III allows it, and the deadlines laid down in the rules of procedure are respected. DG A III is given authority
to refuse the translation of any document not on the list.

(9)

The Council’s core documents are: draft legislation at certain milestone stages; agendas for the Council; ‘A’ item notes and their addenda;
documents for adoption or discussion by the Council agenda; opinions of the legal service; Council minutes; Council replies to European
Parliament written questions and oral questions with debate; declarations by the Presidency on behalf of the Union; press releases for
sessions of the Council; written procedure telexes; manuals which are intended for use by national departments in Member States; Euro-
pean Council Presidency conclusions.

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THE METHOD DEVELOPED BY THE COURT TO ESTIMATE TRANSLATION COST

ANNEX II

The full cost (cost before tax and pension), as estimated by the auditors, includes all the direct and indirect costs related

1.
to the translation activity.

2.
By deducting the Community tax paid by staff translators from the ‘cost before tax and pension’ and by adding the
fictitious employer’s pension contributions for staff translators (which are equal to twice the contribution paid by the offi-
cial), the cost to the Community budget is obtained (cost after tax and pension).

3.
Direct costs are the staff costs of the activities related to translation, performed by translators or secretaries (includ-
ing pre-translation by the translation units, revision and formatting, and excluding the time spent on tasks other than
translation).

4.
Indirect costs include the salaries and allowances of staff who are not directly involved in specific translation tasks
(terminologists, working method specialists, Heads of Unit, language advisors and senior management, freelance unit
and planning) as well as a pro rata for time spent by translators on activities other than translation or revision, plus over-
head costs such as IT, buildings and office furniture, human resources management, etc., which in part are not directly man-
aged by the translation services. The split between direct and indirect cost was agreed with the institutions.

5.

To work out the staff cost the following elements have been used:

— the average staff cost established by Directorate-General for Personnel and Administration of the Commission for each
grade. This staff cost included all salary and allowance items. The audit team considered two different average staff costs:
before and after deducting tax and adding pension contributions (1),

— the specific mix of grades of the translation service of each institution,

— the buildings costs (5 854 euro per official), as defined by an external consultant in collaboration with the institutions,

— the average cost of payroll and human resources management, according to a pro rata defined by DGT (for the Com-

mission) or by an external consultant (for the other institutions).

6.
The amount of the IT cost was worked out in the light of the 2003 budget implementation for the specific budget
lines and the average acquisition and maintenance cost of the IT equipment as established by the IT and Finance services.

As internal translators carry out quality control and revision of translations made by freelance translators, part of their

7.
time and cost was allocated to external translation.

8.
The total translation costs of the three institutions were then divided by the number of pages translated per year to
obtain the cost per page (see Tables 2, 3 and 4). For the Commission and the Parliament the official number of pages trans-
lated, as produced by DGT and DG VII, were used, as the page count methods used by these two institutions (see foot-
notes 8 and 9 in the report) lead to comparable results. As the official Council figures for 2003 were simply based on the
number of printed pages of the documents, instead of on the number of characters to be translated, the Court calculated the
average correction factor for a sample of 100 documents (2). By multiplying this average correction factor by the official
number of printed pages issued by DG A III, a comparable production figure was obtained.

9.
The cost per page calculated by the Court is not the full cost of multilingualism, as it is does not include the cost of
revision by the lawyer-linguists or the additional costs of publishing documents in 20 languages. As during the legislative
process many consecutive versions of the same draft legislation are translated, the actual cost of adopted legislation is a mul-
tiple of the cost per page mentioned in Table 2 of the current report. As an example, 15 versions of the Constitution for
Europe were translated.

(1) The pension contributions borne by the Commission were estimated at 16,5 % of the gross salary or twice the contributions paid by the

officials.

(2) The correction factor to be applied to the page count of each sampled document in order to make the documents comparable with those
of other institutions is equal to the ratio between the number of characters (or, in case the document is a new version of a document
already translated, the number of modified characters marked up by 50 % as DGT does for internal translations) without blanks divided
by 1 500, and rounded up to the unit, on the one hand, and the number of physical pages, on the other.

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PARLIAMENT’S REPLIES

Within the European Parliament, the number of working
1.
languages has not been reduced. This means that all sittings docu-
ments and documents for meetings of official bodies are trans-
lated into all the working languages of the Union.

Parliament does not restrict the number of working languages
and does not recognise the concept of ‘procedural languages’. (See
also the reply to point 1).

13-14.
In connection with translation work, Parliament
applies its Rules of Procedure and the Code of Conduct on Mul-
tilingualism adopted by the Bureau, which entered into force on
1 May 2004.

While the code of conduct does not of itself constitute an autho-
risation system, it does establish a ranking of bodies authorised to
request translations, lays down a set of priorities concerning the
types of document to be translated, both in-house and externally,
during the various legislative procedures, and an order of priority
for the languages requested, and lays down deadlines for submit-
ting translating requests as well as limits on the length of the texts
to be translated. The code of conduct also lays down conditions
requiring express authorisation of translation requests made by
entities that are not included on the list of authorised users. Such
requests are submitted to the Bureau and authorisation is given
only if the document in question is of essential importance to Par-
liament’s business.

15-16.
Access to the system is granted solely at the request
of the head of a requesting service. However, as part of the over-
haul of the GEPRO IT system (ITMS project) all the current
accesses will need to be re-authorised and, as far as is possible, the
overall number will be reduced. In Parliament’s view, the risk to
which the Court refers is minimal owing to the restrictions set in
place by the afore-mentioned provisions.

See also the reply to points 13-14 above.

17.
Although this does not happen frequently, in some cases
Planning reduces the number of languages requested, either in
accordance with the rules on language profiles or with other spe-
cific exceptions of which the requesting services may have failed
to take account.

Approximately 90 % of the time, translations are delivered prior
to the meeting date. In cases where the deadline cannot be met,
the text is translated only if it will serve as the basis for the next
stage in the procedure.

The situation was as follows in April 2006: 238 FTE
20.
translators (FTE = full time equivalent), of which 25,75 CS, 25 ET,
26 HU, 24,5 LT, 28 LV, 23 MT, 31 PL, 26,75 SK and 28 SL,
and 5 heads of unit (CS, LV, PL, SK, SL), plus one acting head of
unit (MT), were responsible for translating into the EU-10
languages.

The concept of ‘procedural languages’ does not exist

26.
within Parliament. (See point 23).

32-33.
The concept of ‘language profiles’ has been intro-
duced under the code of conduct. As the Court points out, docu-
ments considered by the parliamentary committees are translated
only into the languages of the full and substitute members of the
committees.

In Parliament’s views, the approaches are not inconsis-
36.
tent because they meet the specific needs of each institution, and
those needs differ from institution to institution.

Parliament would draw the Court’s attention to the qual-
37.
ity action plan drawn up by the Interinstitutional Committee for
Translation and Interpreting (ICTI) at
the
secretaries-general of the institutions, which will be implemented
in the near future. The plan sets out 14 practical measures, some
of which apply to both translation and interpretation, in areas
such as human resources, the technical and linguistic quality of
originals and translations, documentation, terminology and tools.
Provision has been made for an official in charge of quality to be
appointed in each of the services concerned.

the request of

39.
It is important to point out that within Parliament sys-
tematic checks are made for all types of error, and this includes
checking that the correct terminology has been used.

40.
Although a specific tool to measure user satisfaction has
not been introduced, there is a procedure for submitting com-
plaints, for which a specific form exists. Furthermore, the ‘clients’
in the EU institutions, particularly MEPs, have sufficiently close
links with the Secretary-General to be able at any time, and with-
out having to follow a specific procedure, to express their dissat-
isfaction should they have cause to do so.

This provision of the code of conduct cannot be imple-
47.
mented under the current system. However, the ITMS project cur-
rently under development will contain a billing module designed
for this purpose.

52.
As the Court points out, it is important not to focus
solely on the price indicator which, taken in isolation, cannot
reflect the realities of the translation process; account should also
be taken of factors such as quality, deadlines and document types.

53.
Parliament’s translation and planning services have
started to compile statistics covering three of the points raised,
namely:

(a)

the total number of requests;

23.
Within Parliament, translations from the new languages
have almost always been performed by translators whose mother
tongue is the same as the target language.

(c)

failure to meet submission deadlines (= breach of the code of
conduct);

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Official Journal of the European Union

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(d)

number

the
service/language combination.

pages

of

translated

by

requesting

These statistics are intended to provide performance indicators
enabling management to take appropriate action.

Planning of this kind is indeed necessary. However, some
institution are inherently

56.
aspects of the work of a political
unforeseeable.

66.
The EP has initiated a preparatory study into a new man-
agement system (T-Flow). This system, which will enable Parlia-
ment to meet the concerns raised by the Court, is currently in the
development stage and will be operational in the autumn of 2006.

67.
The relevant IT departments are currently looking into
the ‘scattered documents’ issue raised by the Court. The transla-
tion units do, nonetheless, have a translated-work repository in
which to search for texts already translated.

69.
The ratio is 1 to 2 for the EU-15 languages. For the EU-10
languages, the secretaries/translators ratio is currently approxi-
mately 0,7 to 2 and should not go higher than 0,8 to 2.

70.
It is true that IT use is not yet uniform throughout the
translation service and that working methods sometimes differ.
This is due in particular to the large differences in the age of staff.
However, as a result of the extensive experience of the more
senior translators, per capita productivity is much the same
between age groups. The EP Bureau would like to ensure better
use of new technologies and has instructed the Secretary-General
to submit a report on the issue. Parliament’s administration is cur-
rently in the process of preparing this report.

The remark requires clarification because, as the Court
74.
notes, the outsourcing of translation work, excluding the CRE,
was suspended during the period referred to.

As regards the stable outsourcing rate, the apparent contradiction
with the lower overall workload does not bear scrutiny. The rea-
son why the average outsourcing rate hardly changed despite the
decrease in the workload is that the main bulk of the workload
fell in the first part of the year, which resulted in more work being
outsourced during that period.

83.
The EP cannot endorse the Court’s conclusion that pro-
ductivity is lower in the two units referred to, given the difference
in the substance and nature of some of their tasks compared to
those of other units. This difference requires the deployment of
additional human resources. The fact that the English and French
units produce fewer-than-average pages translated in-house can
be explained by the fact that they serve as a relay for translations
from lesser-used original languages, by larger volumes of origi-
nals to revise and edit, by a larger volume of verbatim reports of
proceedings to transcribe and revise, by the need to manage some
of the new units and by EU-10 language training needs. Further-
more, since the autumn of 2005, the English Unit has been shar-
ing responsibility with the Tabling Office for systematic verifica-
tion of originals.

See also the reply to point 73.

In the event of an overly heavy workload in the language
95.
units, Planning first looks into whether workload balancing is fea-
sible on the basis of the language combinations involved and
availability in the other institutions.

The EU-10 languages have been excluded only for the time being.
Once the EU-10 language units have a full complement of staff,
they will be involved on the same basis as the EU-15 language
units.

It is important to put the remark concerning the French
73.
Unit’s internal capacity in its proper perspective. That capacity
was not underused; it was used for other, additional work. The FR
Unit was obliged to devote a particularly large amount of time to
setting up and managing the new Polish and Lithuanian Units and
to language courses to prepare translators to translate from the
EU-10 languages. Its additional tasks also included providing
relay translations for other language units and transcribing and
revising the Verbatim Report of Proceedings of part-sessions and
the ‘economic and monetary dialogue’.

It should be emphasised that active cooperation between the
institutions’ planning units in connection with workload balanc-
ing did not start until 2006. The statistics for the first quarter of
2006 show a significant increase in the volumes exchanged.

96-109.
The EP notes all of the Court’s recommendations
and will take appropriate action thereon. In particular, an ad hoc
working party has started work on a revision of the code of con-
duct. IT projects covering some of the issues raised by the Court
are also under way.

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COUNCIL’S REPLIES

GENERAL REMARKS

The General Secretariat of the Council (GSC) welcomes the first
audit on translation expenditure in some of the EU institutions
and acknowledges its usefulness. It would point out that changes
to aspects which were criticised in the course of the audit have
already been implemented or are under active consideration in
the Language Department.

The GSC would nevertheless like to stress that, faced with the
major challenge of enlargement, it put in place for its entire struc-
ture a controlled approach, which was endorsed at the highest
political level in 2002, and which made it possible to limit the
budgetary impact of enlargement on its administrative costs.

Specifically, in the area of translation, whereas an extrapolation
of the approaches adopted for previous enlargements would have
resulted in an increase in staff numbers in the Language Depart-
ment of approximately 765 new officials, the controlled approach
referred to above will ensure a drastic reduction in overall figures
when these measures are fully operational. At the end of the cur-
rent period of adaptation and adjustment, the GSC will have fewer
translators for a Union consisting of 25 Member States (551) than
it had for a Union of 15 Member States (578).

This result has been made possible inter alia by limiting transla-
tion to the documents deemed essential to the political and leg-
islative process (the so-called core documents), by implementing
an in-depth rationalisation of the translation services, and by
adopting guidelines on the drafting, content, register and length
of Council documents. In doing so, the GSC has set the path for
other institutions to follow.

The GSC acknowledges that, as a consequence of this approach,
it now faces a problem of overcapacity in the EU-15 language
units, but it stresses the transient and non-structural nature of this
situation, which, in its view, must be evaluated from a dynamic
point of view, duly taking into account the undeniable middle-
and long-term benefits which will result in terms of controlling
administrative expenditure.

The quality control procedure necessary to ensure such quality
and consistency naturally leads to additional costs. Unlike other
institutions which can use the services of freelance agencies exten-
sively for certain documents in order to reduce costs, this avenue
is not open to the GSC, as in-house translation is the best and
most cost-effective way to ensure such quality. The need for high
quality texts for publication has, of course, a major impact on the
cost of translation in the Council.

The GSC is however tackling this problem of overcapacity in a
proactive manner and within a policy-mix addressing simulta-
neously all the aspects of the problem. In addition to the fact that
translators or secretaries who left the nine EU-15 language units
(other than English and French) after 2002 have not been
replaced, Translation Department staff are actively encouraged to
apply for vacancies in other DGs and directorates. A special rede-
ployment programme, which includes identification of adequate
posts, training for new functions, and motivation for change, is
being set up.

Moreover, the GSC is participating actively in the interinstitu-
tional ‘Workload balancing’ project as a net contributor and is
also considering interinstitutional mobility and other possible
measures provided for by the Staff Regulations.

The GSC is therefore confident that it will successfully remedy the
weaknesses highlighted in the report, in particular those of a tran-
sitional nature, and that it will efficiently fulfil its mission within
the limits set for its operations.

COMMENTS ON THE FINDING OF THE COURT

EXECUTIVE SUMMARY

III.
Although the GSC does not have written translation
guidelines, the Coordination and Production unit (Central Coor-
dination) ensures a controlled production of translations.
.

The GSC also points out that, as the last link in the legislative
chain prior to approval and publication of legislation in 20 lan-
guages, the Council, together with the European Parliament as
regards co-decisions, must ensure that legislation adopted by the
Council is of the highest quality as repeatedly demanded by the
Member States. This is also true for the Council’s political texts.

The problems experienced in 2004 for the EU-10 lan-
IV.
guages had to do with the difficulties in recruiting staff (see com-
ments on paragraph 19 below). Quality and timely delivery of
translation improved significantly in 2005.
this
improvement can be seen by the reduction in requests for trans-
lations sent to freelance agencies.

In 2006,

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Official Journal of the European Union

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Since the second half of 2005, the Head of Central Coor-
V.
dination resumed close contacts with Permanent Representations,
especially from the EU-10, with a view to:

INTRODUCTION

(a) having feedback on:

— the quality of translations,

6.
The GSC does not have a freelance unit, or an IT unit
attached to its translation department. The structure in place in
the GSC is therefore lighter than the other institutions.

— the amount of translated documents,

OBSERVATIONS

— the availability of those documents at the meetings,

— the relations between C&P and the translation teams, on
one hand, and Permanent Representations and the
national authorities, on the other;

(b) exchanging information on:

— the functioning of the Council, namely the circuit of

documents,

The GSC has clear procedures, although these might be

13.
improved.

It should be noted that those who can request a translation are
defined in the General Secretariat of the Council and known
to Coordination. Similarly, types of documents which should be
translated are clearly defined in the list of core documents.

— the situation of the translations teams, particularly in

terms of staff,

14.
The GSC is reluctant to take a differentiated approach to
EU-10 and EU-15 languages which could leave it open to accu-
sations of discrimination.

— general issues of terminology, deadlines, etc.

A mailbox is to be launched in the very near future. That mailbox
will concentrate all the comments from the delegations, provide
an overall view of the perceived quality of the translations pro-
duced by the Council and improve the synergy between transla-
tion teams and delegations. The delegations were informed of this
on 5 May 2006.

VI.
The General Secretariat of the Council intends to set up a
system which would allow a permanent review of the cost of
translation. There are, however, reasons why GSC translations are
expensive, and which are discussed in greater detail elsewhere in
this document: the specificities of the Council’s work and its dead-
lines, the need to ensure adequate quality in legislative documents
near the end of the production chain, and the temporary struc-
tural reasons linked to the restructuring of the Directorate.

VII.
The GSC intends to reduce overcapacity, for example by
means of internal redeployment (to other DGs) and interinstitu-
tional mobility (to translation departments in other institutions).

Moreover, the GSC is examining all possibilities provided by the
Staff Regulations.

15.
The conclusion of the Court on the translation request is
correct. However the acceptance of the requests depends on the
control structure in place.

16.
In the Council, Central Coordination, which is upstream
of the Translation Department, always checks the appropriateness
of a translation before sending the text to one or all the 20 units.
In case of problems the Head of Central Coordination intervenes
and contacts even with the Presidency may ensue. Central Coor-
dination, namely Coordination DG and Linguistic Coordination,
is in constant contact with DGs and also to a lesser extent with
the Presidency, and this enables it to make informed judgments
on the appropriateness of translations and to prioritise transla-
tions in the event of insufficient translation resources.

18.
The authorisation and refusal of translations is a task of
the Coordination (especially Tour de Contrôle). The situation is sat-
isfactory in the Council’s view. Improvements are however pos-
sible. Excluding the ‘check by management’, statistics on refusals
may be prepared for further analysis. No measures are required as
far as authorisations are concerned.

VIII.
The GSC is a major contributor to the workload-
balancing system and has accounted for the translation of 55 %
of the total number of pages processed under this system in 2005.

The fact that the ‘acceptance of translation requests (1) often
depended more on the availability of translation capacity than on
actual needs’ is inevitable, due to:

IX.
In 2004 and 2005, the GSC developed a coherent policy
on the use of modern technology. All the new language units
have worked with the available IT instruments since their cre-
ation, for the ‘old-language’ units the policy is currently being
rolled out in line with the development of appropriate IT tools.

— the staff ‘overcapacity’ or shortfalls in certain translation

units,

(1) Non-core documents.

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Official Journal of the European Union

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— the policy of reducing overtime work to a minimum,

— the two different translation speeds (EU-10 vs. EU-15).

even after that date (late 2006), not only as regards translators,
but also as regards Heads of Unit, quality controllers and
secretaries.

Translations that are really needed are never refused.

19.
The recruitment made through EPSO has turned out to
be more difficult than expected as a result of the short number of
suitable candidates, despite the best efforts made by the institu-
tions to raise the awareness of Member States and other parties
to this problem.

20.
It cannot be implied that the fault of not achieving the
recruitment targets falls to the individual institutions. Unfortu-
nately, this situation (shortfall in staff numbers) will continue

23.
It is correct to state that very few translators in the EU-15
units other than EN and FR have knowledge of an EU-10 lan-
guage. That is the result of a deliberate policy decision carefully
designed to increase the number of official languages from 11
to 20 without requiring a commensurate increase in staff levels.
In preparation for the 2004 enlargement, the GSC has been orga-
nising training for translators in the EN and FR units in one or
more EU-10 languages, and this has led to the situation presented
in the following table (situation as of 22 May 2006).

EN and FR translators knowledge of EU-10 languages (situation on 22 May 2006)

FR

EN

CS

ET

HU

LT

LV

MT

2

4

6

0

3

3

1

4

5

0

2

2

0

3

3

0

0

0

Total

PL

3

2

5

SK

0

4

4

SL

0

4

4

Moreover, the GSC is also examining other ways of providing
coverage for all official languages, including using retour transla-
tion (having translators working from their native language into
EN and FR).

number of milestone versions is translated. A number of intan-
gibles such as the political importance of a text, and its priority
for a Presidency programme, and time constraints are elements
which are taken into account by Linguistic Coordination when
deciding on the translation of a milestone version.

26.
The EN unit participates extensively in the workload bal-
ancing system. However, it should be noted that even though
there is some overcapacity in the EN unit, intended to ensure full
multilingualism in that unit, this should be compared with the
cost of the previous system whereby every language unit had the
capacity (approximately a minimum of six translators with
knowledge of each EU language) to translate from every official
language even though the number of pages to be translated from
most of those languages represented less than 1 % of the number
of pages of the source documents.

Nevertheless, the GSC has always said that it would review its
policy in the light of experience (a minimum of two years). This
review will take place in the second half of 2006/early 2007.

38.
In certain cases, when a balance has to be made between
timeliness and quality, Linguistic Coordination makes recommen-
dations about the non-revision of a text. This can only occur at
intermediate stages.

However, as the Council only translates core documents, a high
level of quality is normally required.

The GSC is putting in place a quality control procedure
39.
at language unit level and has recently implemented a formal pro-
cedure for handling quality complaints and allowing our clients
to provide feedback on translations.

40.

See comment to paragraph 39.

35.
Central Coordination does control the compliance with
the ‘milestones stages’ policy, namely by assessing the need of a
translation at a certain stage and refusing to translate certain
documents. On the basis of the resources available and the time
constraints, Linguistic Coordination ensures that the appropriate

41.
The GSC is pleased to note that the Court of Auditors
acknowledges that its clients are satisfied with the quality of the
service provided. It is however ready to put in place harmonised
quality assurance procedures.

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The general feedback from EU-10 delegations is now also
42.
generally satisfactory. The revision of external translations is a
problem. Translations are outsourced because of understaffing
problems and their revision would reduce the benefit of such out-
sourcing (use of valuable resources for revision).

44.
The Council will examine, in the framework of statistical
developments in Central Coordination, how to assess the level of
compliance with the translation deadlines. However, core docu-
ments that comply with the Rules of Procedure are always ready
at the meeting for which they are required.

46.
This was due to the dramatic lack of capacity in those
languages. However, there is no evidence that the adoption of any
legislation was delayed because of
the unavailability of
documents.

47.
The GSC intends to build on the experience obtained
during this audit to set up a system for keeping the cost of trans-
lation under review. The GSC is also considering the possibility of
systematically sending DGs and the Presidency the ‘cost’ for cer-
tain translations especially those giving rise to excessive overtime.

51.
As the Council is at the end of the legislative procedure,
it has a particular responsibility for the quality of the adopted
(and published) text. Quality comes at a price and has implica-
tions for the productivity of
the translators. Moreover, as
explained earlier, it is not appropriate to send legislative and
politically sensitive documents to freelance agencies. This is the
reason why the general policy of the GSC is to avoid the use of
external translation.

53.

(b) The Council will put in place a procedure for monitoring the
percentage of requests that do not adhere to deadlines for
submission of translations and the reasons for that failure
without losing sight of the aspects pointed out in the com-
ment to paragraph 44.

(e) The Council will put in place a procedure for monitoring the
percentage of ‘core’ documents for which translation is man-
datory, out of the total number of documents translated.

(f) The Council will put in place a procedure for obtaining addi-
tional information on translations that were not needed due
to subsequent changes made to the original.

The argument of the Court of Auditors on the impor-
56.
tance of accurate forecasts is valid, but in reality it is often beyond
the reach of the translation services, e.g. the progress of legisla-
tive texts in the Council depends on the progress achieved in dif-
ferent working groups, committees and Council meetings, some-
times even in bilateral meetings.

The staff complement of 25 translators is based on the
61.
normal anticipated workload, which in turn is based on the ‘core
documents’ policy. The surge or peak in workload at the end of
each Presidency is resolved by a much stricter management of the
work in the units, renegotiation of deadlines, but most impor-
tantly of all by the use of overtime at the end of the working day
and, exceptionally, during the weekend or public holidays.

The fact that Council translations are only provided shortly before
the meeting is due to the fact that 62 % of Council documents
have deadlines of less than 72hrs. It is therefore unavoidable that
the translations are available shortly before the meeting.

64.
Correct, but they are anyway experienced enough to
know the peaks and in most of the translation units they are
‘helped’ by translators acting as full-time coordinators. Both the
Head of Unit and the coordinator are kept constantly informed by
Central Coordination. At the Council, which only works with
short-term deadlines, the initiative on deadlines is left to Central
Coordination which is the unit with a global view on the volume
of work.

65.
The Council has changed its system of counting pages for
estimating workload and it now uses a system of weighted stan-
dard pages, called ‘net’ pages.

This task is performed by the Central Coordination using

67.
technical means.

The Council has made considerable progress on this front
69.
since the period covered by the Audit, and the ratio of secretaries
to translators is still improving.

70.
The Council has invested a lot of time into optimising the
use of IT tools. An implementation plan involving the develop-
ment of tools (EURAMIS and in-house tools), a training pro-
gramme and the setting up of a special TRADOS cell in Central
Coordination is currently being rolled out. The Council intends
however to introduce a system of statistical indicators to monitor
the use of TRADOS in the Translation Department.

78.
The private sector is concerned less about quality
and consistency than the institutions. The experience of the insti-
tutions in general, as confirmed by the work of CIEQ, is that leg-
islative texts should not be sent to external agencies. The experi-
ence of the Council is that even when texts are sent out to agencies
during the early stages of negotiations within the Council (Work-
ing Party level), this has not been of much help during the trans-
lation of subsequent versions of the text.

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There are indeed very limited possibilities of internal
85.
redeployment. Translators constitute approximately 66 % of AD
staff (790 LA excluding JLs; 450 A) at the Council.

It should also be noted that in the eight language units with
supernumerary staff, there is a very high proportion of staff in the
age bracket 55-65.

Proportion of staff in language sections
in the age bracket 55-65

Supr

55-65

DA

12

15

DE

25

8

EL

15

11

ES

16

10

NL

12

10

FI

19

8

PT

18

15

IT

18

12

In addition to the tasks mentioned in the Court of Audi-
86.
tors’ report, the English language unit also provides direct assis-
tance to the Presidency (one translator works on the premises of
the Presidency) and to other DGs.

The performance indicators and statistics mentioned will
88.
be implemented gradually as soon as the resources available for
workflow development permit the necessary enhancements.

The statistics used by the Council were changed in 2005
90.
to reflect the practice in other institutions. Statistics for 2003
and 2004 were amended retroactively to bring them into line
with the new methods of calculation.

It is difficult to retrain and redeploy translators in great numbers
as translators come with a specialist language background. Never-
theless, the Council intends to look at every possibility of rede-
ployment, both internally and interinstitutionally. Appropriate
action is under way.

105.
Central Coordination in the Council tries to forecast
translation workload and to plan the workload accordingly. In
this way, it seeks, within the political constraints, to balance
workload and translation capacity.

CONCLUSIONS AND RECOMMENDATIONS

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COMMISSION’S REPLIES

EXECUTIVE SUMMARY

I.
The Commission is committed to support multilingual
written communications through equal linguistic treatment of all
official languages. It also sustains multilingualism in the Union,
which has become a sensitive political matter. Matching real
needs, high quality and cost effectiveness are the guiding prin-
ciples followed by the Commission in providing translations.

The Commission is the institution that has the initiative of mak-
ing legislative proposals and therefore is often faced with trans-
lations of completely new texts, subsequently modified in the
Council and the Parliament. This entails a higher difficulty and
more research, mainly in the field of terminology.

II.
Since the completion of the audit, the Commission has
introduced further changes in its translation practices and proce-
dures which, in its opinion, address the observations of the Court
and are highlighted in the Commission’s reply to the relevant
paragraphs.

III-IV.
The Commission will update its translation strategy
e.g. by including guidelines for non-core documents. DGs will be
encouraged to streamline their internal procedures for requesting
translations.

V.
The Commission is currently examining the most appro-
priate ways of measuring quality. DGT has intensified its contacts
with Commission DGs and services which allows for regular feed-
back on the quality of service offered to them. It considers that
regular user satisfaction surveys at the level of DGs and services
will not provide significant added value.

The Commission’s quality control procedures are based on risk
assessment and cost-effectiveness, with the aim of producing
translations that are fit for purpose in every case. This policy ren-
ders a single ‘quality indicator’ based on number of errors per
page inappropriate (see also point 100 below).

VI-VII.
The Commission calculated its translation cost
and cost per page for 2002 and suspended subsequent updates of
these calculations awaiting the outcome of the audit which is sub-
ject of this report.

The increase in the cost per page in 2005 for the Commission
(compared to 2003) results from the implementation of a strict
demand management reducing demand equally across the differ-
ent languages and below available capacities in ‘old’ language
departments. This allowed the Commission to reduce its need for

resources for the new language departments thereby creating sig-
nificant immediate savings for the Commission’s administrative
budget equivalent to some 380 posts.

Resulting capacity surpluses in the ‘old’ languages were already
partly addressed in 2004 and 2005 by means of compensating
measures, such as internal redeployment, new methods for
increased flexibility, drastic reductions of freelance translations
for the ‘old’ language departments, etc. These measures were
stepped up at the end of 2005 with the introduction of a strategy
for resources allocations within DGT, confirmed in the Commis-
sion’s APS 2007 decision, aiming at a better balance between sup-
ply and demand and improving cost-efficiency, thereby creating
additional savings for the Commission’s administrative budget, in
the medium to long term. This should ensure that differences in
work rate and outsourcing percentages are evened out in the
medium term.

VIII.
The Commission supports interinstitutional coopera-
tion including the workload balancing mechanism as a means to
share spare translation capacity between institutions and has been
the highest net contributor throughout the pilot project.

The Commission will continue to contribute towards the fine-
tuning of this procedure. However, its potential will be reduced
in future as a result of measures currently being taken to adjust
resource allocations in accordance with real needs. Moreover,
there are limits to how far one can go because of the different
nature of work and timetables and agendas of the different insti-
tutions and workload balancing cannot replace freelance work,
nor will it allow complete absorption of idle capacity across
institutions.

IX.
While no information was available in 2004 and 2005 on
the average use of the IT tools among Commission translators, a
survey concluded in late 2005 concluded that use of these tools
is at least 76 %, while in the ‘new’ EU-10 languages it reaches
almost 100 %.

The Commission is currently setting up statistics on the use of IT
tools. Work is underway to automatically register actual use and
on the setting of other indicators.

The Commission’s centralised translation demand management
unit has significantly improved its capacities and performance in
forward planning, negotiating realistic deadlines and consistency
in outsourcing practices but these efforts do not yet encompass
the totality of translation activity in the Commission. The forth-
coming review of the Commission’s translation strategy will
strengthen the coordination role of DGT for all translation activi-
ties of the Commission.

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INTRODUCTION

11.
Since the completion of the audit, the Commission has
introduced further changes in its translation practices and proce-
dures which, in its opinion, address the observations of the Court
and are highlighted in the Commission’s reply to the relevant
paragraphs.

OBSERVATIONS

The Commission has established its procedures for
13-18.
requesting translations to DGT, supported by a web-based appli-
cation (POETRY) which channels all translation requests from its
DGs and services to DGT and which is used by DGT in handling
these requests in the light of its translation strategy. Within these
constraints, each client service organises its internal workflow
to channel its requests through ‘POETRY’.

Given the lack of consistency in the translation authorisation pro-
cedures in the Commission, DGT’s screening of demand plays an
important role in harmonising translation practices among DGs.
As of 2005, the authorisations given within the Commission’s
planning unit are supervised more systematically, especially with
respect to categories of documents for which no guidelines have
been set in its translation strategy.

The Commission will address the authorisation procedures and
the screening of translation requests within its DGs and services
and will establish guidelines also for the translation of non core
documents as part of its updated strategy for the period 2007 and
beyond (scheduled for end 2006). This will strengthen its capac-
ity for a consistent screening of demand.

19-20.
The levels of effective recruitment per 31 Decem-
ber 2004 are to be assessed against the decisions of the budget
authority to phase-in resources for enlargement over the period
2004 to 2006.

In spite of staff shortages and fragile structures due to the high
numbers of temporary staff, the Commission was able to meet its
legal obligations and has therefore satisfied all crucial translation
needs for these languages. This has been achieved through con-
sistent demand management, staff in the EU-10 departments
working considerable overtime, and heavy reliance on external
translation.

The original target of 90 full-time equivalents, set before the tran-
sitional translation strategy was adopted, has been revised in line
with the estimated impact of this strategy on the demand for
translation was set at 75 full-time equivalents (as confirmed by
the Commission’s APS 2007 decision).

21-23.
The Commission organises its translation activity in
its central premises in Brussels and Luxembourg in order to facili-
tate cooperation between language departments, multilingual
coordination as well as management, training and IT support.

The Commission nevertheless needed to set-up translation facili-
ties in most of its representation offices as a temporary measure
to complement scarce capacities available during the phasing-in
period for the new languages. The role of these facilities is cur-
rently being reassessed.

The Commission actively prepared for translations out of the
EU-10 languages and in 2004 more than 25 % of total ‘old’ lan-
guage translators had taken or were taking courses in the ‘new’
languages (216 in training, 87 proficient and 68 partial).

The Commission uses (0,9 % of the total production) translation
or revision by native speakers of the source rather than the target
language to deal with capacity shortages for some language com-
binations and increase cost-efficiency.

25.
The rising trend in translation volumes for the Commis-
sion was halted in 2004 as a result of the introduction of its
demand management strategy. The slowdown of legislative activ-
ity highlighted by the Court of Auditors had only a limited impact
as large volumes of legislative texts such as agricultural acts, anti-
dumping, competition, State aids, etc., are not affected.

In addition, the anticipated build-up of a backlog of translations
into the EU-10 languages did not materialise.

With respect to direct outsourcing and grey translations (referred
to in footnote 13), the Commission agrees that currently there are
no reliable estimates for the scope of grey translations or direct
outsourcing and is therefore launching a survey within its DGs
and services to assess the scope of such practices. The result of
this survey will be used for a Commission update of its transla-
tion strategy for 2007 and beyond.

The Commission’s translation quality control policy
37-43.
has focused on producing translations that are ‘fit for purpose’
and it has not so far devised a unified quality indicator as such.
DGs and services may not always give sufficient consideration to
the differentiated quality requirements in accordance with fit-for-
purpose principles in assessing the quality of freelance transla-
tions. The Commission is currently examining the most appro-
priate ways of measuring quality.

All freelance translations are evaluated on the basis of a sample
check of pages and are rejected if the quality is found on that basis
to be unsatisfactory.

The quality problems for outsourced legislative proposals submit-
ted by the Commission for the new languages during the start-up
period in 2004 are explained by the limited capacity for internal
revision in that period. While autonomous acts were fairly sys-
tematically revised, co-decision acts often were not as these would
still be read at least once (by Parliament or Council) before pub-
lication. This temporary problem has been fully addressed in
2005 and more than 90 % of all in-house and freelance transla-
tions is being revised or checked.

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The Commission acted on experiences of poor quality of freelance
translations, especially for the new contractors for the EU-10 lan-
guages, by (i) organising workshops for freelance translators at
the beginning of 2005 in the capitals of the new Member States;
(ii) ensuring the growing availability of translation tools and ref-
erence material and (iii) providing systematic feedback to exter-
nal translators for all translations not assessed as ‘very good’
and containing more than five pages. As a result, the frequency
of quality problems with freelance translations has dropped in the
second half of 2005.

44-46.
The improvement in the Commission’s respect of
deadlines for translations is due to a better translation demand
management and pro-active programming.

DGT experiences problems with deadline keeping much more as
an issue of improving quality of planning by the services and the
institutions, rather than shortages in translation capacity. The
Commisison considers translation as a part of the enacting pro-
cess whereby translation deadlines need to be fully integrated into
the programming and DGT is participating in agenda planning
and coordination networks. The Commission has now set up a
monitoring system on the timely delivery of translations in accor-
dance with the Commission and Council meeting schedules and
results so far demonstrate that the translation services offered in
this context are compatible with legal obligations and operational
needs.

Deadlines set for mid and end of 2004 for translations into the
EU-10 languages were indeed longer due to a lack of resources as
pointed out under paragraphs 19-20. As of 2005 the deadlines
are shorter and programming smoother.

The Commission is launching a survey to quantify the magnitude
of grey translation and direct outsourcing and will address these
issues in the context of the forthcoming update of its translation
strategy for 2007 and beyond.

47-49.
The Commission’s costing project referred to by the
Court of Auditors was developed in 2001 and applied until mid-
2003. It did achieve its objective of raising awareness on the cost
of translation. Nevertheless, maintaining this system by provid-
ing up-to-date information on the total cost of translations
requested was not considered a priority as this would provide
little additional value to client DGs in a context where their trans-
lation demand was scrutinised in detail against the transitional
translation regime.

The Commission will propose for its Preliminary Draft Budget
2007 (PDB 2007) the creation of a new policy area ‘31-Language
Services’ which will group the budgetary impacts of all language
services (but no longer allocated to the different policy areas).

The Commission is currently updating its permanent cost calcu-
lation system, in line with the methodology applied by the Court
of Auditors, to support management in monitoring the efficiency
of the translation process through the evolution of the costs
incurred in providing its translation output (and other products).

51-52.
In spite of the near doubling of the number of official
languages the total cost of translation for the Commission in
2005 only increased by some 20 % compared to 2003. This was
achieved by a strict implementation of the demand management
strategy. It nevertheless resulted in a drop in the work rate and a
linked increase of the cost per page for the Commission which is
of a transitional nature and can be explained by:

— the political imperative of giving equal treatment to all lan-
guages while translation capacity for the nine new official
languages following the 2004 enlargement is only gradually
building up over the period 2004 to 2006,

— the lack of experienced translators, translation memories, ter-
minology support, machine translation support, etc., for the
nine new official languages, which results in lower produc-
tivity capacity for these languages compared to the ‘old’
languages,

— the 2003 translation demand and resulting work rate, which
was at a record high and required tremendous efforts from
staff in terms of overtime, delaying planned leave, etc. As
such, this level is not a fair benchmark for a long-term work
rate target.

The Commission proceeded with some internal redeployments
already in 2004 and 2005 and has set more ambitious targets on
internal redeployments for DGT in the Commission’s APS 2007
decision to adjust fixed costs to changing demand patterns by lan-
guage groups. Other corrective measures include reducing
freelance translations (although outsourcing may be required in
view of specific subject matter or language expertise not available
internally), two-way translation, the temporary secondment of
translators to other DGs, and the expansion of the Commission’s
Editing Service.

The Commission considers that, as of 2005, the num-
53. (f)
ber of translations carried out in full or in part but not needed
because of subsequent changes made in the original is marginal
due to its policy of not beginning a translation until a stable text
exists.

Following the May 2004 Communication, the Commission
shifted its focus from raising awareness on the cost of translation
to a pro-active demand management resulting in a significant
reduction of total translation costs.

The only exceptions are those documents which, for political rea-
sons, confirmed at the highest level, are subject to tight deadlines
that could not be respected if translations were not initiated
before the stable document existed.

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The Commission is launching a survey to assess the
54.
extent of grey translations and direct outsourcing and the result
of this survey will feed into the forthcoming update of the Com-
mission’s translation strategy for 2007 and beyond.

56-59.
As of 2005 the Commission improved significantly
its capacity for forward translation programming: a large part of
the Commission’s translation workload is covered by agenda
planning and regular monitoring with DGs in coordination meet-
ings. DGT’s demand management unit maintains regular contacts
with translation correspondents in every DG and these efforts
have resulted in a situation in which most DGs send regular fore-
casts, especially when there are important issues at stake.

The need to rely on a more robust programming instrument has
been recognised by the Secretariat-General and steps are being
taken to integrate translation better in the programming instru-
ments of the Commission.

However, such systems for forecasting demand will always be
subject to uncertainties, linked to the political nature of our work,
unforeseen events which require new initiatives, etc. Moreover,
even when in-house capacities are available, freelance capacity
may still be needed for such documents (e.g. with a high degree
of technical terminology) for which internal expertise does not
exist.

DGT fixes deadlines with the requesting DGs in the
60-62.
light of their requirements linked to the destination/purpose of
the document (e.g. for discussion at specific Council or Commis-
sion meetings). This approach is preferred over tabling deadlines
as it allows a more flexible and efficient use of available resources
and reduces the need for additional capacity to deal with peak
workloads.

Pre-processing in the Commission is highly automated
67.
and does not require its central translation planning unit to do
any specific search: all documents (except confidential ones) to be
translated are checked automatically against Euramis, a huge lin-
guistic database containing thousands of documents divided into
sentences linked to corresponding translations and these checks
also include the content of Eur-Lex.

The organisation of the translation workflow within
68-71.
the Commission’s translation units is supported by tools show-
ing the availability of individual translators. However, these tools
do not fully reflect all aspects of translator availability such as spe-
cialist or language knowledge. Therefore the Head of Unit’s judg-
ment remains an important factor.

and the Commission issued recently some ‘best practices guide-
lines’ for its translators and special efforts are also made to train
newly recruited translators and secretaries to use computer tools.
It remains however partly up to the translator to decide what
tools and resources are best suited to his job, depending on the
pre-processing reports and his own background, knowledge and
experience.

The Commission’s decision to outsource or not
73-74.
depends heavily on the types of documents which are under con-
sideration. In a situation where a 30 % externalisation target was
imposed and translation workload within the Commission was
very high, certain decisions were taken to automatically outsource
certain documents.

After the introduction of the new demand management policy in
2004, the Commission abandoned its earlier outsourcing targets.
There was, however, a certain delay before outsourcing practice
changed. In the meantime, outsourcing is largely limited to cases
of real need (i.e. to complement in-house capacities). Neverthe-
less, in exceptional cases where the necessary expertise on spe-
cific subject matters is lacking within a given language depart-
ment, translations will continue to be outsourced, irrespective of
available in-house capacity.

75.
The Commission’s translation strategy will be extended
to include also guidelines on the translation of non-core docu-
ments and will strengthen the coordination role of DGT through
channelling all information on translation requests through DGT.

76.
The Commission understands ‘productivity’ to refer to
‘workrate’ meaning the production by translator per day taking
demand into account, as productivity cannot be measured by
simply quantifying the number of pages by FTE.

78.
In comparing translation in the EU institutions with the
private sector the following additional factors have be taken into
consideration:

(a)

the market supply of expert translators varies considerably
depending on the language concerned;

(b) a major problem is that freelance quality is inconsistent and
this makes it hard to programme quality control activities
effectively;

With respect to the use of IT tools, the Commission actively pro-
motes their use to increase cost-efficiency. Actions in this area
have consisted of awareness-raising, training (in particular with a
view to enabling end-users to make efficient use of these tools),
and ensuring that productivity-enhancing tools run smoothly
with other applications (e.g. TWB with LegisWrite). The use of
such tools has been constantly advocated by senior management

(c)

translation agencies often have leaner structures since they
can directly subcontract translation requests to a roster of
available individuals who are not permanently employed
and can therefore adapt more flexibly to changing demand.
The EU institutions need to maintain a critical mass of staff
for quality and independence reasons and to meet fluctua-
tions in demand as well as unforeseen demand.

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The Commission is therefore of the opinion that the cost advan-
tages of external translation do not always outweigh quality-
related risks in political organisations such as the European
Institutions.

79-80.
The Commission underlines that the evolution of the
average work rate per translator for 2004 and 2005 is atypical
and not presenting a fair view on translators’ performances. It
rather is the result of drops in demand creating structural imbal-
ances between demand and supply in the language departments,
the lack of experienced translators, terminology bases and linguis-
tic memories for the EU-10 languages, and time spent by EU-10
translators on the revision of the numerous freelance translations
(the work rate statistics presented by the Court have not been
adjusted for this aspect).

Demand, and the linked work rate, can fluctuate with the level of
policy and legislative activity at the Commission. Part of the ratio-
nale for a relatively high-cost in-house translation service is to
allow coverage of urgent political needs, which implies a certain
measure of slack capacity at times when activity is low.

The Commission has taken a number of initiatives in response to
the structural decline of demand levels for the EU-15 non-
procedural languages:

— internal redeployments to strengthen new language depart-
ments, DGT’s horizontal services or other Commission ser-
vices (32 establishment plan posts in 2004; 41 in 2005; 43
scheduled for 2006 and 205 for 2007),

— reducing external translation for EU-15 languages from 20 %

in 2003 to practically zero,

— introducing two-way translation (translation into translators’

second language),

— secondment of translators to other DGs.

These measures will be further pursued and the Commission aims
to adjust staff levels for all its language departments to real needs
by the end of 2006. It will also address the issue of direct out-
sourcing and grey translations by DGs without any supervision
by DGT in the context of its forthcoming update of its transla-
tion strategy for 2007 and beyond.

81.
The Commission will intensify its efforts to achieve a
greater balance in the workload of the various units by (a) increas-
ing intra-departmental flexibility and (b) streamlining portfolios
among the units within the language departments, mirrored by
similar structures for the sectors of the demand management unit.

The Commission nevertheless points out that the characteristics
and constraints of different language departments should be
taken into account in comparing their respective work rates.

The Commission has made significant efforts in 2004 to
87.
adjust such statistical systems to cover also relevant indicators for
the implementation of the translation strategy decided in May
2004. It is currently developing a Data Warehouse to incorpo-
rate more detailed data on translation workflows. A review of cer-
tain key statistical concepts such as ‘daily pressure’ is planned for
2006.

88.
The Commission prefers to use a work rate at an aggre-
gate level (per unit/department; averages per translator; etc.)
which it considers adequate for monitoring the performance of its
translation workflow. Statistics at a more detailed level should be
used with care as different factors impact on such a statistic: the
availability of translation memories and terminology, the subject
matter expertise of the translator, the language competency of the
translator with respect to the source language (translators third,
fourth or even fifth language), quality assurance efforts in accor-
dance with the fit-for-purpose approach, etc. Such statistics are
complex and costly to set-up considering the complexity of the
translation workflow.

The Commission’s translation data warehouse, currently under
construction, will incorporate more detailed data on quality con-
trol on the basis of an agreed definition of revision, cross-reading,
proof-reading, random sample checking and other quality con-
trol operations, and an understanding of the place and purpose
of each in assuring a product that is fit for purpose.

With respect to correlations between workload and outsourcing,
it should be borne in mind that certain translations sometimes
have to be outsourced, regardless of available in-house capacity
(also see comment on points 73 and 74).

The Commission has no established performance indicators on
the impact of IT translation tools on productivity but has some
statistics, which have to be interpreted. Data on yearly produc-
tion and work rate are available which can be correlated with IT
translation tools expenditure. Nevertheless, this correlation is not
obvious, since impact is always bigger in the first stages.

89.
The Commission is of the opinion that text segments
translated automatically should be taken into account when cal-
culating the impact of investments in IT tools on productivity.

Adjusting the Commission’s workload statistics for the impact of
translation memories or other translation support tools would
represent a significant investment. Other elements impacting on
productivity (e.g. the disadvantage of translating from a fourth or
fifth language or the advantage of translating a well-known sub-
ject) are more difficult to factor-in.

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The workload balancing scheme was a pilot project to
91-95.
build up mutual confidence. Results were very positive: the Com-
mission offered to the other institutions its full spare translation
capacity in the EU-8 languages and agreed with all institutions
that the EU-10 translation departments were still not in a posi-
tion to fully adhere to the workload balancing scheme due to
their scarce resources; they will be involved during 2006.

Workload balancing figures in 2006 show a steady and large
increase of the total volume. The Commission is fully committed
to use and further develop the workload balancing mechanism
but notes that a certain margin of internal capacity must always
be available to meet unforeseen demand.

The potential of the workload balancing scheme will decrease as
the result of ongoing actions to adjust resources allocations for
the language departments in line with real needs. These correc-
tive actions remain the first priority for the Commission.

Recommendation

The Commission notes the recommendation of the Court of
Auditors to establish an action plan to increase awareness and
foster interest from the Community’s translation activity in the
EU-10 Member States and other candidate countries but points
out that it has taken steps to prepare the translation markets in
the acceding countries by increasing awareness and fostering
interest in the Commission’s translation activities: it established
facilities in the representation offices in the EU-10 Member States
before their accession and recently also in the EU-2 acceding
countries. These are pursuing active contacts with translators’
professional organisations, universities and media in the respec-
tive countries and. The Commission’s ‘Visiting translator scheme’
has been extended to universities in all of these countries, includ-
ing Bulgaria and Romania. Professional visits have been organ-
ised from these countries to the Commission and special efforts
were made to enhance media coverage on — and professional
interest in — the translation activity via the visits of the Director-
General of DGT to Bulgaria and Romania in early 2005.

If an average of 20 % of the global workflow is being outsourced
by the institutions instead of being exchanged among them, this
is mostly due to the lack of coincidence between available idle
capacity on the one hand and request for exchange on the other
hand, over the whole period needed to meet the request.

98. Recommendation

The additional savings of 11 million euro estimated by the Court
of Auditors relating to freelance activities is not relevant for the
Commission which concentrated, as of May 2004, its freelance
translations mostly on EU-10 languages, thereby reducing poten-
tial further savings of freelance budget to practically zero.

The Commission welcomes the recommendation of the Court of
Auditors to establish Service Level Agreements with users of
translation services. Such Service Level Agreements for the trans-
lation of guides for DG SANCO and DG EMPL have already been
established: these DGs have made a full evaluation of their needs
for the whole year, DGT has offered linguistic advice in the draft-
ing of the originals, and a calendar for the translation of the texts
has been agreed.

CONCLUSIONS AND RECOMMENDATIONS

96.
Procedures and tools are in place for channelling trans-
lation requests from Commission DGs to DGT and for subse-
quent handling of such requests.

99.
The lack of internal capacity to revise freelance transla-
tions for translations into the EU-10 languages was limited to the
first few months following enlargement and limited to documents
which benefited from the safety net provided by subsequent read-
ings in Parliament and Council.

Recommendation

Recommendation

The Commission agrees with the recommendation of the Court
of Auditors to streamline procedures for requesting translations
in DGs and services and will establish rules/guidelines concern-
ing translation of non core documents in the context of a forth-
coming update of the translation strategy.

The Commission doubts the value added of the regular use of sat-
isfaction surveys. Nevertheless, it is currently examining the most
appropriate ways to measure service quality. In addition, feedback
is received regularly and followed-up.

The Commission has been able to deliver on its political
97.
and treaty obligations in terms of translation. It also points out
that the acceding countries have the primary responsibility in
developing their translation markets and the Commission has
repeatedly communicated this message to the respective
governments.

Product quality controls (revision and other checks) on
100.
internal translations are performed with a view to providing texts
that are fit for purpose, but do not produce a quality indicator as
such, and may not be applied to all translations (risk assessment).
External translations are evaluated on the basis of a sample of
pages and those found of poor quality are subsequently revised.

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Recommendation

The Commission agrees with the recommendation of the Court
of Auditors to perform regular random quality checks. It plans, as
part of its total quality management efforts, to introduce a sys-
tem to define, monitor and document its quality control opera-
tions more systematically. A more systematic approach includ-
ing sample checks will be carefully considered in the context of a
more global analysis on quality and quality measurement which
is currently being undertaken.

101. Recommendation

The Commission accepts the recommendation of the Court of
Auditors to monitor the level of direct outsourcing and ‘grey
translations’ and is launching a survey to quantify the magnitude
of these grey translations and direct outsourcing more precisely.
Conclusions from this survey will feed into the preparations of an
update of the translation strategy for 2007 and beyond.

102-103.
The Commission calculated its translation cost
and cost per page for 2002 and suspended subsequent updates of
these calculations awaiting the outcome of the audit which is sub-
ject of this report.

Recommendation

The Commission accepts the recommendation of the Court of
Auditors to ensure adequate management information on the
cost of translation activities and is currently updating its cost-
calculation and monitoring system, in line with the methodology
applied by the Court of Auditors, as part of its regular manage-
ment information reporting.

The drop in the work rate and the structural imbalance
104.
of supply and demand for translation across the different official
languages result from the impacts of the translation strategy
introduced in May 2004. These imbalances are nevertheless of a
transitional nature and are currently being addressed.

This strategy has created a basis for significant savings to the
Community budget: immediate savings have been obtained by
setting recruitment targets for the new languages significantly
below historical averages. Additional savings will be obtained by
ongoing redeployments out of the old languages and other human
resources management
continuous
actions
re-adaptations of the translation strategy.

as well

as

105.
The Commission has improved significantly its forward
translation planning capacity: the network of translation corre-
spondents in the DGs has been revamped to provide specific con-
tact points for DGT’s demand management unit and to promote
both coordination of translation issues within DGs and upstream
translation programming.

Closer attention is now paid to translation aspects at both Com-
mission and interinstitutional level: close follow-up of transla-
tions of legislative proposals has been organised in cooperation
with the Commission, Council and European Parliament regis-
tries. Efforts are being pursued with the SG to further improve
translation programming tools in the context of eGreffe. Meet-
ings with the Council Presidency, focusing on the planning of

translation and the establishment of priorities, have become a
regular feature, thereby contributing to enhanced forward plan-
ning. Also, regular inter-services meetings on translation are orga-
nised with the Commission DGs.

The Commission is determined to continue on this road in order
to further improving its forward programming of translation.

106.
Although some transitional problems did occur in 2004
the Commission has now adjusted its outsourcing policy and is
reducing outsourcing to practically zero for language depart-
ments with spare capacity. However, outsourcing will be main-
tained to respond to specific shortages in terms of language com-
petency (i.e. specific language combinations) or subject matter
expertise (e.g. international accounting standards, banking direc-
tives, etc.).

107.
The Commission is determined to continue its role of
promoter and active contributor to the inter-institutional work-
load balancing scheme. However, it believes that the Court of
Auditors’ estimate of EUR 11 million in potential savings is not
relevant to the Commission (see point 95).

Workload balancing remains subject to restrictions linked to dif-
ferences in the nature of work in the different institutions, time-
tables and agendas of the different institutions and the need to
maintain some capacity to respond to unforeseen and urgent
demand.

Recommendation

The Commission accepts the recommendation of the Court of
Auditors with respect to strengthening future translation plan-
ning by its services and points out the efforts which have been
taken in this respect (see point 105 above).

The Commission supports interinstitutional cooperation and also
accepts the recommendation to address direct outsourcing and to
extend the pilot project on interinstitutional workload balancing.
However, it considers that an interinstitutional billing system
would entail an administrative burden which would be dispropor-
tionate to any possible benefits.

108. Recommendation

The Commission accepts the recommendations of the Court of
Auditors relating to further improvements of the translation pro-
cess and most of those have already been implemented: best prac-
tices are issued regularly in relation to use of modern technology;
new translators adopt immediately these best practices and use
extensively (100 %) IT translation tools. Concerning the integra-
tion of computer tools, this is an ongoing project both for admin-
istration and translation tools. The automation of pre-processing
was one important step in this direction.

21.11.2006

EN

Official Journal of the European Union

C 284/39

The Commission is currently increasing the number of telework-
ers in DGT from 100 to 200.

continuous basis to adjust them to developing needs for targeted
management information.

109.
The Commission considers that management informa-
tion to follow-up on the translation cost is adequate. Neverthe-
less, statistical databases are being updated and improved on a

Moreover, the Commission favours aggregated statistics which
are deemed adequate for monitoring purposes.