Commission staff working document - Ex ante evaluation – Assessment of the need to establish a multi-annual programme in order to organise training and exchanges of officials in charge of the implementation of mutual assistance under the Services Directive (2006/123/EC) - Accompanying document to the Report from the Commission on training and exchanges of officials in charge of the implementation of mutual assistance under the Services Directive (2006/123/EC) COM(2010)134
Date: 2010-04-09
Institutions: European Commission
Subjects: administrative cooperation, exchange of information, information system, provision of services, services contract, single market, vocational training

EN 

EN  

 
EUROPEAN COMMISSION 

Brussels, 9.4.2010 
SEC(2010) 395 final 

COMMISSION STAFF WORKING DOCUMENT 

Ex ante evaluation – assessment of the need to establish a multi-annual programme in 
order to organise training and exchanges of officials  
in charge of the implementation of mutual assistance 
 under the Services Directive (2006/123/EC) 

Accompanying document to the 

REPORT FROM THE COMMISSION 

On training and exchanges of officials in charge of the implementation of mutual 
assistance under the Services Directive (2006/123/EC) 

COM(2010)134 

 
 
 
  
 
 
 
TABLE OF CONTENTS 

1. 

INTRODUCTION....................................................................................................... 2 

1.1.  Background........................................................................................................ 2 

1.2.  The aim of this assessment ................................................................................ 3 

2.  THE CURRENT SITUATION ................................................................................... 4 

2.1. 

IMI for the Services Directive – a rapidly growing network ............................ 4 

2.2.  Training for competent authorities and IMI coordinators ................................. 5 

2.3.  Exchanges of officials ....................................................................................... 6 

3.  NEEDS ASSESSMENT.............................................................................................. 6 

3.1.  Gathering information about the needs of users and coordinators.................... 6 

3.2.  Analysis of the results ....................................................................................... 7 

4.  OBJECTIVES ........................................................................................................... 12 

4.1.  Training ........................................................................................................... 12 

4.2.  Support material .............................................................................................. 13 

4.3.  Exchanges of officials ..................................................................................... 13 

4.4.  General considerations .................................................................................... 13 

5.  AVAILABLE POLICY OPTIONS........................................................................... 13 

5.1.  Maintain the status quo.................................................................................... 13 

5.2.  Adapt and extend current approach................................................................. 13 

5.3.  Set up a multi-annual programme ................................................................... 14 

5.4.  Comparison of options .................................................................................... 15 

6.  CONCLUSION ......................................................................................................... 16 

7.  FOLLOW-UP:  ARRANGEMENTS 

FOR  MONITORING  AND 

EVALUATION ......................................................................................................... 16 

ANNEX  I:  RESULTS  OF  SURVEY  AMONGST  ALL  AUTHORITIES 

REGISTERED IN IMI FOR THE SERVICES MODULE....................................... 18 

ANNEX  I:  RESULTS  OF  SURVEY  AMONGST  ALL  AUTHORITIES 

REGISTERED IN IMI FOR THE SERVICES MODULE....................................... 18 

ANNEX  II:  SUMMARY  OF  RESULTS  OF  TRAINING  WORKSHOP  HELD 

ON 17 JUNE 2009 .................................................................................................... 23 

ANNEX III: RESULTS OF SURVEY AMONGST IMI COORDINATORS ................. 25 

 
1. 

INTRODUCTION 

1.1.  Background 

The Services Directive1 seeks to make it easier for both businesses and consumers to take 
full  advantage  of  the  fundamental  freedoms  guaranteed  in  Articles  49  and  56  of  the 
Treaty  on  the  Functioning  of  the  European  Union  (TFEU)2  –  the  freedom  of 
establishment and the freedom to provide services across borders. Its provisions aim to 
simplify  administrative  procedures,  to  remove  obstacles  for  services  activities  and  to 
enhance trust between Member States3 in each others' rules and controls.  

Articles 28 to 36 of the Services Directive oblige Member States to assist each other and 
to  exchange  information  on  service  providers.  The  objective  of  this  day  to  day 
cooperation is to avoid a multiplication of controls and to ensure effective supervision of 
service providers. In practice, this means that competent authorities operating at national, 
regional and local level need to provide information directly to their counterparts in other 
countries and, if necessary, carry out factual checks, inspections and investigations.  

In  order  to  function  properly,  administrative  cooperation  needs  to  be  supported  by 
technical  means  which  enable  direct  and  fast  communication  between  the  competent 
authorities of different Member States. Therefore, Article 34(1) of the Services Directive 
obliges  the  Commission  to  "establish  an  electronic  system  for  the  exchange  of 
information between Member States, taking into account existing information systems".  

The  Internal  Market  Information  System  (IMI)  fulfils  this  function.  This  IT-based 
information  network  was  developed  by  the European  Commission  in  close  cooperation 
with Member States. IMI contains, most notably, (1) a multilingual search function that 
helps  competent  authorities  identify  their  counterpart  in  another  country,  (2)  pre-
translated  questions  and  answers  for  all  cases  in  which  they  are  likely  to  require 
information  from  abroad,  and  (3)  a  tracking  mechanism  that  allows  them  to  follow  the 
progress of their information request and that also allows IMI coordinators at national or 
regional level to intervene in the event of problems.  

IMI  has  been  tested  successfully  for  information  exchanges  in  the  framework  of  the 
Directive on the recognition of professional qualifications4 and is now operational in that 
area.5  

1   Directive  2006/123/EC  of  the  European  Parliament  and  of  the  Council  of  12  December  2006  on 

services in the internal market (OJ L376 of 27.12.2006, p. 36). 

2   Ex Articles 43 and 49 of the EC Treaty. 

3   The term ‘Member States’, in this document, is used to refer to the 27 EU Member States and the three 
EFTA  countries  participating  in  the  European  Economic  Area  (EEA),  i.e.  Norway,  Iceland  and 
Liechtenstein. 

4   Directive  2005/36/EC  of  the  European  Parliament  and  of  the  Council  of  7  September  2005  on  the 

recognition of professional qualifications (OJ L255 of 30.9.2005, p. 22). 

5   See  "Delivering  the  benefits  of  the  single  market  through  enhanced  administrative  cooperation  – 
Progress  Report  on  the  Internal  Market  Information  System",  Commission  Communication  of  6 
November 2008 (COM(2008) 703 final), p. 10.  

2

 
                                                 
Setting  up  IMI  for  the  Services  Directive is a challenging task. By 28 December 2009, 
the  deadline  for  the  implementation  of  the  Directive,  an  operational  network  for 
administrative cooperation that caters for all authorities with responsibilities in any of the 
many areas of application of the Directive had to be in place. To help prepare competent 
authorities for the use of IMI, the Commission and Member States agreed to start using 
the system on a pilot basis throughout 2009. The pilot ran until 28 December 2009.  On 
that date, the IMI services module became operational. 

On  2  October  2009,  the  Commission  formally  decided  that  IMI  shall  be  used  as  the 
electronic system mentioned in Article 34(1) of the Services Directive.6  

1.2.  The aim of this assessment 

The wide scope  of  application of the Services Directive is likely to lead to a large and 
diverse pool of IMI end-users. They all need to understand how IMI works and how it 
can  support  them  in  their  tasks.  Awareness-raising  and  training  activities  are  therefore 
crucial  for  the  correct  implementation  of  the  provisions  on  administrative  cooperation. 
However, organising these activities in a way that reaches every user and addresses his 
or her individual needs is highly complex.  

Article  34(2)  of  the  Services  Directive  calls  on  Member  States  to  take,  with  the 
assistance  of  the  Commission,  "accompanying  measures  to  facilitate  the  exchange  of 
officials  in  charge  of  the  implementation  of  mutual  assistance  and  training  of  such 
officials, including language und computer training".  

Article  34(3)  asks  the  Commission  to  "assess  the  need  to  establish  a  multi-annual 
programme in order to organise relevant exchanges7 of officials and training". 

In a progress report on IMI of 6 November 2008, the Commission reached the conclusion 
that, with regard to administrative cooperation under the Services Directive, "the current 
level  of  investment  in  training  and  awareness  needs  to  be  intensified  in  order  to  bring 
about the desired outcomes". Therefore, it announced that in 2009 it would "carry out an 
ex-ante evaluation to look at different options and to assess whether there is a need to set 
up  a  possible  multi-annual  training  and  exchange  programme  for  the  administrative 
cooperation provisions of the Services Directive"8. 

This  document  accompanies  the  Commission  Report  on  training  and  exchanges  of 
officials  in  charge  of  the  implementation  of  mutual  assistance  under  the  Services 
Directive.  It  assesses  the  need  for  a  multi-annual  programme,  on  the  basis  of  the 
experience gathered between the date of the adoption of the Directive (December 2006) 
and October 2009, in particular from the IMI pilot project for services. It considers the 

6   Commission Decision 2009/739/EC of 2 October 2009 setting out the practical arrangements for the 
exchange of information by electronic means between Member States under Chapter VI of Directive 
2006/123/EC  of  the  European  Parliament  and  of  the  Council  on  services  in  the  internal  market  (OJ 
L263 of 7.10.2009, p. 32). 

7   Other language versions make it clearer than the English that what is meant by "relevant" exchanges 
and  training  is  in  fact  the  exchanges  and  the  training  referred  to  in  paragraph  2  (German:  "(…)  zur 
Organisation  derartiger  Beamtenaustausch-  und  Fortbildungsmaßnahmen";  French:  "(…)  afin 
d'organiser lesdits échanges de fonctionnaires et formations"; emphasis added). 

8   See footnote 4. 

3

 
                                                 
need  for  training  on  the  one  hand  and  the  need  for  exchanges  of  officials  on  the  other 
hand separately.  As regards training,  it distinguishes between training in relation to (1) 
the  general  obligation  of  administrative  cooperation  in  the  framework  of  the  Services 
Directive (content-related training), (2) the use of IMI from a technical point of view and 
(3)  general  "language  and  computer  training"  as  mentioned  in  Article  34(2)  of  the 
Services Directive. 

It should be noted that Article 34(1) of the Services Directive refers to the Commission 
as the main actor, whereas Article 34(2) refers to Member States as the main actors. This 
difference will be reflected in the approach to the analysis:  

– 

– 

As regards Article 34(1), the Commission has met its obligation to set up IMI and 
is  now  responsible  for  ensuring  that  IMI  works  well  from  a  technical  point  of 
view. The assessment will therefore examine how well competent authorities and 
IMI coordinators are able to use IMI and what training is needed to support them 
in this respect; 

As  regards  all  other  aspects,  in  particular  the  exchange  of  officials  and  general 
language and computer training (Article 34(2)), the Commission is asked to assist 
Member  States.  Therefore,  the  assessment  in  these  regards  will  be  based  on  an 
analysis of initiatives and demands on the part of the Member States.  

2. 

THE CURRENT SITUATION 

2.1. 

IMI for the Services Directive – a rapidly growing network 

The  decentralised  structure  of  the  IMI  network  requires  each  participating  country  to 
nominate  a  "national  IMI  coordinator"  (NIMIC)  to  manage  overall  IMI  project 
coordination  in  this  country.  The  NIMIC  is  free  to  decide  how  to  go  about  this,  in 
particular how to ensure that all competent authorities that need to use IMI are registered, 
how to raise awareness and how to provide training and support to end-users. Depending 
on  their  administrative  structures,  many  Member  States  have  decided  to  delegate  all  or 
certain coordinating functions to other levels, to "delegated IMI coordinators" (DIMIC) 
or, in the case of regional coordinators with full IMI responsibility, to "super-delegated 
IMI coordinators" (SDIMIC). Given that IMI now operates in different legislative areas 
(professional  qualifications  and  services),  some  Member  States  have  asked  for  the 
introduction  of  a  coordinator  with  full  responsibility  for  one  legislative  area  at  either 
national or regional level, a "legislative area IMI coordinator" (LIMIC). 

At the time of writing, 2912 competent authorities throughout the EU were registered in 
IMI with access to the services module, compared to 731 for professional qualifications. 
From the second to the third quarter of 2009, the number of authorities registered for the 
services  module  nearly  doubled,  on  the  one  hand  showing  that  Member  States  were 
making good use of the pilot project to put the necessary structures in place, but on the 
other hand  making it impossible to predict how many authorities will be using IMI for 
services at maturity. 

4

 
 
Total number of authorities with access to Services module

3000

2500

2000

1500

1000

500

0

NIMIC

SDIMIC

CA/LIMIC/DIMIC

Q1

30

39

939

Q2

30

43

Q3

30

45

1242

2046

01/10-
22/11/2009

30

45

2912

Moreover,  system  statistics  show  that  most  registered  authorities  have  only  one 
registered user so far, and a significant percentage of these have so far not yet logged in 
to IMI. 

2.2.  Training for competent authorities and IMI coordinators 

Despite the low login rate, in a survey carried out in July and August 2009 amongst all 
authorities  registered  in  IMI,  71%  of  respondents  registered  for  services  indicated  that 
they  had  already  participated  in  an  awareness-raising  and/or  training  event  about  IMI, 
most of them at national level. 

Up  until  now,  the  Commission  has  supported  Member  States  in  their  training  and 
awareness-raising activities in a number of ways, namely by: 

(1) 

(2) 

organising  regular  training  sessions  for  NIMICs  and  other  IMI  coordinators  in 
Brussels, on the basis of a "train the trainers" concept;9 

providing assistance in the organisation of national training and awareness-raising 
events;10 

(3)  making  available  an  IMI  training  system  as  a  tool  to  familiarise  end-users  with 

IMI; 

9   During  the  services  pilot  project,  the  Commission  organised  three one-day sessions for coordinators 

catering for around 60 participants each. 

10   Assistance was provided on request and subject to availability, ranging from advice on developing the 
course  to  Commission  staff  acting  as  trainers.  Priority  was  given  to  Member  States  with  large  user 
groups. During the pilot project, the Commission provided assistance to Germany, Spain, Cyprus and 
Denmark. 

5

 
 
                                                 
(4) 

producing  a  range  of  training  materials,  including  a  comprehensive  user 
handbook, a handbook on IMI and the Services Directive, interactive eLearning 
modules  explaining  important  specific  IMI  functions  and  standard  Powerpoint 
presentations;11 

(5) 

distributing promotional material such as an IMI brochure and small promotional 
items;  

(6)  maintaining and developing a multilingual website; and 

(7) 

providing ongoing assistance to IMI coordinators through a central IMI helpdesk. 

Also,  to  mark  the  launch  of  the  pilot  project  for  IMI  and  the  Services  Directive,  the 
Commission  held  a  large-scale  conference  in  Brussels  on  25  February  2009,  bringing 
together  nearly  400  representatives  of  national, regional and local administrations from 
throughout the EU. 

At  Member  State  level,  training  and  awareness-raising  efforts  differ  enormously. 
Whereas  some  Member  States  systematically  organise  training  on  a  large  scale,  some 
others have organised hardly any training so far.12  

2.3.  Exchanges of officials 

No formalised exchanges of officials in charge of administrative cooperation have taken 
place so far.  

However,  the  regular  training  events  for  NIMICs  and  other  IMI  coordinators  that  the 
Commission organises in Brussels provide a forum for participants to share experiences 
and good practices. The Commission has encouraged this by setting time aside for group 
discussions on points that are of interest to all. 

3. 

NEEDS ASSESSMENT 

3.1.  Gathering information about the needs of users and coordinators 

The  data  that  underpins  this  assessment  has  been  drawn  from  a  number  of  different 
sources, in order to allow for cross-checks of the reliability and validity of the data. 

3.1.1.  Ongoing data collection in IMI and through trainer feedback forms 

Authorities  that  have  participated  in  an  information  exchange  in  IMI  are  automatically 
sent an electronic feedback form, in which they can report their experiences of using the 

11   All  of  these  materials  are  available  in  the  section  "Training  on  IMI"  of  the  IMI  website  at 

http://ec.europa.eu/internal_market/imi-net. 

12   Member States are under no obligation to inform the Commission about their activities in this respect. 
On a voluntary basis, the Commission was informed about a total of 93 training and awareness raising 
events between March and October 2009, 37 out of which were organised in Germany. 

6

 
                                                 
system. This form includes questions about the usability of IMI. At the time of writing, 
106 users had given their feedback after using IMI for services.13 

The Commission has also made a feedback form (in Word format) available to Member 
States,  with  which  trainers  at  national  or  regional  events  can  communicate  their 
experiences to the Commission. 22 trainers have made use of this opportunity so far. 

3.1.2.  Survey amongst all authorities registered in IMI 

Between  6  July  and  21  August  2009,  all  authorities  registered  in  IMI  were  invited  to 
participate in an electronic survey about their training needs in relation to using IMI ("the 
authority  survey"14).  378  replies  from  authorities  registered  for  services  were  received 
(out of about 900 registered in that period), making for a very good return rate that can 
be  interpreted  as  a  sign  of  considerable  interest  in  the  questions  asked  on  the  part  of 
competent authorities. 

3.1.3.  Detailed feedback from IMI coordinators 

On  17  June  2009,  during  one  of  the  regular  training  sessions  organised  by  the 
Commission  in  Brussels,  IMI  coordinators  took  part  in  a  workshop  with  group 
discussions about their experience with training so far and their needs for the future ("the 
training workshop"15). 47 coordinators participated in this training session. 

Coordinators  were  then  also  given  the  opportunity  to  comment  in  more  detail  on  these 
issues  in  a  paper-based  survey  that  ran  from  10  July  to  15  September  2009  ("the 
coordinator survey"16). Replies were received from 51 coordinators from 26 countries. 

3.1.4.  Exchanges of officials organised by the Commission in other policy areas 

Given that there have so far not been any formalised exchanges of officials in charge of 
implementing administrative cooperation under the Services Directive, information was 
gathered  on  exchange  programmes  organised  and/or  financed  by  the  Commission  in 
other policy areas. 

Informal  meetings  were  organised  with  Commission  officials  from  the  Directorates-
General concerned in order to learn from their experiences with such programmes. 

3.2.  Analysis of the results 

On the basis of all the information gathered, eight main conclusions can be drawn. 

3.2.1.  IMI is user-friendly, but training remains necessary. 

13   During the pilot project, competent authorities can exchange information about either fictional or real 
cases falling within the scope of the Services Directive. 97% of exchanges concerned fictional cases.  

14   For an overview of all results of this survey, see Annex I. 

15   For a summary of the results of the group discussions, see Annex II. 

16   A synthesis of the results is shown in Annex III. 

7

 
                                                 
A  large  majority  of  users  of  the  IMI  services  module  who  responded  to  the  authority 
survey  find  IMI  easy  to  use.17  Similarly  positive  reactions  were  registered  for  the 
statements "I was able to carry out all the tasks that I had to complete in IMI without any 
problems"  and  "The  legal  obligations  under  the  Directive  are  easy  to  put  into  practice 
using IMI". This encouraging result is confirmed by feedback received from participants 
in training courses18 and from users who participated in an information exchange through 
IMI: 52% of the latter found IMI very intuitive and easy to use, 42% found it quite easy 
to use, but would consider some training and guidance useful. Only 6% did not find IMI 
easy to use.  

When  asked  directly  which  type  of  training,  if  any,  was  essential  for  successful 
administrative  cooperation,  only  6%  of  respondents  to  the  authority  survey  replied  that 
no training at all was necessary. 

3.2.2.  Training  in  legal  and  practical  implications  of  the  Services  Directive  is  more 
challenging than training in how to use IMI from a technical point of view. 

The  three  areas  in  which  respondents  to  the  authority  survey  consider  that  training  is 
most essential for successful administrative cooperation are: understanding the practical 
implications  of  the  Directive  (75%),  understanding  the  legal  obligations  under  the 
Directive (70%) and how to use IMI from a technical point of view (67%).19  

This  is  mirrored  in  the  replies  from  coordinators  who  were  asked  where  they  see  the 
main  challenges  for  competent  authorities  in  using  IMI  for  services.  Most  frequently 
named  as  the  biggest  challenges  were:  dealing  with  differences  in  rules  and 
administrative  structures  in  other  countries,  understanding  the  legal  changes  introduced 
by  the  Services  Directive  and  understanding  the  practical  implications  of  the  Services 
Directive for their work.20 

The  coordinators  who  participated  in  the  training  workshop  concluded  that  there  is  a 
need  for  training  both  at  a  technical  and  at  a  content  level.  However,  in  their  opinion, 
technical training is mainly needed when users first join the system in order to overcome 
reluctance  to  use  a  new  computer  system.  In  the  view  of  a  number  of  participants, 
content  is  much  more  of  an  issue  for  training,  as  competent  authorities  often  lack 
information about the expected impact of the Services Directive on their work. 

3.2.3.  General language and computer training is offered as part of on-the-job training 

and is not essential for administrative cooperation. 

17   27%  completely  agree  with  the  statement  "IMI  is  easy  to  use",  48%  agree  somewhat,  9%  disagree 

somewhat and 2% disagree completely. 

18   Feedback given personally to Commission representatives where they were present at training sessions 
in  the  Member  States  and  feedback  given  to  the  trainers  who  filled  in  the  trainer  feedback  form 
provided  by  the  Commission.  19  out  of  22  trainers  reported  that  their  trainees  either  completely  or 
somewhat agreed with the statement: "IMI is easy to use." 

19   The question allowed for multiple replies. 45% of respondents found training in how to respect data 
protection  rules  when  using  IMI  essential,  18%  found  language  training  essential  and  9%  general 
computer training. 

20   Coordinators were asked to rank a number of possible challenges on a scale from 1 to 10.  The three 

fields mentioned here were included in the "top 3" by 27, 24 and 24 coordinators respectively.  

8

 
                                                 
Relatively  few  respondents  to  the  authority  survey  feel  that  language  training  and/or 
general  computer  training  are  essential  for  successful  administrative  cooperation  (18% 
language training, 9% general computer training).  

According  to  information  provided  by  IMI  coordinators,  such  general  language  and 
computer  training  is  in  many  Member  States  part  of  the  on-the-job  training  to  which 
officials either have access on a regular basis or if and when they need to address specific 
job-related requirements. However, a relatively large minority of coordinators (20 out of 
51)  feel  that  there  is  a  need  for  more  computer  and  language  courses  for  officials  in 
charge of implementing mutual assistance in their country. 

3.2.4.  Users like to be trained locally. 

In the authority survey, IMI users were asked to name the three most appropriate forms 
of  learning  about  administrative  cooperation  and  IMI.  Four  possible  replies  received 
about the same amount of assent: Short informal sessions with an experienced colleague 
in  the  respondent's  own  authority  (51%),  self-learning  with  support  material  (50%), 
training  at  regional  level  (47%)  and  training  at  national  level  (46%).  Only  20%  of 
respondents feel that centralised training at EU level is one of the most appropriate forms 
of learning. 

Respondents to the coordinator survey gave similar replies, except that only nine out of 
51  coordinators  felt  that  training  sessions  organised  locally  would  be  appropriate.  This 
may be explained by the fact that, at the moment, many competent authorities are new to 
the  system,  which  means  that  there  is  often  no  experienced  colleague  able  to  hold  an 
informal training session, and it is of course unrealistic for IMI coordinators especially in 
large Member States to provide individual training locally. However, participants of the 
training workshop confirmed that small events are preferable to larger ones as they result 
in more interaction with the participants and less stress for the trainer. 

More  coordinators  than  users  also  find  awareness-raising  events  and  training  sessions 
organised centrally by the Commission appropriate. Participants of the training workshop 
pointed  out  that  the  large-scale  conference  organised  by  the  Commission  in  February 
2009  convinced  many  representatives  of  competent  authorities  of  the  importance  and 
usefulness of IMI and created considerable momentum in implementing it at home. 

3.2.5.  The availability of trainers with the right skills is more of a concern than training 

costs. 

The number of persons who are involved in organising training on IMI and the Services 
Directive  varies  widely  between  Member  States.21  Additionally,  in  many  cases  only  a 
very  small  amount  of  their  total  working  time  is  allocated  to  this  task.  This  is  a  big 
concern  to  a  number  of  coordinators.  Nine  out  of  51  respondents  to  the  coordinator 
survey think that they need a lot more human resources; 10 think they need a little more. 

As regards training costs, most coordinators who replied to the survey stated that they do 
not have any funding for training on IMI and the Services Directive. 20 coordinators out 
of  51  feel  that  they  need  additional  funding.  However,  according  to  the  participants  of 

21   The average number of persons is three, whereby the numbers ranged from 0 to 20. 

9

 
                                                 
the training workshop, training costs are actually not a big issue in most Member States 
as trainers can use their own resources and participants can cover their own costs.  

For some coordinators, insufficient human resources also mean that there is insufficient 
expertise in how to organise and conduct training sessions. A number of respondents to 
the coordinator survey indicated that it is difficult for them to decide whom to invite to 
training  sessions.  Others  struggled  with  convincing  reluctant  competent  authorities  to 
attend or with handling widely varying levels of prior knowledge. Several coordinators 
stated that they did not have any experience or skills in training. 

Lack of support from the hierarchy was also frequently mentioned as a big difficulty in 
raising awareness and organising training. 

3.2.6.  The support material produced by the Commission is much appreciated, but not 

known well enough. 

Among  those  respondents  to  the  authority  survey  who  have  used  training  and  support 
material produced by the Commission, all of these materials receive very good marks for 
usefulness. Of those who have used the IMI user handbook (containing a comprehensive 
description  of  all  IMI  functions),  92%  find  it  either  very  useful  or  quite  useful.  89% 
consider  the  IMI  website  to  be  useful.  The  eLearning  modules  about  individual  IMI 
functions are seen as useful by 86%. 92% of respondents who have already used the new 
guide to IMI and the Services Directive find it either very or quite useful. 

However,  it  is  disappointing  to  see  that  a  large  number  of  respondents,  most  of  whom 
have already participated in a training or awareness-raising event, have never used these 
materials. Whereas it is understandable that 30% of respondents have never used the new 
guide to IMI and the Services Directive, it is difficult to see why 23% have never used 
the user handbook. Given that both users and coordinators emphasised that self-learning 
is  an  appropriate  form  of  learning  about  administrative  cooperation  and  IMI,  it  is  also 
disappointing to see that 60% of users have never used the eLearning modules that were 
produced by the Commission exactly for the purpose of self-learning. 

It is somewhat surprising that even a significant number of coordinators state that they 
never  or  only  rarely  use  the  eLearning  modules for training purposes, whereas  most of 
them use the user handbook and the Commission's website very often. 

Opinions  about  the  IMI  training  system  that  allows  trainers  to  simulate  information 
exchanges and set exercises in a safe environment differ among coordinators. Some use it 
very  often  and  find  it  very  useful.  Others  do  not  use  it  at  all,  frequent  reasons  being, 
according  to  coordinators  who  participated  in  the  training  workshop,  the  lack  of 
meaningful data in the training system and the fact that it is time-consuming to prepare 
exercises in it. 

3.2.7.  The  main  responsibility  for  training  now  lies  with  Member  States,  but  the 

Commission should play a role as well. 

Amongst the participants of the training workshop, a broad consensus emerged that the 
Commission  had  already  provided  a  lot  of  valuable  assistance  and  that,  with  the 
implementation  date  of  the  Services  Directive  approaching  rapidly,  it  was  now  the 
coordinators' turn to take action in their Member States. When asked how they intend to 
address the main challenges for competent authorities (see point 3.2.2), a large majority 
of  respondents  to  the  coordinator  survey  stated  that  they  plan  to  organise  training  and 

10

 
information events that will focus on the most challenging points. A number of them also 
plan to send regular newsletters and/or to provide individual assistance, by setting up a 
helpdesk or creating a web-based forum for IMI users.  

Some coordinators feel that it will be most useful to train competent authorities only as 
of 2010, once they are legally obliged to cooperate. However, concern was expressed by 
some  as  to  whether  they  would  be  provided  with  appropriate  human  and  financial 
resources after the implementation has been finalised. 

Whilst  coordinators  accept  their  responsibility  in  raising  awareness  and  training  IMI 
users in their countries, a majority of them (29 out of 51 coordinators) see a role for the 
Commission in the areas they identified as the most challenging. The main requests that 
were made in this respect were the following: 

(1)  More and faster translations of all material; 

(2) 

(3) 

(4) 

(5) 

(6) 

Improve  the  IMI  system  itself  (decrease  system  response  time,  enhance  search 
function for identifying competent authorities in other Member States); 

Produce  some  shorter  and  targeted  support  material  (e.g.  Frequently  Asked 
Questions on the IMI website); 

Give a clearer overview of available material; 

Collect "success stories" from users who had good experiences using IMI; 

Raise awareness with media/the general public. 

3.2.8.  Exchanges of officials could add significant value. 

A  majority  of  respondents  to  the  authority  survey  think  that  it  would  add  significant 
value  to  meet  officials  from  other  countries  who  work  with  IMI  in  order  to  exchange 
experiences  (64%).  A  majority  of  these  consider  that  such  meetings  should  best  be 
organised  in  the  form  of  regional  training  events  with  participants  from  different 
countries  (52%).  Many  also  supported  the  idea  of  smaller  scale  conferences  for 
geographical  regions  (46%)  and  short-term  visits  in  authorities  in  different  countries 
(45% - multiple replies allowed). 

On the coordinators' side, there are concrete plans to organise exchanges of officials in 
two  Member  States.  Coordinators  from  three  further  countries  stated  that  they  might 
organise exchanges in the future. However, obtaining sufficient funding and overcoming 
language barriers are seen as problematic in this context. One coordinator stated that they 
would organise exchanges only if they were supported by the Commission.  

During  the  training  workshop,  the  idea  of  organising  exchanges  and/or  cross-border 
events  met  with  a  positive  reaction.  However,  some  participants  expressed  the  feeling 
that it was premature to consider such activities. 

Experience from exchange programmes organised and/or financed by the Commission in 
other  policy  areas  appears  to  have  been  positive  throughout.  According  to  officials 
involved in the running of such programmes, the programme set-up requires a significant 
investment  both  in  financial  terms  and  in  terms  of  staff  time.  However,  once  the 
programme  is  established,  it  can  generally  run  at  a  relatively  small  scale  with  low 

11

 
maintenance  costs.  According  to  the  officials,  feedback  from  participants  was 
consistently positive, with many of them reporting to the Commission that the exchange 
had  helped  them  come  up  with  good  ideas  to  implement  in  their  own  country.  Some 
drawbacks  included  the  fact  that,  due  to  language  barriers,  many  participants  chose  to 
visit neighbouring countries with which their Member State communicates well anyway, 
and that, for prestige reasons, high-ranking officials took part who would not be involved 
in  the  practical  application  of  what  they  learned  abroad.  A  recurring  recommendation 
therefore  was  to  define  the  purpose  and  target  group  of  the  exchanges  very  precisely 
before starting a programme. 

4. 

OBJECTIVES 

The  objectives  to  be  achieved  need  to  be  defined  in  the  context  of  higher-ranking 
objectives that all derive from the Services Directive. The broadest objective, that of the 
Services  Directive  itself,  is  to  make  it  easier  for  businesses  and  consumers  to  take  full 
advantage of the freedom of establishment and of the freedom to provide services across 
borders.  Then,  the  objective  of  the  provisions  on  administrative  cooperation  within  the 
Services  Directive  is  to  avoid  a  multiplication  of  controls  and  to  ensure  effective 
supervision  of  service  providers.  The  objective  of  IMI  is  to  provide  an  efficient  and 
secure technical tool that supports administrative cooperation. This leaves the objective 
of the measures  to be taken on the  basis of this assessment, which should be to ensure 
that the users of IMI have the necessary knowledge and skills to be able to use the system 
effectively. 

The needs assessment has shown that, in order to achieve this last objective, (1) training 
is  necessary,  (2)  appropriate  support  material  is  useful  and  (3)  exchanges  of  officials 
could  be  useful.  In  relation  to  all  three  of  these  means,  further  objectives  can  be 
identified. 

4.1.  Training 

One  objective  should  be  to  organise  training  close  to  the  user,  where  this  is  possible. 
However,  large  scale  events  at  European  level  are  seen  as  helpful  as  well  and  could 
therefore  be  organised  in  parallel  to  local  training.  For  all  training  activity,  the 
Commission's  aim  should  be  to  ensure  that  training  is  provided  as  consistently  as 
possible throughout the EU.  

In  the  provision  of  training,  IMI  coordinators  play  a  crucial  role.  Therefore,  one 
important objective for the Commission should be to support coordinators in a way that 
ensures that they can in turn train users more effectively. In the context of this support, it 
appears to be more important to address staff shortages than any financial concerns. 

In  terms  of  the  content  of  the  training,  the  needs  assessment  has  shown  that  users  and 
coordinators consider the main training needs to be, apart from technical training to help 
them get started in IMI, understanding the legal and practical implications of the Services 
Directive  on  the  users'  daily  work.  However,  one  has  to  bear  in  mind  that  the  surveys 
amongst users and coordinators were carried out at a time when, in many Member States, 
national legislation to implement the Services Directive had not yet been adopted and/or 
training on legal issues had not yet been provided. Therefore, it is not unlikely that the 
needs  in  terms  of  the  content  of  training  will  change  over  time.  It  would  thus  appear 
premature to define objectives concerning the content of training at this stage.  

12

 
4.2. 

Support material 

One clear objective in the provision of support material should be that it is adapted to the 
needs  of  users  and  trainers.  As  far  as  can  be  seen  from  the  needs  assessment,  this  is 
already  the  case  to  a  large  extent.  A  more  pressing  objective  is  therefore  to  make  the 
available  material  better  known  and  more  used.  This  is  true  in  particular  for  the  self-
learning material. 

4.3.  Exchanges of officials 

IMI  users  consider  that  it  could  add  significant  value  to  meet  officials  from  other 
countries  who  work  with  IMI  in  order  to  exchange  experience.  Therefore,  another 
objective to be achieved should be to promote and support exchanges of officials. 

4.4.  General considerations 

Any measures that are adopted have to be cost-effective and proportionate to the needs 
identified.  Their  impact  on  the  workload  of  Commission  staff  needs  to  be  taken  into 
account as well. 

5. 

AVAILABLE POLICY OPTIONS 

5.1.  Maintain the status quo 

The policy option that would be easiest to implement for the Commission is, naturally, to 
continue providing assistance to Member States in exactly the same way as to date. The 
Commission  has  gathered  considerable  experience  in  these  activities  which,  as  all 
information sources indicate, meet with high levels of satisfaction. Choosing to continue 
working in this way would imply no additional costs or impact on staff. 

On  the  other  hand,  coordinators  would  continue to face the difficulties with organising 
training  and  raising  awareness  in  their  country  that  are  described  in  point  3.2.5.  They 
would have to find solutions for staff shortage and, in some countries, financial concerns 
at national level. There would also be no European framework for those Member States 
that are going to, or would like to, organise exchanges of officials. 

5.2.  Adapt and extend current approach 

A second option could be to develop the Commission's current approach to training and 
awareness-raising  by  adapting  it  to  emerging  needs  or  preferences  communicated  by 
Member States. For example, even with the financial and staff resources currently at the 
Commission's  disposal,  it  would  be  possible  to  support  Member  States  that  decide  to 
organise  a  conference  with  participants  from  several  countries,  by  providing  advice  in 
organisational  matters,  by  helping  in  the  production  of  conference  material  and/or  by 
sending speakers.  

If  some  Member  States  would  like  to  organise  exchanges,  the  Commission  could 
establish  contacts  between  them  and  help  in  pairing  up  interested  candidates.  On  the 
basis  of  the  information  gathered  about  existing  European  exchange  programmes,  the 
Commission could also give advice on the organisational set-up of exchanges.  

13

 
In terms of training, the Commission could offer targeted training events according to the 
needs identified by Member States, for example for individual service sectors or specific 
IMI functions.  

As  regards  support  material,  the  Commission  could  further  develop  and  adapt  the 
available material, for example by making it accessible in a user-friendly form through 
the IMI system itself.  

Based on the wishes voiced by some coordinators, the Commission could also assign a 
higher priority to the issues that were raised, such as translation of material (within the 
limits of the Commission's restricted resources) and system development. 

However, any such requests would have to remain within the allocated resources.  

5.3. 

Set up a multi-annual programme 

Running  a  multi-annual  programme  would  allow  for  a  sharp  increase  in  the  scale  of 
training  and  awareness-raising  activities.  There  are  various  ways  of  setting  up  such  a 
programme. They could include, to name only a few examples, systematic training in all 
Member  States  provided  by  external  specialists,  professional  assistance  in  organising 
cross-border  conferences  and/or  a  centralised  system  to  plan  and  run  exchanges  of 
officials.  

It is clear that such a programme would make it possible to reach many more IMI users 
much more effectively than at present. It could help to ensure that all users receive the 
same  standard  of  training  and  it  could  professionalise  awareness-raising  activities. 
Additionally,  it  could  contribute  to  solving  the  staff  and  financial  concerns  that  some 
coordinators are facing and would relieve them from some tasks for which they have not 
been trained. Moreover, the mere existence of such a programme would be likely to raise 
awareness also within the officials' hierarchies, which could undoubtedly have a positive 
impact on the overall implementation of administrative cooperation.  

Since users and coordinators consider that the main training needs, apart from technical 
training to get started in IMI, lie in understanding the legal and practical implications of 
the  Services  Directive,  a  possible  programme  could  be  devised  accordingly.  General 
computer  and  language  training,  which  are  generally  not  perceived  as  essential  for 
administrative cooperation, would not need to be comprised in a programme. However, 
as explained under point 4.1, the needs in terms of the content of the training may well 
change over time. 

The costs of a multi-annual programme to the EU budget would depend very largely on 
the scope and ambition of such a programme.  Whereas, for example, exchanges between 
officials in border regions could be organised at relatively low cost, the organisation of 
systematic  training  by  external  specialists  throughout  the  EU  would  require  substantial 
financial  resources.  Similarly,  the  impact  on  the  Commission's  human  resources  would 
depend on the chosen programme content and on how much of its organisation could be 
delegated to external partners. 

However, the information received from coordinators raises the question whether now is 
the  appropriate  moment  for  setting  up  a  programme.  Many  coordinators  are  only  just 
starting  to  organise  training  and  awareness-raising  activities  in  their  Member  States. 
They stated that the Commission had already provided substantial assistance and that it 
was  now  up  to  them  to  make  use  of  it.  Moreover,  all  of  the  requests  that  have  been 
14

 
voiced  by  coordinators  for  additional  action  on  the  part  of  the  Commission  are  of  a 
relatively small-scale and practical nature. None of the actions that were called for would 
require a fully-fledged programme.  

5.4.  Comparison of options 

The findings of the preceding analysis are presented in the table below, the criteria being 
defined as follows: 

•  Effectiveness = degree to which the objectives are met 

•  Costs = necessary input in terms of financial and human resources 

•  Time = time needed for implementation 

Effectivenes
s 

Costs 

Time 

Low (+ to +++) 
High (- to ---) 

Short (+++) 
Medium (+/-) 
Long (---) 

High (+++) 
Medium (+/-) 
Low (---) 

Overall assessment 
(Proportionality) 

Positive (+ to +++) 
Negative (- to ---) 

+/- 

+/- 

+/- 

+/- 

+ 

- 

+/- 

+++ 

--- 

-- 

+ 

-- 

Option 1: 
Status quo 

Option 2: 
Adapt 
and 
extend current 
approach 

Option 3: 
Multi-annual 
programme 

In this table, the status quo (continuing to provide assistance to Member States exactly 
like  up  to  date)  is  set  as  a  base  line,  with  all  criteria  being  fulfilled  to  an  intermediate 
degree. 

Adapting and extending the Commission's current approach could be more effective than 
the  status  quo  in  meeting  the  needs  identified.  It  can  be  implemented  quickly  and 
relatively easily. It would naturally not be as effective as a multi-annual programme in 
reaching large numbers of new and existing IMI users in a consistent manner throughout 
the EU and it would not solve some of the coordinators' problems described under point 
3.2.5. However, it would allow for a high level of flexibility in respect of the needs that 
are  starting  to  develop  in  the  Member  States,  whilst  not  precluding  the  adoption  of  a 
more resource intensive solution at a later stage. 

In comparison with this base-line situation, a multi-annual programme would score much 
more  highly  in  effectiveness,  i.e.  it  would  fulfil  the  objective  of  ensuring  that  all  IMI 

15

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
users  have  the  necessary  knowledge  and  skills  to  use  IMI  better,  albeit  only  once  he 
medium-  and  long-term  needs  in  respect  of  the  content  of  the  training  can  be  assessed 
reliably. On the other hand, a multi-annual programme would be significantly more cost-
intensive. The real impact in terms of financial and human resources cannot be quantified 
exactly  as  it  depends  to  a  large  extent  on  the  measures  that  would  make  up  such  a 
programme.  Setting  up  a  multi-annual  programme  would  in  any  event  require  a  lot  of 
preparation  time  and  would  be  relatively  complex  to  implement.  On  the  basis  of  the 
feedback received from users and coordinators, it appears that a multi-annual programme 
would not be proportionate to the needs identified at this stage. 

6. 

CONCLUSION 

The  overall  results  of  the  assessment  suggest  that  there  is  currently  no  need  to  adopt  a 
multi-annual  programme  for  training  and  exchanges  of  officials.  Such  a  programme 
would be premature, at a point in time when cooperation under the Services Directive has 
only just become mandatory and operational. The Commission and coordinators need to 
gain more experience in order to be able to identify the medium- and long-term needs for 
training and, potentially, exchanges of officials. 

In the meantime, the Commission will continue its current efforts in supporting Member 
States  in  raising  awareness  for  administrative  cooperation  and  in  training  IMI  users, 
which have been very successful so far. However, it proposes to adapt and extend them 
in a flexible manner as and when it receives corresponding requests from Member States 
(option  2).    On  the  part  of  the  Member  States,  and  in  particular  IMI  coordinators,  this 
requires  that  they  take  seriously  their  crucial  role  in  raising  awareness  and  in  training 
officials,  by  making  use  of  the  Commission's  support  and  by  allocating  sufficient 
financial and human resources to these tasks. 

The  Commission  will  continue  to  monitor  developments  in  the  Member  States  closely 
and  will  re-assess  the  necessity  to  adopt  a  multi-annual  programme  on  the  basis  of  the 
experience that will be gathered during the first year of mandatory use of the IMI module 
for services. 

7. 

FOLLOW-UP: ARRANGEMENTS FOR MONITORING AND EVALUATION 

Developments in the Member States will be monitored through a number of mechanisms: 

(1) 

(2) 

(3) 

Ongoing feedback from users who have participated in an information exchange 
through  IMI,  by  way  of  an  electronic  survey  about  IMI  usability  and  potential 
difficulties encountered; 

Feedback from trainers through trainer feedback form; 

Feedback  from  IMI  coordinators  during  regular  training  sessions  in  Brussels, 
during  meetings  of  the  IMI  experts'  working  group  and  through  direct  contact 
with the IMI helpdesk. 

The Commission will report on the situation in the IMI Annual Report for 2010 (which is 
planned to be published in February 2011) in the light of the following two factors: 

16

 
– 

– 

the growth of IMI for services in terms of the number of registered authorities and 
users (growth rates are currently impossible to predict, see point 2.1); 

the  frequency  with  which  IMI  is  used  following  the  implementation  of  the 
Services  Directive  in  the  Member  States,  measured  e.g.  in  the  number  of 
information exchanges. 

On this basis the Commission and IMI coordinators will be in a position to evaluate the 
real  need  and  demand  for  training  and  exchanges  of  officials.  The  Commission  will 
transmit necessary statistical information to Member States on a regular basis, in order to 
allow them to provide their input for the annual report. 

17

 
 
ANNEX  I:  RESULTS  OF  SURVEY  AMONGST  ALL  AUTHORITIES  REGISTERED  IN  IMI  FOR 
THE SERVICES MODULE 

ABOUT YOU AND YOUR AUTHORITY 

Please provide us with some information about your authority. 

Country 

Czech Republic 
Netherlands 
Spain 
Germany 
Hungary 
Austria 
Greece 
Poland 
United Kingdom 
Sweden 
France 
Italy 
Bulgaria 
Cyprus 
Romania 
Estonia 
Lithuania 
Malta 
Ireland 
Slovakia 
Slovenia 
Belgium 
Denmark 
Latvia 
Portugal 
Finland 
Iceland 
Luxembourg 
Liechtenstein 
Norway 

 Level (geographical coverage) 

National 
Local 
Regional 

What is your authority's role in IMI? 

Competent Authority 
Delegated IMI coordinator (DIMIC) 

18

Number of 
responses 

Number of 
responses 

Number of 
responses 

71 
61 
52 
35 
24 
19 
12 
11 
11 
8 
7 
7 
6 
6 
6 
5 
5 
5 
4 
4 
4 
3 
3 
3 
3 
1 
1 
1 
0 
0 

176 
104 
98 

238 
54 

% 

     (18.8%)      
     (16.1%)      
     (13.8%)      
     (9.3%)      
     (6.3%)      
     (5%)      
     (3.2%)      
     (2.9%)      
     (2.9%)      
     (2.1%)      
     (1.9%)      
     (1.9%)      
     (1.6%)      
     (1.6%)      
     (1.6%)      
     (1.3%)      
     (1.3%)      
     (1.3%)      
     (1.1%)      
     (1.1%)      
     (1.1%)      
     (0.8%)      
     (0.8%)      
     (0.8%)      
     (0.8%)      
     (0.3%)      
     (0.3%)      
     (0.3%)      
       (0%) 
       (0%) 

% 

     (46.6%)      
     (27.5%)      
     (25.9%)      

% 

     (63%)      
     (14.3%)      

 
 
 
 
  
 
  
  
  
  
  
Don't know 
National IMI coordinator (NIMIC) 
Super-delegated IMI coordinator (SDIMIC) 

ABOUT USING IMI 

Have you logged in to IMI so far? 

Yes 
No 

40 
26 
20 

323 
55 

Number of 
responses 

[If yes] In which way have you used IMI? (multiple replies allowed)  
Number of 
responses 

I have carried out administrative work in IMI (such as: 
update your authority's data, register new user, reset 
passwords). 

I have logged in and looked at the system, but never 
actively used it. 

I have used IMI to exchange information with an 
authority in another Member State. 

(only for coordinators) I have worked on the set-up 
and/or management of authorities I coordinate in IMI 
(such as: register new authorities, follow your 
authorities' information exchanges, intervene in case 
of problems). 

173 

125 

119 

63 

Please describe the impressions you had when you used IMI.  

     (10.6%)      
     (6.9%)      
     (5.3%)      

% 

     (85.4%)      
     (14.6%)      

% 

     (53.6%)      

     (38.7%)      

     (36.8%)      

     (19.5%)      

IMI is easy to use. 

Agree somewhat 
Agree completely 
Disagree somewhat 
Disagree completely 

Number of 
responses 

181 
100 
35 
7 

% 

     (56%)      
     (31%)      
     (10.8%)      
     (2.2%)      

I was able to carry out all the tasks that I had to complete in IMI without any problems.  

Agree somewhat 
Agree completely 
Disagree somewhat 
Disagree completely 

Number of 
responses 

158 
96 
62 
7 

% 

     (48.9%)      
     (29.7%)      
     (19.2%)      
     (2.2%)      

The legal obligations under the Directive(s) are easy to put in practice using IMI. 

Agree somewhat 
Disagree somewhat 
Agree completely 
Disagree completely 

Number of 
responses 

193 
66 
56 
8 

% 

     (59.8%)      
     (20.4%)      
     (17.3%)      
     (2.5%)      

If I have a question or a problem with the Directive(s) and/or using IMI, I know whom to 

19

 
 
 
 
 
  
 
  
 
 
  
 
  
 
  
  
contact for advice. 

Agree completely 
Agree somewhat 
Disagree somewhat 
Disagree completely 

ABOUT TRAINING ON IMI 

Number of 
responses 

188 
100 
29 
6 

% 

     (58.2%)      
     (31%)      
     (9%)      
     (1.9%)      

The Commission and Member States have already organised a number of training and 
awareness raising events. Have you taken part in any of these events? 

Yes 
No 

Number of 
responses 

267 
111 

% 

     (70.6%)      
     (29.4%)      

[If yes] Please specify in which of these events you have taken part.  

General awareness raising event (multiple replies allowed)   

National level 
EU level 
None 
Regional level 
Local level 

Training event (multiple replies allowed) 

National level 
EU level 
None 
Regional level 
Local level 

Exchange of officials (multiple replies allowed) 

None 
National level 
Regional level 
EU level 
Local level 

Number of 
responses 

Number of 
responses 

Number of 
responses 

119 
72 
54 
43 
21 

163 
50 
33 
28 
23 

236 
16 
12 
5 
3 

% 

     (44.6%)      
     (27%)      
     (20.2%)      
     (16.1%)      
     (7.9%)      

% 

     (61%)      
     (18.7%)      
     (12.4%)      
     (10.5%)      
     (8.6%)      

% 

     (88.4%)      
     (6%)      
     (4.5%)      
     (1.9%)      
     (1.1%)      

The Commission and Member States have developed a range of support material for IMI 
users (see the IMI website at ec.europa.eu/internal_market/imi-net). Please rate the 
usefulness of those items that you have used. 

IMI User Handbook 

Quite useful 
Very useful 

Number of 
responses 

% 

     (38.9%)      
     (32.8%)      

147 
124 

20

 
  
 
 
  
 
 
  
  
  
 
  
 
 
  
Never used 
Not so useful 
Not useful at all 

User Guide to IMI and the Services Directive 

Quite useful 
Never used 
Very useful 
Not so useful 
Not useful at all 

European Commission website 

Quite useful 
Never used 
Very useful 
Not so useful 
Not useful at all 

eLearning modules ("Captivate") 

Never used 
Quite useful 
Very useful 
Not so useful 
Not useful at all 

Powerpoint presentations 

Never used 
Quite useful 
Very useful 
Not so useful 
Not useful at all 

National material 

Never used 
Quite useful 
Very useful 
Not so useful 
Not useful at all 

85 
17 
5 

153 
114 
91 
15 
5 

146 
133 
70 
28 
1 

224 
79 
54 
21 
0 

175 
129 
50 
24 
0 

170 
130 
63 
10 
5 

Number of 
responses 

Number of 
responses 

Number of 
responses 

Number of 
responses 

Number of 
responses 

     (22.5%)      
     (4.5%)      
     (1.3%)      

% 

     (40.5%)      
     (30.2%)      
     (24.1%)      
     (4%)      
     (1.3%)      

% 

     (38.6%)      
     (35.2%)      
     (18.5%)      
     (7.4%)      
     (0.3%)      

% 

     (59.3%)      
     (20.9%)      
     (14.3%)      
     (5.6%)      
       (0%) 

% 

     (46.3%)      
     (34.1%)      
     (13.2%)      
     (6.3%)      
       (0%) 

% 

     (45%)      
     (34.4%)      
     (16.7%)      
     (2.6%)      
     (1.3%)      

In your opinion, which of the following types of training, if any, are essential for successful 
administrative cooperation? (multiple replies allowed)  

Number of 
responses 

% 

21

 
 
  
 
  
 
  
 
  
 
  
 
  
Understanding the practical implications of the 
Directive(s) 

Understanding the legal obligations under the 
Directive(s) 

How to use IMI from a technical point of view 
How to respect data protection rules when using IMI 
Language training 
General computer training 
No training is necessary 
Other 

282 

264 

254 
171 
69 
35 
21 
12 

     (74.6%)      

     (69.8%)      

     (67.2%)      
     (45.2%)      
     (18.3%)      
     (9.3%)      
     (5.6%)      
     (3.2%)      

What do you think are the most appropriate forms of learning about administrative 
cooperation and IMI? (multiple replies allowed)  

Short informal session with an experienced colleague 
in your own authority 

Self-learning with IMI User Handbook, eLearning 
modules ("Captivates") and other support material 

Training session at regional level 
Training session at national level 
Centralised training at EU level 
Other 

ABOUT MEETINGS AND EXCHANGES 

193 

190 

176 
173 
75 
9 

Number of 
responses 

% 

     (51.1%)      

     (50.3%)      

     (46.6%)      
     (45.8%)      
     (19.8%)      
     (2.4%)      

Do you think if would add significant value to meet officials from other countries who work 
with IMI in order to exchange experience? 

Yes 
No 

Number of 
responses 

240 
138 

% 

     (63.5%)      
     (36.5%)      

[If yes] In which form should such meetings be organised in your opinion? (multiple replies 
allowed) 

Regional training events with participants from 
different countries 

Smaller scale conferences for geographical regions 
Short term visits in authorities in different countries 
Centralised training events  
Centralised large scale conferences 
Longer term exchanges of officials 

125 

111 
107 
73 
46 
37 

Number of 
responses 

% 

     (52.1%)      

     (46.2%)      
     (44.6%)      
     (30.4%)      
     (19.2%)      
     (15.4%)      

22

 
 
  
 
 
  
 
  
ANNEX II: SUMMARY OF RESULTS OF TRAINING WORKSHOP HELD ON 17 JUNE 2009 

1. Training needs in relation to IMI and the Services Directive 

•  Participants  felt  that  there  is  a  need  for  training  both  on  technical  and  content 

level. 

•  Feedback  from  competent  authorities  shows  that  IMI  is  seen  as  user-friendly. 
Technical  training  seems  to  be  needed  mainly  at  the  beginning  to  overcome 
reluctance to use a new system. 

•  Participants from a number of Member States felt that training on content would 
be  important,  as  competent  authorities  often  need  more  information  about  the 
impact  of  the  Services  Directive  on  their  work  and  about  their  obligations  that 
derive from it. 

2. Organisation of training in Member States 

•  Training organised in the Member States has been well received and successful. 
•  Commission training material is widely used and much appreciated. 
•  Mix of theory and practice in training sessions was seen as most effective. 
•  Small  events  were  often  more  successful  than  big  ones,  resulting  in  more 

interaction and less stress for the trainer. 

3. Resources 

• 

In  most  Member  States,  financial  resources  for  training  are  not  perceived  as  a 
major problem. 

•  On the other hand, many participants feel they have insufficient human resources 

to manage training. 

4. Typical problems 

• 

It is difficult to reach the right audience (Should one invite people working on the 
technical or on the content side? Which level of hierarchy should participate?). 
•  Motivating  authorities  to  participate  in  training,  especially  if  geographically 

remote, is a challenge. 

•  Finding the right balance in length and content of training can be difficult as well 

(danger of overloading trainees). 

•  Staff shortage. 
•  Some participants reported a lack of interest and support from hierarchy. 

23

 
 
 
 
 
 
 
 
5. Good practice  

[not reproduced] 

6. Ideas for Member State activity 

•  Exchanges of officials and regional events are generally perceived as good ideas, 
but as dependent on sufficient resources and on overcoming language barriers and 
logistic  problems;  some  participants  said  it  is  premature  to  think  about  such 
activities. 

•  Data  protection:  Participants  suggested  building  up  regular  contacts  with  an 
expert  or  data  protection  supervisor,  to  prepare  simplified  guidelines  and  to 
circulate them to competent authorities. 

•  Organising  training  right  away  after  coordinators  come  back  from  Brussels 

ensures that the acquired skills are not lost. 

•  An  idea  could  be  to  organise  meetings  focussing  on  a  particular  sector  (eg 

tourism) and to work on fictional cases. 

•  One could also organise online training on a platform on which participants can 
exchange  theoretical  information  and  practise  in  the  system;  this  seems  to  exist 
already in other areas. 

7. Requests for Commission activity 

•  The  general  feeling  seems  to  be  that  the  Commission  is  already  doing  a  lot 
(training help, publications and helpdesk) and that it is up to the Member States 
now to become active. However, a number of requests were mentioned: 

•  The Commission should translate more material into all languages. 
•  Some participants raised concerns about the training database: the data in it is not 

meaningful, the email function is switched off and it often performs poorly. 

•  The  Commission  should  set  up  a  fictional  authority  and  send  out  fictional 

requests for training purposes. 

•  Another large awareness raising conference in Brussels would be very useful; it 

would be good to have a lot of competent authorities represented there. 

•  Many  Member  States  are  working  on  setting  up  an  IMI  helpdesk;  it  would  be 
useful  if  the  Commission  could  hold  a  training  session  on  how  to  organise  a 
helpdesk. 

•  The Commission could publish a diagram of the IMI structure in each country on 

the IMI website. 

•  Training on alerts and case-by-case derogations would be good. 
•  The  Commission  could  give  more 

information  about  experiences  with 
professional  qualifications  and  success  stories,  so  that  trainers  can  use  them  as 
examples. 

24

 
 
 
 
 
 
 
ANNEX III: RESULTS OF SURVEY AMONGST IMI COORDINATORS 

General information 

(1) 

Please provide us with some information about your authority: 

Country:  

51 replies received from 26 countries. 

Level:   

36 national, 15 regional 

(2)  What is your authority's role in IMI?  22 national IMI coordinators 

      15 delegated IMI coordinators 
      13 super-delegated IMI coordinators 

Exchange of officials and training – where do we stand? 

(3) 

In  your  opinion,  which  are  the  most  appropriate  forms  in  which  IMI  users 
should learn about administrative cooperation and IMI? (Please tick up to 3 
options) 

31 

20 

9 

23 

31 

17 

Self-learning on the basis of handbooks and support material  

Self-learning on the basis of eLearning modules ("Captivates")  

Training sessions organised locally  

Training sessions organised at regional level  

Training sessions organised at national level  

Awareness raising events and training sessions organised centrally 
by the Commission  

7 

Exchanges of officials from different countries  

(4) 

Are there any programmes already  in place in your  country that  have  been 
established irrespective of the requirements of the Services Directive, but 
that  could  facilitate  the  training  of  officials  and/or  exchanges  between 
officials for the purposes of the Directive?  

Yes: 6, No: 32, n.a.: 13 

If yes, please specify: [not reproduced] 

(5) 

Are there any accompanying measures that have been taken in your country 
specifically  for  the  purposes  of  the  Services  Directive  so  far  or  are  such 
measures planned? 

13  

  No.  

0 

  Yes, to facilitate the exchange of officials.  

34 

  Yes,  we  have  organised/plan 

to  organise 

training  and/or 

awareness raising events.  

25

 
 
 
 
 
 
 
 
 
 
 
[sub-questions about detailed plans not reproduced]  

(6) 

(7) 

If  you  organised  training  sessions,  please  indicate  which  subjects  were 
covered: [not reproduced] 

Do  officials  in  charge  of  the  implementation  of  mutual  assistance  in  your 
country have access to general computer and/or language training?  

Yes, to both: 15 
Yes, to computer training: 6 
Yes, to language training: 2 
No: 13 
Don't know: 1 
n.a.: 4 

If  yes,  please  describe  the  organisation  and  accessibility  of  such  courses 
[not 
(e.g.  duration, 
reproduced] 

intensity,  number  of  available  places,  costs): 

Training – resources 

(8) 

For training that relates specifically to IMI and the Services Directive, please 
indicate the number of persons who are currently involved in providing such 
training and the amount of their working time they spend on this training: 

Between 0 and 20 persons with roughly 0-100 % of their working time. 

(9)  Do you think that these figures should be increased?  

Yes, a lot: 9 
Yes, a little: 10 
No: 19 
n.a.: 13 

(10) 

If  training  on  IMI  and  the  Services  Directive  has  been  provided  in  your 
country, how have these activities been financed so far? 

  3 

 5 

16 

 Specific funds were made available for the implementation of the 
Services Directive.  

Through existing national programmes for training of officials.  

No  funding  was  available.  The  trainers  used  their  own  resources 
and participants covered their own costs.  

4 

Other.  

n.a.: 23 

(11)  Do  you  feel  that  you  need  additional  funding  for  training  on  IMI  and  the 

Services Directive?  

Yes: 20 

26

 
 
 
 
 
 
 
No: 17 
n.a.: 14  

Training – practical experiences 

(12) 

If you organised training sessions, please describe any difficulties you may 
have had: (please tick all relevant boxes) 

7 

2 

I did not have any difficulties.  

I was not sure which subjects to cover.  

10  

I hesitated about whom to invite to the training.  

2 

7 

9 

6 

 I  felt  that  I  did  not  have  sufficient  knowledge  about  IMI/the 
Services Directive to hold the training.  

I have no experience or skills in training.  

 I did not have enough time to hold the training myself and could 
not find another trainer.  

 I did not have sufficient funding to organise the kind or number of 
training sessions I wanted to organise.  

7  

Other; please specify:  

Reaching reluctant competent authorities 5 

Handling different levels of understanding 2 

(13) 

If you organised training, please indicate how often you used the following 
support  material  for  training  purposes  (the  material  made  available  by  the 
Commission can be found at http://ec.europa.eu/internal_market/imi-net): 

IMI User Handbook 

Very   Often   Sometimes   Rarely   Never 
often 

13          8           5              0           1        

Guide  to  IMI  and  the 
Services Directive 

 5           9            5             1           7      

IMI training database 

13          3            2             4           4        

European  Commission 
website 

10          8            7             3           1        

27

 
 
 
 
 
 
 
 
 
 
 
 
 
eLearning 
("Captivate") 

Powerpoint 
presentations 

modules 

 6         4           4              4            8        

11        5           4              4            2       

National material 

10        6           4              2            3       

(14) 

Please rate the usefulness of this material: 

IMI User Handbook 

Very     Quite      Not so    Not useful  
Never 
useful   useful     useful      at all           used 

24         13          1            0              0        

Guide to IMI and the 
Services Directive 

17         13          2             0             8         

IMI training database 

14         12          7             2             4         

European 
Commission website 

eLearning  modules 
("Captivate") 

Powerpoint 
presentations 

18         19          4             0             0        

10          13         8              0            7       

14          20         4              0            3         

National material 

15          12         4               0           5       

(15) 

Is there anything about the material produced by the Commission which, in 
your opinion, should be changed? 

No: 25 
Yes: 19 

-  
-  
-  

more and quicker translations: 8 
produce shorter/practical support material: 4 
improve performance of training database: 1 

28

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
-  
-  
-  

improve search function: 1 
organise material better: 1 
provide example cases: 1 

 (16) 

Please describe any material which, in your opinion, would be useful to add 
to the range of support material provided by the Commission: 

n.a.: 39 

Yes: 11 
- 
-  

-  
-  

Future needs 

Frequently asked questions 
short  targeted  material  (eg  "Captivates"  on  specific 
function, targeted test questions) 
success stories 
information about administrative structures in Member 
States 

 (17)  What do you see as the main challenges for competent authorities in using 
IMI for the purposes of implementing the Services Directive? (please rank 
the options below on a scale of 1 to 10, 10 being  the biggest challenge and 
1 the smallest) 

(number of respondents who ranked items in top 3) 

24 

24 

17  

27 

10  

11  

4   

6   

5   

2   

Understanding  the  legal  changes  introduced  by  the  Services 
Directive 

Understanding the practical implications of the Services Directive 
for their work 

How to identify the correct authority in another country 

How to deal with differences in rules and administrative structures 
in other countries (for example when an authority asks for a type 
of  authorisation  through  IMI  that  does  not  exist  in  the  other 
country) 

How to interpret the information provided through IMI 

Overcoming initial reluctance to use a new computer system 

How to use IMI from a technical point of view 

Language problems 

Data protection issues 

Other 

29

 
 
 
 
 
 
 
 
(18)  For the three aspects that you identified as the most challenging in question 
17,  please  describe  how  you  intend  to  support  and  train  competent 
authorities: [not reproduced] 

(19) 

 Do you think the Commission should play a role in these areas? 

No: 12 
Yes: 29 

If yes, please explain what this role should be in your opinion: 

-  
-  
-  
-  
-  
-  
-  
-  
-  
-  
-  

Advice: 7 
Improve system functionality: 7 
Help in interpreting the Directive (eg example cases): 6 
Produce support material: 4 
Translations: 4 
Training: 2 
Large conference in Brussels: 2 
Awareness raising with general public: 2 
Formal letter to hierarchy: 2 
Produce data protection report: 1 
Organise exchanges and cross-border conferences: 1 

(20) 

In your view, is there a need for more computer and language courses for 
officials in charge of implementing mutual assistance in your country? 

Yes: 20 
No: 27 

If  yes,  please  describe  how  such  courses  should  be  organised:  [not 
reproduced] 

(21)  Are you planning any exchanges of officials? 

Yes, concrete plans: 2 
Yes, possibly: 3 
No: 31 
n.a.: 15 

If yes, please specify: [not reproduced] 

(22) 

Any additional comments and suggestions: 

[not reproduced] 

30