Commission staff working document - Implementation of the Internal Market Information System (IMI): report on the Professional Qualifications Directive pilot project - Accompanying document to the communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions - Delivering the benefits of the single market through enhanced administrative cooperation - Progress report on the Internal Market Information System (IMI) {COM(2008) 703 final}
Date: 2008-11-06
Institutions: European Commission
Subjects: action programme, administrative cooperation, information society, information system, information technology, single market

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COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 6.11.2008 
SEC(2008) 2743 

COMMISSION STAFF WORKING DOCUMENT 

Implementation of the Internal Market Information System (IMI): report on the 
Professional Qualifications Directive pilot project 

Accompanying document to the 

COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, 
THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE 
COMMITTEE OF THE REGIONS 

Delivering the benefits of the single market through enhanced administrative cooperation 

Progress report on the Internal Market Information System (IMI) 

{COM(2008) 703 final} 

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1. 

INTRODUCTION 

1.1. 

Background 

The Internal Market Information System (IMI) is an electronic information exchange 
network  developed  by  the  European  Commission  in  close  cooperation  with  the  27 
EU Member States and the 3 European Economic Area (EEA) States.1 IMI sets out 
to  support  day-to-day  administrative  cooperation  between  public  administrations  in 
the internal market.2  

IMI currently supports a pilot project for the administrative cooperation provisions of 
the new Professional Qualifications Directive.3 A second IMI pilot project in support 
of  the  mutual  assistance  obligations  of  the  Services  Directive  will  be  launched  in 
January 2009.4  

1.2. 

Aim of the report 

This  report  accompanies  the  Commission  Communication  on  "Delivering  the 
benefits  of  the  single  market  through  enhanced  administrative  cooperation".  It 
provides a detailed picture of progress in the implementation of IMI, looking at two 
dimensions:  the  development  of  the  IMI  system  and  its  roll-out  during  the 
Professional Qualifications Directive pilot project. As such it forms the basis of the 
conclusions and action points presented in the Communication. 

The pilot project aims to assess whether IMI is fit for the purpose of supporting cross 
border administrative cooperation. A conscious decision was taken to deliver IMI in 
a  progressive  manner.  Thus,  an  initial  basic  software  package  was  delivered  at  an 
early  stage  to  allow  the  first  pilot  project  to  be  run.  Feedback  from  the  pilot  will 
inform future releases of IMI and allow for continuous improvements.  

The  pilot  project  also  sets  out  to  give  Member  States  the  opportunity  to  test  the 
appropriate  organisational  structures  to  support  a  larger-scale  use  of  IMI  in  future. 
Facts and figures in this report are based on an evaluation of the project carried out in 
cooperation with national administrations in July 2008. 

1 

2 

3 

4 

The term "Member States" in this report is used to refer to the 27 EU Member States and the 3 EFTA 
countries participating in the EEA, i.e. Norway, Iceland and Liechtenstein.  
For  more  detailed  information  in  all  EU  languages,  see:  http://ec.europa.eu/internal_market/imi-
net/index.html  
Directive  2005/36/EC  of  the  European  Parliament  and  of  the  Council  of  7  September  2005  on  the 
recognition of professional qualifications, OJ L 2005/255 p.22. (Art 8, 50 and 56 in particular) 
Directive  2006/123/EC  of  the  European  Parliament  and  of  the  Council  of  12  December  2006  on 
services in the internal market, OJ L 2006/376 p. 36. (Art 28-36 in particular) 

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2. 

PROGRESS ON SYSTEM DEVELOPMENT 

2.1. 

Approach taken 

2.1.1. 

Software design 

The  principle  of  IMI  is  to  build  a  single  information  system  which  can  potentially 
support  the  administrative  cooperation  requirements  of  many  different  community 
acts. The IMI architecture is modular. Certain functionality provided in IMI will be 
the same for all legislative areas and the relevant modules can be re-used. Additional 
functionality  will  sometimes  be  needed  to  meet  the  information  exchange 
requirements  of  specific  legislative  acts  and  in  such  cases  additional  modules  will 
need to be designed and programmed. 

Figure 1 - IMI Modular Architecture 

COMPETENT AUTHORITIES AND NATIONAL EXPERTS
COMPETENT AUTHORITIES AND NATIONAL EXPERTS
COMPETENT AUTHORITIES AND NATIONAL EXPERTS
COMPETENT AUTHORITIES AND NATIONAL EXPERTS

CACA
CACA
CACA
CACA
DATADATA
DATADATA
DATADATA
DATADATA

CACA
CACA
DATADATA
DATADATA

CACA
CACA
DATADATA
DATADATA

CACA
CACA
DATADATA
DATADATA

Information
Information
Information
Information
exchange for
exchange for
exchange for
exchange for

Information
Information
Information
Information
exchange for
exchange for
exchange for
exchange for

Information
Information
Information
Information
exchange for
exchange for
exchange for
exchange for

Information
Information
Information
Information
exchange for
exchange for
exchange for
exchange for

LANGUAGE
LANGUAGE
LANGUAGE
LANGUAGE
SUPPORT
SUPPORT
SUPPORT
SUPPORT

SERVICES
SERVICES
SERVICES
SERVICES

PROFESSIONAL
PROFESSIONAL
PROFESSIONAL
PROFESSIONAL
QUALIFICATIONS
QUALIFICATIONS
QUALIFICATIONS
QUALIFICATIONS

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

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

QUESTIONS
QUESTIONS
QUESTIONS
QUESTIONS

QUESTIONS
QUESTIONS
QUESTIONS
QUESTIONS

QUESTIONS
QUESTIONS
QUESTIONS
QUESTIONS

QUESTIONS
QUESTIONS
QUESTIONS
QUESTIONS

QUESTION SET GENERATOR
QUESTION SET GENERATOR
QUESTION SET GENERATOR
QUESTION SET GENERATOR

In  order  to  allow  for  the  piloting  and  continuous  improvement  of  the  software,  the 
IMI system is being developed in a progressive manner, as outlined below: 

(1) 

(2) 

(3) 

(4) 

release  basic  version  of  the  application  to  support  a  pilot  project  on  the 
Professional Qualifications Directive 

release  enhanced  version  of  the  IMI  application  in  support  of  a  fully 
operational system for the Professional Qualifications Directive 

deliver  a  version  containing  the  tools  so  that  IMI  can  support  additional 
legislative areas (first step will be to add the Services Directive) 

design  and  programme  additional  workflows  specific  to  the  Services 
Directive 

The first version of the IMI application is in production. The second version has been 
programmed  and  is  currently  being  tested  before  going  into  production.  The  third 
version is being programmed and is planned to go into production in January 2009. 
Once this version is available, it will technically be  possible  to add new  legislative 
areas  to  IMI  without  any  additional  programming.  The  requirements  for  the 
additional workflows specific to the services directive are currently being analysed in 
close cooperation with Member States. 

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2.1.2.  Governance 

Member  States  are  closely  involved  in  the  development  of  IMI.  Two  committees 
oversee its overall deployment: the Pan-European eGovernment Services Committee 
is  responsible  for  the  release  of  IDABC  funding  based  on  recommendations  issued 
by the Internal Market Advisory Committee. 

Since March 2006 Member States and the Commission have been working together 
intensively  in  order  to  agree  on  the  detailed  requirements  for  the  system.  Regular 
meetings take place with Member State committees and working groups in order to 
determine  how  best  to  support  each  specific  piece  of  legislation  in  IMI.  National 
experts  are  therefore  able  to  provide  regular  input  and  feedback,  thus  shaping  each 
step in the process. 

This course of action is in itself an example of the principle of shared responsibility 
that  underpins  the  renewed  partnership  approach  between  the  Commission  and 
Member States needed to deliver the full benefits of the internal market. 5  

2.2. 

Delivery to date 

Despite initial delays due to difficulties in the performance level of the application, 
the  first  version  of  the  IMI  application  was  delivered  to  allow  the  launch  of  the 
Professional Qualifications Directive pilot project on time.  

This  first  version  contains  all  the  basic  building  blocks  necessary  to  support 
information exchanges between competent authorities across the EEA. This includes: 

•  Repository  which  can  store  the  contact  details  and  search  criteria  for  relevant 

competent authorities throughout the EEA  

•  Multilingual search facility to identify partner authorities in other Member States 

without prior knowledge of their administrative structure 

•  List  of  predefined  questions  and  answers  (based  on  the  specific  piece  of 
legislation) available in all official EU languages to help authorities communicate 
with each other 

•  Transparent set of procedures on how to deal with requests, agreed by all Member 

States 

•  Request  management  tool  to  monitor  progress  and  identify  potential  problems 

with specific information requests 

•  In addition, a number of support elements are included: 

•  Language  management  tool  to  allow  European  Commission  to  manage  the 

translation of screen information into all official EU languages 

5 

See: Communication from the Commission to the European Parliament, the Council, the Economic and 
Social Committee and the Committee of the Regions, "A single market for 21st century Europe", COM 
(2007) 725 

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•  Access to online IMI training system in all EU languages to help users familiarise 

themselves with the application 

•  IMI  website  in  all  EU  languages  acting  as  a  gateway  to  the  application  (IMI 
Production  and  IMI  Training  System)  and  containing  the  relevant  system 
documentation 

2.3. 

Outlook 

The  enhanced  version  of  the  IMI  application  needed  to  support  a  fully  operational 
system  for  the  Professional  Qualifications  Directive  is  currently  undergoing  testing 
and  will  be  released  in  the  autumn  of  2008.  It  includes  a  number  of  additional 
functions requested by Member States (such as the possibility to print requests) and 
the use of online machine translation for certain language pairs. Other improvements 
identified by IMI users, such as the introduction of a more sophisticated competent 
authority search tool, will be incorporated in future releases.  

Analysis  and  design  is  complete  and  programming  is  well  advanced  to  ensure  that 
IMI is able to support additional legislative areas. A number of new features will be 
introduced,  including  most  notably  a  so-called  "question  set  generator".  This  tool 
will  allow  the  online  creation  of  new  question  sets  based  on  the  provisions  of  a 
specific  piece  of  legislation  without  any  additional  programming  intervention.  It  is 
planned for delivery in time for the launch of the Services Directive pilot project in 
the beginning of 2009.  

Analysis is underway to ensure that IMI can support the specific requirements of the 
Services  Directive,  which  requires  specific  additional  workflows  such  as  case-by-
case  derogations  and  the  alert  mechanism.  The  high  level  requirements  for  these 
workflows have been defined in close cooperation with Member States. 

As  the  anticipated  volume  of  authorities  using  IMI  for  the  Services  Directive  is 
significantly  higher  than  for  Professional  Qualifications,  analysis  has  also  been 
completed on a module to allow authorities to self-register in IMI. 

3. 

IMPLEMENTATION  AND  ROLL-OUT  –  THE  PROFESSIONAL  QUALIFICATIONS 
DIRECTIVE PILOT PROJECT 

3.1.1.  Approach taken 

The  Commission  and  Member  States  are  working  together  to  establish  a  general 
information exchange system to facilitate efficient cooperation in the internal market. 
But in order for IMI to deliver the expected benefits, establishing the system alone is 
not sufficient. Additional steps need to be taken to roll-out IMI across the EEA. 

Each  country  has  nominated  a  'National  IMI  Coordinator'  (NIMIC)  to  manage 
overall IMI project coordination. It is up to the NIMIC to decide how best to do this. 
Critical elements of a successful IMI roll-out would include the following tasks: 

•  Registration of authorities in IMI 

•  Organisation of awareness-raising and training for competent authorities 

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•  Provision of support facilities for end-users 

•  Involvement in requests in case of problems 

It is possible to carry out all the above tasks within one NIMIC. Depending on the 
administrative  structures,  it  is  also  possible  to  delegate  all  or  certain  coordinating 
functions  to  other  levels  of  the  administration,  acting  as  'Super-Delegated  IMI 
Coordinators' (SDIMIC) or 'Delegated IMI Coordinators' (DIMIC) within IMI.6 Each 
country  has  to  decide  on  the  IMI  set  up  which  is  best  suited  to  its  administrative 
structure and practices.  

IMI also offers the flexibility for each Member State to find the most appropriate fit 
in terms of how to best organise the workflows. It is possible, for example, for some 
Member States  to involve IMI Coordinators in approving information requests sent 
by its authorities, and for others to allow authorities to send information directly. A 
Member  State  may  choose  that  certain  authorities  should  only  be  allowed  to  send 
queries, but not be able to respond to requests from other Member States. 

In Member States with regional structures, IMI also allows each region to choose its 
own set up so that it is possible for the set up to vary between different regions in the 
same  Member  State.  IMI  can  also  be  set  up  differently  between  legislative  areas  – 
this is particularly important since the mutual assistance provisions are not the same 
in different community acts.  

The  first  step  in  rolling-out  and  testing  the  IMI  system  was  the  launch  of  the 
Professional Qualifications pilot project in November 2007. Initially, Member States 
concentrated  on  identifying  and  registering  relevant  competent  authorities.  By 
February  2008,  a  sufficient  critical  mass  of  authorities  had  been  registered  for  the 
pilot  information  exchange  between  authorities  to  commence.  The  project  was 
limited  to  four  professions  (doctors,  pharmacists,  physiotherapists  and  accountants) 
and involved all 30 EEA countries. 

Professional Qualifications Directive pilot project  

The use of IMI is not expressly foreseen in the Professional Qualifications Directive. 
The  Commission  makes  it  available  to  Member  States  who  are  free  to  use  it  in 
support of the administrative cooperation provisions of the directive.  

information  between  competent  authorities,  which 

The  aim  of  the  Professional  Qualifications  pilot  project  is  two-fold.  First,  it  is  an 
opportunity to assess the added value of the IMI system in supporting the exchange 
of 
the 
administrative  cooperation  provisions  of  internal  market  legislation.  Secondly,  it 
provides  an  important  opportunity  for  Member  States  to  progressively  put  in  place 
appropriate organisational structures to support a large-scale use of IMI in future.  

is  required  by 

In  the  summer  of  2008,  the  Commission  undertook  a  series  of  steps  to  gather 
feedback from Member States and to evaluate the pilot project: 

6 

A DIMIC can carry out all the same actions as a NIMIC within the IMI system with the exception of 
registering other DIMICs. In order to cater for Member States with federal structures, it is possible to 
nominate regional "Super DIMICs" who will be able to register further DIMICs in its region. 

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•  Electronic  questionnaire  sent  to  IMI  Coordinators  and  to  the  Group  of 
Coordinators  for  the  recognition  of  professional  qualifications:  28  (out  of  30) 
National  IMI  Coordinators  responded  as  well  as  21  (out  of  59)  Delegated  IMI 
Coordinators7 

•  Electronic  end-user  feedback  gathered  after  each  request:  43  responses  were 

received by 28 July 2008 

•  Interactive feedback session on 24-26 June 2008: 40 participants from 21 Member 
States  attended  (20  National  IMI  Coordinators,  10  Delegated  IMI  Coordinators, 
10 Competent Authorities) 

The results of this exercise are presented below. 

3.2. 

Organisational aspects 

3.2.1. 

IMI  suitably  flexible  for  diverse  administrative  structures  but  some  Member  States 
have not yet made the necessary investment in understanding the available choices 

For  the  Professional  Qualifications  Directive  pilot,  Member  States  decided  to 
delegate the role of National IMI Coordinator (NIMIC) to national-level ministries, 
either responsible for economic affairs, European affairs or administrative reform. In 
addition,  almost  all  Member  States  chose  to  also  involve  other  ministries  with 
responsibility  for  the  recognition  of  professional  qualifications  (in  most  cases 
education, labour or health/ social affairs).8 

Of all Member States, only Germany implemented a decentralised IMI model: each 
federal state or Land nominated a Super-Delegated IMI Coordinator (Super-DIMIC) 
responsible for overall IMI coordination in its territory.9 In addition, the majority of 
the  German  Länder  also  involved  the  authorities  responsible  for  professional 
qualifications recognition, as Delegated IMI Coordinators. 

7 

8 

9 

In  addition  to  the  28  National  IMI  Coordinators  and  the  21  Delegated  IMI  Coordinators,  the 
Commission also received the response from 2 Professional Qualifications Coordinators: Denmark and 
Cyprus. The views expressed have been taken into account throughout the report. 
For the IMI pilot project, Finland, Italy, Malta and Portugal decided that it was sufficient to nominate a 
National IMI Coordinator and no additional Delegated IMI Coordinators. 
Most  SDIMICs  in  Germany  are  institutions  with  responsibility  for  IT  and  public  administration  (8), 
some  are  situated  in  the  economics,  finance  or  labour  ministry  (6).  In  one  case  the  SDIMIC  is  the 
Ministry of the Interior and in another it is the Ministry of Health.  

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Figure 2 - Different options for the set-up of IMI 

EC
EC

European Commission – IMI Administration
European Commission – IMI Administration
- EC IMI Helpdesk -
- EC IMI Helpdesk -

Member State 1
Member State 1

Member State 2
Member State 2

Member State 3
Member State 3
e.g. a Member State with federal structure
e.g. a Member State with federal structure

Member
Member
States
States

NIMIC
NIMIC
- helpdesk -
- helpdesk -

NIMIC
NIMIC

NIMIC
NIMIC
- helpdesk -
- helpdesk -

Regional
Regional
Level
Level

Functional
Functional
Level
Level

Competent
Competent
Authorities
Authorities

Federal State 1
Federal State 1

Federal State ...16
Federal State ...16

SDIMIC 1
SDIMIC 1

SDIMIC 16
SDIMIC 16

DIMIC 1
DIMIC 1
- helpdesk -
- helpdesk -

DIMIC 2
DIMIC 2
- helpdesk -
- helpdesk -

DIMIC 1
DIMIC 1
- helpdesk -
- helpdesk -

DIMIC 2
DIMIC 2
- helpdesk -
- helpdesk -

CA
CA

CA
CA

CA
CA

CA
CA

CA
CA

CA
CA

CA
CA

CA
CA

CA
CA

CA
CA

CA
CA

CA
CA

CA
CA

CA
CA

CA
CA

CA
CA

CA
CA

Most  of  the  Member  States  report  that  the  organisational  structure  chosen  proved 
suitable to support the smooth running of the IMI pilot project.10 In response to the 
European  Commission  questionnaire,  most  IMI  Coordinators  state  that  they 
encountered no problem in relation to the organisational structure of IMI. The main 
problems that were encountered – according to the questionnaire responses – were: 

•  Unsure  how  to  best  reflect  administrative  structure  of  Member  State  within  the 

IMI virtual organisational architecture11  

•  Unsure which responsibilities to delegate to Delegated IMI Coordinators12 

•  Difficulty in identifying all competent authorities13 

A similarly positive picture emerged in terms of the suitability of the structure for the 
extension  of  IMI  to  additional  professions  under  the  Professional  Qualifications 
Directive. Most think that no significant changes are required but that additional IMI 
Coordinators  will  be  needed  to  support  such  system  growth.14  Belgium  and  Spain, 
for  instance,  have  both  come  to  the  conclusion  that  a  model  similar  to  the  German 
example outlined above may be more suitable in the long run. 

10 

11 
12 
13 
14 

In response to the Commission electronic questionnaire, 23 NIMICs fully agree that their organisational 
structure was suitable to run the IMI pilot project, 5 NIMICs tend to agree. The DIMICs were slightly 
more sceptical: about half fully agree, half tend to agree. 
3 NIMICS, 7 DIMICs  
4 NIMIC, 4 DIMIC 
3 NIMIC, 3 DIMIC 
17  NIMICs  believe  that  the  organisational  structure  is  adequate  to  support  this  growth.  8  think  it  is 
adequate  but  additional  Coordinators  will  have  to  be  nominated.  All  DIMICs  think  that  the 
organisational  structure  is  adequate  for  an  extension  to  additional  profession  but  that  additional 
Coordinators will have to be nominated. 

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The pilot has illustrated that IMI is able to reflect the diverse administrative realities 
in Europe. This flexibility, however, means that each Member State has to make an 
initial  investment  in  understanding  the  available  possibilities.  At  this  stage,  not  all 
have done so. 

3.2.2.  Getting competent authorities on board is crucial  

Perhaps the most important and in some cases challenging aspect of rolling out IMI 
is the identification and registration of competent authorities in the system. With only 
four professions included in the pilot project, the number of competent authorities in 
the  majority  of  Member  States  was  limited:  with  the  exception  of  Poland  (27 
authorities),  Greece  (59)  and  Germany  (109),  no  country  registered  more  than  ten 
authorities to deal with the four professions.  

Member  States  did  not  always  register  all  authorities  involved  in  professional 
qualifications  recognition  for  the  professions  involved.  As  expected,  there  was  a 
marked  difference  from  profession  to  profession.  Where  levels  of  cross-border 
activity  are  particularly  high  and  there  is  a  regular  need  for  administrative 
cooperation, authorities were far more interested in being part of the pilot project.15 
Therefore,  for  doctors  the  proportion  of  registered  competent  authorities  is  highest, 
followed by physiotherapists and pharmacists. For accountants, on the other hand, 10 
Member States registered either no authorities at all or only some. The main reason 
appears to be the low level of cross-border migration; other reasons include the fact 
that  the  profession  of  'accountant'  is  not  regulated  everywhere  and  it  may  cover 
different sets of activity in each Member State concerned. 

Other  challenges  encountered  by  Member  States  in  relation  to  the  registration  of 
competent  authorities  include  delays  in  the  transposition  of  the  Professional 
Qualifications  Directive  and  difficulties  in  identifying  all  competent  authorities. 
Some Member States have expressed uncertainty about whether to register only those 
authorities competent which take decisions or also those that hold specific pieces of 
information  that  may  be  required  by  another  Member  State.  In  some  cases,  a 
conscious decision was taken to only register a limited number of authorities and to 
rely on those authorities to contact others in order to answer requests via IMI.  

It  is  up  to  Member  States  to  decide  how  to  best  organise  their  mutual  assistance 
obligations. However, the pilot shows that it is most efficient if the exchange directly 
involves the requesting authority in one country and the competent authority in the 
other country that actually holds the required information.  

3.3. 

Quality and benefits of the IMI system 

It  is  important  to  bear  in  mind  that  the  aim  of  the  Professional  Qualifications 
Directive  pilot  was  to  test  the  suitability  of  the  IMI  system  in  supporting 
administrative  cooperation.  To  do  so,  a  critical  mass  of  requests  was  needed. 
However, IMI does not set out to increase the volume of information exchanges but 

15 

Compare for instance the number of decisions taken in relation to the professional recognition of 
doctors (2006=8650) with the number of decisions in relation to accountants (2006=15). See the 
summary compiled by the Commission of the requests for recognition of diplomas by profession: 
http://ec.europa.eu/internal_market/qualifications/regprof/index.cfm?fuseaction=home.welcome 

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rather to increase their quality and efficiency. It is intended to support the exchange 
of  information  between  competent  authorities  only  when  this  is  required  by  the 
provisions of internal market legislation. 

3.3.1.  Levels of system usage meets expectations 

In the five months of the pilot more than 130 information requests were dealt with 
through  IMI.16  With  the  exception  of  Iceland,  Liechtenstein, Malta  and  Estonia,  all 
Member States submitted or received requests.  

It  is  interesting  to  note  that  three-quarters  of  requests  were  sent  from  the  UK, 
Germany,  Ireland  and  Belgium.  More  than  half  of  the  requests  were  addressed  to 
Romania,  Bulgaria,  Poland,  and  Italy.17  In  terms  of  the  professions  covered  by  the 
requests,  almost  two-thirds  concerned  doctors,  followed  by  pharmacists  and 
physiotherapists.  Only  4%  of  requests  covered  accountants.18  It  is  also  worthwhile 
mentioning  that  the  majority  of  requests  concerned  the  permanent  establishment  of 
professionals or contained questions of a general nature; no exchanges took place on 
the  provision  of  temporary  services.19  This  is  probably  because  –  unlike  the 
permanent  establishment  rules  –  the  general  provisions  on  temporary  services  have 
only been introduced with the new directive on professional qualifications. Since the 
directive  has  only  recently  come  into  effect20,  the  number  of  professionals  making 
use  of  the  new  provisions  at  this  early  stage  is  likely  to  be  rather  low.  As 
professionals and authorities become more familiar with this chapter of the directive, 
the number of cases – and of requests in IMI – is likely to increase. 

Figure 3 - Number of requests handled per Member State (from 28.02.2008-31.07.2008) 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

ES 

ET 

FI 

6 

19 

12 

2 

4 

31 

2 

19 

0 

4 

   FR 
  GR 
  HU 
IE 

IS 

  RO 
SE 

SK 

SL 

   UK 

9 

4 

8 

17 

0 

23 

6 

4 

1 

47 

IT 

LI  

LT 

LU 

LV 

  MT 
  NL 
  NO 
  PL 
   PT 

14 

0 

4 

3 

1 

0 

5 

1 

12 

6 

16 

17 

18 

19 

20 

All  statistics  related  to system  usage  refer to  the  time  period  between  28  February  and 31  July  2008, 
thus covering a total of 5 months. 
In the time period covered by this report, the UK sent 37 requests, followed by Germany (26), Ireland 
(15),  Belgium  (13)  and  Spain  (7).  Most  were  addressed  to  Romania  (23),  followed  by  Bulgaria  (12), 
Poland (11) and Italy (11). To a lesser degree requests were also addressed to Spain (9), Hungary (7), 
Germany (7), UK (6) and France (5). 
In the time period covered by this report, 87 requests dealt with doctors, 29 with pharmacists, 11 with 
physiotherapists and 5 with accountants. 
In  the  time  period  covered  by  this  report,  74  requests  contained  questions  related  to  permanent 
establishment and 58 requests were of a general nature. 
The transposition deadline for Directive 2005/36/EC of the European Parliament and of the Council of 
7 September 2005 on the recognition of professional qualifications was the 20 October 2007. 

EN 

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Although it is too early to reach any definitive conclusions, the numbers do seem to 
suggest  that  IMI  usage  roughly  reflects  migration  patterns  recorded  for  the  four 
professions.  It  also  seems  clear  that  countries  with  higher  levels  of  in-  or  out-
migration of professionals have higher levels of IMI usage. 

20%  of  authorities  registered  in  IMI  were  involved  in  requests.  It  is  apparent  from 
user feedback that not all communication between authorities has taken place in IMI, 
particularly,  where  existing  contacts  are  already  in  place  and  there  is  no  language 
barrier. Other reasons why authorities did not make use of IMI include hesitance to 
use  IT  systems  in  general  as  well  as  uncertainty  as  to  how  IMI  works  and  what  it 
adds.21 

However,  feedback  also  seems  to  indicate  that  as  authorities  get  used  to  the 
application, they start recognising its added value. This translates into higher system 
usage: compared to the first months, the average number of requests per month at the 
end of the pilot phase has more than tripled.  

Three-quarters  of  IMI  Coordinators  state  that  this  level  of  usage  is  what  they  had 
expected  for  the  pilot  phase.  Around  two-thirds  of  Member  States  think  it  is  likely 
that authorities will use IMI whenever the need arises and about half are convinced 
that IMI will become the preferred communication channel between authorities.  

3.3.2. 

IMI  has  the  potential  to  simplify  administrative  cooperation  for  the  benefits  of 
citizens in the internal market 

Quality of the IMI System 

Based  on  the  experience  of  the  pilot  project,  Member  States  report  that  the  IMI 
system  is  suitable  to  support  crossborder  cooperation.  Almost  all  IMI  Coordinators 
believe that the IMI system is easy to use.22 The building blocks that IMI offers are 
seen  to  be  of  good  quality.  Member  States  highlight  in  particular  the  ease  of 
registering  competent  authorities  in  IMI23,  the  ability  to  search  for  competent 
authorities  in  other  Member  States24  and  the  availability  to  monitor  progress  of 
requests25  within  the  system,  including  the  use  of  automatic  email  alerts26.  The 
request creation and request reply module was also seen as very good.27 

Feedback  from  end-users  gathered  after  each  request  draws  a  similar  picture:  more 
than half of the respondents found IMI to be very user-friendly, whilst the remainder 
described the system as 'quite user-friendly'.  

21 

22 
23 
24 
25 
26 
27 

The  vast  majority  of  IMI  Coordinators  state  that  the  main  reason  why  authorities  did  not  use  IMI  is 
because there was no need to contact partner authorities in other Member States (70% of NIMICs and 
86% of DIMICs). 44% of NIMICS (26% DIMICs) believe that authorities not using IMI have already 
existing  contacts  to  their  counterpart,  thus  not  needing  to  make  use  of  IMI  in  those  cases.  IMI 
Coordinators also think that a significant factor why authorities may not use IMI yet is uncertainty as to 
how IMI works and what value it adds (22% of NIMICs and DIMICs).  
27 NIMICs and 18 DIMICs responded that they believe IMI is easy to use. 
26 NIMICs and 17 DIMICs answered excellent or very good.  
24 NIMICs and 19 DIMICs answered excellent or very good. 
19 NIMICs and 12 DIMICs answered excellent or very good. 
21 NIMICs and 11 DIMICs answered excellent or very good. 
21 NIMICs and 13 DIMICs answered excellent or very good. 

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11 

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"The IMI system is a very useful alternative to simple email as a means of contacting 
other  Member  State  competent  authorities  when  we  have  queries  or  need  to  raise 
'justified doubts' as per Article 50 of Directive 2005/36/EC.  

The high number of times we have used the system is a result of the high number of 
EEA applications we receive every year (around 700, of which around 500 register), 
the vast majority of which do not require further clarification. When the system came 
online,  we  used  the  opportunity  to  send  requests  via  IMI  that  had  not  received 
responses via email for some time. From our perspective, the system is a much better 
alternative to email as  

• 

we are able to keep track of all the requests we have sent,  

• 
we  are  sure  that  we  are  sending  the  request  to  the  correct  person  or  body 
(rather  than  emailing  an  individual  who  no  longer  works  for  the  organisation 
concerned for example, as has happened in the past) 

we  are  able  to  use  preset  questions  to  ensure  that  we  receive  all  the 

• 
information we require." 

Frequent IMI user, United Kingdom 

The pilot phase has also shown that more work is needed to fine-tune the application. 
In  particular,  users  have  expressed  a  need  for  more  advanced  language  support.  A 
number of end-users have stated that at times due to the complexity of the cases they 
are  dealing  with,  it  is  not  always  possible  to  resort  to  the  structured,  pretranslated 
questions/  answers.  Whilst  IMI  provides  the  possibility  to  enter  free-text,  the  pilot 
version  does  not yet offer the translation of this text – a functionality much sought 
after by  users involved.  To respond to this need, the next version of IMI will offer 
online machine translation for certain language pairs. 

IMI Coordinators have also indicated that a more sophisticated competent authority 
search module as well as other practical improvements would be helpful for the long 
term success of IMI.28 

Added value of IMI 

The great majority of end-users and IMI Coordinators emphasise that IMI is a very 
useful  tool  with  great  potential.  Particularly  for  professions  with  high  cross-border 
migration, where there are language barriers or no established contacts, IMI can be 
extremely useful. Member States particularly emphasise the following benefits: 

Helps authorities identify their counterparts in other Member States29 

Overcomes language barriers and make communication easier30 

Can lead to faster and clearer responses31 

28 
29 
30 

For further details on the next IMI versions, refer to section 2.3 of this report. 
Very beneficial=25 NIMICs, 14 DIMICs; Beneficial=2 NIMICs, 6 DIMICs 
Very beneficial=18 NIMICs, 15 DIMICs; Beneficial=7 NIMICs, 2 DIMICs 

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12 

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Offers a uniform, transparent working method.32 

"Ladies and gentlemen. I have been very content with IMI until now (my compliments 
to  the  company;  I  did  not  think  such  good  quality  was  possible).  IMI  contributes 
significantly to making my job easier."33 

IMI user, Germany 

In  terms  of  response  times,  system  statistics  back  the  feedback  provided  from 
Member States. Despite initial teething problems and some delays, even in the early 
phase  of  the  project,  almost  one-quarter  of  the  requests  were  answered  within  one 
day and three-quarters received a response within two weeks. In general, the system 
does speed up the process and enables competent authorities to take more informed 
decisions  quickly,  thus  providing  a  better  service  to  citizens  and  businesses  and 
reducing the costs associated with delays. 

3.4. 

Training, support and awareness 

The success of IMI does not only depend on having the right software in place and 
the right fit between a country's administrative structure and the 'virtual' structure in 
IMI. Without an adequate level of awareness, users will be hesitant to make use of 
this  new  tool.  Based  on  the  Pilot  project,  Member  States  have  singled  out  training 
and awareness-raising as the single most important success factor. 

The Commission has supported Member States with the organisation of awareness-
raising  and  training  for  competent  authorities.  The  following  approach  has  been 
taken: 

(1) 

(2) 

(3) 

(4) 

Investment  in  'training-the-trainers',  including  training  sessions  and  material 
for IMI Coordinators34 

Assistance with the organisation of national IMI training events35 

Development  of  an  IMI  Training  System  as  a  tool  to  familiarise  end-users 
with IMI 

Promotional  activities  such  as  a  multilingual  IMI  website  or  conference 
participation 

31 
32 
33 

34 

35 

Very beneficial=11 NIMICs, 10 DIMICs; Beneficial=7 NIMICs, 4 DIMICs 
Very beneficial=11 NIMICs, 6 DIMICs; Beneficial=14 NIMICs, 9 DIMICs 
This  is  a  translation  of  the  original  comment  received by  a  German  user  through  the online  IMI  user 
questionnaire.  The  original  reads::  "Sehr  geehrte  Damen  und  Herren,  bisher  bin  ich  mit  IMI  sehr 
zufrieden.  (Mein  Kompliment  an  die  Firma;  ich  habe  solch  eine  gute  Qualität  nicht  für  möglich 
gehalten.) IMI erleichtert die Arbeit deutlich."  
In the course of the pilot project, the Commission held 4 training sessions for IMI Coordinators catering 
for an average of 60 participants on each occasion. In addition, IMI Coordinators were offered training 
material and support in the preparation of national training events. 
The Commission offers assistance upon request in developing and organising national training events. 
This is subject to availability and can range from advice in developing the course to acting as trainers. 
Priority  has  been  given  to  Member  States  with  large  user  groups.  During  the  pilot  project,  the 
Commission  collaborated  in  organising  IMI  training  activities  in  Germany,  Greece,  Hungary,  Cyprus 
and Romania. 

EN 

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(5) 

(6) 

Limited  end-user  support  material  such  as  a  user  handbook36  or  interactive 
presentations of the IMI system37 

Regular  assistance  to  IMI  Coordinators  through  the  Commission  IMI 
Helpdesk 

3.4.1.  European-level support is seen as helpful 

During  the  pilot  project,  all  Member  States  participated  in  IMI  training  sessions 
offered  by  the  Commission.  All  IMI  Coordinators  state  that  they  have  found  them 
very  useful.  The  training  material  provided  by  the  Commission  was  also  seen  in  a 
positive light: all NIMICs and over three-quarters of DIMICs reported making use of 
the  material  and  found  the  presentations  provided  as  well  as  the  access  to  the  IMI 
training system particularly useful. 

Member  States  also  see  a  role  for  the  Commission  in  raising  awareness  on  IMI 
through  the  provision  of  generic  promotional  material,  such  as  an  information 
brochure  or  European-level  awareness  events.  Further  steps  will  be  taken  in  this 
direction as the project progresses. 

3.4.2.  Member States have taken first steps to provide training and support 

As the majority of Member States only registered a limited number of authorities for 
the Professional Qualifications pilot project,38 the need to undertake comprehensive 
training  measures  was  limited.  Accordingly,  most  Member  States  offered  only  a 
number of small training events (10-25 participants) or raised awareness about IMI at 
conferences.  In  addition,  4  Member  States  set  up  national  IMI  websites  and  3 
Member States prepared paper-based IMI brochures.  

With a view to the expected expansion of the IMI system in the near future, it is of 
particular  interest  to  take  a  closer  look  at  the  countries  where  the  number  of  IMI 
users  during  the  pilot  phase  was  substantially  higher.  In  Greece,  for  instance,  a 
national  IMI  training  week  for  over  90  users  was  offered  by  the  National  IMI 
Coordinator, organised and executed in cooperation with the Commission.  

In  Germany  –  with  140  competent  authorities  and  over  300  registered  users  –  the 
National IMI Coordinator took a two-step approach. The priority was to ensure that 
IMI Coordinators at Länder-level were enabled to use the system and to train further 
users in their territory. In cooperation with the European Commission, initial training 
was  offered  over  four  days.  It  was  open  to  IMI  Coordinators  as  well  as  competent 
authorities.  Through 
initial  step,  one-fourth  of  IMI  users  received  a 
comprehensive  introduction  to  the  system.  As  a  second  step,  the  Länder-level  IMI 
Coordinators were encouraged to organise additional training where required – a full 
set of training material was provided for this purpose. Five IMI Coordinators report 

this 

36 

37 

38 

EN 

is  available 

in  all  official  EU 

The  user  handbook 
http://ec.europa.eu/internal_market/imi-net/docs/user_procedures2_en.pdf  
The interactive presentations (Captivate presentations) are available in English on the IMI website. See: 
http://ec.europa.eu/internal_market/imi-net/training_en.html  
See section 3.2.2 of this report: with the exception of Poland (27 authorities), Greece (59) and Germany 
(109), no country registered more than ten authorities to deal with the four professions. 

the  IMI  website.  See: 

languages  on 

14 

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having  organised  their  own  training  sessions,  partly  using  existing  IT  education 
programmes for public authorities. This brought the proportion of German-based IMI 
users that benefited from training up to around 60%.  

3.4.3.  More efforts are needed to equip authorities to make use of IMI 

Despite these efforts across the Member States, some end-users report that they did 
not  always  feel  equipped  to  use  the  IMI  system  properly.  Almost  half  of  the  IMI 
Coordinators confirm that one of the key challenges during the pilot was that users 
were not aware of the added value of IMI.  

One  of  the  reasons  is  undoubtedly  the  limited  availability  of  resources.  IMI 
Coordinators often have not had the means to carry out structured IMI training, both 
financially and in terms of skills. In other cases, training was provided too late or too 
early in the process or training material was not available in the relevant language on 
time.  

It  is  clear  that  as  the  IMI  system  grows  and  the  number  of  users  increases,  further 
activities  will  be  required.  Based  on  the  pilot  project,  a  number  of  potential  steps 
have  been  identified  to  improve  the  level  of  awareness  of  IMI  users  in  the  future. 
These include: 

•  Providing more multilingual user material such as basic IMI Guide or eLearning 

tools 

•  Increasing promotional activities 

•  Ensuring that appropriate authorities participate in Commission training sessions 

•  Embedding IMI training into existing administrative capacity programmes 

3.5. 

Overall view of the pilot project 

3.5.1.  Lessons learnt for future roll-outs of IMI 

During the pilot, a number of critical success factors were identified: 

(1) 

(2) 

(3) 

Awareness-raising  amongst  competent  authorities  of  the  added  value  and 
functionality of IMI was seen as the most important aspect.  

European  Commission  guidance, 
IMI 
Coordinators and the provision of a European IMI Helpdesk was felt to have 
made a significant contribution to the pilot project and should be continued in 
future. 

regular  meetings  amongst 

IMI coordination within a Member State will become particularly important 
as  the  system  grows.  This  includes  not  only  the  timely  registration  of 
competent  authorities  but  also  well  trained  IMI  Coordinators  that  can  assist 
competent authorities and can ensure that requests are dealt with in a timely 
fashion.  

EN 

15 

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(4) 

Political support was considered vital to support a larger operational system. 
IMI Coordinators need to have formal backing and mandate to coordinate the 
project in their respective areas of competence  

3.5.2.  Extension of IMI to additional professions is recommended 

Member States agree that the Professional Qualifications Directive pilot project has 
shown that the IMI system offers the functionality needed to support administrative 
cooperation. The majority see it is a very useful tool that has the potential to bring 
substantial  benefits  to  authorities  across  the  EEA  in  the  implementation  of  internal 
market  legislation.39  On  that  basis,  over  two-thirds  of  IMI  Coordinators  fully  agree 
that it is advisable to extend IMI to additional professions. The remaining one-third 
tend to agree.  

39 

• 

• 

• 

IMI Coordinators gave the following answers to evaluation questionnaire:  
"The pilot project has shown that IMI offers the functionality to support administrative cooperation." – 
Fully  agree=  13  NIMICs,  9  DIMICs;  Tend  to  agree=  12  NIMICs,  8  DIMICs;  Tend  to  disagree=  1 
DIMIC 
"The  pilot  project  has  shown  that  IMI  is  a  very  useful  tool."  –  Fully  agree=  16  NIMICs,  9  DIMICs; 
Tend to agree= 10 NIMICs, 7 DIMICs; Tend to disagree= 3 DIMICs 
"The pilot project has shown that IMI has the potential to bring great benefits to authorities across the 
EEA".  –  Fully  agree=  14  NIMICs,  11  DIMICs;  Tend  to  agree=  13  NIMICs,  7  DIMICs;  Tend  to 
disagree= 2 DIMICs. 

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