Administrative formalities and costs involved in accessing markets cross-border for provisions of accountancy, engineering and architecture services : final report.
Date: 2017-05-24
Institutions: Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs
Subjects: accounting, administrative cooperation, administrative formalities, architecture, cost analysis, market, report, technology

Administrative formalities and 
costs involved in accessing 
markets cross-border for 
provisions of accountancy, 
engineering and architecture 
services 

Final Report 

Written by Ecorys Netherlands B.V. 
May – 2017 

 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs  
Directorate E – Modernisation of the Single Market 
Unit E1 — Service Policy for Consumers 

Contact: GROW-E1@ec.europa.eu 

European Commission 
B-1049 Brussels 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Administrative formalities and 
costs involved in accessing 
markets cross-border for 
provisions of accountancy, 
engineering and architecture 
services 

Final Report 

Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs 

2017 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Luxembourg: Publications Office of the European Union, 2017 

ISBN 978-92-79-68683-2 

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4 I May 2017 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

TABLE OF CONTENTS 

EXECUTIVE SUMMARY .................................................................................................... 7 

1 

INTRODUCTION ................................................................................................... 12 

1.1 
Aim of the study ......................................................................................... 12 
1.2  Definitions and scope .................................................................................. 12 
1.3  Organisation of the study and the report ........................................................ 14 

2 

METHODOLOGY ................................................................................................... 15 

2.1 
Introduction ............................................................................................... 15 
2.2 
Inventory of general aspects of procedure...................................................... 15 
2.3 
Inventory of regulatory requirements ............................................................ 17 
2.4 
Inventory of administrative formalities .......................................................... 18 
Interviews with services providers................................................................. 20 
2.5 
2.6  Questionnaire ............................................................................................. 23 
Allocation of costs to administrative formalities ............................................... 24 
2.7 
Extrapolation of costs .................................................................................. 25 
2.8 

3 

ARCHITECTURAL SERVICES ................................................................................... 27 

3.1 
Types of authorization procedures ................................................................. 27 
3.2  Regulatory requirements .............................................................................. 29 
3.3 
Procedural steps ......................................................................................... 32 
3.4  Deadlines ................................................................................................... 36 
3.5 
Tacit approval and validity ........................................................................... 38 
Fees .......................................................................................................... 40 
3.6 
3.7  Online information and procedures ................................................................ 43 
Submission demands - branches ................................................................... 44 
3.8 
Submission demands – temporary services .................................................... 50 
3.9 

4 

ENGINEERING SERVICES ...................................................................................... 53 

4.1 
Types of authorization procedures ................................................................. 53 
4.2  Regulatory requirements .............................................................................. 55 
Procedural steps ......................................................................................... 58 
4.3 
4.4  Deadlines ................................................................................................... 62 
Tacit approval and validity ........................................................................... 64 
4.5 
Fees .......................................................................................................... 66 
4.6 
4.7  Online information and procedures ................................................................ 68 
Submission demands - branches ................................................................... 69 
4.8 
Submission demands – temporary services .................................................... 74 
4.9 

5 

ACCOUNTANCY SERVICES ..................................................................................... 77 

5.1 
Types of authorization procedures ................................................................. 77 
5.2  Regulatory requirements .............................................................................. 80 
Procedural steps ......................................................................................... 82 
5.3 
5.4  Deadlines ................................................................................................... 85 
Tacit approval and validity ........................................................................... 87 
5.5 
Fees .......................................................................................................... 88 
5.6 
5.7  Online information and procedures ................................................................ 89 
Submission demands - branches ................................................................... 90 
5.8 
Submission demands – temporary services .................................................... 95 
5.9 

6 

INTERVIEWS WITH SERVICE PROVIDERS ................................................................ 98 

May 2017 I 5 

Approach ................................................................................................... 98 
6.1 
6.2 
Familiarisation with formalities ................................................................... 100 
6.3  Collecting supporting documents from authorities ......................................... 101 
6.4  Collecting data/information on shareholders and managers ............................ 102 
6.5  Completing forms ..................................................................................... 103 
6.6  Certain formalities related to liability insurance ............................................. 103 
6.7 
Translation and certification of documents ................................................... 104 
6.8  Changes to legal form and/or reallocating shares or voting rights ................... 106 
6.9 
Examination and/or language skills ............................................................. 108 
6.10  Collecting / submitting documents and travel tickets ..................................... 109 
6.11  Paying registration or membership fees ....................................................... 111 
6.12  Recurrent costs ........................................................................................ 111 

7 

COMPLEXITY OF FORMALITIES ............................................................................. 113 

Approach ................................................................................................. 113 
7.1 
Familiarization with formalities ................................................................... 113 
7.2 
7.3  Collecting supporting documents from authorities ......................................... 115 
7.4  Collecting data/information on shareholders and managers ............................ 117 
7.5  Completing forms ..................................................................................... 118 
7.6  Certain formalities related to liability insurance ............................................. 119 
7.7 
Translation and certification of documents ................................................... 120 
7.8  Changes to legal form and/or reallocating shares or voting rights ................... 121 
Examination and/or language skills ............................................................. 124 
7.9 
7.10  Collecting / submitting documents .............................................................. 127 
7.11  Paying registration or membership fees ....................................................... 128 
7.12  Recurrent costs ........................................................................................ 129 

8 

COSTS .............................................................................................................. 131 

8.1 
Approach ................................................................................................. 131 
8.2  Wage rates of staff involved in administrative formalities ............................... 131 
8.3  Weighting formalities that do not apply to all firms ........................................ 133 
The costs of formalities .............................................................................. 134 
8.4 
Estimated aggregate costs ......................................................................... 143 
8.5 

9 

SUMMARY AND CONCLUSIONS ............................................................................ 146 

ANNEX 1 LIST OF CONTACTED AUTHORITIES ............................................................... 159 

ANNEX 2 BUSINESS QUESTIONNAIRE .......................................................................... 162 

ANNEX 3 BUSINESS RESPONSE OVERVIEW .................................................................. 186 

ANNEX 4 CLASSIFICATION OF FORMALITIES ................................................................ 191 

ANNEX 5 TABLES AND FIGURES OF REGULATORY ASPECTS ............................................ 204 

6 I May 2017 

 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

EXECUTIVE SUMMARY 

Background 

Providers of architectural, engineering and accountancy services often face many 
barriers when they want to offer services in another Member State. These barriers are 
very diverse in nature, ranging from regulatory and administrative obstacles or 
language differences to the ability to find business opportunities abroad.  

Objective and scope 

The objective of the study is to identify cross-border market access formalities and 
procedural steps that are needed to comply with administrative requirements. 
Moreover, the aim is to assess the costs related to such formalities and procedural 
steps.  

The study is focused on formalities and procedural steps faced by legal entities (i.e. 
companies) providing architectural, engineering and accountancy services cross-
border, either via a branch or agency in the host country or via temporary cross-
border service provision. General business registration and authorization of 
professionals providing the service are out of scope of this study. The study covers 17 
EU Member States: Austria, Belgium, Cyprus, the Czech Republic, Denmark, France, 
Germany, Ireland, Italy, Luxembourg, Malta, Poland, Portugal, Romania, Slovakia, 
Spain and the United Kingdom.  

Overview of methodology  

An inventory of administrative formalities and the regulatory requirements from which 
they stem was made by collecting information primarily from the websites of the 
professional chambers in architectural, engineering and accountancy services. 
Moreover, where necessary these professional chambers were directly contacted. In 
addition, a wider online search was performed on available information in the 
countries covered.  

In order to obtain information on the costs of the identified administrative formalities, 
a business survey among 52 cross-border service providers was conducted. Costs 
consist of the time spent by staff going through the various steps of the formalities 
identified and of expenses incurred on issues such as translation, certification and 
external advice.  

Based on the survey, costs of various activities and expenditures were classified in up 
to four categories of “complexity” (simple, medium, complex and in exceptional cases 
very complex), with greater complexity corresponding to higher costs. For each 
degree of complexity, the characteristics of the administrative formalities causing the 
costs were examined. This approach mitigates the impact of outliers on the results. 
Lastly, the costs were extrapolated to the business population operating cross-border 
in the 17 countries covered by this study for three future scenarios.  

Overall conclusions and key findings of study 

In several countries covered by the study, businesses from other European countries 
face significant administrative requirements and must therefore incur high 
administrative costs involved in gaining authorization to provide architectural, 
engineering or accounting services in that market.  

While the identified authorization requirements investigated in this study appear to 
serve clear purposes, there seems considerable scope to simplify or reduce the 

May 2017 I 7 

administrative requirements to prove compliance, such as where documents already 
have been assessed in the home country, or even in the host country.  

Based on the study findings, the greatest gain in simplification and subsequent cost 
reduction could be achieved by doing background checks on registration in the home 
country as proof of compliance with regulatory requirements that may be similar in 
home and host country. This would reduce the need of the service provider to collect, 
certify, translate and submit documents and for the host country authority to assess. 
Such an approach would require enhanced administrative cooperation and information 
sharing between EU countries. This report offers harmonized information that could 
serve as a first step. A second step would be to continuously update or improve online 
information on applicable requirements and formalities, as necessary. As a third step, 
the procedures for background checks would need to be (further) developed.  

In theory, there is even potential to reduce costs of formalities to zero, given that for 
each of the services considered, two or more countries do not require any 
authorization of legal persons from other EU countries. This gives cause to reflect on 
the necessity of authorization requirements and where they are deemed necessary, to 
reduce the complexity and costs of demonstrating compliance.  

In the remainder of this executive summary, first the aggregate cost of formalities is 
presented. Then, the regulatory requirements causing administrative formalities are 
summarized. Lastly, a summary is given of the formalities, as well as of the tools to 
reduce their burden.  

Aggregate costs on businesses of going cross-border 

Usually, aggregate costs are calculated by multiplying costs per firm with the number 
of existing firms. However, costs of authorization are mostly one-off costs that already 
have been sunk in the past for existing firms. In addition, there is little information on 
the current number of cross-border operating firms. Therefore, the costs of going 
cross-border is estimated for three future scenarios: 

−  Lower-end scenario: one per cent of the businesses go cross-border in one 

other country each; 

−  Medium scenario: one per cent of the businesses go cross-border, but in 

ten other countries each; 

−  High-end scenario: ten per cent of the business go cross-border, in ten 

other countries each.  

The table below gives the aggregate costs for businesses from the EU28 going cross-
border in one or more of the 17 countries covered by this study for the above three 
scenarios. The costs range from EUR 29 million in the base scenario to EUR 2.9 billion 
in the high scenario, and is the total cost incurred throughout the time it takes 
businesses to get mobilized cross-border in the scenarios. Also, as each year firms 
enter and exit the market, any new firm going cross-border incurs costs of formalities 
even if and when numbers of cross-border firms stabilize.  

8 I May 2017 

 
 
 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

Table  A  Aggregate  costs  of  additional  cross-border  firms  (3  scenarios),  EUR 
million 

Architecture 

Engineering 

Accountancy 

Total

Branches, 
subsidiaries

Temp. 
Services 

Branches, 
subsidiaries

Temp. 
Services

Branches, 
subsidiaries 

Temp. 
Services 

Lower-
end 

Medium 

High-
end 

9.3

93

2.1 

21 

12.9

129

3.3

33

1.6 

0.2 

29

16 

2 

294

932

206 

1,292

328

158 

20  2,936

Regulatory requirements causing administrative formalities  

Regulatory requirements are not administrative formalities in themselves, but may 
cause administrative formalities depending on how compliance must be proven. 
Regulatory requirements in the following areas are covered by the inventory: 

−  Authorization (whether permission to provide services is needed); 

−  Legal form (determining which regulations apply to the firm); 

−  Shareholding, voting rights and managers (the % of professionals); 

−  Multidisciplinary restrictions (prohibition of conflicting activities); 

−  Professional indemnity insurance. 

Additionally, the following formalities related to the process of obtaining authorization 
are investigated: 

−  Data submission demands; 

−  Document changes, translation and certification; 

−  Handling fees; 

−  Handling deadlines and tacit approval; 

−  Validity of authorizations; 

−  Electronic information and procedures. 

The key results on each of these requirements are summarised below. 

Regulatory requirements – authorization 

Legal persons need authorization to establish an architecture or engineering branch 
cross-border in roughly half of the countries covered by the study, and in roughly one 
third of the countries for accountancy branches. Authorization of legal persons for 
temporary services is much less common. 

Regulatory requirements – legal form restrictions 

The legal form of a business contributes to determining which regulations apply to it. 
The most common legal forms in the EU are sole traders, partnerships and limited 
liability firms. Restrictions in the choice of legal forms are virtually absent for 
temporary services but exist to varying degrees in a few countries for establishing a 
branch cross-border. Recognition of at least common legal forms in the EU would 
already significantly reduce cross-border barriers which may cause costs to change 

May 2017 I 9 

 
 
 
legal forms or to set-up a subsidiary instead of a branch (causing for example 
incorporation costs).  

Regulatory requirements – shareholding, voting rights and management  

Requirements on shareholders, voting rights and managers are considered to be 
administrative formalities because the shareholders and managers need not be those 
providing the cross-border services. For temporary services, shareholding and/or 
manager restrictions apply in only three countries and only for carrying a voluntary 
title in the company. In contrast, for cross-border branches, restrictions on 
shareholding and management apply to varying degrees in up to half of the countries 
covered by this study. An example of such a restriction is the requirement of all, or at 
least half of the shareholders, partners or managers to be professionals.  

Regulatory requirements – multidisciplinary restrictions 

Multidisciplinary restrictions mean that some services may not be provided by the 
same legal person, for example architecture firms that may not engage in land 
development or accountancy firms that may not engage in real estate. 
Multidisciplinary restrictions are common, but based on the study findings they need 
not cause administrative formalities in all cases.  

Regulatory requirements – professional indemnity insurance 

Professional indemnity requirements are common but they need not cause 
administrative formalities in the form of an insurance policy or certificate as is the 
case in some countries. Other countries simply formalize the common practice in 
architecture and engineering that this insurance is proven to the client before a 
service contract is signed.  

Administrative formalities - data submission demands 

In multiple countries, data that is burdensome to compile must be submitted to obtain 
authorization, up to listing the positions that shareholders, partners and/or managers 
hold in other legal persons. For example, the cost of collecting shareholder data 
ranges from 3 to 34 hours depending on the required detail. Collecting other 
information takes from 3 to 20 hours, and completing forms from 1 to 30 hours, 
depending on the number of forms and the number of people who must fill in forms. 
In a worst case scenario businesses spend over 80 hours on collecting data and 
completing forms. Meanwhile, in some cases the required data is already registered by 
other authorities in the host country. Therefore, resubmission is a duplication of 
already existing information.  

Administrative formalities – document changes, translation and certification 

Company statutes are commonly required, and in addition proof of professional 
indemnity insurance (policy or simple declaration of insurer) is required in multiple 
countries. Often these and sometimes other documents must be certified and 
translated, causing administrative costs. Translation costs are on average EUR 500 for 
company statutes and EUR 400 for insurance policies, and EUR 100 or less for other 
documents. Changes to documents or other efforts are not always necessary to get 
documents accepted by the host country, but if they are this leads to additional costs. 
Usually all required documents are certified at the same time, at an estimated average 
cost of EUR 150 regardless of the number of documents.  

Administrative formalities – handling fees 

Authorities may charge fees for the initial authorization and for (often compulsory) 
membership. These are obvious costs, ranging from EUR 14 to EUR 1,400 for first-
time fees and up to EUR 500 for annual membership fees.  

10 I May 2017 

Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

Administrative formalities – handling deadlines and tacit approval 

Deadlines to grant authorizations can be very long, up to six months, delaying the 
provision of cross-border services through both branches and temporary services. 
Tacit approval means that if the authorities have not responded at the moment of the 
deadline, authorization is deemed to have been granted. When an authorization is 
required, tacit approval rarely applies.  

Administrative formalities - validity of authorizations 

Authorization is nationally valid in almost all countries. However, authorizations are 
limited in time in multiple countries. This means services providers need to renew 
their authorization, although the renewal procedure is usually lighter than the first 
time authorization.  

Administrative formalities - electronic information and procedures 

All countries have a “Point of Single Contact” (PSC) portal with information on 
business procedures. However, the quality of these portals varies with regard to 
practical information and the availability of this information in English. If little or no 
online information on requirements is available, it costs businesses 5 to 17 hours to 
become familiar with them, depending on how many authorities are involved in the 
procedure, and 10 hours on average if the information is available but not in the 
English language.  

Electronic authorization processes are often not (fully) available. Instead, forms can 
usually be downloaded from the websites of the chambers. However, these forms and 
supporting documents typically must be sent by regular mail and in one country even 
delivered in person. Especially submission in person cross-border is costly in terms of 
both ticket costs (hundreds of euros) and travel time (on average 12 hours).  

May 2017 I 11 

 
1  INTRODUCTION 

1.1  Aim of the study 

Services account for two-thirds of the EU economy, but the cross-border provision of 
services is underdeveloped, particularly for professional services such as architecture, 
engineering and accountancy.  

While administrative formalities are not the only barrier to cross-border services, this 
barrier could be significantly reduced, such as where information is not available 
online, or not in the English language, or no fully electronic procedure is available. In 
addition, an inventory or benchmark of administrative formalities may help Member 
States identify and assess specific requirements that are not common practice in other 
countries.  

Of course, online information, procedures and simplified requirements would reduce 
costs of administrative formalities not only for cross-border service providers, but also 
for domestic service providers. However, certain requirements can be expected to be 
particularly burdensome for cross-border service providers, such as requirements that 
documents are in the language of the host country (due to translation costs), or 
requirements to submit documents in person (due to longer travel distances). Thus, 
even administrative formalities that are the same for domestic and cross-border 
service providers may affect the working of the EU internal market if substantial costs 
are involved.  

The main objectives of this study are therefore to: 

1.  Identify the formalities and procedural steps faced by legal entities (i.e. 

companies) that provide architectural, engineering and accountancy services 
and wish to access cross-border markets. This is either on a temporary basis or 
while setting up a branch or an agency for secondary establishment; 

2.  Better understand cross-border service providers' practical experiences and the 
effort required by them to complete these formalities, and to quantify the costs 
involved. 

1.2  Definitions and scope 

The administrative formalities covered by this study refer to legal entities (i.e. 
companies). Formalities specifically linked to professional qualifications of natural 
persons (individuals) providing the services are beyond its scope, as are 
administrative requirements related to the posting of workers. However, certain 
formalities required of natural persons may also be part of the administrative 
procedure for legal entities, particularly if they apply to managers or shareholders who 
might not directly provide the cross-border services. Examples of formalities to be 
fulfilled by legal persons include requirements for managers to submit documents in 
person, to meet certain residence or language skill criteria or that they must be 
interviewed by an examination board.  

The formalities discussed are specific to the services sectors covered by this study. 
Thus general procedures such as registration in the general business register, 
requesting a VAT number or a company ID number for social security administration 
are beyond the scope of this study. Nevertheless, when such general procedures are 
interwoven with the procedure for professional chambers, they will be referred to.  

12 I May 2017 

 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

To limit the study to formalities associated with getting access to markets, formalities 
related to the establishment of subsidiaries - entities with a separate legal identity - 
are not included. The study’s focus is on:  

•  Establishment of branches or cross-border agencies; 
•  Temporary provision of cross-border services. 

The study covers only formalities required to enter a market and start providing 
services and excludes procedures associated with on-going business such as: 

•  Continuing Professional Development; 
•  Annual report on activities and/or list of clients; 
•  Building permits, zoning plans and other project-related requirements; 
•  Public procurement requirements. 

The exceptions are formalities that are caused by territorial and/or time validity 
limitations, e.g. a repetition of formalities when seeking access to work in other 
regions of the same country, or if permissions are valid for only one year. Annual fees 
of professional chambers are included, because in this case a time limitation is implicit 
(conditional on payment of the annual fee). If an annual fee is charged of 
professionals instead of firms, it is assumed that the fee is paid for one professional, 
because in this case a distinction between professionals and firms would be artificial. 

Formalities relating to competition or criminal law, taxation, labour and social security 
(including health and safety) are also excluded. Some countries do not, for instance, 
allow legal persons to operate in their country if they are still involved in clearing a 
bankruptcy, although an application of a bankrupt firm is likely an exceptional 
situation. Several firms reported spending large amounts of time arranging cross-
border social security and employment contract arrangements, but these are typically 
costs incurred after gaining access to a market and thus beyond the scope of the 
study.  

The three sectors covered by this study are accounting, architectural and engineering 
services. For comparability between countries, accounting services are defined in the 
narrow sense of accountancy. This means that regulations for statutory auditing or tax 
consulting services that do not apply to accountancy services are beyond the scope of 
the study. Architecture typically refers to the design of buildings, but in a few 
countries the supervision of construction works is also reserved for architects. For 
engineers, three types of engineering are distinguished in this study:  

•  Civil engineering; 
•  Electric engineering; 
•  Mechanical engineering. 

In some countries the same regulations are in place for architecture and civil 
engineering, while different regulations are in place for electric and mechanical 
engineering. For these countries, architecture is indicated as “architecture / civil 
engineering” and engineering is indicated as “electric / mechanical engineering”. In 
other countries the same regulations are in place for all types of engineering, and 
engineering is indicated without specific reference to civil, electric and mechanical 
engineering. 

The study covers 17 countries: Austria, Belgium, Cyprus, Czech Republic, Denmark, 
Ireland, France, Germany, Italy, Luxembourg, Malta, Poland, Portugal, Romania, 
Slovakia, Spain, and the United Kingdom. From a cross-border perspective, these are 

May 2017 I 13 

 
 
 
“host” countries where the services are provided. The “home” country where the 
service provider has its primary establishment can be any of the EU28 countries.  

1.3  Organisation of the study and the report 

The study was organized in four parts: 

Inventory of administrative formalities; 
Interviews with services providers; 

• 
• 
•  Calculation of costs; 
•  Extrapolation of costs. 

The starting point of the inventory of formalities was the portal of the Points of Single 
Contact.1 However, most of the information was obtained via the websites of the 
respective professional chambers and if necessary those chambers provided 
clarifications of the admission procedures (see also Annex 1).  

To identify the relevant service providers to be interviewed about the costs of cross-
border formalities, various sources were used, as explained in the next chapter. In 
general, establishments in the home country were asked to participate in the study. If 
subsidiaries in the host country were interviewed it was ensured that the respondent 
did not include procedures specific to the establishment of subsidiaries (and in two 
cases of doubts about this the interview was disregarded).  

The costs reported in the interviews were averaged across all respondents for 
requirements of similar complexity, as explained in the next chapter. This was done to 
ensure that differences in costs between countries reflect differences between 
requirements, and not random differences between respondents. Lastly, the costs 
were extrapolated to the whole business population in the relevant services, based on 
a number of scenarios about the mobility of service providers. 

The remainder of the report is organised as follows. Chapter 2 elaborates the 
methodology briefly outlined above. Chapters 3, 4 and 5 discuss the formalities faced 
by architecture, engineering and accountancy firms respectively. Each of these three 
chapters starts with an outline of formalities to establish a cross-border branch. 
Chapter 6 presents the costs of the types of formalities reported by service providers. 
Chapter 7 classifies the formalities into the cost categories of Chapter 6. Lastly, 
Chapter 8 presents the calculation of costs of individual formalities and extrapolates 
the costs to the total business population operating cross-border in the 17 host 
Member States covered by the study in various scenarios.  

1   http://ec.europa.eu/internal_market/eu-go/index_en.htm . 
14 I May 2017 

 
 
 
                                                           
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

2  METHODOLOGY 

2.1  Introduction 

To assess the costs involved with administrative formalities of gaining authorization to 
provide specific services, an inventory was made of the formalities and businesses 
were interviewed about the associated costs.  

The starting point of the inventory was the portal of the Points of Single Contact. 
However, most of the information was obtained via the websites of the respective 
professional chambers. If necessary those chambers provided clarifications of the 
admission procedures (see also Annex 1) or a wider online search of regulations was 
conducted. Various general aspects of authorization procedures influence the number 
of firms affected, the frequency of formalities and the complexity of going through the 
procedure, and help to classify formalities along these dimensions.  

To efficiently collect the relevant information, it was determined in advance which data 
about procedures and formalities needed to be filled in. Sections 2.2 to 2.4 outline the 
aspects for which information was collected and the rationale for including those 
aspects.  

Sections 2.5 and 2.6 describe the methodology of identifying cross-border service 
providers and how they were interviewed about the costs of complying with 
administrative formalities. The methodology includes the sampling approach, the 
interview modes and the questionnaire.  

Section 2.7 describes the methodology of allocating costs to individual administrative 
formalities and the regulatory requirements from which they stem. This allocation 
cannot be directly based on the interviews for several reasons, including the small 
sample size, the representativeness of the respondents and the decision to ask for 
information on the costs of combined documents rather than individual ones in order 
to reduce the response burden. The cost reported by businesses were first classified 
into categories of complexity reflecting increasing costs, which were then linked to 
types of requirements. This helped allocate costs to individual requirements in 
individual countries in a coherent matter, reducing the impact of random differences 
between respondents, for example with regard to language proficiency, and to allocate 
costs to situations for which no business responses are available.  

Lastly, Section 2.8 describes how costs were extrapolated to the level of the 17 host 
countries of this study. Since the current number of cross-border service providers is 
not known, the aggregate costs are calculated for three future scenarios. It may be 
unlikely that all administrative formalities can be removed, and the scenarios are 
uncertain, but nevertheless it gives a sense of the magnitude of the potential gain of 
reducing administrative formalities.  

2.2  Inventory of general aspects of procedure 

Procedural steps are key to understand the magnitude and sequence of what needs to 
be done from an administrative perspective. To efficiently collect information, the data 
requirements to be filled were determined in advance. This section outlines the 
procedural steps for which data were collected, each with a motivation for including 
them in the inventory.  

May 2017 I 15 

 
Services covered 

Sometimes different procedures are in place for similar services and it is not always 
immediately evident which one is the relevant procedure. For example specific 
requirements apply to statutory auditing as governed by the Statutory Audits Directive 
and tax consultancy, which are out of scope. Also, whether for example civil 
engineering is best classified together with architecture or other types of engineering 
is not always clear. A definition of the services covered by an authorization procedure 
helps decide on these matters.  

Reserved activities 

Reserved activities were investigated mainly to assess the extent to which 
authorizations are necessary in order to provide services. For example if authorization 
is necessary to carry a professional title in the company name, it is relevant whether 
the company can provide the services without this title. If a professional title is needed 
to start working, it is de facto mandatory. But if a professional title only has a 
signalling purpose to clients, it has a more voluntary nature. Knowledge of reserved 
activities helps underpinning assumptions about the need of a title to start providing 
services. 

Type of authorization procedure 

The type of authorization procedure further helps classify the applicability and the 
complexity of the procedure. Relevant characteristics of control procedures include: 

•  applicability to natural persons providing the services only (out of scope) or to 

legal persons (in scope); 

•  authorization (services may only start after permission) or a simpler 

notification (permission is not necessary or is granted after only a perfunctory 
check); 

•  authorization for only certain legal forms (helps estimate the number of firms 

affected); 

•  authorization to provide services or to carry a protected title (determines 

whether all or some firms are affected); 

•  Certain authorization procedures are not available to foreign firms and 

alternative procedures must be used.  

Responsible authority 

Investigating the relevant authority (name and web-link) helped determine whether a 
procedure was mandatory and within the scope of the study. It helped to exclude 
procedures for the general business registration, and procedures for voluntary 
memberships of sector organizations that have no relation to access to services.  

Relation with the general business register 

An aspect that may complicate the authorization procedure is its relation with the 
procedure for the general business register. If both procedures can be followed 
independently of each other and in parallel, there is no complication. If preliminary 
registration in the business register must be proved as part of the procedure to get 
authorization to provide services, this slightly complicates the procedure, depending 
on how fast general business registration is. If the procedure bounces back and forth 
between the general business authority and the professional chamber, it will be 
inevitably be slower and more complicated.  

Deadlines and tacit approval 

Deadlines for authorities to handle a procedure do not translate into monetary costs, 
but a longer procedure creates a barrier to new entrants. Deadlines were only used as 
a final reality check on the complexity of a procedure: an short deadline does not 
indicate a complex procedure, nor does a long deadline indicate a simple procedure. 

16 I May 2017 

 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

Tacit approval refers to the possibility to provide services after the deadline for the 
authority has expired, if applicable. It is another aspect that helps determine the 
complexity of a procedure.  

Territorial limitations 

Territorial limitations can refer to both different regional procedures and limited 
regional validity of the authorization. If procedures are regionally different, they are 
described for only one region. If procedures are regionally different, this may further 
increase the cost of collecting information, for example to identify the responsible 
authority for a specific region and the requirements of that authority. If authorization 
is only regionally valid, the national extension procedure is described. A limited 
regional validity in principle increases the likelihood of recurrent costs.  

Time validity 

This includes the period during which the authorization is valid, whether authorization 
can be renewed and the renewal procedure. The time validity determines the recurrent 
nature of costs.  

Points of Single Contact 
Points of Single Contact (PSC) can be accessed via one central link at the EU level.2 
From this link, the national web-links containing all practical information for all access 
to services procedures can be accessed. PSC are not a formality, but a tool to facilitate 
gathering information about procedures or even to download forms from or upload 
forms and documents to. Their usefulness depends on the inclusion of specific 
procedures and the language(s) in which the information is available, and the 
functionality as a depository of e-documents. Therefore, absence of practical 
information, absence of information in the English language and absence of a central 
depository for e-documents were inventories since their absence is likely to increase 
the cost of administrative formalities.  

Availability of e-procedures 

Like PSC, e-procedures are not an administrative formality, but rather a tool to help 
with the procedure. In case e-procedures are not available at the PSC, e-procedures 
via the portal of the relevant professional body were examined. The following types of 
e-procedures are distinguished in this study: 

•  Full electronic case handling (typically including uploading of documents and 

sometimes monitoring of administrative progress); 
•  Electronic submission of documents (e.g. by email); 
• 
• 
•  Documents must be collected or submitted in the host country in person.  

Information must be posted but forms can be downloaded; 
Information must be posted, no forms can be downloaded; 

2.3  Inventory of regulatory requirements 

Regulatory requirements were investigated mainly to assess which could impact 
administrative formalities. A direct impact arises when compliance with regulatory 
requirements needs to be demonstrated. Specifically, an inventory of regulatory 
requirements helps to assess which proportion of businesses must go through the 
administrative formalities stemming from them.  

Again, to efficiently collect information about regulatory requirement, they were 
determined in advance. An inventory is made of the following regulatory 
requirements:  

2   http://ec.europa.eu/internal_market/eu-go/index_en.htm. 

May 2017 I 17 

 
                                                           
•  Legal form requirements (e.g. sole traders, partnerships and limited liabilities); 
•  Shareholding, voting rights and management composition requirements; 
•  Multidisciplinary restrictions; 
•  Professional indemnity insurance requirements; 
•  Chamber Membership if compulsory. 

The information collected on legal form requirements consists primarily of which legal 
forms are allowed, and whether legal form restrictions apply to the provision of 
services or to the use of a voluntary title in the company name.  

Regarding the other requirements, a common element that was investigated was to 
which legal forms those requirements apply, for example if shareholders must be 
professionals in all firms providing the services or only in professional partnerships.  

Specifically with regard to shareholding, voting rights and management composition 
requirements, the percentage that must be in the hands of professionals is relevant in 
order to determine the number of firms affected. The higher this percentage, the more 
firms may need to change for example the allocation of shares and correspondingly 
the shareholding register (or the company statutes).  

Multidisciplinary restrictions typically require a statement, on honour, in the company 
statutes or from an authority. To identify such a requirement, the multidisciplinary 
restriction itself needs to be identified.  

For professional indemnity insurance, the amount and period to be covered were 
investigated with the idea that absence of mutual recognition provisions and/or 
complexity of insurance requirements would affect the burden of formalities stemming 
from insurance requirements.  

Compulsory Chamber membership is from a cost perspective relevant if fees are 
charged. Data and documents to be submitted for Chamber membership are the same 
as those to gain access to the services, because the Chamber is usually a key 
regulatory authority controlling access to the services.  

2.4  Inventory of administrative formalities 

Building on the inventory of regulatory requirements, an inventory is made of the 
administrative formalities that are at the heart of this study. Administrative formalities 
typically stem from a requirement to prove compliance with regulatory requirements 
such as discussed above. The following types of administrative requirements are taken 
stock of: 

•  Data submission demands (which data to fill in on forms); 
•  Document submission demands (which supporting documents to provide with 

the application form); 

•  Certification requirements (what proof of truthfulness of the document is 

accepted); 

•  Translation requirements; 
•  Acceptance of equivalent documents (what alternative documents are accepted 

if the standard required document is not available, if explicitly specified) 

•  Other formalities. 

Data submission demands 

Data submission demands often stem directly from regulatory requirements. For 
example, if only certain legal forms are accepted, an authority may require 

18 I May 2017 

 
 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

information on the legal form in the home country. To demonstrate compliance with 
shareholding requirements, one might expect that data must be submitted on the 
names of shareholders and the number of shares they hold. In general, data might 
need to be filled in to enable an assessment of compliance with regulatory 
requirements.  

An inventory is also made of the ID data that must be submitted, since their number 
and detail are also expected to influence the cost of the formality.  

Document submission demands 

To prove compliance with regulatory requirements, supporting documents may be 
required as proof. For example, as proof of the legal form, one might expect that an 
extract from the general business register could be required. And for shareholding 
requirements, submission of the shareholding register or the company statutes might 
be required. In general, supporting documents might need to be enclosed with the 
application form as proof of compliance.  

Certification requirements 

Documents that are required as proof of compliance, may in turn need to be certified 
as proof of their truthfulness. Certification may be accepted in many forms and vary 
from Member State to Member State. In EU legislation, certification is one of three 
document formats with regard to their truthfulness:  

•  Simple formats, meaning the issuer produces the document without following 
particular requirements on format (also referred to as "simple copies" – since 
no rules on format issuance exist, the original or a photocopy, or even a copy 
of a copy, may assumed to be acceptable as long as it is legible); 

•  Certification, meaning that a certifier, normally a public authority or someone 
vested with public powers such as a notary, must certify a fact stated in the 
document. The certifier can be the initial producer of the document, which is 
normally the case for public documents, or the certifier can be someone 
intervening after the document was originally produced, which is normally the 
case for private documents. The fact to be certified can be anything from 
whether the document is an accurate copy of an original (in which case the 
document format is referred to as "certified copy") to the veracity of the 
document's content, or the capacity of the person signing the document;  

•  Authentication, under EU Law this means that the identity of the person signing 
a private document (always a private document) must be certified, however 
concepts of certification/authentication are fluid and different across Member 
States.  

For both certifications and authentications it may be assumed that since rules on 
format issuance apply, only the original of the certified or authenticated document is 
acceptable.  

Certification may be allowed in many forms, for example a stamp, a notarized 
statement or an upload facility that is restricted to notaries, so basically anything that 
looks like a certification requirement is regarded as such.  

Note that in this context, certification only refers to documents, not certifications of 
professionals or the company.  

Translation requirements 

Documents may need to be translated. It is an administrative formality because it is 
part of the requirements to submit documents as proof of compliance. There are 
various aspects to translation requirements, including: 

May 2017 I 19 

 
• 
• 

• 

• 

the languages in which the original document is accepted; 
the languages into which the document must be translated if not originally in 
an accepted language; 
the use of an authorized translator, or even the use of an authorized translator 
from the host country; 
certification of the correctness of the translation. 

The distinction between the first two aspects is that a document in the English 
language may be accepted, but if not it must be translated into a language used in the 
host country.  

If a translation is required, the applicant may be allowed to translate the documents. 
Alternatively, it may be required that an authorized translator must be hired. In the 
latter case, the translator may need to certify that he or she has done the translation. 
All of these aspects are included in the inventory since they may influence the cost of 
this formality.  

Acceptance of equivalent documents 

Documents may not always be available. For example, if a profession is not regulated 
in the home country, there may not be a professional body that can issue a certificate 
that the firm is registered and that no sanctions apply to the firm. In such cases, the 
question is whether equivalent documents are accepted, for example an extract from 
the general business register, and/or a certificate from a general court of justice that 
the firm is not subject to certain legal procedures. Acceptance of equivalent 
documents is not a requirement but rather absence of acceptance of equivalent 
documents creates an administrative barrier.  

This aspect was included in the inventory but in the end not included in this report. 
This means that in the cost calculations, required documents are implicitly assumed to 
be available in the home country.  

Other formalities 

Other formalities refer to requirements that were not expected in advance, except 
possibly as a theoretical notion. Consequently, no criteria were determined in advance 
about their inclusion. Such notions existed with regard to residence requirements or 
the use of an insurance provider from the host country. For example, it is conceivable 
that firms from outside the EU can register with professional bodies in EU countries, 
and proof of a location in the EU might be required. Or, a collective arrangement 
might exist with an insurance provider in the host country and proof of insurance is 
not necessary if that collective arrangement is used. The inclusion of such other 
formalities is decided on a case-by-case basis. 

2.5  Interviews with services providers 

Following the inventories, cross-border service providers were interviewed to collect 
their views on the most burdensome requirements and to collect information about the 
costs of administrative formalities, in order to quantify the costs and to make the 
burdens of various administrative formalities comparable.  

A challenge was the number of different segments that needed to be covered in order 
to make meaningful comparisons between administrative formalities: 14 countries, 
three types of services and two types of cross-border services provision. Hence, a 
sampling strategy was developed to cover as many combinations as possible. The 
study also covers many formalities, and a questionnaire was developed to cover the 
whole range of formalities without overburdening the respondent. Lastly, because the 

20 I May 2017 

 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

number of cross-border operating service providers in the relevant categories was 
quite small, a mix of interview modes was used to maximize the number of interviews.  

During the preparation phase great care was taken in the selection of firms operating 
across borders. As it turned out, not many firms in the sectors covered by this study 
operate cross-border. To identify as many firms as possible, various sources were 
combined:  

•  Amadeus database of firms including cross-border branches (and subsidiaries); 
•  The EU database of public procurement from which services awarded to foreign 

companies were selected; 

•  Foreign-company registers of the professional chambers; 
•  Foreign-company lists of the general business register; 
•  Lists of firms or professionals working abroad on the web pages of professional 

organisations; 

•  Direct inquiries and in the case of architecture also indirectly via their European 
umbrella organisation, with professional organisations and/or chambers about 
firms operating from or in another EU country (although this did not result in 
many contacts); 

•  Random references to firms working abroad on the internet; 
•  Own professional networks. 

Annex 1 gives an account of professional organisations and chambers contacted to 
suggest firms that could be interviewed, as well as the numbers of firms identified 
(including duplications of firms known under slightly different names in the various 
sources).  

Annex 3 shows that 52 service providers were successfully interviewed. This 
corresponds to 5 per cent of the identified business population. This response rate 
may seem low, but it is to be expected given difficulties to identify the relevant 
contact person within the firm and the fact that respondents need to prepare for the 
survey in advance. All countries were covered, mostly by three or four interviews, with 
the exceptions of Poland (one interview), Belgium and Slovakia (2 interviews each). 
Most interviews were held with engineering firms (30), followed by architectural firms 
(17) and accountancy firms (5). This distribution reflects the identified population 
sizes of cross-border service providers. Both permanent establishments and temporary 
services were covered, by 26 interviews each.  

Annex 3 presents in steps how the 52 interviews were achieved. It first gives an 
overview of the number of identified cross-border operating firms by pooling data from 
the various sources. Some firms occur in more than one source and hence the firms 
need to be de-duplicated. Also, firms that on closer inspection were beyond the scope 
of the study needed to be removed. This was particularly the case for engineering 
divisions of firms in industries such as oil, gas, railways and air transport as well as 
financial holding companies that do not provide accountancy services to third parties. 
Contact data were not available for all firms that were identified. Lastly, not all firms 
needed to be called, for example if for one host country more than one firm in the 
same category of sector and service mode was already called.  

Once a phone number was identified, ideally of a promising contact person and 
otherwise the general phone number of the company, the next challenge was to 
identify the relevant contact person. To start and get beyond the company’s central 
telephonist, the interviewers asked for: 

•  A professional occasionally working abroad if the home country establishment 

was called (primarily to cover cross-border temporary services); 

•  A founding partner if the host country establishment was called (primarily to 

cover cross-border branches).  

May 2017 I 21 

 
Challenges and solutions for finding relevant contact persons included:  

•  Lack of phone numbers, which mostly were looked up from the firm’s web 

page; 

•  Lack of relevant contact persons, which could not always be looked up; 
•  Fielding in the months of July and August, with better progress in September; 
•  The use of different pitches when contacting the establishment in the home 

country or the host country;  

•  Language difficulties, with national experts being familiar with their country’s 
requirements but needing to interview firms of other countries – interviews 
were occasionally switched between experts. 

The most pertinent challenges during the interviews were: 

•  Unfamiliarity of the respondent about the difference between branches, 

subsidiaries and temporary cross-border services – not a surprise given the 
fluid changes between different modes of cross-border services provision as 
described above. Interviewers first asked about the establishment of branches, 
then if no branch was established they asked about temporary services and as 
a last resort they asked about the establishment of subsidiaries; 

•  Uncertainty about costs, especially if the authorization had been granted a 
couple of years earlier – this required a lot of additional guidance to the 
respondent with mixed results; 

•  Not being able to identify detailed costs – in which case interviewers asked to 

provide estimates; 

•  Specifically for subsidiaries: not being able to exclude costs that are specific for 
establishing subsidiaries as opposed to those linked to branches or agencies. 
However, the questionnaire did include questions about those specific costs, 
and if the respondent provided additional costs, they had to be named 
explicitly. Costs of steps with descriptions that clearly related to subsidiaries 
were excluded from our calculations. 

Annex 3 presents the business response. Up to three contact attempts have been 
made for each of the 1,087 firms in the call population, resulting in the 52 completed 
interviews. The broad reasons for the low response rate (with approximate 
percentages) were: 

•  Could not reach a person or the phone number did not work 
• 
• 

Immediate refusal to participate in any survey 
Initial interest but inability or refusal to provide cost data 

 10% 
 10% 
 50% 

There are many reasons why a person may be initially interested to participate in a 
survey but in the end may refuse to provide cost data. These reasons were not 
documented in detail but include: 

•  The authorization was gained years earlier and the respondent does not clearly 

recall the time and costs anymore; 

•  The person was indirectly involved and the person who was directly involved 

has left the company; 

•  And most often: the respondent is too busy to take time to recollect the hours 

and costs involved. 

Depending on the sector, other main reasons for the low response rates were: 

22 I May 2017 

 
 
 
 
 
 
 
 
 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

•  The services were out of scope (accountancy only) 
•  The authorization was too long ago (architecture and engineering) 
• 
Interview excluded as out of scope (architecture and engineering) 

 25% 
 10% 
 10% 

For accountancy, firms offering statutory auditing, tax consultancy or business 
investments services were considered out of scope. Even if firms offer accountancy 
services besides for example statutory auditing, they were out of scope if their 
authorization was obtained for statutory auditing – and by implication for accountancy 
services, because in most countries stricter requirements are in place for statutory 
auditing services.  

Interviews that included procedures that were out of scope were mostly held for 
temporary services in host countries without access formalities. One reason why such 
interviews were completed in the first place is that unexpected costs in scope might 
turn up. But also, some respondents insisted on covering issues that were important 
to them rather than limiting themselves to the administrative formalities that are the 
subject of this study. In either case, whenever comments indicated that procedures 
out of scope were covered, the results from that interview were excluded. 

2.6  Questionnaire 

In order to efficiently collect both views on most burdensome formalities and to 
quantify the costs, without losing the respondents in detail, a questionnaire was 
developed that grouped the formalities in broader categories. For example, 
respondents were not asked about costs of collecting and translating each individual 
document, but simply about the total costs of collecting and translating documents. To 
structure the questionnaire, requirements were further grouped into four types for 
which similar activities are required: 

1.  Familiarization and collection of data and documents; 
2.  Purchases of services such as certification and translation of documents; 
3.  Changes such as in shareholding or management to comply with formalities; 
4.  Submission of the application. 

Table 2.1 gives an overview of activities about which the businesses were prompted to 
give cost estimates. For each of the four groups of activities, the respondent was 
asked if the respondent was involved in other activities in that area.  

Table 2.1 Activities and fees to meet administrative formalities 

Purchases of 
services 
1.Identifying 
translators  

2.Translation fees 
(amount) 

3.Identifying 
certifying authorities 
and certification fees 
4.Certification fees 
(amount) 

Familiarization and 
data collection 
1.Identification and 
familiarization of 
requirements 
2.Downloading / 
requesting and 
completing forms 
3.Collecting documents 
in person 

4.Collecting certificates 
of previous 
employment 

5.Collecting other data 
on management/ 

Changes for the 
firm and managers 
1.Time to make legal 
form changes 

2.Time to reallocate 
shares or voting 
rights 
3.Time to change the 
management 

Submission of the 
application 
1.Authorization 
and/or registration 
fees (amount) 
2.Membership fee of 
the professional body 
or chamber (amount) 
3.Transferring the 
payment (hours) 

4.Examination or 
interview of manager 
or shareholders 

5.Acquiring language 
skills if required of 

4. Submitting the 
application 
electronically or by 
post 
5.Submitting 
documents in person 

May 2017 I 23 

 
 
 
 
 
 
Familiarization and 
data collection 
shareholders/ 
professionals 

Purchases of 
services 

Changes for the 
firm and managers 
managers or 
shareholders 

Submission of the 
application 

For all activities, questions were asked about the time spent by staff: of senior 
managers, professional and administrative support staff. To measure the costs of the 
time spent on administrative requirements, the wage rates of senior managers, 
professionals and administrative support staff were also sought in the interview.  

Annex 2 presents the questionnaire that was used for the interviews. The same 
questionnaire about the costs of administrative formalities was used for all firms. In 
the questionnaire, first, the mode of cross-border services of the company is asked, 
because this is not clear for all sources and can be very fluid. Many firms can, for 
example, start by providing temporary services before establishing permanently. Or, a 
firm could establish a branch in a distant country and gradually provide temporary 
services to its neighbouring countries. The preferred currency of the costs was asked, 
the costs of the various steps to meet requirements and the costs of recurrent steps, if 
any. In addition, the questionnaire covered the most burdensome administrative 
requirements and alternatives to avoid or reduce costs, to help pinpoint down 
requirements that cause particularly high costs.  

2.7  Allocation of costs to administrative formalities 

To calculate costs, the principles of the Standard Cost Model have been applied. 
Various elements are taken into account in order to arrive at estimates of costs per 
sector and Member State. These combine the results of the inventories (Chapters 3-5) 
with the interviews (Chapter 6).  

Firstly, the costs reported by the service providers were grouped in categories ranging 
from low to (very) high. This was done by indicating per type of administrative 
formality the distribution of costs across all countries, sectors and modes of service 
provision.  

Secondly, these categories of complexity were linked to types of formalities by way of 
synthetic analysis.  

Thirdly, the individual administrative formalities of the various countries, sectors and 
modes of service provision were classified in a range from simple to (very) complex. 
This was based on similarities of formalities (belonging to the same type of formality 
identified in the second step).  

Lastly, the same average cost was allocated to all individual formalities with the same 
degree of complexity. This was mainly done to avoid random differences between 
efficiency of service providers (for example caused by differences in their language 
proficiency or travel distances) influencing the costs allocated to formalities. This is 
described in detail in Chapter 8.  

Service providers were asked to quantify different types of costs:  

•  Staff time spent on formalities; 
•  Expenses on third parties such as notaries, translators and (language) trainers; 
•  Fees of authorities; 
•  Recurrent costs. 

24 I May 2017 

 
 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

The first type of cost was expressed in a money equivalent by multiplying the hours 
involved with the relevant wage rates of different staff involved. The relevant wage 
rates were based on a mix of interview results and Eurostat data as discussed in 
Section 8.2. 

The estimation of expenses on third parties was mainly based on interview results, but 
sometimes standard rates based on internet search were used as well. For example, 
service providers were only asked about total translation costs, not about translation 
costs per document. Hence, translation costs were estimated based on a mix of 
interview results and translation costs per word and the number of words in typical 
types of documents. The interview results were used to adjust the assumed number of 
words per type of document to make the calculated translation costs consistent with 
the reported translation costs.  

Fees of authorities were based on the inventories, but interview results helped assess 
the interpretation of fee rates, for example for how many shareholders the fee rate 
typically applies or how to interpret a single fee rate for both legal and natural 
persons.  

For recurrent costs the type and frequency of the recurrent costs was asked. The 
present value of future costs was calculated by discounting costs up to ten years in 
the future (for both permanent establishment and temporary services) at a rate of 
four per cent per year. Thus, at least one temporary cross-border service is assumed 
to be offered every year.  

Table 2.2 summarizes the types of costs, the underlying elements and the sources of 
information that were used to estimate the costs involved.  

Table 2.2 Type of costs, underlying elements and sources of information 

Type of costs  Elements taken into account 
Average staff time required per 
Wage 
different levels of complexity 
equivalent of 
(simple, medium, complex) for 
staff time 
each administrative step 
spent on 
formalities 

Individual levels of complexity per 
administrative step for each sector 
and Member State  
Wages rates  

Expenses on 
third parties 

Fees of 
authorities 
Recurrent 
costs 

Averages of external costs of 
translation, certification, etc. 
Standard fee rates 
Requirements 
certification, etc.  
Official  fees  and  costs  as  publicly 
available  
Type of recurrent costs 
Frequency of occurrence 

translations, 

on 

Source of information 
Interview results (Chapter 6) 

Inventories (Chapters 3-5) 

Eurostat data and interview results 
(Section 8.2) 
Interview results (Chapter 6)  

Internet search (Chapter 6) 
Inventories (Chapters 3-5)  

Inventories (Chapters 3-5) 

See above (Section 6.12) 
Fees of authorities: inventories 
(Chapters 3-5) Other: interview results 
(Chapter 6) 

2.8  Extrapolation of costs 

Due to lack of data on numbers of cross-border service providers, scenarios were 
developed with regard to potential future cross-border activity.  

May 2017 I 25 

 
 
 
 
 
The scenarios are further developed in Section 8.5, but essentially in each scenario the 
estimate aggregate costs of administrative formalities is the product of three factors: 

•  The number of firms involved; 
•  The number of host countries per firm; 
•  The cost per firm.  

The third element, the cost per firm, is a weighted average of the costs in the 17 host 
countries of this study. The weights allocated to each host country reflect the size of 
the country in a ratio of 25 to 5 to 1 for large, medium and small countries 
respectively. Thus, costs in France have a five times greater impact than costs in 
Belgium, and costs in Belgium have a five times greater impact than costs in 
Luxembourg on the calculated average cross-border costs, reflecting their market 
sizes.  

26 I May 2017 

 
 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

3  ARCHITECTURAL SERVICES 

3.1  Types of authorization procedures 

Overlap with civil engineering in four countries 

The main architectural services on offer concern the design and construction planning 
of  buildings.  There  is  some  overlap  with  civil  engineering  services,  for  example  with 
regard  to  drainage,  foundations  and  the  stability  of  buildings.  In  four  countries 
(Austria, Cyprus, Luxembourg and Malta) the regulations or even the control body for 
authorization  is  the  same  for  architecture  and  civil  engineering  services  –  see  Table 
A5.1 in Annex 5. In Luxembourg the authorization procedure is identical for all types 
of architects and engineers, while in Cyprus access requirements for architecture and 
civil  engineering  are  the  same,  with  only  slight  differences  for  other  types  of 
engineers.  In  Austria,  the  need  for  authorization  is  limited  to  the  activity  of  building 
design,  which  means  engineering  that  does  not  include  designing  buildings,  is  not 
affected by these access regulations.  

Identical  procedures  for  architecture  and  civil  engineering  are  advantageous  in  that 
there  is  no  need  for  architects  wishing  to  offer  civil  engineering  services  to  register 
with  a  second  control  body  (for  civil  engineering).  On  the  other  hand,  access 
regulations are usually more burdensome for firms that solely provide civil engineering 
services than the regulations in case of separate procedures. 

Activities not regulated in three countries, title not regulated in one country 

The impact of access procedures depends on what is controlled. The impact of control 
of activities, like exercising the profession, is larger than the impact of control of the 
use  of  a  professional  title.  It  also  matters  whether  authorization  is  needed  for  all 
activities or only specific activities.  

In  most  countries,  access  to  all  the  usual  activities  conducted  by  providers  of 
architectural services is controlled (Table A5.2 in Annex 5). There are four exceptions: 
Denmark  and  the  United  Kingdom,  where  legal  persons  need  no  prior  authorization, 
and  Germany  and  Ireland.  In  Germany  (Nordrhein-Westfalen),  authorization  is  only 
needed for professionals submitting building plans and representing customers and for 
legal persons wishing to carry the professional title in the company name.  In  Ireland 
legal  persons  only  need  prior  authorization  when  they  wish  the  carry  the  title 
‘architect’  in  the  company  name.  Control  of  professionals  providing  the  services  is 
beyond  the  scope  of  the  study,  but  conditions  for  voluntary  professional  titles  in  the 
company  name  are  examined  (and  assumed  to  apply  to  part  of  the  business 
population). In the United Kingdom, access requirements for legal persons are similar 
to  those  in  Ireland,  but  only  controlled  ex  post  by  means  of  a  periodic  survey.  In 
Denmark, not even the use of a title of architect or providers of architectural services 
is regulated. Firms may become voluntary members of an architecture association, but 
this falls out of scope of the study. 

Authorization for establishment of architecture branches in ten countries 

In eight of the 17 countries covered by the study, firms need authorization to establish 
an  architecture  branch  (Table  3.1).  In  six  countries,  only  professionals  need 
authorization  and  authorization  of  their  firm  is  not  required.  This  means  that  to 
provide services, firms need to employ at least one professional with the qualifications 
of  the  host  country.  The  three  remaining  countries  are  Austria,  Germany  and 
Denmark. In Austria no procedure exists for firms from other EU countries to establish 
an architecture branch in Austria. In Germany only the use of a voluntary professional 

May 2017 I 27 

title in the company name is controlled. In Denmark, as remarked earlier, architecture 
services are not regulated at all.  

Authorization for temporary services of legal persons in five countries 

Five  countries  have  set  rules  on  the  temporary  provision  of  architectural  services  by 
firms. Authorization of firms from other EU countries to provide temporary services is 
required  of  all  firms  in  four  countries:  Belgium,  Cyprus,  Ireland  and  Spain.  In 
Germany,  only  the  use  of  the  voluntary  title  “architect”  in  the  company  name  is 
controlled.  

In two  countries, no specific controls are in place, but rules do apply. In Luxemburg, 
notification  requirements  do  not  limit  access  to  temporary  services,  but  do  entail 
(some)  formalities.  In  Austria,  a  requirement  to  inform  the  customer  of  chamber 
membership  and  professional  indemnity  insurance  exists,  but  this  is  regarded  as  an 
administrative  formality  for  on-going  services  instead  of  gaining  access  and  thus  not 
included in the cost calculations (nor reported by service providers).  

In Denmark and the United Kingdom, access to the profession is not regulated at all. 
In the United Kingdom, no activities are reserved for architects. Even using ‘architect’ 
in the company name does not require authorization in the United Kingdom, although 
the title is protected for both professionals and firms.3  

The rules with respect to control procedures applicable to establishment of a branch or 
provision of temporary services are summarized in Table 3.1, with numbers indicating 
an  increasing  degree  of  restrictiveness.  Where  in  Table  3.1  or  the  remainder  of  this 
report  a  “voluntary  partnership”  is  mentioned,  it  refers  to  partnerships  as  one  of 
several legal forms allowed for providing the services as a legal person.4 

Table 3.1 Architecture - Authorization procedure 

MS  Establishment of a branch 
AT 

8.Not possible for branches, only 
subsidiaries 
7.Authorization 
7.Authorization 
6.Authorization of professionals and 
voluntary partnerships a) 
5.Authorization of professionals & title in 
company name 
1.No authorization/notice 
7.Authorization 
7.Authorization 

7.Authorization 
7.Authorization 

LU 
MT 

7.Authorization 
6.Authorization of professionals and 

BE 
CY 
CZ 

DE 

DK 
ES 
FR 

IE 
IT 

Temporary cross-border services 
2.Only to inform client 

7.Authorization 
7.Authorization 
4.Authorization of professionals providing the 
services only 
5.Authorization of professionals & title in 
company name 
1.No authorization/notice 
7.Authorization 
4.Authorization of professionals, notification 
for firms 
7.Authorization 
4.Authorization of professionals, notification 
for firms 
3.Notification 
4.Authorization of professionals, notification 

3   To protect the use of the title of Architect, the Architects Registration Board monitors the business 

4  

directory. If sufficient evidence is gathered that the title of Architect is used by an individual not in the 
register, the ARB can take the case to court to stop the offender using the title. Alternatively, a warning 
letter is issued. Source: 
www.arb.org.uk/files/files/What%20we%20do%20to%20regulate%20use%20of%20the%20title%20%
27architect%27%281%29.pdf. 
"voluntary partnerships" in the context of this study means a partnership the formation and operation of 
which, although subject to specific rules, is not mandatory for the provision of the services in question 
by a legal person in a given jurisdiction (because other legal forms are allowed in that jurisdiction for 
the provision of the same services, because a certain title is legally reserved to a partnership complying 
with certain controls and requirements but the same services may be provided without the use of such 
a title, or for any other reason). 

28 I May 2017 

                                                           
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

MS  Establishment of a branch 
voluntary partnerships 
4.Authorization of professionals 
providing the services only 
7.Authorization 

PT 

PL 

Temporary cross-border services 
for firms 
4.Authorization of professionals providing the 
services only 
4.Authorization of professionals providing the 
services only 
4.Authorization of professionals providing the 
services only 
4.Authorization of professionals providing the 
services only 
1.No prior authorization/notice, only control 
ex post 

4.Authorization of professionals 
providing the services only 
6.Authorization of professionals and 
voluntary partnerships a) 
1.No prior authorization/notice, only 
control ex post 
In two countries (the Czech Republic and Slovakia) the Trade Licencing Office verifies compliance 
with professional regulations for legal persons, under the Czech Trade Act (§ 10.2, 28.2 and Annex 
2) and the Slovak Trade Act (§ 10.4 and Annex 2 item 14th) respectively. Since this is the authority 
general business register which is out of scope in other countries, their document requirements are 
also considered out of scope for these two countries, but specific requirements for architecture 
services such as shareholding or examination requirements are in scope.  

RO 

SK 

UK 

a) 

3.2  Regulatory requirements 

Legal forms of business 

The legal form of a business determines how various national laws are applied to it. 
Alongside sole traders, commonly used legal forms in the EU include partnerships and 
limited liability firms. In most countries covered by this study all legal forms of 
business are allowed for architecture companies (Table A5.4 in Annex 5).  

In  Austria,  procedures  to  access  the  profession  for  architectural  services  are  only 
available  for  firms  with  specific  national  legal  forms.5  Regulations  in  other  countries 
may  also  refer  to  national  legal  forms,  but  only  in  Austria  did  the  chamber  of 
architects confirm that similar legal forms in other countries are not accepted.  

In  Belgium,  only  two  legal  forms  are  available  for  architecture  services:  partnerships 
and  the  so-called  Laruelle  form.  Firms  from  other  EU  countries  may  use  this  Laruelle 
form.  A  commercial  court  decides,  as  part  of  the  access  control  procedure,  whether 
legal forms of companies from other EU countries are accepted as fitting into either of 
the available legal Belgian forms. This complicates the procedure but is not necessarily 
prohibitive. 

Three  countries  specify  that  only  natural  persons,  partnerships  and  limited  liability 
firms  are  allowed  to  register  as  architecture  firms:  Cyprus,  the  Czech  Republic  and 
France.  The  French  law  on  architecture  even  specifies  in  the  subsequent  article  that 
branches  (succursales)  of  firms  from  other  EU  countries  with  any  legal  form  are 
allowed. 

German regional law (of Nordrhein-Westfalen) indicates that partnerships and limited 
liability firms in general may carry the title ‘architect’ in the company name. These are 
commonly used legal forms in the EU and architecture firms did not mention the need 
to match these legal forms as a costly barrier.  

For  temporary  cross-border  services,  all  legal  forms  are  allowed  across  the  EU,  with 
the  exception  of  Germany,  where  the  above  mentioned  limitations  exists  for 
companies wishing to carry the voluntary title of ‘architect’ in the company name. 

5  

the offene Gesellschaft, the Kommanditgesellschaft, the Gesellschaft mit beschränkter Haftung and the 
Aktionsgesellschaft. These translate freely as open partnership, limited partnership, limited liability firm 
and public liability firm.  

May 2017 I 29 

 
                                                           
Nominative shareholding requirement 

Requirements  on  nominative  shareholding  can  be  both  explicit  and  implicit.  In 
Luxembourg, the access control procedure specifies that no companies with bearer or 
endorseable shares are allowed. In 11 other countries with shareholding requirements 
(Table 3.2), the limitation to nominative shares is implicit. This may, for example, be 
caused  by  a  requirement  to  provide  a  list  of  all  shareholders  and  the  number  and 
values of their shares (and/or voting rights), or a requirement to submit a shareholder 
register, which per se eliminates the possibility of shareholding other than nominative. 
A  notable  exception  is  Germany  (Nordrhein-Westfalen)  where  the  Building  Chamber 
Law 
and 
“Aktiengesellschaften” 
“Kommanditgesellschaften  auf  Aktien”  (limited  partnerships)  only  the  majority  of 
shares must be nominative. Nonetheless, overall access is complicated for companies 
having  anonymous  shareholders  in  most  countries  where  shareholding  requirements 
exist. 

companies) 

specifies 

(stock 

that 

for 

Requirements may depend on the legal form 

In a number of countries, requirements depend on the legal form: Belgium, the Czech 
Republic, Italy, Malta, Portugal and Spain. In particular, requirements are different for 
partnerships. In Belgium, for example, partnerships can register with the professional 
chamber independently of the business register, but other firms cannot. Consequently, 
different  requirements  apply 
in 
requirements complicates the familiarization with procedures because it is not always 
clear  to  the  firm  aiming  to  provide  cross-border  services  which  legal  forms  in  the 
home country correspond to which legal forms in the host country.  

firms.  This  difference 

for  partnerships  and 

Shareholding, voting rights and management requirements 

Shareholding, voting rights and management requirements cover rules dictating that a 
certain percentage of shares, voting rights and management positions must be held by 
professionals.  These  rules  are  relevant  for  administrative  formalities  in  two  ways. 
Firstly, whenever they exist, compliance needs to be proven (regardless of the precise 
requirements),  which  causes  administrative  formalities.  Secondly, in some  situations, 
the  requirements  are  particularly  prone,  in  themselves,  to  increase  the  level  of 
administrative  barriers,  for  example  the  need  to  include  a  qualified  architect  as  a 
partner  causes  additional  forms  and/or  documents  to  be  submitted  and  sometimes 
even  an  examination  of  the  partner  in  the  host  country.  How  often  this  is  the  case, 
depends  on  the  required  percentage  of  actual versus  mandatory  participation:  a  firm 
with  100  per  cent  professionals  as  shareholders  faces  no  barriers  when  only  50  per 
cent  is  required,  but  a  firm  with  50  per  cent  professionals  as  shareholders  faces  a 
barrier  when  100  per  cent  is  required.  Therefore,  the  required  percentages  are 
relevant for this study. They are presented in Table 3.2 but not discussed further.  

To establish a branch, shareholding, voting rights and management requirements exist 
regardless  of  legal  form  in  nine  countries:  Austria,  Belgium,  Cyprus,  the  Czech 
Republic  (for  half  of  the  managers  or  more),  France,  Luxembourg,  Portugal  (for  one 
manager), Slovakia and Spain. In three additional countries, such requirements exist 
to  carry  the  title  “architect”  in  the  company  name:  Germany  (Nordrhein-Westfalen), 
Ireland  and  the  United  Kingdom.  In  two  further  countries,  such  requirements  exist 
only  for  partnerships:  Italy  and  Malta.  The  three  remaining  countries  in  the  study: 
Denmark, Poland and Romania do not impose any such restrictions.  

For  temporary  cross-border  services,  no  restrictions  apply  to  exercise  the  profession, 
except to carry the voluntary title in the company name in Germany, Ireland and the 
United Kingdom.  

Table  3.2  provides  an  overview  of  the  rules  on  shareholding,  voting  rights  and 
management requirements. 

30 I May 2017 

Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

Table  3.2  Architecture  –  Shareholding,  voting  rights  and  manager 
requirements 

MS  Establishment of a branch 

Temporary cross-border services 

Managers  Shareholding  Voting 
rights 
None 

100% 

None 

Managers 

None 

AT  51% a) 

Shareholding  Voting 
rights 
See 
shareholding 
60%; 100% 
b) 

BE  60%; 100% b)

CY  100% 

CZ  100% b); 50%

e) 

DE  None; 50% c)

DK  None 
ES  51% 
FR  51% 
IE  None 

IT  None; 2/3 b) 
LU  None  
MT  100% b) 
PL  None 
PT 

none; 51% b)

RO  None 
SK  51% 

UK  None 

none; 50% 
b) 
100% 

See 
shareholding 
See 
shareholding 
None; 50% c)  None; 50%

100% b); 
50% e) 

None 

None 

None 

See branches

None 
51% 
51% 
None; head 
architect d) 

None; 2/3 b) 
None 
100% b) 
None 
See 
shareholding 
None 
See 
shareholding 
None; head 
architect d) 

c) 
None 
None 
50% 
None; 
head 
architect d) 
None 
100% 
None 
None 
None; one 
architect b) 
None 
None 

None; 
head 
architect d) 

None 
None 
None 
None 

None 
None 
None 
None 
None 

None 
None 

None 

None 

None 

None 

None 

None 

None 

See 
branches 
None 
None 
None 
See 
branches 

See 
branches 
None 
None 
None 
See 
branches 

None 
None 
None 
None 
None 

None 
None 

None 
None 
None 
None 
None 

None 
None 

See 
branches 

See 
branches 

a)  Only for subsidiaries, because branches of foreign architecture firms are not recognized in Austria; 
b)  For professional partnerships only; 
c) 
d) 

In Germany, the 50% is required to carry the title “architect” in the company name; 
In Ireland and UK: “To carry the name "Architect" in the company name, it must be under control 
of a registered professional.” To exercise the profession: no requirements; 
In the Czech Republic, in a limited liability firm at least half of both shareholders and managers 
must be an architect. 

e) 

Voting  rights  and  management  requirements  usually  result  in  formalities  but  this  is 
not always the case. For example in the United Kingdom the Architecture Registration 
Board has no authorization procedure but monitors the business register and issues a 
warning  letter  or  takes  the  case  to  court  if  enough  evidence  of  title  misuse  is 
gathered.  

Multidisciplinary restrictions 

Multidisciplinary restrictions refer to prohibitions on combining certain services, aimed 
at avoiding conflicts of interest. They are relevant for administrative formalities to the 
extent that, apart from a control of corporate purpose, a statement can be required to 
demonstrate compliance. Multidisciplinary restrictions exist in one or other form in all 
17  countries  except  Denmark,  Ireland  and  the  United  Kingdom  (Table  A5.5  in  Annex 
5).  Explicit  statements  are  required  in  five  countries.  In  four  of  these,  the  company 
statutes  must  include  a  statement  on  multidisciplinary  restrictions  according  to 
specifics  of  the  host  country:  Austria,  Belgium,  Luxembourg  (for  branches  only)  and 
Spain  (for  partnerships  only).  The  fifth  country,  Romania,  requires  a  statement  from 
an authority in the home country on applicable multidisciplinary restrictions. 

May 2017 I 31 

 
 
Liability and insurance 

Regulations of liability and insurance were investigated in case they  have impacts  on 
administrative formalities, but with a few exceptions this is not the case. Figures A5.1 
and  A5.2  in  Annex  5  present  the  professional  liability  periods  and  amounts  to  be 
covered by compulsory professional indemnity insurance but are not discussed except 
when relevant for administrative formalities.  

In  Austria,  professional  indemnity  insurance  is  only  compulsory  for  public  works  but 
professional liability lasts  10  years  and  civil liability  as  defined in  the  Civil  Code  lasts 
30  years.  Hence,  insurance  is  regarded  as  de  facto  mandatory  and  it  takes  time  to 
assess what liabilities are covered by insurance policies (as reported in interviews).  

In  Belgium  and  France,  an  attestation  of  the  insurer  is  needed  in  which  the  insurer 
declares  that  works  in  the  host  country  are  insured  according  to  the  law  of  the  host 
country. The underlying reason is likely that in both countries the amount of damage 
is in principle limitless,  although in Belgium in practice damage caps  of EUR 500,000 
or EUR 700,000 are accepted. In addition, in Belgium the insurer needs to inform the 
professional  chamber  every  three  months  which  professionals  are  still  insured,  which 
indirectly is also an administrative formality for the architecture firm.  

In Italy, voluntary professional partnerships are required to subscribe to a professional 
indemnity  insurance  negotiated  by  the  professional  chambers.  However,  this  is  a 
regulatory  requirement  that  comes  without  administrative  formalities  and  is  not 
included in the cost calculations.  

In  Denmark  and  Romania,  architects  are  professionally  liable  for  their  work  but 
professional  indemnity  insurance  is  not  compulsory.  In  both  countries,  the  developer 
needs  to  insure  buildings,  in  particular  residential  dwellings.  Hence,  no  proof  of 
insurance is required to gain access to the market.  

3.3  Procedural steps 

Some  countries  set  more  procedural  steps  to  gain  authorization  than  others.  The 
following aspects of procedures were examined: 

•  Prior requirements (e.g. e-ID or inscription in the general business register); 
•  Prior authorization of shareholders, partners or managers; 
•  Different steps within the procedure. 

Prior  requirements  -  Establishment  procedure  integrated  with  business 
register in two countries 

Requirements  related  to  the  establishment  of  the  general  business  are  beyond  the 
scope of this study. However, in some countries they play a role in the authorization of 
service  providers  by  professional  chambers.  In  most  countries,  the  professional 
chamber is the authority controlling access to  the market for both establishment and 
temporary  cross-border  services  (Table  A5.3  in  Annex  5).  In  two  countries  (Belgium 
and Italy) permission to establish an architecture branch is integrated with the general 
business  procedure.  This  complicates  matters  because  the  procedure  starts  with  the 
professional  chamber,  is  continued  with  other  authorities  and  is  resumed  by  the 
chamber only after inscription with the other authorities is completed.  

In  Germany  (to  carry  the  voluntary  title  ‘architect’  in  the  company  name)  and  in 
Malta,  applicants  must  prove  inscription  in  the  general  business  register  to  the 
professional chamber. However, nothing prevents a firm from starting both procedures 

32 I May 2017 

 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

at  the  same  time  and  this is  a  mere  aspect  of  submission  demands.  In  Luxembourg, 
the Chamber does a background check on prior registration with the general business 
register and the VAT authority. In Spain a regional professional chamber passes on an 
application  to  the  national  ministry  of  development  with  their  advice.  This  ensures 
national  validity  of  authorization  and  does  not  otherwise  affect  administrative 
formalities.  

As  already  noted  in  Section  2.2,  compliance  with  professional  regulations  for  legal 
persons are checked by the Trade Licencing Office in the Czech Republic and Slovakia. 
This  is  considered  beyond  the  scope  of  this  study,  because  for  the  other  countries 
general  business  registration  (which  may  duplicate  the  chamber  procedure)  is  not 
analysed either.  

Prior requirements - National e-IDs are not required 

A  national  e-ID  may  be  used  to  handle  procedures  fully  online  in  Belgium,  Italy  and 
Malta, but procedures can also be handled by post in those three countries. Hence the 
national e-ID means that full online handling is only available to nationals but does not 
restrict foreign applicants apart from them having to post documents. 

Prior registration of shareholders does not seem to affect the procedure 

In  eight  out  of  the  17  countries  covered  by  the  study,  shareholders,  partners  or 
managers  must  be  authorized  before  a  legal  person  can  obtain  the  authorization  for 
permanent  establishment  (Austria,  Belgium,  France,  Ireland,  Italy,  Luxembourg, 
Portugal and Spain). In Germany, authorization is required to carry the title ‘architect’ 
in  the  company  name.  However,  except  perhaps  in  Austria  there  is  nothing  that 
prevents  firms  from  starting  the  procedure  for  authorization  of  the  shareholders, 
partners  or  managers  and  the  procedure  for  authorization  of  the  firm  at  the  same 
time.  In  Cyprus  (for  all  legal  forms)  and  Malta  (for  partnerships)  where  all  partners 
need to be authorized architects, the procedure for natural and legal persons is even 
one and the same.  

Different steps within the procedure 

Table 3.3 presents the  different steps within the procedure for establishing a branch. 
In three federally or quasi-federally organised countries (Austria, Italy and Spain) the 
chamber forwards the  application or part  of it to national authorities and informs the 
applicant  of  the  outcome.  This  ensures  coherent  national  validity  and  still  has  the 
advantage that the applicant needs to deal with only one office.  

The  procedures  of  countries  differ  mostly  with  regard  to  the  options  after  negative 
decisions.  These  were  identified  for  six  countries,  mostly  in  the  south  of  Europe: 
Austria, Cyprus, Ireland, Italy, Malta and Spain. In these countries, the chamber may 
demand  a  corrective  measure,  usually  with  the  example  of  examination  of 
shareholders or managers, or an adaptation period in the case of Malta. For the other 
countries no information was found that indicates to what extent a rejection is always 
final or if corrective measures may be demanded.  

Table 3.3 Architecture – Procedural steps to establish a branch cross-border 

MS 
AT a) 

Architecture - Steps to establish a branch 
Legal persons: the firm submits application form, names of all partners, their 
certificates of admission to a regional chamber. The regional chamber forwards the 
application together with their opinion to the Ministry of Science, Research and 
Economy. The Ministry decides and if positive, the regional chamber registers the firm. 
Natural persons (including mandatory for the executive manager): after all 
requirements are checked and approved, the authorisation for professional activity 
“Befugnis” is awarded by the Federal Ministry for Economics, Family and Youth. If the 
proof of authorization to practice as an architect is deemed insufficient, an exam needs 

May 2017 I 33 

MS 

BE 

CY 

CZ 

DE 

DK 

ES 

FR 

IE 

IT 

Architecture - Steps to establish a branch 
to be taken, the "Ziviltechnikerprüfung". Before making use of the authorisation the 
applicant has to take the oath that he will observe the law, his other responsibilities 
and the duty to confidentiality. 
For the Laruelle legal form: submit draft statutes to the Association of Architects of the 
Provincial Council. After approval submit the statutes to a Court of Commerce (for 
registration in the general business register). The procedure then resumes with the 
Provincial Council of the Association of Architects; further documents need to be 
submitted. 
For the professional partnership, documents can be submitted in parallel with the 
general business register. 
After approval by the council meeting the entity will be included in the professional 
tableau. In both cases authorization of the manager is needed before the firm can be 
registered.  
For both legal and natural persons (including mandatory for all shareholders): 1; 
Application of membership to the Cyprus Scientific and Technical Chamber (ETEK) 
accompanied with necessary documentation and fees; 2. In case of a rejected 
application the applicant can ask for i) guidance on steps needed in order to 
successfully register and ii) ask for re-examination after completing missing documents 
and repaying the registration fee. 
Natural persons (including partners of a voluntary professional partnership): 1. The 
applicant needs to have his signature verified; 2. the applicant pays the fee; 3. the 
applicant has to submit to the Czech Chamber of Architecture a notification and 
application for registration together with accompanying documents; 4. the Chamber 
can ask for additional information or documents and if necessary, investigates the 
professional qualification of the applicant; 5. if nothing prevents the registration, the 
applicant is put in the list of registered architects in the Czech Republic; Legal persons 
in general: requirements to establish a branch cross-border follow from the general 
business register, which is beyond the scope of the study. 
For natural persons (including mandatory for shareholders of firms that wish to carry 
the title “architect” in the company name): 1. Secure a professional or residence 
address in Germany; 2. Register in the general business register; 3. Pay the 
registration fee to the chamber; 4. Submission of documents (no proof of insurance); 
5. Chamber decides and if it approves enters the application in a the list of architects; 
For branches (and subsidiaries): 1. Secure a professional address; 2. Register in the 
general business register; 3. submission of documents (including proof of insurance); 
4. Chamber decides. 
Architecture is not regulated. Branches (and subsidiaries) must register in the general 
business register but this is out of scope. 
For legal persons: The demand is presented to a regional Chamber of Architects which 
analyses it and demands additional documents if needed; authorization to do 
architectural works in Spain is granted by the Ministry of Development (Ministerio de 
Fomento); the Chamber of Architects notifies the service provider of a positive decision 
(published in the Official Journal) or of the need for corrections. In addition, the firm 
must register in the general business register (also branches and one-person firms). 
For natural persons (including mandatory for shareholders of voluntary partnerships): 
application to register with the Chamber.  
Both natural (including mandatory for shareholders) and legal persons: 1. A 
professional address in France must be secured; 2. all documents are submitted, 3. the 
chamber verifies the documents; 4. insurance must be proved to the client for every 
project. 
Legal persons wishing to carry the title "architect" in the company name must register 
a natural person as architect and submit company data for approval. For this natural 
person documents must be submitted. For non-nationals, the Admissions Board may: 
a. require any additional data; b. require an application interview; c. seek independent 
verification; d. require an aptitude test or an adaptation period of up to 3 years; or e. 
decide that language aptitude is insufficient. 
Legal persons (both branches and subsidiaries): First registration of the natural 
persons providing the services. Chamber of Commerce of the relevant province: 1. 
Opening of the local unit (non-legal entity) to be registered in Italy's Economic and 
Administrative Index (REA). The Chamber of Commerce then registers the branch or 
agency with the fiscal authorities, INAIL (for professional liability), INPS (worker 
pensions). 2 Registration at the Order of Architects of the relevant province. 3. After 
the firm is registered with this chamber, the registration in the general business 
register is finalized. Natural persons (including mandatory for the shareholders of 

34 I May 2017 

Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

MS 

LU 

MT 

PL 
PT 

RO 
SK 

UK 

Architecture - Steps to establish a branch 
voluntary partnerships): 1. Submission of the application to the competent authority 
(Ministry); 2. The Ministry analyses the file; 3. the application is accepted and the 
provider is notified, or compensative measures can be required, usually an exam, 4. 
Registration with a regional Order of Architects. 
First step: authorisation of establishment; this requires a fixed business place in 
Luxembourg, proof of good reputation (the administration will do a background check) 
and sufficient professional qualifications (this requires registration of the diploma with 
the Ministry for Higher Education and Research). Second step: obtain a licence to the 
Luxembourg VAT registration. Third step: Registration with the Order of Architects.  
Legal persons: only need to register in the general business register. The professional 
chamber checks the requirements for voluntary professional partnerships in one and 
the same procedure as for natural persons. Natural persons (including mandatory for 
partners of a voluntary partnership): they need a warrant to practice the profession of 
a Perit in Malta. Besides submission of documents, for residents of other EU countries 
S.L.453.01, Art.16 provides that a Board may require an adaptation period in Malta of 
up to 3 years under supervision if foreign qualifications differ substantially from the 
Maltese requirements. The Periti regulation S.L. 390 3.4 specifies this training shall not 
be less than 6 months and that the Board may subject the applicant to additional tests 
as is deemed necessary.  
None: only professionals providing the services can (and must) be registered 
Both legal and natural persons (including mandatory for shareholders of a voluntary 
partnership): submission of documents and decision by the chamber.  
None: only professionals providing the services can (and must) be registered 
Natural persons (including a majority of shareholders of a voluntary architecture 
partnership): an exam in Slovakia Legal persons: none (the Trade Licencing office 
checks compliance with professional regulations for legal persons which is beyond the 
scope of the study). 
None: use of the title “architect” in the company name is only controlled ex post. 
a)  Only for subsidiaries, because branches of foreign architecture firms are not recognized in Austria. 

Procedures  for  temporary  services  (Table  3.4)  are  usually lighter  than  for  permanent 
establishment.  In  the  east  of  Europe  (the  Czech  Republic,  Poland  and  Romania),  the 
procedures  again  only  apply  to  natural  persons  and  actually  only  procedures  for  the 
general  business  registration  (which  are  out  of  scope  of  this  study)  are  lighter. 
Practically,  in  these  countries  foreign  architecture  firms  collaborate  with  local  firms. 
This is explicitly required in the Czech procedure.  

In  France  and  Italy,  it  is  explicitly  stated  that  an  aptitude  test  may  be  required  for 
temporary  services,  but  only  for  professionals  providing  the  services,  which  falls 
outside the scope of the study. In Austria, the only requirement is to provide the client 
with certain documents and temporary services can be provided without limitation. In 
Ireland, there is no different procedure to carry the voluntary title of ‘architect’ in the 
company name to provide temporary services. Hence authorization of a head architect 
is  assumed  to  be  required  as  is  the  case  for  branches,  but  a  lighter  “route”  can  be 
followed for authorization of temporary services. In Denmark and the United Kingdom, 
no ex ante procedures are in place for architecture services.  

Table 3.4 presents the different steps within the procedure for provision of temporary 
services. 

Table 3.4 Architecture – Procedural steps for temporary services 

MS  Architecture – steps for temporary services 
AT  None: only a number of documents needs to be provided to the client 
BE  One-off assignments: register with the National Council of the Order to be included in the 

register of service providers and submit qualification documents.  

CY  Application with the Chamber accompanied with the necessary documentation for approval 
CZ 

Legal persons: need to have their signature verified, to submit documents for 
professionals delivering the services, swear an oath and pay registration fees 

DE  Natural persons (including mandatory for shareholders of firms that wish to carry the title 
‘architect’ in the company name): 1. Notification of first assignment with the Chamber of 

May 2017 I 35 

MS  Architecture – steps for temporary services 

Architects; 2. Payment of the fee; 3. Submission of qualification documents; 4. Chamber 
decides and if it approves enters the application in a special list of foreign architects; 5. 
Chamber issues an attestation ("Bescheinigung") that entitles the service provider (natural 
person) to carry the title 'architect'; 6. The attestation has duration of maximum five 
years, so other activities within the duration of the attestation need not be notified. 7. 
There is no renewal procedure after the attestation expires. Legal persons: submission of 
documents, Chamber checks and enters the company in the company directory of the 
Chamber after approval  
DK  Architecture is not regulated 
ES 

Legal persons, if not a partnership: Submission of documents to the ministry of 
Development (Ministerio de Fomento) which then decides. Voluntary professional 
partnerships: 1- Application for a certificate to prove that no other company is operating 
under the same name (negative certifications). 2- Tax Agency (AEAT): Tax Identification 
Number; 3- Notary: Public deed; 4- Chiefs of Finance of the Autonomous Communities: 
Tax on capital transfers and documented legal acts; 5- Provincial Companies Registry: 
Registration of the company; 6. Registration with a provincial College of Architects 

FR  Only a notification. Authorization only applies to professionals providing the service. 
Submit documents to the Chamber (RIAI). On approval, registration in a register of 
IE 
temporary service providers. RIAI may require the temporary cross-border service 
provider to furnish the client with the same documents. Voluntary to carry the title 
“architect” in the company name: a natural person must be registered as an architect. For 
this natural person documents must be submitted. For non-nationals, the Admissions 
Board may: 
a. require any additional data; b. require an application interview; c. seek independent 
verification; d. require an aptitude test or an adaptation period of up to 3 years; or e. 
decide that language aptitude is insufficient. 

IT  Only a notification. Authorization only applies to professionals providing the service. 
MT  A prior declaration of temporary cross-border services is needed. Other requirements 

apply only to natural persons providing the service and are out of scope. 

PL  None: requirements only apply to professionals providing the service. 
PT  None: requirements only apply to professionals providing the service. 
RO  None: requirements only apply to professionals providing the service. 
SK  None: requirements only apply to professionals providing the service and legal persons 

cannot even be registered. 

UK  None: misuse of the title “architect” in the company name is only controlled ex post 

3.4  Deadlines 

Deadlines  for  completing  authorization  procedures  vary  between  Member  States 
(Table  3.5).  In  countries  where  qualification  of  shareholders,  partners  and/or 
managers  is  a  prerequisite  for  authorization  of  a legal  person,  it is  assumed  that  the 
procedures  for  authorization  of  natural  and  legal  person  run  in  parallel.  Only  very 
rarely does the law specify that an application of a legal person can only be submitted 
after all relevant natural persons are authorized. Hence, there seems no legal basis to 
refuse  processing  applications  of  the  legal  and  natural  persons  at  the  same  time. 
Austria  may  be  an  exception  because  all  documents  (including  proof  of  authorization 
of  the  executive  manager)  need  to  be  submitted  before  the  procedure  for  legal 
persons starts. A period of three months for the procedure in Austria was used (eight 
weeks for the executive manager and four weeks for the legal person). 

Table 3.5 Architecture – Deadline for handling by authorities 

MS  Establishment of a branch 

AT 
a) 

The national deadline for any processing by the Chamber is 
3 months. Länder may provide shorter deadlines e.g. 8 
weeks for natural persons and 4 weeks for legal persons but 
they tend to be indicative 

Temporary cross-
border services 
Not applicable (no 
procedure) 

BE  Professional partnerships (and natural persons including 

mandatory for shareholders): 3 months; Other legal forms 
(Laruelle form): Preliminary check of draft statutes: not 

Natural persons: 3 
months Legal persons: not 
applicable (no procedure) 

36 I May 2017 

 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

MS  Establishment of a branch 

Temporary cross-
border services 

specified; General business register (with which the 
procedure of the professional chamber is integrated): 30 
days; registration with Chamber: 3 months 
CY  3 months after submission of complete documents 

(procedures for natural and legal persons are one and the 
same) 

CZ  Natural and legal persons: 60 days after documents are 

DE 

considered complete and 3 months from the submission of 
the application; for legal persons in addition the 
representative needs to swear an oath after approval of the 
documents 
Legal persons wishing to carry the title “architect” in the 
company name: no set deadline but presumably short 
(simple formalities) Natural persons (including mandatory 
for shareholders to carry the title “architect” in the company 
name), if from Germany: 1 month to confirm completeness 
of documents, 3 months after submission of complete 
documents with a possible extension of 2 months (BauO 
NRW § 70.4), for other EU nationals no deadline is set 
(BauO NRW § 70.5);  

DK  None (not a regulated profession) 

ES 

Legal persons: 1 month for the Chamber with a possible 
extension of 2 months Natural persons (including mandatory 
for shareholders): 3 months  

FR  Registration (both legal and persons including mandatory 

IE 

for shareholders): 2 months from the date of the 
acknowledgement of receipt, note that prior recognition of 
natural persons (managers) takes 5-7 months (see 
temporary services) 
Legal persons to carry the title ‘architect’ in the company 
name: 8 weeks. Natural persons (including mandatory for 
the head architect to use the title ‘architect’ in the company 
name: 3 months with a possible extension of 1 month 
IT  General business register (with which the procedure of the 
professional chamber is integrated): 30 days; Order of 
architects (both legal and natural persons including 
mandatory for shareholders of voluntary professional 
partnerships): 30 days to examine completeness of the 
files, 3 months after submission to accept the demand; 4 
months if the demand is rejected and the service provider 
needs to provide compensative measures  
Legal persons: one month (the Examination Committee 
meets once a month) 

LU 

MT  General business register: 3 days for assessing 

completeness and 10 days for approval (but could be one in 
1 day after all documents are complete); Chamber of Periti: 
3 months from complete application, 1 month extension 
possible 

PL  None: only for professionals providing the services  
PT 

In case of no issues: 20 days 

RO  None: only for professionals providing the services  
SK  For shareholders of voluntary architecture partnerships: the 

exam can be done three times per year and qualification 
documents must be submitted one month in advance, so 
the deadline varies from 1 to 4 months (the requirement is 
checked by the Trade Licence Office but the exam is with 
the Chamber) 

Same as for branches 

Natural persons: same as 
for branches Legal 
persons: not applicable 
(no procedure) 

Same as for branches 

None (not a regulated 
profession) 
Legal persons: 1 month 
with a possible extension 
of 2 months  
None (only a notification 
is required, authorization 
only applies to 
professionals providing 
the services)  
Same as for branches 

None (only a notification 
is required, authorization 
only applies to 
professionals providing 
the services)  

Legal persons: one month 

None (only a notification 
is required) 

None 
In case of no issues: 20 
days 
None 
None 

UK  None: use of the title ‘architect’ is only controlled ex post 

Same as for branches 

a)  Only for subsidiaries, because branches of foreign architecture firms are not recognized in Austria. 

May 2017 I 37 

Figure  3.1  shows  the  maximum  times  for  authorities  across  the  EU  to  process 
applications  for  setting  up  branches  of  architecture  firms  and  providing  temporary 
architectural  services.  The  maximum  possible  extension  is  also  shown,  but  time 
expended  by  the  examination  requirements  for  shareholders  or  managers  is  not 
covered  (for  example  in  Ireland,  Italy  and  Malta),  except  for  Slovakia  where  the 
frequency  of  examination  is  explicit.  The  procedure  takes  longest  in  Belgium,  France 
and  Italy  and  is  quickest  in  Portugal  and  Luxembourg.  For  temporary  services,  the 
procedure takes longest in Malta (for voluntary professional partnerships). It should be 
noted  that  interpretations  of  deadlines  vary  across  countries.  For  example,  in  Italy  a 
decision  can  be  expected  after  four  months  whereas  in  Austria  and  Malta  it  could  be 
made anytime up to three months after receipt of the application.  

Figure 3.1 Architecture – Deadlines for handling by authorities (in months) 

3.5  Tacit approval and validity 

Tacit  approval  means  that  the  activities  may  be  started  if  the  deadline  for 
authorization  has  expired  before  the  authority  has  notified  its  decision.  For 
establishment  of  a  branch,  tacit  approval  is  explicit  in  three  countries  (Germany  to 
carry  the  voluntary  title  in  the  company  name),  Luxembourg  and  Portugal.  Tacit 
approval  is  implicit  because  no  procedure  applies  to  legal  persons  in  five  further 
countries:  Denmark,  Poland,  Romania,  Slovakia  and  the  United  Kingdom.  For 
temporary services, tacit approval is explicit in Luxembourg and Portugal and implicit 
in nine further countries (Table 3.6). 

Table 3.6 Architecture – Tacit approval 

Establishment of a branch 

No, except for partnerships 
No 
No (authorization required of 

MS 
AT a)  No 
BE 
CY 
CZ 

38 I May 2017 

Temporary cross-border services 
N/A (no authorization needed) 
No 
No 
N/A (and not for professionals providing the 

 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

MS 

DE 

DK 
ES 
FR 

IE 
IT 

LU 
MT 

PL 

PT 
RO 

SK 

UK 

Establishment of a branch 
shareholders if a partnership and of 
managers if a limited liability firm) 
Yes (to carry the voluntary title in 
the company name) 
N/A (not a regulated profession) 
No 
No 

No 
No 

Yes 
No 

N/A (and no for professionals 
providing the services) 
Yes 
N/A (and no for professionals 
providing the services) 
No (authorization required of 
shareholders of a voluntary 
professional partnership) 
N/A (only control ex post) 

Temporary cross-border services 
service) 

No (to carry the voluntary title in the company 
name) 
N/A (not a regulated profession) 
No 
N/A (and no for professionals providing the 
services) 
No 
Yes (even for professionals providing the 
services) 
Yes 
N/A (and no for professionals providing the 
services) 
N/A (and no for professionals providing the 
services) 
Yes 
N/A (and no for professionals providing the 
services) 
N/A (and no for professionals providing the 
services) 

N/A (only control ex post) 

a)  Only for subsidiaries, because branches of foreign architecture firms are not recognized in Austria. 

N/A: no authorization needed, hence tacit approval is not applicable. 

When  an  architecture  branch  is  established,  authorization  is  in  most  countries 
indefinite,  or  depends  on  an  annual  fee.  Only  in  Cyprus  the  time  authorization  has 
limited  time  validity,  namely  one  year.  Each  year,  the  same  application  needs  to  be 
filled in for renewal of the license (Table 3.7).  

For  temporary  cross-border  services,  the  authorization  is  valid  for  one  year  in  most 
countries  and  can  be  renewed  every  year  except  in  two  countries  (Malta  -  for 
voluntary  partnerships  -  and  Spain),  where  authorization  for  temporary  services 
depends on the duration, regularity and continuity of the services. In most countries, 
new documents need to be submitted, although always with the exception of proof of 
professional  qualifications  (of  natural  persons).  In  Germany,  a  license  for  temporary 
cross-border  services  is  valid  for  at  most  five  years.  This  means  that  the  German 
Chamber may issue a licence for  five years, but also for a  shorter period.  In Austria, 
temporary cross-border services may be provided indefinitely. 

Table 3.7 Architecture – Time validity 

MS  Establishment of a branch 
AT 
a) 

Indefinite 

BE  Annual fee 
CY  1 Year; new docs required 

CZ 
DE 

Indefinite 
Indefinite 

DK 
ES 

Indefinite (not a regulated profession) 
Legal persons: indefinite, natural 
persons (including mandatory for 
shareholders): annual fee 

FR  Annual fee 
Annual fee 
IE 
Annual fee 
IT 
LU 
Indefinite 
MT  Annual fee 

Temporary cross-border services 
Indefinite 

1 Year; new docs required 
Shortest of project duration and 1 year; new 
docs required 
Legal persons: no procedure 
Legal persons: indefinite, natural persons: at 
most 5 years  
Indefinite (not a regulated profession) 
Depends on duration, continuity and regularity; 
if issued then for 1 Year; new docs required 

1 Year; new docs required 
1 Year; new docs required 
1 Year; new docs required 
Project duration 
Depends on duration, regularity, periodicity, 

May 2017 I 39 

MS  Establishment of a branch 

PL 

Indefinite: no procedure for legal 
persons 

PT  Annual fee 

RO 

SK 

UK 

Indefinite: no procedure for legal 
persons 
Indefinite: no procedure for legal 
persons 
Indefinite (no control ex ante) 

Temporary cross-border services 
continuity of services 
Indefinite: no procedure for legal persons 

Legal persons: no procedure, natural persons: 
annual fee 
Indefinite: no procedure for legal persons 

Indefinite: no procedure for legal persons 

Indefinite (no control ex ante) 

a)  Only for subsidiaries, because branches of foreign architecture firms are not recognized in Austria.  

In most countries the authorization is nationally valid. This includes countries such as 
Austria, Italy and Spain, where a regional chamber usually forwards applications to a 
national  ministry.  The  greatest  exception  to  this  rule  is  Germany,  where  both  the 
procedures and the validity are regional (at the level of a Bundesland). Recognition in 
another Bundesland depends on the laws of that Bundesland. For example, Nordrhein-
Westfalen  recognizes  membership  in  other  German  regions  (Länder).  Hence 
Nordrhein-Westfalen  only  requires  proof  of  registration  in  another  Bundesland  and  in 
that  case  will  not  enter  the  natural  person  in  the  NRW  register.  In  case  the  person 
wants a secondary entry in the NRW register, the regular requirements apply.  

In Italy, authorization is nationally valid but if a firm or professional moves within Italy 
and  wants  to  make  use  of  the  services  of  a  different  regional  chamber,  he  needs  to 
follow a procedure to move the registration.  

In  France,  authorization  of  an  establishment  is  nationally  valid.  Authorization  of 
temporary  services  is  nationally  or  regionally  valid  depending  on  whether  a  shorter 
regional procedure or a longer national procedure is followed.  

3.6  Fees 

Figure 3.2 presents the fees charged by the responsible authorities for compulsory 
registration and/or compulsory chamber membership of the firm and/or shareholders 
or managers (even if they do not provide the services). The fees presented in Figure 
3.2 are first-time fees, but the part of the fee that must be paid every year is marked 
in a lighter colour. Fees of the general business register are excluded as they are 
beyond the scope of the study, even if it is mandatory for branches of firms from other 
EU countries to register with the general business register. Fees of social security 
institutes that must be paid as part of the registration process with the professional 
chamber in Italy are also excluded. Furthermore, a fee per project required by the 
chambers in Portugal and Spain (this is not the building permit fee but a fee for a 
check that the project is managed by qualified professionals, the so-called “visado”), is 
excluded as they relate to ongoing work instead of initial access to the market.  

Information about fee requirements for shareholders or managers was found for only 
one country, Austria where fees need to be paid for the registration and membership 
of the  executive manager. For the  other countries fees for managers  or shareholders 
are  included  if  (a)  he  or  she  needs  to  be  an  authorized  professional  even  if  he  does 
not  provide  the  services  and  (b)  registration  or  membership  is  compulsory  for 
professionals.  

In  three  countries  (the  Czech  Republic,  Romania  and  Slovakia)  there  is  no  fee  for 
firms, shareholders or managers. Still, a fee is levied for at least one professional for 
access to the market and the fee for one professional is used.  

40 I May 2017 

 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

If a fee is required for registration or membership of shareholders and/or managers, it 
is  included  for  one  person  even  if  a  firm  has  more  shareholders  or  managers.  One 
reason is that there might just be one shareholder or manager, and applying the fee 
to  more  persons  would  reflect  differences  between  firms  rather  than  between 
administrative requirements. Another reason is that in many countries only half of the 
shareholders  must  be  an  authorized  professional  (see  Table  3.2)  and  then  the  fee 
need not be paid for all shareholders or managers.  

Another  assumption  is  that  whenever  (a)  shareholders  and/or  managers  need  to  be 
professionals and (b) the same fee applies to both natural and legal persons, the fee 
must be paid twice: once for the shareholder or manager and once for the firm. This is 
the case for Luxembourg (for both branches and temporary services) and for Germany 
(for  temporary  services).  This  interpretation  confirmed  by  an  architecture  firm 
operating  cross-border  in  Luxembourg  that  reported  EUR  140  registration  fees  while 
the  (current)  official  fee  is  EUR  80  for  both  the  registration  of  natural  and  legal 
persons. 

Lastly,  whenever  fees  are  available  both  including  and  excluding  professional 
indemnity  insurance,  the  fee  excluding  professional  indemnity  is  used  because 
professional 
is  a  regulatory  rather  than  administrative 
requirement,  which  is  beyond  the  scope  of  the  study.  However  in  one  country  (the 
Czech Republic) there is just one fee which includes professional indemnity insurance.  

indemnity 

insurance 

The fees are highest in the three countries where it is required for the voluntary title 
‘architect’ in the company name: the United Kingdom, Germany and Ireland. The fees 
are  mainly  for  the  authorization  of  a  shareholder  (in  Germany)  and  fully  for  the 
authorization of the head architect (in Ireland and the United Kingdom):  

•  United Kingdom (to carry the voluntary title ‘architect’ in the company name, 
with exchange rate 0.8): application fee GBP 35 and registration fee GBP 142; 
for the prescribed examination of the head architect: GBP 1,671 per part; GBP 
300 for referral to a lead examiner and twice the annual fee of GBP 100 per 
head architect (in case one becomes sick). The fee is calculated as (35 + 142 + 
1671 + 300 + 2 x 100)/0.8 = 2,998; 

•  Germany (branches wishing to carry the voluntary title ‘architect’ in the 

company name): For legal persons EUR 500, for natural person: Registration 
fee of EUR 260 or 450 depending on the situation (e.g. in case of need for an 
opinion from the committee of experts); EUR 550 -800 for expert opinion; 
membership fee of EUR 126 (not employed), 196 (employed) or 277 (freelance 
members). The fee is calculated as 500 + 450 + 800 + 126 = 1,876; 
Ireland (branches): EUR 145 for qualifications check (but this is beyond the 
scope of the study), in addition for non-Irish nationals (route B): assessment of 
documentary evidence EUR 325 and interview EUR 465. Annual fee (whether 
registration only or registration + membership): EUR 490. The fee is calculated 
as 325 + 465 + 490 = 1,280. 

• 

For  the  other  countries  the  following  is  included  in  the  fees  for  branches  (in 
descending order of total fee amount): 

•  Belgium: 580 = 100 + 480 (annual membership of the firm and one 

shareholder); 

•  France: 760 = 480 (registration of the firm) + 280 (registration of one 

shareholder); 

•  Austria: 420 = 220 (authorisation (Befugnis) by the Federal Ministry) + 2 x 

100 (registration of the firm and the executive manager); 

•  Spain: 380 = registration fee of a regional College of architects (COAM in 

Madrid); 

May 2017 I 41 

 
• 

Italy: 343 = 168 registration tax (this is a national tax and the same for all 
regional chambers) + 175 annual membership fee (the average of EUR 100 in 
Milan and EUR 250 in Modena); 

•  Cyprus: 295 = 100 (registration of legal persons) + 10 (registration certificate) 
+ 55 (registration of one shareholder) + 100 (annual membership of legal 
persons) + 30 (annual professional licence of one shareholder). The annual 
cost is 230 = 140 (registration certificate + membership + professional licence) 
+ 90 (annual renewal of subscription); 

•  Portugal: 295 = registration fee for a voluntary professional partnership from 

other EU countries; 

•  Czech Republic (with exchange rate 27): 296 = (CZK 2,000 registration and 

CZK 6,000 annual membership)/27; 

•  Slovakia: 250 (registration of one professional); 
•  Luxembourg: 160 = 2 x 80 per registration (for the firm and one shareholder); 
•  Romania (with exchange rate 4): 158 = 630 / 4 (registration of one 

professional);  

•  Malta: 94 = 14 registration fee + 80 full annual membership fee of one 

shareholder in a voluntary professional partnership.  

Figure 3.2 Architecture – First-time fees for legal persons a) (in EUR) 

a)  Except for the Czech Republic, Poland, Romania and Slovakia where no chamber procedure for 

legal persons exists (only for natural persons).  

No  fees  for  legal  persons  are  charged  in  Denmark  and  Poland.  In  Denmark,  fees  are 
absent  because  the  profession  is  not  regulated,  the  fee  for  the  compulsory  general 
business  registration  (also  for  branches)  is  not  included  and  membership  of  the 
professional  association  Danske  Ark  is  voluntary.  In  Poland,  registration  is  a  free 
public service.  

42 I May 2017 

 
 
 
 
Administrative formalities and costs involved in accessing markets cross-border for 
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3.7  Online information and procedures 

The  availability  of  online  information  and  procedures  are  not  formalities,  but  rather 
tools  to  facilitate  going  through  the  procedure.  As  confirmed  in  this  study,  in  some 
countries  a  substantial  part  of  the  burden  of  administrative  formalities  consists  of 
finding the relevant practical information about the procedure. Also, as demonstrated 
earlier,  procedures  can  take  many  months  to  complete  and  online  procedures  may 
help reduce the length of the procedure.  

At  the  EU  level,  one  single  start  page  is  available  which links  to  national  start  pages 
about  access  control  procedures  and  applicable  requirements,  the  so-called  Points  of 
Single Contact (PSC).6 The national PSC pages are updated by the Member States. All 
countries  have  a  point  of  single  contact  (PSC);  however  in  five  countries  the  PSC  is 
not  specific  about  procedures  for  authorization  of  architectural  services:  Belgium, 
Germany,  Ireland,  Italy  and  the  United  Kingdom  (Table  3.8).  In  Portugal  and  Spain, 
information  about  access  to  the  profession  is  available,  but  only  in  the  national 
language.  

In almost all countries forms can be downloaded, but documents need to be posted. In 
three  countries  online  procedures  are  available  to  non-nationals:  in  Cyprus  and 
Portugal  via  email  (which  respondents  prefer  over  uploading);  and  in  Luxembourg 
documents  need  to  be  posted  but  further  case  handling  is  fully  electronic.  In  three 
further  countries  (Belgium,  some  Italian  regions  and  Malta)  full  electronic  case 
handling is only available to nationals because a national e-ID is required.  

In Romania and Spain documents must be delivered in person. In the Czech Republic 
a person must, according to the law, have his signature certified on a special form in 
the  presence  of  a  local  official;  foreign  persons  can,  however,  swear  their  signature 
before a notary in their own country.  

The  availability  of  online  information  and  procedures  is  practically  the  same  for 
establishing branches and temporary services. 

Table 3.8 Architecture – Electronic information and procedure 

MS  PSC 

Establishment of a branch 

AT  DE, EN 

BE  NL, FR 
CY  EL, EN 

CZ  CZ, EN 

DE 

--- 

DK  DK, EN 

ES  ES 
FR  EU* 
IE 
IT 

--- 
--- 

LU 

FR,DE,EN 

Forms can be downloaded; documents must be 
posted 
Documents must be posted 
Electronic submission procedure available (but link 
not working during the study), forms (in Greek) 
can be downloaded 
Signature must be notarized, forms (in the Czech 
language) can be downloaded, documents must be 
posted 
Forms can be completed online, documents must 
be posted 
No authorization or notification 

Forms downloadable, must be delivered in person 
Forms downloadable and must be posted 
Forms downloadable and must be posted 
Some regional Orders of Architects: online 
procedure, but in most: documents must be 
posted 
Information must be posted, a VAT registration 
form must be collected in person 

Temporary cross-
border services 
No authorization or 
notification  
Same as for branches 
Same as for branches 
but forms in English 

Same as for branches 

Same as for branches 

No authorization or 
notification 
Same as for branches 
Same as for branches 
Same as for branches 
Same as for branches 

Same as for branches 

6   http://ec.europa.eu/internal_market/eu-go/index_en.htm. 

May 2017 I 43 

                                                           
MS  PSC 

Establishment of a branch 

MT  EN 

PL 

PL, EN 

PT 
PT 
RO  RO, EN 

SK  SK, EN 

UK 

--- 

Forms can be downloaded; documents must be 
posted  
Forms can be downloaded; documents must be 
posted 
Documents can be emailed 
None (only for professionals providing the 
services: forms can be downloaded and emailed, 
documents must be delivered in person) 
None (for legal persons: checked by the office for 
the general business register, for shareholders of 
voluntary professional partnerships: only 
professional qualification documents; both are out 
of scope) 
No authorization or notification 

Temporary cross-
border services 
Same as for branches 

Same as for branches 

Same as for branches 
Same as for branches 

None (only for 
professionals providing 
the services) 

No authorization or 
notification 

--- means: not available. 

3.8  Submission demands - branches 

Most  countries  require  an  application  form  to  be  filled  in  with  personal  data  and 
sometimes  a  passport/ID-number  and  details  about  the  educational  degree  of 
shareholders  and/or  managers  (Table  3.9).  Countries  that  require  substantial 
additional  data  to  be  submitted  are  Cyprus  (multiple  registration  and  ID  numbers, 
start  and  end  dates  of  all  qualifications),  Ireland  (specific  details  about  the 
organization  structure  and  all  premises)  and  Portugal  (start  and  end  dates  of  all 
previous employment).  

With  regard  to  data  requirements  on  shareholders  and  managers  as  opposed  to 
professionals  providing  the  service,  in  only  one  country  (Austria)  the  submission 
demands  are  clearly  differentiated.  Sometimes  one  page  in  English  clarifies  demands 
for non-nationals. This is the case in Cyprus where the application form may give the 
impression  that  residency  in  Cyprus  is  required  and  the  page  in  English  clarifies  that 
residency in any EU Member State is accepted for EU citizens.  

In most countries, however, the submission demands for shareholders and managers 
on  the  one  hand  and  for  professionals  providing  the  services  are  not  clearly 
differentiated. This is the case in Germany but also some other countries. In Germany 
(Nordrhein-Westfalen), to carry the title “architect” in the company name, 50 per cent 
of  the  shareholders  must  be  authorized  architects.  And  §  8.2  BauKaG  NRW  provides 
firstly  that  the  shareholding  architects  must  be  able  to  exercise  their  profession 
independently  (freien  Beruf),  and  secondly  that  for  the  shareholders  one  of  the 
professions from a list in § 1 of that law for which authorization is needed. There is no 
indication  that  recognition  according  to  the  EU  Professional  Qualifications  Directive 
suffices,  even  though  from  interviews  this  sometimes  appears  to  be  the  case.  More 
generally, whenever submission demands for shareholders who must be architects are 
not  separately  provided,  as  in  Austria,  the  submission  demands  for  authorization  of 
professionals is presented.  

The data submission demands for the authorization of professionals are given in Table 
3.9. The minimum requirement is the name and address of the firm. Other data that 
may  be  demanded  include  further  ID  information,  further  contact  details,  a  tax 
number  of  the  host  country  (in  Belgium,  Cyprus  and  Italy),  details  of  the  area  of 
expertise (typically in host countries where the same procedure applies to architecture 
and  civil  engineering:  Austria,  Cyprus,  the  Czech  Republic)  and  educational  data 
(included  for  countries  where  this  is  required  of  shareholders  and/or  managers: 
Cyprus, France, Germany for a voluntary title in the company name, and Italy). 

44 I May 2017 

 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

Data requirements are particularly demanding in four countries: Cyprus (start and end 
dates  of  educational  qualifications  with  specializations  for  shareholders),  Ireland 
(details  on  the  business  structure),  Italy  (a  lot  of  data  including  for  example  year  of 
graduation for shareholders of voluntary professional partnerships) and Portugal (a list 
of all previous employers with start and end dates).  

Table 3.9 Architecture – Data to be submitted (branches) 

MS  Architecture – data submission demands (branches) 
AT 

Legal persons: area of expertise of the firm, name of the company, address of company 
headquarters Natural persons (including mandatory for the executive manager): name 
and city of residence, date and place of birth, place of office, phone number and email 
address 

BE  Registration in the general business register (as part of the integrated procedure with the 

CY 

Chamber of Architects): City and registration number under which the firm is registered 
in the general business register of the home country Address and activities of the branch 
in Belgium, company name and identity of legal representatives of the firm in the home 
country Registration with the Chamber: Name of person or firm, nationality, authority 
where registered as architect (name, country, street and house number, city, postal 
code), place of office (country, street and house number, city, postal code, phone, fax, 
GSM, email) 
Legal persons: Name and address, Engineering disciplines of specialisation, Company 
number of registration with Tax authorities, Name and registration number and discipline 
of employees registered with ETEK, Company logo Natural persons: Personal data (name, 
surname, father's name, ID, Passport, nationality, date and place of birth, occupation); 
Contact details (Residential, professional address or other contact details and 
preference); Educational qualifications with specializations, start and end date; Specifics 
of internship in Cyprus; Choice of engineering discipline of registration; Document 
checklist; Declaration of honour (regarding truthful information and of criminal record 
status) 

CZ  Natural persons providing the services (which the legal person needs to submit) and 

mandatory for managers and partners of voluntary partnerships: notification form and 
application for registration form; activities which he/she plans to perform systematically 
in the Czech Republic; delivery address on the territory of the Czech Republic 

DE  Natural persons (including for 50% of the shareholders of firms that wish to carry the 

title “architect” in the company name) and legal persons (Nordrhein-Westfalen): Name; 
nationality; academic degree; birth date; address; address of the registered office.  

DK  None: not a regulated profession 
ES 

FR 

IE 

IT 

Legal persons, for authorization by Ministry of Development: address notifications; bank 
details 
Legal persons: a written statement of the intention to provide a service in France Natural 
persons (including mandatory for shareholders): personal details, education and 
professional information 
Legal persons wishing to carry the title of architect in the company name: the name, 
registration number and registered address of the business; the company type and 
status of the business, including relevant dates; a general statement as to the nature of 
the business and a detailed statement of the extent to which the business relates to 
architecture; specific details setting out the organisation and management of the 
business as it relates to architecture (whether this is the entire business or part of the 
business); details of all premises from which business, so far as it relates to architecture, 
is done; details of the organisational structure of the company indicating the names and 
registration status of those in management positions relating to the business of 
architecture; proof of payment of the specified fee; and, where a business is wholly or 
partially owned by another company, then (a) the information set out at point (i) above 
shall also be required for the parent company, in addition to (b) a statement setting out 
the relationship between the parent company and the applicant business as it relates to 
the management and control of the business so far as it relates to architecture 
Legal persons (general business register, Milano, as part of the integrated procedure with 
a regional Order of Architects): surname, name, date of birth, country, province and 
place of birth, nationality, passport/ID number, email address, (for invoicing:) country, 
name, city, address, post code, phone, fax, mobile phone and activity of business. 
Natural persons (including mandatory for the shareholders of voluntary partnerships), in 
Milano: name, nationality, place of birth, date of birth, city, postal code, street and house 
number, phone, mobile phone, professional address (city, postal code, street and house 

May 2017 I 45 

MS  Architecture – data submission demands (branches) 

number, phone, fax), fiscal number, VAT number, current activity, university and year of 
graduation, university, session and year of State Exam, specialization and checklist 
LU  Natural persons (including mandatory for shareholders): personal details, education and 

professional information 

MT  For the Periti Warrant (including mandatory for the shareholders of voluntary 

partnerships): name, surname, email, street address, city, postal code, country, state (if 
outside Malta), warrant number, ID-card/passport number 

PL  None: only for professionals providing the services 
PT  Natural persons including all partners of a voluntary partnership: Full name, ID number 
and date and issuing authority, Name of firm, department within the firm, function and 
start date of employment, postal address data, country, email, phone/mobile/fax, if 
available country, number and date of registration with a chamber of architects in the 
home country, list of all previous employers with start and end date 

RO  None: only for professionals providing the services 
SK  None (for legal persons: checked by the office for the general business register), for 

shareholders: professional qualification documents (for general business registration) 

UK  None: access is only controlled ex post 

In most countries a certified copy of the company statutes needs to be submitted for 
authorization of an architecture branch (Table 3.10). In some countries where not only 
subsidiaries but also branches of foreign companies need to be entered in the general 
business  register,  company  statutes  need  to  be  submitted  twice  (for  the  general 
business register and the Chamber): Belgium, Germany and Malta.  

Table  3.10  includes  information  about  the  format  in  which  documents  must  be 
submitted (for example certified copies or simple copies). If no information about the 
format  in  which  documents  must  be  submitted  is  available,  no  information  on  this  is 
presented in Table 3.10 either. In the analysis, it will be assumed that in these cases 
simple copies are sufficient.  

In  France  and  Germany  (in  Germany  only  if  the  firm  wishes  to  carry  the  title 
“architect” in the company name) the company statutes of architecture firms need to 
include the details of shareholding, voting rights and the executive managers. In other 
countries,  documents  on  these  can  be  submitted  separately  whenever  they  are 
required.  

Proof  of insurance is required as part  of the authorization procedure in six countries: 
Belgium,  Cyprus,  the  Czech  Republic,  France,  Malta  and  in  some  Bundesländer  in 
Germany. Usually a copy of an insurance policy is sufficient, but Belgium requires an 
attest of the insurance provider (as well as a statement from the insurer every three 
months which professionals are still covered by insurance but this is outside the cost 
calculations  for  architecture  firms).  In  Italy,  firms  that  are  not  a  partnership  must 
specify  to  the  Chamber  after  registration  what  insurance  they  will  take  and  the 
chamber checks if it is sufficient; the law does not specify what is deemed sufficient.  

Other  documents  that  may  be  required  are  proof  of  professional  qualifications  of 
shareholders,  partners  and/or  managers  (not  documented  since  they  are  beyond  the 
scope  of  the  study),  a  certificate  of  registration  in  the  home  country  (for  example 
Belgium) and annual accounts (Belgium).  

Table 3.10 Architecture – Documents to be submitted (branches) 

MS  Architecture – document submission demands (branches) 
AT 

Legal persons: A1) Application form must be signed by all persons who can legally 
represent the firm: original in duplicate A2) Company statutes: original or certified copy 
A3) Certificates of admission to the profession for all persons who can legally represent 
the firm: simple copy Natural persons (including mandatory for the executive manager): 
B1) evidence of nationality B2) proof of authorisation to practice as an architect in the 
home country B3) certificate of authorities on reliability (extract from judicial record) B4) 

46 I May 2017 

 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

MS  Architecture – document submission demands (branches) 

certificate of authorities on non-bankruptcy B5) certificate of authorities on absence of 
professional misconduct. B6) signed declaration  

BE  Registration in the general business register (as part of the integrated procedure with the 

professional chamber): A1) Company statutes A2) Certificate confirming registration of 
the firm in the home country: A3) Annual accounts These documents need to be legalized 
by way of apostille, except for firms from Denmark, France, Italy and Ireland Registration 
with the Chamber: B1) Company statutes: photocopy signed by the notary B2) Extract 
from the Belgian Official Gazette with publication of the statutes: original B3) Certificate 
of registration in the register of legal entities at the Crossroads Bank for Enterprises: 
simple copy B4) Written request for recognition of the legal person to the competent 
provincial council of the Order of Architects B5) Extract from the shares-register: certified 
copy B6) Letter with a letterhead meeting certain format requirements: original B7) 
Declarations on honour about provision of services by architects only and knowledge of 
the professional code Natural person (including mandatory for shareholders, all certified 
copies): C1) a certificate demonstrating entitlement to the concerned activities in the 
home Member State C2) a certificate that demonstrates that the person concerned holds 
one of the diplomas, certificates or other titles, included in the annex to the Law of 20 
February on the protection of the title and the profession of architect, C3) Proof of 
exercising the profession of architect for at least two years in the ten years preceding the 
service provision (if profession nor education is regulated in the MS of establishment), 
C4) an attest of the insurer confirming professional indemnity insurance including ten-
year liability according to Belgian law C5) proof of nationality of the service provider  
Legal persons: A1) Application for company registration: authenticated copy A2) 
Certificate proving the formation of the company: authenticated copy A3) Certificate 
proving the shareholders of the company: authenticated copy …..This includes the ETEK 
registry numbers and engineering discipline of the shareholders/board of management 
A4) Certificate of registration in the Companies register: authenticated copy A5) 
Certificate of the Board of Directors: authenticated copy A6) Statute of the company: 
authenticated copy A7) Certificate of Professional Insurance: authenticated copy Natural 
persons (including mandatory for all shareholder): B1) Passport proving citizenship of an 
EU Member State; B2-1) For EU citizens: proof of marriage with a Cypriot citizen and 
proof of habitual residence in Cyprus, or alternatively B2-2) Copy of Civil Registry and 
Migration Department’s Permit or other proof of residence in the State (not clear from 
the application form that this may be any EU Member State, but confirmed by 
information on the website in English) B3) Certificate stating that he/she has adequate 
knowledge of the Greek language to practice the profession in Cyprus B4) Exact copies of 
all qualifications mentioned in your application; B5) Exact copies of all certificates with 
detailed records per year of study courses and scores for the above qualifications; B6) 
Copy of High School Diploma B7) Certificate of Competent Body or Authority stating that 
the qualifications of the applicant allow him/her to practice the profession in the country 
of issue without any limitations B8) Certificate of one year ETEK internship under the 
supervision of a civil engineer or architect B9) License to practice by the competent body 
of the country or a similar attest or certificate B10) Two passport size photographs B11) 
Registration fee of €55 (either by cash, cheque, credit card, online payment, or bank 
transfer) per field applied for 
Legal persons: branches of foreign firms also need to be registered with the general 
business register but this is beyond the scope of this study. No additional registration 
with the professional Chamber is required. Natural persons, including mandatory for 
managers of limited liability firms and of partners of professionals partnerships, 
Notification form: - Proof of the nationality (a simple copy of a passport or identity card); 
- Proof that the applicant is legally established in his country of origin (trade license or a 
statement from the trade register); - Copy of qualification certificate; or proof of the 
activity in question for at least two years in the course of the last ten years (copies of 
invoices, etc.) if the profession is not regulated in the home country; Application for 
registration: - Proof of professional qualification in the field of architecture in the MS of 
origin; - Structured professional CV; - A sample of selected works; - Proof of integrity 
(extract from police record) not older than 3 months; - Proof of professional indemnity 
insurance; - Proof of payment of the application fee For all documents originals or 
authorized copies must be submitted (if the signature is certified) 
Legal persons, voluntarily to carry the title ‘architect’ in the company name: A1) Proof of 
entitlement to carry the name 'architect' in the company name in the home country: 
certified copy A2) Constitutive act demonstrating compliance with the German 
requirements for carrying the title 'architect' in the company name: certified copy A3) 
Proof of professional indemnity insurance meeting the requirement for firms carrying the 

CY 

CZ 

DE 

May 2017 I 47 

MS  Architecture – document submission demands (branches) 

name 'architect' in the company name: certified copy Natural persons (including for 50% 
of the shareholders to carry the title ‘architect’ in the company name): B1) Higher 
education diploma B2) Certificate of residence in Nordrhein-Westfalen not older than 6 
months B3-1) Certificate of membership in the home country and Proof of good repute 
issued by the Chamber of the home country, or alternatively B3-2) Work certificates 
proving at least 2 years of full-time work in the last 10 years; Certificates of at least 80 
hours of additional training and two construction designs; B4) In other Bundesländer 
additional documents might be required: certificate of good character; certification of 
solvency; proof of professional indemnity insurance 

DK  Architecture is not regulated  
ES  Registration with the Ministry of Development: B1) Original public Deed of professional 

society, or where appropriate, to adapt to the Law of Professional Societies, if not a new 
constitution. (The writing should have already passed by the commercial register): 
certified copy B2) Certificate accrediting the ownership structure and participation of each 
partner in relation to the particulars thereof (name and profession where applicable): 
certified copy B3) Relationship charges of government and administration and people 
who occupy them, issued by the administrator of society: certified copy Natural persons 
(including mandatory for shareholders of voluntary partnerships, certified copies): C1) ID 
card or passport; C2) proof of professional qualifications (academic or professional title)  
Legal persons: A1) Registration form: A2) Company statutes which must include the 
allocation of shares, signed and initialled by every associate: A3) A separate appointment 
decision of the first manager(s) if this information is not in the statutes A4) Registration 
fees (payment) Since document format requirements are not specified, the 
administrative default applies: originals with 3 simple copies Natural persons (including 
mandatory for shareholders): B1) Registration form B2) Identity picture (glue on 
registration form) B3) Photocopy of diploma which is recognised by France B4) Original 
police clearance certificate (to be requested online: www.cjn.justice.gouv.fr/b3/eje20 or 
by post) or equivalent document if the applicant is not a resident in France for one year 
or longer B5) Photocopy of identity document (birth certificate, civil status record or 
identity card or passport) B6) Evidence of a professional address (rent receipt, electricity 
or phone bill) B7) Documents providing evidence on the activity of the service provider 
B8) Professional indemnity certificate. Both legal and natural persons need to send their 
professional indemnity insurance certificate within 30 days after their registration. The 
certificate may not be older than three months. This certificate must be provided every 
year before 31st March.  
A complete list of shareholders indicating shares held (%) and registration status of each 
shareholder (this refers to registration as an architect, not company registration). This 
must comply with the current share register held by the company for inspection 
Legal persons: A) Registration form: duly filled and stamped; B) Statute and Articles of 
Incorporation of the company: translated into Italian by an expert and sworn before a 
court of law C) Certificate of inscription in the Company Register (they get that after the 
REA): original D) Certificate of registration to a professional chamber of the members: 
original E) Declaration of non incompatibility (2 forms by which the members declare to 
respect the legal requirements): original F) Proof of payment of the EUR 168 registration 
tax: photocopy G) Proof of identity: photocopy H) Disclaimer on personal data: duly filled 
and signed; I) List of shareholders (personal data) J) A statement on the insurance the 
firm will take if not a professional partnership. Professional partnerships are required to 
subscribe to an insurance of Inarcassa that the professional chambers have negotiated 
Legal persons: branches of foreign firms also need to be registered with the general 
business register but this is beyond the scope of this study. No additional registration 
with the professional Chamber is required. For registration with the chamber: registration 
of the diploma to the Ministry for Higher Education and Research, registration in the 
general business register, license to the Luxembourg VAT registration (these are 
checked, simple copies suffice)  

FR 

IE 

IT 

LU 

MT  Legal persons, Periti partnership registration for a voluntary partnership: A1. Partnership 
agreement, certified copy; A2. Proof of due registration with MFSA (the general business 
register), simple copy; A3. The firm's professional indemnity Insurance Coverage, simple 
copy; A4. The registration fee (payable cheque)  
PL  None: only for professionals providing the service 
PT  A1) Request presented to the President of the National Directing Council A2) Presentation 

of full content, authenticated and updated with no more than 90 days, of the contract of 
company or the statutes, which content do not show any doubt about the social object in 
the field of architecture A3) identification and proof of the legitimacy of those who act as 
manager or administrators are professional architects or equivalent in full exercise of 

48 I May 2017 

Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

MS  Architecture – document submission demands (branches) 

their rights in the Member State of the EU or the EEA to request admission in accordance 
with Article 47 of Law no. No. 9/2009, of March 4, amended by Law No. 41/2012 of 28 
August, and Law No. 25/2014, of May 2 A4) Identification of the professional public body 
in the EU or EEA to which it is bound A5) Proof of the majority of voting rights are 
preserved by architects or equivalent professional or professional membership 
organization that fulfils this requirement in accordance with the law of the EU and the 
EEA if the proof of this fact does not result from the company contract or statutes All 
documents need to be certified copies of certified or authenticated originals Natural 
persons (including mandatory for shareholders of voluntary partnerships): B1) 
Registration form duly completed B2) Curriculum Vitae summed up to 2 pages to file in 
the registration process; B3) Statement of the competent authority of the country 
provenance, confirming the lawful exercise professional activity Architect, indicating the 
date of registration  

RO  None: only for professionals providing the service 
SK  For general business registration, according to the Slovak Trade Register (§ 66): Extract 
of criminal record not older than 3 months Proof of nationality Proof of nature and 
duration of activity for which the national is authorized in the home country Copy of the 
certificate of competence, giving access to the profession (in Slovakia: either university 
degree or vocational secondary education Construction of direction and three years 
experience in the field) Bank declaration on financial soundness Proof of equivalent 
professional indemnity insurance  
UK  None: access is only controlled ex post 

Austria,  Cyprus  and  Germany  accept  original  documents  in  the  English  language 
(Table  3.11).  The  Belgian  Chamber  of  Architects  also  accepts  original  documents  in 
English.  However,  to  establish  a  branch  in  Belgium,  the  company  statutes  must  also 
be  submitted  for  the  general  business  register,  which  does  not  accept  originals  in 
English.  Cyprus  accepts  a  translation into  English  if  the  original is  not in  English,  but 
Austria and Germany require a translation into German. All other countries only accept 
translations into a national language.  

In all countries translations must be certified, except in Luxembourg where a certified 
translation  is  customary  but  simple  translations  may  also  be  accepted.  Belgium, 
France  and  Italy  require  a  translation  by  a  sworn  translator.  Belgium  requires  the 
translator to be sworn before a Belgian court of law and Italy requires the translation 
to be sworn before an Italian court of law; France accepts a translator sworn before a 
court in any EU Member State but the translation may not be older than one year.  

In Belgium and Spain translations need to be legalized by way of apostille, and in Italy 
translations  need  to  be  sworn  before  an  Italian  court  of  law  or  legalized  in  an  Italian 
embassy.  Translation  requirements  are  the  same  for  branches  and  temporary 
services.  

Table 3.11 Architecture – Translation requirements  

MS  Architecture – translation requirements  
AT  All documents: if original is not in English or German, certified translation into German, 

may be done in country of original document 

BE  General business register: all documents in Dutch, French or German, certified copy of a 
certified translation done by a translator sworn before a Belgian court. Registration with 
Chamber of Architects: all documents: in Dutch, French, German or English, if not 
certified translation into Dutch or French is required (depending on the region), certified 
copy of a certified translation done by a translator sworn before a Belgian court 

CY  Certified translation if the document is not in Greek, Turkish or English, may be done in 

any EU Member State 

CZ  General business registration (Czech Trade Act, § 5.3 and 5.4): translation into Czech, 
the requirement to use a Czech translator and the requirement to verify authenticity do 
not apply to nationals from other EU Member States if there is no doubt about the 
correctness of the translation 
If original is not in English or German: certified copies of certified translations into 
German (no restriction on translator) 

DE 

May 2017 I 49 

 
MS  Architecture – translation requirements  
DK  Architecture is not a regulated profession 
ES  Certified copy of certified translation into Spanish, may be done in any EU Member State 
FR  Each document in a foreign language must be accompanied by a dated and certified 

translation into French (with a stamp of an official or sworn translator) which may not be 
older than one year, the sworn translator may reside in any EU Member State 
IE  Only data (not documents) need to be submitted hence translation is not applicable 
The company statutes and the certificate of registration certificate to a professional 
IT 
chamber in the home country must be translated into Italian, either in an Italian 
embassy or consular post (apostille) or by an expert who swears the correctness of his 
translation before an Italian court of law.  

LU  Documents must be translated into Luxembourgish, French or German, a certified 

translation is customary but a simple translation is also accepted; no restrictions apply to 
the translator 

MT  Certified translations into Maltese or English, no restrictions apply to the translator 
PL  Nothing applicable to legal persons 
PT  Certified translations into Portuguese, may be done in any EU Member State 
RO  Nothing applicable to legal persons 
SK  General business registration (Slovak Trade License Act, § 46.5 and § 66): certified 

translation into Slovak 

UK  None: access is only controlled ex post 

3.9  Submission demands – temporary services 

Tables 3.12 and 3.13 provide the data and documents that architecture firms need to 
submit for authorization of temporary services, if any. In Austria, there is no 
authorization or notification for temporary services, but clients need to be informed of 
certain specifics about the service provider before the contract is signed.  

In eight countries, requirements for temporary services apply only to natural persons 
delivering the service: Cyprus, the Czech Republic, Italy, Malta, Poland, Portugal, 
Romania and Slovakia.  

In Belgium, the firm needs to provide essential information and documents for all 
employees providing the services (they cannot do that on their own behalf). In France 
and Spain, the firm needs to notify a regional Chamber and to provide “light” details 
and documents for one person legally representing the firm, including insurance in 
France. In Luxembourg the firm needs to provide certain data, but much less than to 
establish a permanent branch and no documents are required.  

In Germany and Ireland, the same data and documents need to be provided as for 
branches to carry the title “architect” in the company – however (as for branches) this 
is voluntary.  

In the remaining two countries, Denmark and the United Kingdom, no authorization is 
needed for architecture services and no data or documents need to be submitted.  

Table 3.12 Architecture – Data to be submitted (temporary services) 

MS  Architecture – data submission demands (temporary services) 
AT  No authorization or notification, but to be submitted to the client before signature of the 
contract: 1. Register where he is registered and identification number in this register; 2. 
Name and address of the responsible controlling authority in the country of establishment 
3. Professional body or similar organisation of which the architect/engineering consultant 
is part of 4. Professional title / formal qualification 5. Turnover tax identification Number 
6. Details about insurance protection concerning professional liability 

BE  1. The functions of all natural persons exercising the profession in the company in 

Belgium 2. A written declaration that that the tasks will be completed by the persons that 
are authorized only 

CY  None: only for professionals providing the services 

50 I May 2017 

 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

MS  Architecture – data submission demands (temporary services) 
CZ  None: only for professionals providing the services 
DE  For natural persons (including mandatory for shareholders of firms that wish to carry the 
title “architect” in the company name): and legal persons (Nordrhein-Westfalen, the 
requirements are the same as for the establishment of a branch): Name; nationality; 
academic degree; birth date; address; address of the registered office. The same 
information must be supplied to both the municipality for the general business register 
and the Chamber of Architects 
DK  None: the profession is not regulated 
ES 

Legal persons, for authorization by Ministry of Development: information about any 
insurance cover or other means of personal or collective that it may have in relation to 
their professional liability protection 

FR  Only a notification form. Authorization only applies to professionals providing the 

IE 

services. 
Legal persons wishing to carry the title of architect in the company name: the name, 
registration number and registered address of the business; the company type and status 
of the business, including relevant dates; A complete list of shareholders indicating 
shares held (%) and registration status of each shareholder (this refers to registration as 
an architect, not company registration). This must comply with the current share register 
held by the company for inspection; a general statement as to the nature of the business 
and a detailed statement of the extent to which the business relates to architecture; 
specific details setting out the organisation and management of the business as it relates 
to architecture (whether this is the entire business or part of the business); details of all 
premises from which business, so far as it relates to architecture, is done; details of the 
organisational structure of the company indicating the names and registration status of 
those in management positions relating to the business of architecture; proof of payment 
of the specified fee; and, where a business is wholly or partially owned by another 
company, then (a) the information set out at point (i) above shall also be required for the 
parent company, in addition to (b) a statement setting out the relationship between the 
parent company and the applicant business as it relates to the management and control 
of the business so far as it relates to architecture 

IT  Only a notification form. Authorization only applies to professionals providing the 

services. 

LU  VAT Registration, insurance information and professional activity information 
MT  A prior declaration of temporary cross-border services 
PL  None: only for professionals providing the services 
PT  None: only for professionals providing the services 
RO  None: only for professionals providing the services 
SK  None: only for professionals providing the services 
UK  None: use of title is only controlled ex post 

Table 3.13 Architecture – Documents to be submitted (temporary services) 

MS  Architecture – document submission demands (temporary services) 
AT  None 
BE 

Legal persons, registration with the Chamber: Certified copy of proof of registration of all 
natural persons in the firm exercising the profession in Belgium  
Legal persons: A1) Simple copy of company registration certificate from other EU 
Member State A2) Simple copy of professional licence from another EU Member State 
Certificate  

CY 

CZ  None: only for professionals providing the service 
DE  Legal persons, to carry the voluntary title ‘architect’ in the company name (the same as 
for branches): A1) Proof of entitlement to carry the name 'architect' in the company 
name in the home country: certified copy A2) Constitutive act demonstrating compliance 
with the German requirements for carrying the title 'architect' in the company name: 
certified copy A3) Proof of professional indemnity insurance meeting the requirement for 
firms carrying the name 'architect' in the company name: certified copy Natural persons 
(including mandatory for shareholders to carry the title ‘architect’ in the company name) 
in Nordrhein-Westfalen, the requirements are the same as for a branch: B1) Higher 
education diploma B2) Certificate of residence in Nordrhein-Westfalen not older than 6 
months B3-1) Certificate of membership in the home country and Proof of good repute 
issued by the Chamber of the home country, or alternatively B3-2) Work certificates 
proving at least 2 years of full-time work in the last 10 years; Certificates of at least 80 

May 2017 I 51 

 
MS  Architecture – document submission demands (temporary services) 

hours of additional training and two construction designs; B4) In other Bundesländer 
additional documents might be required: certificate of good character; certification of 
solvency; proof of professional indemnity insurance 

DK  None: profession is not regulated 
ES  Representative of a legal person, for registration with the Ministry of Development 

FR 

(certified copies of certified originals): 1- Documentation proving the nationality of a EU 
Member State; 2- Certificate certifying that the applicant is legally established in a State 
of the European Union in order to pursue the activities in question and the absence of 
any prohibition, at the time of making the declaration, preventing him from performing 
the profession in the State of origin, not even temporarily, issued by the competent 
authority of the country of origin  
Legal persons: (1) Evidences of the qualification of the architect (natural person) who 
represents the company (2) Mandate/authorisation indicating the natural person, 
architect, representing the company (3) Insurance coverage certificate on behalf of the 
representative Since document format requirements are not specified, the administrative 
default applies: originals with 3 simple copies  
IE  Only data to be submitted (see previous table) 
IT  None: only for professionals providing the service 
LU  Only data need to be submitted (see previous table) 
MT  Nothing applicable to legal persons 
PL  None: only for professionals providing the service 
PT  None: only for professionals providing the service 
RO  None: only for professionals providing the service 
SK  None: only for professionals providing the service 
UK  None: use of title is only controlled ex post 

52 I May 2017 

 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

4  ENGINEERING SERVICES 

4.1  Types of authorization procedures 

Three main types of engineering 

There is a large variety of engineers, from weapons engineers to forest engineers. In 
most of the countries covered by this study the authorization procedure for access to 
the  profession  is  the  same  for  all  types  of  engineers.  The  required  professional 
qualifications  may  be  different  depending  on  the  specialization,  but  professional 
qualifications  are  out  of  scope  of  this  study.  To  categorize  the  types  of  authorization 
procedures,  it  is  useful  to  distinguish  three  main  types  of  engineers:  civil  engineers, 
mechanical engineers and electric engineers. Civil engineers are closely related to the 
construction  of  works.  Mechanical  engineers  are  typically  found  in  manufacturing. 
Electric  engineers  are  required  for  the  construction  and  maintenance  of  high-voltage 
applications, and thus typically employed by electricity providers.  

Public procurement and qualified personnel requirements out of scope 

As a rule, requirements to gain access to the services are lighter for engineering than 
for architecture, and the reason may be that quality is controlled in different ways. For 
example  public  works  such  as  roads  and  bridges  are  typically  publicly  procured,  and 
contracting  authorities  may  control  access  by  demanding  certain  company 
certifications,  and  electricity  providers  may  be  required  to  employ  only  qualified 
electric  engineers.  These  types  of  access  control  however  are  out  of  scope  of  this 
study.  

Overlap with architecture in four countries 

Authorization procedures for engineering overlap at least partially with architecture in 
four mostly smaller countries: Cyprus, Luxembourg, Malta and Austria (Table A5.6 in 
Annex 5). In Luxembourg the authorization procedure is the same for architecture and 
all types of engineering. In Cyprus and Malta the access regulations are the same for 
civil  engineering  and  architecture,  and  lighter  authorization  procedures  apply  to 
mechanical  and  electric  engineering.  In  Austria  the  authorization  procedure  is  the 
same for architecture and any engineering where building designs are involved. Thus 
authorization  would  not  be  needed  for  civil  engineering  firms  that  only  design  roads 
and would be needed for mechanical and electric engineering firms that are involved in 
building designs (if firms specialize that much).  

Authorization  procedure  depends  on  type  of  engineering  in  three  further 
countries 

In  three  countries,  authorization is  needed  for  some  types  of  engineering  but  not  for 
other types of  engineering: the Czech Republic, Denmark and Slovakia.  In the Czech 
Republic  and  Slovakia  the  authorization  procedure  for  civil  engineering  (more 
precisely:  for  chartered  engineers  in  the  Czech  Republic)  are  lighter  than  for 
architecture,  and  mechanical  and  electric  engineering  are  not  regulated  in  those  two 
countries.  In  Denmark  only  structural  engineering  is  regulated,  which  refers  to  the 
design  of  complicated  constructions  such  as  hospitals  and  shopping  centers.  These 
complicated structures might be considered exceptional from a domestic point of view, 
however  international  competition  exists  especially  for  complicated  structures,  and 
public  buildings  exceeding  a  construction  value  of  EUR  5  million  must  be 
internationally procured.  

May 2017 I 53 

Authorization only for engineering related to construction in six countries 

In  five  countries  authorization  for  engineering  services  is  only  needed  for  activities 
that are related to construction designs (Table A5.7 in Annex 5). Besides Austria, the 
Czech  Republic,  Denmark  and  Slovakia  mentioned  above  this  is  also  the  case  in 
Germany  and  Ireland.  As  in  Austria,  mechanical  and  electric  engineering  firms  would 
only  need  authorization  to  the  extent  that  they  are  involved  in  construction  designs, 
and this is assumed the case. In these countries a manufacturing plant can employ a 
mechanical  or  electric  engineer  who  needs  no  authorization,  however,  this  is  beyond 
the  scope  of  the  study  for  two  reasons:  it  applies  to  natural  instead  of  legal  persons 
and no services to third parties are offered.  

No reserved engineering activities in four countries 

Belgium,  France,  Romania  and  the  United  Kingdom  have  no  authorization  procedure 
for any type of engineering. This does not mean that the profession is not regulated at 
all  because  in  except  in  Romania,  the  title  of  (chartered)  engineer  is  protected  and 
may only be used by persons with an appropriate university diploma.7  

Authorization for permanent establishment of engineering in nine countries 

In  six  countries  covered  by  the  study,  all  firms  need  authorization  for  permanent 
establishment: Austria, Cyprus, Italy, Luxembourg, Spain and Portugal (Table 4.1). In 
Austria, firms of other EU countries cannot establish an architecture branch in Austria 
because only Austrian legal forms of the company are possible. In two other countries, 
the  Czech  Republic  and  Malta,  all  partners  of  a  voluntary  professional  partnership 
must be professionals to establish a branch. In Germany firms only need authorization 
to carry the voluntary title of engineer in the company name.  

In  the  United  Kingdom  engineering  no  prior  authorization  is  needed.  The  use  of  the 
title  of  ‘chartered  civil  engineer’  or  ‘chartered  mechanical  engineer’  in  the  company 
name  is  protected,  but  the  professional  bodies  only  take  action  after  receiving 
complaints about improper use of the title. For this country no cost are involved with 
collecting  or  submitting  data  or  documents,  but  costs  of  other  administrative 
formalities to use the protected title in the company name are still included.  

In  four  further  countries,  only  people  providing  the  services  need  authorization  and 
legal  persons  or  their  shareholders  or  managers  do  not:  Denmark  (for  structural 
engineering),  Ireland,  Poland  and  Slovakia.  Since  this  is  beyond  the  scope  of  the 
study,  for  these  countries,  only  a  compulsory  chamber  membership  fee  of  one 
professional is relevant because without it no services can be provided.  

In the remaining countries no authorization procedure applies at all: Belgium, France 
and  Romania  (and  Denmark  again  for  other  types  of  engineering).  In  France  a 
notification  for  recognition  of  the  diploma  is  required  but  this is  beyond  the  scope  of 
the study because firstly it relates to professional qualifications and secondly it applies 
only to professionals providing the services. For these countries, no costs are in scope 
of this study.  

Authorization for temporary engineering services in four countries 

In  two  countries  all  firms  need  authorization  to  provide  temporary  engineering 
services  cross-border:  Cyprus  and  Spain.  In  Malta  all  partners  of  an  engineering 
partnership  need  authorization  to  provide  temporary  services.  In  Germany, 
authorization  is  only  needed  to  carry  the  voluntary  title  of  engineer  in  the  company 
name.  

7   www.ordemengenheiros.pt/fotos/editor2/eng.civil/recognitionandprotectionofprof.title.pdf. 
54 I May 2017 

                                                           
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

In  eight  countries  only  professionals  delivering  the  services  need  authorization  to 
provide  temporary  services:  the  Czech  Republic,  Denmark  (structural  engineering), 
Ireland, Italy, Luxembourg, Poland, Portugal and Slovakia.  

In  the  United  Kingdom  the  voluntary  titles  are  protected  the  same  way  as  for 
branches: without prior authorization but action is taken after complaints. 

In  the  remaining  countries  no  authorization  is  needed  for  temporary  services  at  all: 
Denmark  (for  other  types  of  engineering),  Austria,  Belgium,  France,  Romania.  For 
Austria the requirement to provide documents to customers is considered beyond the 
scope because it relates to on-going services and not to prior market access.  

The rules with respect to authorization procedures applicable to the establishment of a 
branch or provision of temporary services are summarized in Table 4.1. 

Table 4.1 Engineering - Authorization procedure 

MS  Establishment of a branch 
AT  8.Not possible for branches, only 

Temporary cross-border services 
2.Only to inform client 

subsidiaries 

BE  1.No authorization/notice 
CY  7.Authorization 
CZ  6.Authorization of professionals and 

voluntary partnerships 

DE  5.Authorization of professionals & title in 

company name 

DK  Structural engineering: 4.Authorization of 

professionals providing the services only 
Other engineering: 1.No 
authorization/notice 

ES  7.Authorization 
FR  4.Notification (only for recognition of 

diplomas) 
4.Authorization of professionals providing 
the services only 
7.Authorization 

IE 

IT 

LU  7.Authorization 

MT  6.Authorization of professionals and 

voluntary partnerships 
4.Authorization of professionals providing 
the services only 
7.Authorization 

PL 

PT 

RO  1.No authorization/notice 
SK  6.Authorization of professionals and 

voluntary partnerships 

UK  1.No authorization/notice 

1.No authorization/notice 
7.Authorization 
4.Authorization of professionals providing 
the services only 
5.Authorization of professionals & title in 
company name 
Structural engineering: 4.Authorization of 
professionals providing the services only 
Other engineering: 1.No 
authorization/notice 
7.Authorization 
4.Notification (only for recognition of 
diplomas) 
4.Authorization of professionals providing 
the services only 
4.Authorization of professionals providing 
the services only 
4.Authorization of professionals providing 
the services only 
4.Authorization of professionals, 
notification for firms 
4.Authorization of professionals, 
notification for firms 
4.Authorization of professionals providing 
the services only 
1.No authorization/notice 
4.Authorization of professionals providing 
the services only 
1.No authorization/notice 

4.2  Regulatory requirements 

Legal forms of businesses 

The legal form of a firm determines how various national laws are applied to the firm. 
Commonly used types of legal forms are sole traders, partnerships and limited liability 
firms.  

In  most  countries  covered  by  this  study,  all  legal  business  forms  are  in  principle 
allowed for engineering firms (Table A5.9 in Annex 5).  

May 2017 I 55 

 
Cyprus  and  the  Czech  Republic  specify  that  only  permanent  establishment  of  natural 
persons, partnerships and limited liability firms is allowed. In Germany all legal forms 
are allowed, but to carry the title “engineer” in the company name, the firm must be a 
partnership  or  a  public  corporation.  However,  in  these  cases,  this  is  interpreted  to 
refer in a broad sense to types of companies and not to specific national legal forms.  

For  example  regulations  of  the  Czech  general  business  register  also  refer  to  these 
three  legal  forms  but  in  addition  specify  that  branches  of  any  firm  from  another  EU 
Member  State  are  allowed,  and  the  professional  chamber  does  not  do  an  additional 
check  on  legal  persons  (apart  from  managers  and  partners).  And  for  Germany 
shareholder requirements refer to specific German national legal forms, but only in the 
case of specific difficulties to demonstrate compliance (discussed further below).  

In the Czech Republic and Malta professionals can assume joint liability by forming a 
professional  partnership.  However,  this  does  not  prevent  professionals  from  working 
for a limited liability firm or limited liability firms from offering services. Hence also in 
Malta all legal forms are allowed.  

Only  in  two  countries,  use  of  broader  types  of  legal  business  forms  is  restricted.  In 
Austria,  the  same  authorization  procedure 
for  permanent 
establishment  of  firms  with  the  same  specific  national  legal  forms  as  is  the  case  for 
architecture. In practice this means that permanent establishment is only possible by 
setting  up  a  subsidiary  instead  of  a  branch.  This  restriction  does  not  apply  to 
temporary cross-border services where all legal forms are allowed.  

is  only  available 

In the United Kingdom, limited liability firms may not carry the title of ‘chartered civil 
engineer’  or  ‘chartered  mechanical  engineer’  in  the  company  name.  This  restriction 
applies to both branches and temporary services. 

Nominative shareholding requirement 

Requirements  on  shareholding  nominative  can  be  both  explicit  and  implicit.  In 
Luxembourg, the access control procedure specifies explicitly that no companies with 
bearer  or  endorseable  shares  are  allowed.  In  nine  other  countries  with  shareholding 
requirements  (Table  4.2  below),  the  limitation  to  shares  nominative  is  implicit.  This 
may, for example, be caused by requirement to provide a list of all shareholders and 
the  number  and  values  of  their  shares  (and/or  voting  rights),  or  the  requirement  to 
submit  a  shareholder  register,  which  per  se  eliminates  the  possibility of  shareholding 
other  than  nominative.  A  notable  exception  is Germany  (Nordrhein-Westfalen)  where 
the Building Chamber Law specifies that for “Aktiengesellschaften” (stock  companies) 
and “Kommanditgesellschaften auf Aktien” (limited partnerships) only the majority of 
shares  must  be  nominative.  Nonetheless,  access  is  complicated  or  practically 
impossible for companies with anonymous shareholders. 

Requirements may depend on the legal form 

In  five  countries,  requirements  depend  on  the  legal  form:  the  Czech  Republic,  Italy, 
Malta,  Portugal  and  Spain.  In  particular,  requirements  are  different  for  (voluntary) 
professional  partnerships.  Such  differences 
the 
familiarization with administrative formalities because it is not always clear which legal 
forms  in  the  home  country  would  be  considered  as  a  professional  partnership  in  the 
host country.  

requirements  complicate 

in 

Shareholding, voting rights and management requirements 

Shareholding, voting rights and management requirements covers rules dictating that 
a certain percentage of shares, voting rights and management positions must be held 
by  professionals.  These  rules  are  relevant  for  administrative  formalities  in  two  ways. 
Firstly, whenever they exist, compliance needs to be proven (regardless of the precise 

56 I May 2017 

Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

requirements),  which  causes  administrative  formalities.  Secondly, in some  situations, 
the  requirements  are  in  themselves  administrative  barriers,  for  example  the  need  to 
include  a  foreign  engineer  as  a  partner.  How  often  this  is  the  case,  depends  on  the 
required  percentage  of  actual  versus  mandatory  participation:  a  firm  with  100% 
professionals as shareholders faces no barriers when only 50% is required, but a firm 
with  50%  professionals  as  shareholders  faces  a  barrier  when  100%  is  required. 
Therefore,  also  the  required  percentages  are  relevant  for  this  study.  The  exact 
required percentages are presented in Table 4.2 but not further discussed.  

To establish a branch, shareholding, voting rights and management requirements exist 
regardless of legal form in six countries: Austria, Cyprus, the Czech Republic (for half 
or  more  of  the  managers),  Luxembourg,  Slovakia  and  Spain.  In  two  additional 
countries,  such  requirements  exist  to  carry  a  voluntary  professional  title  in  the 
company  name:  Germany  (Nordrhein-Westfalen)  and  the  United  Kingdom.  In  three 
further  countries,  such 
for  voluntary  professional 
partnerships: Italy, Malta and Portugal. The three remaining countries of this study do 
not  impose  any  such  restrictions:  Denmark,  Poland  and  Romania.  For  temporary 
cross-border services, no restrictions apply to exercise the profession, except to carry 
the professional title in the company name in Germany, and the United Kingdom. 

requirements  exist  only 

Table  4.2  gives  an  overview  of  the  rules  on  shareholding,  voting  rights  and 
management requirements. 

Table  4.2  Engineering  –  Shareholding,  voting  rights  and  manager 
requirements 

MS 

Establishment of a branch 

Shareholding  Voting rights  Managers 

AT 

BE 
CY 

CZ 

DE 

DK 
ES 
FR 
IE 
IT 
LU 
MT 
PL 
PT 

RO 
SK 

UK 

51% a) 

None 
100% 

100% b) 

None; 50% c)

See 
shareholding 
None 
See 
shareholding 
See 
shareholding 
None; 50% c)

100% 

None 
100% 

100% b); 
50% e) 
None; 50% c) See 

None 

None 
None 
None 
None 
51% 
51% 
None 
None 
None 
None 
None 
None 
None; 2/3 b)
None; 2/3 b)
None 
None 
100% 
None 
None; 100% b)  None; 100% b)  None 
None 
None 
None 
None; 51% b)
None; one 
See 
engineer b) 
shareholding 
None 
None 
None 
See 
shareholding 
None; 100% d) None 

None 
51% 

None 

branches 
None 
None 
None 
None 
None 
None 
None 
None 
None 

None 
None 

None 

Temporary cross-border 
services 

Share-
holding 
None 

Voting 
rights 
None 

None 
None 

None 
None 

Managers 

None 

None 
None 

None 

None 

See 
branches 
None 
None 
None 
None 
None 
None 
None 
None 
None 

None 
None 

See 
branches 

See 
branches 
None 
None 
None 
None 
None 
None 
None 
None 
None 

None 
None 

None 

a)  Only for subsidiaries, because branches of foreign engineering firms are not recognized in Austria; 
b)  For professional partnerships only; 
c) 
d) 

In Germany, the 50% is required to carry the title ‘engineer’ in the company name; 
In the UK, partnerships can use the chartered status of ‘Chartered Civil Engineer’ or ‘Chartered 
Mechanical Engineer’ in the company name if all partners are members of the relevant body; 
In the Czech Republic, in a limited liability firm at least half of the managers must be a certified 
engineer. 

e) 

May 2017 I 57 

 
 
Voting  rights  and  management  requirements  usually  result  in  formalities  but  this  is 
not  always  the  case.  For  example  in  the  United  Kingdom  the  various  Institutes  of 
Engineers have no authorization procedure but take action when receiving complaints 
about title misuse. 

Multidisciplinary restrictions 

Multidisciplinary restrictions refer to prohibitions to combine certain services, aimed to 
avoid  conflicts  of  interest.  They  are  relevant  for  administrative  formalities  to  the 
extent  a  statement 
is  required  to  demonstrate  compliance.  Multidisciplinary 
restrictions  exist  in  one  or  other  form  for  all  firms  in  five  countries:  Austria,  Cyprus, 
Luxembourg,  Slovakia  and  Spain.  Multidisciplinary  restrictions  apply  to  professional 
partnerships  only  in  four  additional  countries:  the  Czech  Republic,  Italy,  Malta  and 
Portugal.  Lastly,  in  Germany  the  only  apply  to  firms  wishing  to  carry  a  voluntary 
professional title in the company name (Table A5.10 in Annex 5).  

However, only in three countries do multidisciplinary restrictions create administrative 
formalities.  In  Austria  and  Luxembourg  (for  branches  only)  and  Spain  (for  voluntary 
professional  partnerships  only)  the  company  statutes  must  include  a  statement  on 
multidisciplinary restrictions according to specifics of the host country.  

Liability and insurance 

Regulations of liability and insurance were investigated in case they  have impacts  on 
administrative formalities, but with a few exceptions this is not the case. Figures A5.3 
and  A5.4  in  Annex  5  present  the  professional  liability  periods  and  amounts  to  be 
covered  by  compulsory  professional  indemnity  insurance  but  they  only  have 
implications  for  administrative  formalities  in  Austria.  In  this  country,  professional 
indemnity insurance is only compulsory for public works but professional liability lasts 
10 years and civil liability as defined in the Civil Code lasts 30 years. Hence, insurance 
is  regarded  as  de  facto  mandatory  and  it  takes  time  to  assess  what  liabilities  are 
covered by insurance policies (as reported in interviews). 

As discussed further below again under the submission of documents, insurance must 
be  proved  in  four  countries:  Cyprus,  the  Czech  Republic,  Germany  (to  carry  the 
voluntary  professional  title  in  the  company  name)  and  Malta  (for  voluntary 
professional partnerships).  

In Spain, a civil liability insurance is required for engineering branches for accidents on 
their  premises.  This  insurance  must  be  proved  for  the  compulsory  registration  in  the 
Registro Industrial (Madrid) and is therefore included in the cost calculations.  

4.3  Procedural steps 

Some  countries  set  more  procedural  steps  to  gain  authorization  than  others.  The 
following aspects of procedures were examined: 

•  Prior requirements (e.g. e-ID or inscription in the general business register); 
•  Prior authorization of shareholders, partners or managers; 
•  Different steps within the procedure. 

As  noted  at  the  start  of  this  chapter,  in  most  countries  administrative  formalities  are 
(slightly)  lighter  than  for  architecture.  This  is  obviously  the  case  in  Belgium  and 
Romania  where  engineering  services,  contrary  to  architecture  services,  are  not 
regulated,  and  also  in  France  where  engineers  only  need  to  notify  an  office  for 
recognition of equivalent qualifications.  

58 I May 2017 

 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

Professional authorization integrated with business registration in Italy only 

Italy  is  the  only  country  where  permission  to  establish  an  engineering  branch  is 
integrated with the general business procedure. This complicates matters because the 
procedure  starts  with  the  professional  chamber,  is  continued  with  other  authorities 
and  is  resumed  by  the  chamber  only  after  inscription  with  the  other  authorities  is 
completed. 

In  Germany  (to  carry  the  voluntary  title  ‘engineer’  in  the  company  name)  and  in 
Malta,  applicants  must  prove  inscription  in  the  general  business  register  to  the 
professional chamber. However, nothing prevents a firm from starting both procedures 
at  the  same  time  and  this is  a  mere  aspect  of  submission  demands.  In  Luxembourg, 
the Chamber does a background check on prior registration with the general business 
register and the VAT authority. In Spain a regional professional chamber passes on an 
application  to  the  national  ministry  of  development  with  their  advice.  This  ensures 
national  validity  of  authorization  and  does  not  otherwise  affect  administrative 
formalities.  

As  already  noted  in  Section  2.2,  compliance  with  professional  regulations  for  legal 
persons are checked by the Trade Licencing Office in the Czech Republic and Slovakia. 
This  is  considered  beyond  the  scope  of  this  study,  because  for  the  other  countries 
general  business  registration  (which  may  duplicate  the  chamber  procedure)  is  not 
analysed either.  

Prior requirements - National e-IDs are not required 

A national e-ID may be used to handle procedures fully online in Italy and Malta, but 
procedures can also be handled by post in those two countries. Hence the national e-
ID  means  that  full  online  handling  is  only  available  to  nationals  but  does  not  restrict 
foreign applicants apart from having to post documents. 

Prior registration of shareholders does not seem to affect the procedure 

As  for  architecture,  there  seems  nothing  that  prevents  firms  from  starting  the 
procedure  for  authorization  of  shareholders,  partners  and/or  managers  and  the 
procedure for authorization of the firm at the same time, with the possible exception 
of  Austria.  In  Cyprus  (for  all  legal  forms)  and  Malta  (for  partnerships)  where  all 
partners need to be authorized architects, the procedure for natural and legal persons 
is even one and the same.  

Different steps within the procedure 

Table 4.3 presents the  different steps within the procedure for establishing a branch. 
In three federally organised countries (Austria, Italy and Spain) the chamber forwards 
the  application  or  part  of  it  to  national  authorities  and  informs  the  applicant  of  the 
outcome.  This ensures  coherent national validity and still has the advantage that the 
applicant needs to deal with only one office.  

The  procedures  of  countries  differ  mostly  with  regard  to  the  options  after  negative 
decisions.  These  were  identified  for  five  countries,  mostly  in  the  south  of  Europe: 
Austria, Cyprus, Italy, Malta and Spain. In these countries, the chamber may demand 
a  corrective  measure,  usually  with  the  example  of  examination  of  shareholders  or 
managers,  or  an  adaptation  period  in  the  case  of  Malta.  For  the  other  countries  no 
information  was  found  that  indicates  to  what  extent  a  rejection  is  always  final  or  if 
corrective measures may be demanded.  

Table 4.3 Engineering – Procedural steps to establish a branch cross-border 

MS  Engineering - Steps to establish a branch 
AT 

Legal persons: - the firm submits application form, names of all partners, their 

May 2017 I 59 

MS  Engineering - Steps to establish a branch 
a) 

certificates of admission to a regional chamber - the regional chamber forwards the 
application with their opinion to the Ministry of Science, Research and Economy - The 
Ministry decides and if positive, the regional chamber registers the firm Natural persons 
(including mandatory for the executive manager): after all requirements (i.e., university 
degree, professional practice of at least three years after graduation, licensing 
examination (Ziviltechnikerprüfung)) are fulfilled, the authorisation for professional 
activity “Befugnis” is awarded by the Federal Ministry for Economics, Family and Youth. If 
the proof of authorization to practice as an engineer is sufficient, no further exams (i.e. 
the "Ziviltechnikerprüfung") need to be taken. Before making use of the authorisation the 
applicant has to take the oath that he will observe the law, his other responsibilities and 
the duty to confidentiality. 

BE  No authorization needed for engineering 
CY  Both natural persons (including mandatory for all shareholders) and legal persons: 1. 

CZ 

DE 

Application of membership to the Cyprus Scientific and Technical Chamber (ETEK) 
accompanied with necessary documentation and fees; 2. In case of a rejected application 
the applicant can ask for i) guidance on steps needed in order to successfully register and 
ii) ask for re-examination after completing missing documents and repaying the 
registration fee. 
Legal persons: requirements checked by the office for the general business register 
(beyond the scope of the study). Natural persons including mandatory for partners of a 
voluntary engineering partnership: - Application and submission of necessary documents; 
- The Chamber assesses the application and notifies in writing the applicant whether the 
application has been successful - The person shall give the oath either orally in the 
presence of the President of the Chamber or an authorized member of the Board of 
Director. If not possible, Chamber will determine appropriate and equivalent form to 
perform this legal act. - A stamp with a national emblem of the Czech Republic is issued 
with a number under which the person is registered - Insurance needs to be proved to 
each client before the start of the work and, on request, to the Chamber. 
Legal persons wishing to carry the title ‘engineer’ in the company name: 1. submission of 
documents (including proof of insurance); 2. Chamber checks Natural persons (including 
mandatory for shareholders of firms that wish to carry the title ‘engineer’ in the company 
name): 1. Submit qualification documents to Chamber of Engineers (no proof of 
insurance), 2. Payment of 50 euro to Chamber of Engineers (Gebühren- und 
Auslagenordnung der Ingenieurkammer-Bau NRW), 3. Chamber of Engineers checks and 
if approved enters the person in the register of engineers. 

DK  Structural engineering, requirements only apply to natural persons providing the services 

ES 

(beyond the scope of the study) Other engineering: not regulated. 
Legal persons: an application is submitted to a Chamber of Engineers which analyses the 
application and demands integrations if needed. For civil engineering the application must 
be submitted to the Chamber of Architects and the Ministry of Development authorizes 
the firm; the Chamber notifies the service provider of its positive decision (published in 
the Official Journal) or of the need of compensative measures. Natural persons (including 
mandatory for shareholders of voluntary partnerships): Registration in one of the 
Colegios de Ingenieros in Spain.  

FR  None, only notification with a center of professional recognition. 
IE 

Legal persons cannot register as ‘chartered engineer’. There is nothing to stop a company 
using the term ‘Chartered Engineer’ but it has no official standing. Note: in the by-laws of 
the Chamber of Engineers, "corporate member" refers to registered engineers (natural 
persons).  

IT  Natural persons (including mandatory for shareholders of voluntary partnerships): 1. 

Submission of the application to the competent authority (Ministry); 2. The Ministry 
analyses the file; 3. The application is accepted and the applicant is notified, or 
compensative measures can be required, usually an exam, 4. Registration with a regional 
Order of Engineers Legal persons: First registration of the natural persons providing the 
services. Chamber of Commerce of the relevant province (which procedure is integrated 
with that of the professional chamber): 1. Opening of the local unit (non-legal entity) to 
be registered in Italy's Economic and Administrative Index (REA). The Chamber of 
Commerce then registers the branch or agency with the fiscal authorities, INAIL (for 
professional liability), INPS (worker pensions). 2 Registration at the Order of Engineers of 
the relevant province. 3. After the firm is registered with this chamber, the registration in 
the general business register is finalized. 
First step: Authorisation of establishment; this requires a fixed business place in 
Luxembourg, proof of good reputation (the administration will do a background check) 
and sufficient professional qualifications (this requires registration of the diploma with the 

LU 

60 I May 2017 

Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

MS  Engineering - Steps to establish a branch 

Ministry for Higher Education and Research). Second step: obtain a licence to the 
Luxembourg VAT registration. Third step: Registration with the Order of Architects. 

MT  Legal persons: only need to register in the general business register. The professional 

chamber checks the requirements for voluntary professional partnerships in one and the 
same procedure as for natural persons. Natural persons (including mandatory for 
partners of a voluntary partnership): they need a warrant to practice the profession of a 
Engineer in Malta. Besides submission of documents, for residents of other EU countries, 
S.L.453.01 Art.16 provides that a Board may require an adaptation period in Malta of 
working up to 3 years under supervision if foreign qualifications differ substantially from 
the Maltese requirements; the standard requirement is 2 years training under supervision 
of an engineering warrant holder but there is no minimum adaption period (as is the case 
for periti / architects) 

PL  Only natural persons providing the services can (and must) be registered, no legislation 

PT 

applies to legal persons 
Legal persons: 1. Register their permanent representatives in Portugal; 2. Application for 
registration in the Chamber of Engineers (if professional partnership): Article 12 of Lei 
n.º 123/2015 Natural persons (including mandatory for partners of a voluntary 
partnership): Registration in the Chamber of Engineers  

RO  Engineering is not regulated  
SK  None (for legal persons: checked by the office for the general business register which is 

beyond the scope).  

UK  No prior authorization (only control ex post after complaints about use of the professional 

title in the company name) 

a)  Only for subsidiaries, because branches of foreign engineering firms are not recognized in Austria. 

In  most  countries,  procedures  for  cross-border  temporary  services  (Table  4.4)  are 
lighter  than  for  permanent  establishment.  Only  in  two  countries  the  procedure  is  the 
same  as  for  setting  up  a  branch:  Cyprus  and  Germany  (in  the  latter  country  only  to 
carry the voluntary title ‘engineer’ in the company name).  

As already indicated Section 4.1, legal persons need authorization in only two further 
countries,  Malta  (for  partners  of  voluntary  engineering  partnerships)  and  Spain.  For 
temporary  services,  if  professional  qualifications  are  too  different  from  Maltese 
standards, Malta only requires an aptitude test instead of an adaptation period as for 
branches.  In  Spain,  documents  need  to  be  submitted  to  various  authorities  but  the 
decision procedure is simpler.  

Table 4.4 Engineering – Procedural steps for temporary services 

MS  Engineering – steps for temporary services 
AT  A number of documents need to be provided to the client, otherwise no procedure applies
BE  Engineering is not regulated 
CY  Application for the Registry of Engineering Services Providers of the Cyprus Scientific and 

Technical Chamber (ETEK) accompanied with necessary documentation 

CZ  None (only for professionals providing the services which is out of scope) 
DE  Natural persons (including mandatory for shareholders of firms that wish to carry the title 
‘engineer’ in the company name): 1. Notification of first assignment with the Chamber of 
Engineers; 2. Payment of the fee; 3. Submission of qualification documents; 4. Chamber 
decides and if it approves enters the application in a special list of foreign engineers; 5. 
Chamber issues an attestation ("Bescheinigung") that entitles the service provider 
(natural person) to carry the title 'engineer'; 6. The attestation has duration of maximum 
five years, so other activities within the duration of the attestation need not be notified. 
7. There is no renewal procedure after the attestation expires. Legal persons: submission 
of documents, Chamber checks and enters the company in the company directory of the 
Chamber after approval. 

DK  Structural engineers, requirements only apply to natural persons providing the services, 

ES 

which is out of scope Other engineers: not regulated. 
Legal persons (for civil engineering): 1. Registration in the Industrial register; 2. Declare 
interest to work in Spain to the Ministry of Development with description of the services 
to be rendered, with special reference to their duration, continuity and regularity. 3 
Include information on any insurance cover or other means of personal or collective 

May 2017 I 61 

 
MS  Engineering – steps for temporary services 

professional liability insurance. 

FR  None, only notification with a center of professional recognition for professionals 

IE 

IT 
LU 

providing the service. 
Legal persons cannot register as ‘chartered engineer’. There is nothing to stop a 
company using the term ‘Chartered Engineer’ but it has no official standing. Note: in the 
by-laws of the Chamber of Engineers, "corporate member" refers to registered engineers 
(natural persons).  
Requirements only apply to professionals providing the services, none for legal persons. 
Legal (and natural) persons: notification to be registered in the list of temporary service 
providers. 

MT  Legal persons: a prior declaration of temporary cross-border services, which is assessed 

on a case-by-case basis. Natural persons (including shareholders of voluntary 
partnerships): data and documents need to be submitted, and an aptitude test may be 
required if the qualifications are too different from the Maltese requirements. 

PL  Only natural persons providing the services can (and must) be registered, no legislation 

applies to legal persons. 

PT  Requirements only apply to professionals providing the services, none for legal persons 
RO  Engineering is not regulated. 
SK  Requirements only apply to professionals providing the services, legal persons cannot be 

a member of the Chamber. 

UK  No activities are reserved to engineers and use of the title “chartered engineer” is only 

controlled after complaints. 

4.4  Deadlines 

The  deadlines  for  handling  the  application  procedure  vary  between  Member  States 
(Table  4.5).  The  authorization  procedure  for  natural  persons  including  shareholders 
and/or managers is assumed to run in parallel to that for legal persons. Austria is the 
possible  exception,  where  natural  persons  must  be  authorized  before  the  procedure 
for  legal  persons  starts,  with  indicated  processing  times  of  eight  and  four  weeks 
respectively.  

Table 4.5 Engineering – Deadline for handling by authorities 

MS  Establishment of a branch 

AT 
a) 

The national deadline for any processing by the 
Chamber is 3 months. Länder may provide shorter 
deadlines for example 8 weeks for natural persons and 
4 weeks for legal persons but they tend to be indicative.

Temporary cross-border 
services 
Not applicable (no procedure) 

BE  Engineering is not regulated 
CY  3 months after submission of complete documents 

Engineering is not regulated 
Same as for branches 

(procedures for natural and legal persons are one and 
the same) 

CZ  Both natural persons (including mandatory for partners 

of voluntary partnerships) and legal persons: 60 days 
after documents are considered complete and 3 months 
from the submission of the application 

DE  For Germans (natural persons including mandatory for 
shareholders of firms wishing the carry the title 
‘engineer’ in the company name): 1 month to confirm 
completeness of documents, 3 months after submission 
of complete documents with a possible extension of 2 
months (BauO NRW § 70.4), for other EU nationals no 
deadline is set (§ 70.5); For legal persons wishing to 
carry the title ‘engineer’ in the company name: no set 
deadline but assumed to run in parallel with the 
procedure for shareholders 

Natural persons: see branches 
Legal persons: no procedure 

Same as for branches 

DK  Only for natural persons delivering the services (beyond 

Same as for branches 

the scope) 
Legal persons: 1 month with a possible extension of 2 

ES 

Legal persons: 1 month with a 

62 I May 2017 

 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

MS  Establishment of a branch 

months Natural persons (including mandatory for 
shareholders): 3 months 

Temporary cross-border 
services 
possible extension of 2 months 

FR  Engineering is not regulated 
IE  Not applicable (only for natural persons delivering the 

Engineering is not regulated 
Same as for branches 

services) 

IT  General business register (with which the procedure of 
the professional chamber is integrated): 1 month; 
Chamber (both natural and legal persons): 30 days to 
examine completeness of the files, 4 months after 
submission to decide on the application  
Legal persons: one month (the Examination Committee 
meets once a month) 

LU 

MT  Chamber: 3 months from complete application, 1 

month extension possible 

PL  Not applicable (only for natural persons delivering the 

services) 

PT  Chamber: 60 days for approval or, if necessary, to 

request additional documents. 

RO  Engineering is not regulated 
SK  For natural persons (including mandatory for partners 

of voluntary partnerships): 1 month (the requirement is 
checked by the Trade Licence Office which is out of 
scope but the natural person needs to be registered 
with the Chamber) 

Only for professionals 
providing the services (beyond 
the scope) 

Legal persons: one month (for 
registering the business, no 
authorization is required but 
only notification) 
Only for professionals 
providing the services (beyond 
the scope) 
Same as for branches 

Only for professionals 
providing the services (beyond 
the scope) 
Engineering is not regulated 
Same as for branches 

UK  Not applicable, use of the title ‘chartered engineer’ is 
only controlled ex post after complaints are received 

Same as for branches 

a)  Only for subsidiaries, because branches of foreign engineering firms are not recognized in Austria. 

Figure 4.1 shows the maximum processing times for ten countries where this is 
applicable. The maximum possible extension is shown as well. The application takes 
the longest in Italy and the shortest in Luxembourg and Slovakia. For temporary 
services, an application for legal persons must be processed in only six countries, 
including Luxembourg for the registration of a mere notification. In those six 
countries, the same processing time is the same as for branches.  

May 2017 I 63 

 
Figure 4.1 Engineering – Deadline for handling by authorities a) 

a) Austria: subsidiaries because branches of foreign engineering firms are not recognized in Austria. 

4.5  Tacit approval and validity 

Tacit  approval  means  that  the  activities  may  be  started  if  the  deadline  for 
authorization  has  expired  before  the  authority  has  notified  its  decision.  For 
establishing a branch, tacit approval is implicit in Belgium, France and Romania where 
the  profession  is  not  regulated  (Table  4.6).  Tacit  approval  is  furthermore  implicit  for 
legal  persons  in  three  countries  where  only  the  professional  providing  the  services 
need  authorization  (Denmark,  Ireland,  Poland)  and  the  United  Kingdom  where 
entitlement  to  the  voluntary  title  is  only  checked  after  complaints.  Tacit  approval  is 
explicit in Germany and Luxembourg.  

In the Czech Republic and Slovakia, the Trade Licencing Office checks the professional 
requirements  of  legal  persons  (beyond  the  scope  because  not  checked  by  the 
chamber) but the partners of a voluntary professional partnership must be authorized 
by  the  chamber  (in  scope).  Also  in  Malta  only  partners  of  a  voluntary  professional 
partnership  need  authorization.  In  the  other  five  countries  (Austria,  Cyprus,  Italy, 
Portugal Spain) services cannot be started before authorization.  

For temporary cross-border services no tacit approval applies in only three countries: 
Cyprus  and  Spain  for  all  firms  and  Germany  for  firms  wishing  to  carry  the  voluntary 
title ‘engineer’ in the company name.  

Table 4.6 Engineering – Tacit approval 

Establishment of a branch 

N/A (engineering is not regulated) 
No 
Legal persons: N/A (no chamber 

MS 
AT a)  No 
BE 
CY 
CZ 

64 I May 2017 

Temporary cross-border services 
N/A (no procedure) 
N/A (engineering is not regulated) 
No 
N/A (no procedure for legal persons) 

 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

MS 

DE 

DK 

ES 
FR 
IE 
IT 
LU 
MT 

PL 
PT 
RO 
SK 

UK 

Establishment of a branch 
procedure) Natural persons (incl. 
partners of a voluntary partnership and 
managers of limited liability firms): no 
Yes (for firms wishing to carry the 
voluntary title ‘engineer’ in the company 
name, other firms need no authorization) 
N/A (structural engineering: only for 
professionals providing the service; other 
engineering: not regulated) 
No 
N/A (engineering is not regulated) 
N/A (no procedure for legal persons) 
No 
Yes 
Voluntary partnerships: no, Other legal 
forms: yes (no procedure applicable) 
N/A (no procedure for legal persons) 
No 
Yes (engineering is not regulated) 
Legal persons: no chamber procedure, 
natural persons (including partners of a 
voluntary partnership): no 
N/A (use of the title ‘chartered engineer’ 
is only controlled ex post after complaints 
are received) 

Temporary cross-border services 

No (for firms wishing to carry the voluntary 
title ‘engineer’ in the company name, other 
firms need no authorization) 
N/A(structural engineering: only for 
professionals providing the service; other 
engineering: not regulated) 
No 
N/A (engineering is not regulated) 
N/A (no procedure for legal persons) 
N/A (no procedure for legal persons) 
Yes 
N/A (no procedure for legal persons) 

N/A (no procedure for legal persons) 
N/A (no procedure for legal persons) 
N/A (engineering is not regulated) 
N/A (no procedure for legal persons) 

N/A (use of the title ‘chartered engineer’ is 
only controlled ex post after complaints are 
received) 

a)  Only for subsidiaries, because branches of foreign engineering firms are not recognized in Austria. 

N/A: no authorization needed, hence tacit approval is not applicable. 

When a branch is established, authorization is in most countries indefinite, or depends 
on  an  annual  fee  (Table  4.7).  Only in  Cyprus  the  time  authorization has  limited  time 
validity,  namely  one  year.  Each  year,  the  same  application  needs  to  be  filled  in  for 
renewal of the license.  

For  temporary  cross-border  services,  the  authorization  is  valid  for  one  year  in  most 
countries and can be renewed every year. In most countries new documents need to 
be submitted, though always with the exception of proof of professional qualifications 
(of  natural  persons).  Only  in  Malta  the  authorization  for  temporary  cross-border 
services  cannot  be  annually  renewed  and  authorization  depends  on  duration, 
regularity, frequency and continuity of the services.  

In Germany a license for temporary cross-border services is valid for up to five years 
for  natural  persons  (including  shareholders  for  firms  wishing  to  carry  the  title 
‘engineer’  in  the  company  name).  This  means  the  Chamber  may  issue  a  licence  for 
five  years  but  also  for  a  shorter  period.  In  Austria  temporary  cross-border  services 
may be provided indefinitely.  

Table 4.7 Engineering – Time validity 

MS 
AT a) 
BE 
CY 

CZ 

DE 

Establishment of a branch 
Indefinite 
Indefinite (engineering is not regulated) 
1 Year; new docs required 

Legal persons: indefinite (no chamber 
procedure); Natural persons (incl. 
partners of a voluntary partnership and 
managers of limited liability firms): 
annual fee 
Indefinite (for firms wishing to carry the 
voluntary title ‘engineer’ in the company 
name and the shareholders of those 

Temporary cross-border services 
Indefinite 
Indefinite (engineering is not regulated) 
Shortest of project duration and 1 year; 
new docs required 
Legal persons: no procedure; Natural 
persons: 18 months; extension possible 
with 12 months; new docs required 

Legal persons: indefinite (for firms wishing 
to carry the voluntary title ‘engineer’ in the 
company name, other firms need no 

May 2017 I 65 

MS 

Establishment of a branch 
firms; other firms need no authorization) 

DK 

ES 

FR 
IE 

IT 
LU 
MT 

PL 

PT 

RO 
SK 

UK 

Indefinite (structural engineering: only 
for professionals providing the service; 
other engineering: not regulated) 
Legal persons: indefinite; Natural persons 
(including mandatory for shareholders): 
annual fee 
Indefinite (engineering is not regulated) 
Indefinite (authorization is only needed 
for professionals providing the service)  
Annual fee 
Indefinite 
Voluntary professional partnerships (and 
their partners): annual fee 
Indefinite (authorization is only needed 
for professionals providing the service)  
Annual fee 

Indefinite (engineering is not regulated) 
Indefinite (no chamber procedure for 
legal persons and indefinite for natural 
persons including partners of voluntary 
partnerships) 
Indefinite (use of the title ‘chartered 
engineer’ is only controlled ex post after 
complaints are received) 

Temporary cross-border services 
authorization) Natural persons (including 
shareholders of firms wishing to carry the 
title ‘engineer’ in the company name): up 
to 5 years 
Indefinite (structural engineering: only for 
professionals providing the service; other 
engineering: not regulated) 
1 Year; new docs required 

Indefinite (engineering is not regulated) 
Indefinite (authorization is only needed for 
professionals providing the service)  
1 Year; new docs required 
Project duration 
Depends on duration, regularity, 
periodicity, continuity of services 
Indefinite (authorization is only needed for 
professionals providing the service)  
Indefinite (authorization is only needed for 
professionals providing the service)  
Indefinite (engineering is not regulated) 
1 Year with perpetual renewal 

Indefinite (use of the title ‘chartered 
engineer’ is only controlled ex post after 
complaints are received) 

a)  Only for subsidiaries, because branches of foreign engineering firms are not recognized in Austria. 

4.6  Fees 

Figure  4.2  presents  the  fees  charged  by  the  responsible  authorities  for  compulsory 
registration and/or  compulsory chamber  membership of the  firm and/or  shareholders 
or  managers.  With  regard  to  fees  for  engineering  services,  the  same  approach  is 
followed  as  for  architectural  services.  The  fees  presented  in  Figure  4.2  are  first-time 
fees, but the part of the fee that must be paid every year is marked in a lighter colour. 
Fees of the general business register are excluded as they are beyond the scope of the 
study, even if it is mandatory for branches of firms from other EU countries to register 
with the general business register. Fees of social security institutes that must be paid 
as  part  of  the  registration  process  with  the  professional  chamber  in  Italy  are  also 
excluded.  

Information about fee requirements for shareholders or managers was found for only 
one country, Austria where fees need to be paid for the registration and membership 
of the  executive manager. For the  other countries fees for managers  or shareholders 
are  included  if  (a)  he  or  she  needs  to  be  an  authorized  professional  even  if  he  does 
not  provide  the  services  and  (b)  registration  or  membership  is  compulsory  for 
professionals.  

In four countries (the Czech Republic, Denmark, Ireland and Slovakia) there is no fee 
for firms, shareholders or managers. Still, a fee is levied for at least one professional 
for access to the market and the fee for one professional is used, except for Denmark 
where the fee only applies to a specific market segment discussed below.  

If a fee is required for registration or membership of shareholders and/or managers, it 
is  included  for  one  person  even  if  a  firm  has  more  shareholders  or  managers.  One 
reason is that there might just be one shareholder or manager, and applying the fee 

66 I May 2017 

 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

to  more  persons  would  reflect  differences  between  firms  rather  than  between 
administrative requirements. Another reason is that in many countries only half of the 
shareholders  must  be  an  authorized  professional  (see  Table  4.2)  and  then  the  fee 
need not be paid for all shareholders or managers.  

Another  assumption  is  that  whenever  (a)  shareholders  and/or  managers  need  to  be 
professionals and (b) the same fee applies to both natural and legal persons, the fee 
must be paid twice: once for the shareholder or manager and once for the firm. This is 
the case for the same two countries as for architects: Luxembourg (for both branches 
and temporary services) and for Germany (for temporary services).  

Lastly,  whenever  fees  are  available  both  including  and  excluding  professional 
indemnity  insurance,  the  fee  excluding  professional  indemnity  is  used  because 
is  a  regulatory  rather  than  administrative 
professional 
requirement, which is beyond the scope of the study.  

indemnity 

insurance 

Compared to architecture, fees for engineering are similar in some countries (Austria, 
Cyprus, Italy, Luxembourg and Slovakia) and lower in other countries. In Portugal the 
monthly  fee  is  EUR  8  to  10  for  engineering  while  for  architecture  the  fee  is  EUR  200 
per  project.  But  the  big  exception  is  structural  engineering  in  Denmark.  The 
registration  fee  for  professionals  providing  the  service  is  DKK  30,000  (roughly  EUR 
4,000)  and  the  annual  fee  is  DKK  6,000  (roughly  EUR  800)  for  permanent 
establishment.  Although  this  fee  is  presented  in  Figure  4.2,  it  is  not  used  in  the 
calculations  for  two  reasons.  Firstly,  engineering  services  are  not  regulated  in 
Denmark  except  for  professionals  providing  structural  engineering  (the  design  of 
complicated  structures  such  as  hospitals,  shopping  centers  and  such).  Secondly,  the 
fee is only required to operate in a specific market segment for which we have no data 
on the cross-border business population.  

The fees  for  cross-border branches in other countries than Denmark are (in EUR and 
in descending order of total fee amount): 

•  Germany (branches wishing to carry the voluntary title of ‘engineer’ in the 
company name): 700 = 500 for legal persons and 200 for one shareholder 
(reductions may exist for unemployed and disabled persons); 

•  Austria: 420 = 220 (authorisation (“Befugnis”) by the Federal Ministry) + 2 x 

100 (registration of the firm and the executive manager); 

•  Spain: 408 = 136 registration fee + 272 annual fee; 
•  Slovakia: 348 = 116 registration fee + 232 (annual fee for a legal person with 
more than one authorized engineer; for legal persons with only one authorized 
engineer the annual fee is EUR 100);  
Italy: 343 = 168 registration tax (this is a national tax and the same for all 
regional chambers) + 175 annual membership fee (differs between regions, the 
same value as for architecture is assumed); 

• 

•  Portugal: 320 = 200 registration fee for a legal person + 12 x 10 monthly fee 

for a natural person (including mandatory for a partner of a voluntary 
partnership); 

•  UK (to carry the voluntary title ‘chartered engineer’ in the company name, with 

exchange rate 0.8): 313 = GBP 250 / 0.8 annual membership fee; 

•  Cyprus: 295 = 100 (registration of legal persons) + 10 (registration certificate) 
+ 55 (registration of one shareholder) + 100 (annual membership of legal 
persons) + 30 (annual professional licence of one shareholder). The annual 
cost is 230 = 140 (registration certificate + membership + professional licence) 
+ 90 (annual renewal of subscription); 
• 
IE: 225 annual fee for one natural person (professional providing the services); 
•  Luxembourg: 160 = 2 x 80 per registration (for the firm and one shareholder); 
•  The Czech Republic (with exchange rate 27): 74 = CZK 2,000 / 27 annual 

membership fee; 

May 2017 I 67 

•  Malta: 62 = 12 registration fee + 50 annual membership fee of one 

shareholder in a voluntary professional partnership. 

Figure 4.2 Engineering – First-time fees for legal persons a) 

a)  Except for the Czech Republic, Denmark (structural engineering), Ireland, Poland and Slovakia 

where no procedure for legal persons exists but only for natural persons. 

4.7  Online information and procedures 

The  availability  of  online  information  and  procedures  are  not  formalities,  but  rather 
tools  to  facilitate  going  through  the  procedure.  As  confirmed  in  this  study,  in  some 
countries  a  substantial  part  of  the  burden  of  administrative  formalities  consists  of 
finding the relevant practical information about the procedure. Also, as demonstrated 
earlier,  procedures  can  take  many  months  to  complete  and  online  procedures  may 
help reduce the length of the procedure.  

At  the  EU  level,  one  single  start  page  is  available  which links  to  national  start  pages 
about  access  control  procedures,  the  so-called  Points  of  Single  Contact  (PSC).8  The 
national  PSC  pages  are  updated  by  the  Member  States.  All  countries  have  a  point  of 
single  contact  (PSC);  however  in  three  countries  the  PSC  is  not  specific  about 
procedures  for  authorization  of  architectural  services:  Germany,  Italy  and  the  United 
Kingdom  (Table  4.8).  In  Denmark  (structural  engineering),  Portugal  and  Spain, 
specific information about access to the profession is available, but only in the national 
language.  

In almost all countries forms can be downloaded, but documents need to be posted. In 
three  countries  online  procedures  are  available  to  non-nationals:  in  Cyprus  and 
Portugal  via  email  (which  respondents  prefer  over  uploading);  and  in  Luxembourg 
documents  need  to  be  posted  but  further  case  handling  is  fully  electronic.  In  two 

8   http://ec.europa.eu/internal_market/eu-go/index_en.htm. 
68 I May 2017 

 
 
 
                                                           
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

further countries (some Italian regions and Malta) full electronic case handling is only 
available to nationals because a national e-ID is required.  

In  Spain  documents  must  be  delivered  in  person.  In  the  Czech  Republic,  a  person 
must,  according  to  the  law  have  his  signature  certified  by  drawing  a  signature  on  a 
special form in the presence of a local official. However, an interview with an Austrian 
service  provider  revealed  that  foreign  persons  can  swear  their  signature  before  a 
notary in their own country for authorization in the Czech Republic.  

Table 4.8 Engineering – Electronic information and procedure 

MS  PSC 

Establishment of a branch 

AT  DE, EN 

BE  NL, FR 

CY  EL, EN 

CZ  CZ, EN 

DE 

--- 

DK  DK 

ES  ES 

FR  EU* 

IE 

--- 

IT 

--- 

LU 

FR,DE,EN 

MT  EN 

PL 

PL, EN 

PT 
PT 
RO  RO, EN 

SK  SK, EN 

UK 

--- 

Forms can be downloaded; documents must be 
posted 
No authorization or notification 

Electronic submission procedure available (but 
link not working during the study), forms (in 
Greek) can be downloaded 
Signature must be notarized, forms can be 
downloaded, documents must be posted 
Forms can be completed online, documents 
must be posted 
Not applicable (structural engineering: only for 
professionals providing the services, other 
engineering: no authorization or notification) 
Forms downloadable, must be delivered in 
person 
(only a notification for recognition of 
qualifications) 
Not applicable (only for professionals providing 
the services) 
General business register (with which the 
procedure of the chamber is integrated) and 
some chambers of engineers: online procedure 
Information must be posted, a VAT registration 
form must be collected in person 
Forms can be downloaded; documents must be 
posted 
Forms can be downloaded; documents must be 
posted 
Documents can be emailed 
No authorization or notification 

Forms can be downloaded, documents must be 
posted  
No authorization or notification 

--- means: not available. 

Temporary cross-
border services 
No authorization or 
notification  
No authorization or 
notification 
As for branches but forms 
in English 

Same as for branches 

Same as for branches 

Same as for branches 

Same as for branches 

Same as for branches 

Same as for branches 

Same as for branches 

Same as for branches 

Same as for branches 

Same as for branches 

Same as for branches 
No authorization or 
notification 
Same as for branches 

No authorization or 
notification 

4.8  Submission demands - branches 

Most countries require a demand form to be filled in with personal data and sometimes 
a  passport/ID-number  and  details  about  the  educational  degree  (Table  4.9).  With 
regard  to  data  requirements  on  shareholders  and  managers  as  opposed  to 
professionals  providing  the  service,  in  only  one  country  (Austria)  the  submission 
demands  are  clearly  differentiated.  Sometimes  one  page  in  English  clarifies  demands 
for non-nationals. This is the case in Cyprus where the application form may give the 

May 2017 I 69 

 
impression  that  residency  in  Cyprus  is  required  and  the  page  in  English  clarifies  that 
residency in any EU Member State is accepted for EU citizens.  

In  most  countries  the  submission  demands  are  not  clearly  differentiated  between 
shareholders and managers on the one hand and professionals providing the services 
on  the  other  hand,  as  illustrated  in  Section  3.8  for  architects.  Whenever  submission 
demands  for  shareholders  who  must  be  engineers  are  not  separately  provided,  the 
submission demands for authorization of professionals are presented.  

The minimum requirement is the name and address of the firm. Other data that may 
be demanded include further  ID information, further contact details, a tax number of 
the  host  country  (in  Cyprus  and  Italy),  details  of  the  area  of  expertise  (typically  in 
host countries where the same procedure applies to architecture and civil engineering: 
Austria,  Cyprus,  the  Czech  Republic)  and  educational  data  (included  for  countries 
where  this  is  required  of  shareholders  and/or  managers:  Cyprus,  Germany  for  a 
voluntary title in the company name, and Italy). 

For engineering, Cyprus is the only country that requires substantial additional data to 
be  submitted  (multiple  registration  and  ID  numbers,  start  and  end  dates  of  all 
qualifications).  Italy  and  Portugal  also  demand  more  than  average  data  including  for 
example  year  of  graduation,  however  only  for  partner  of  voluntary  engineering 
partnerships.  

Table 4.9 Engineering – Data to be submitted (branches) 

MS  Engineering– data submission demands (branches) 
AT 

Legal persons: area of expertise of the firm, name of the company, address of company 
headquarters Natural persons (including mandatory for the executive manager): name 
and city of residence, date and place of birth, place of office, phone number and email 
address 

BE  Engineering is not regulated 
CY 

Legal persons: Name and address of firm, Engineering disciplines of specialisation, 
Company tax number, Names, registration numbers and disciplines of employees 
registered with ETEK, Company logo Natural persons (including mandatory for all 
shareholders): Personal data (name, surname, father's name, ID, Passport, nationality, 
date and place of birth, occupation); Contact details (Residential, professional address or 
other contact details and preference); Educational qualifications; Choice of engineering 
discipline of registration (incl. certification of practical exercise); Document checklist; 
Declaration of honour (regarding truthful information and of criminal record status) 

CZ  Natural persons providing the services (which the legal person needs to submit): 

notification form and application for registration form; activities which he/she plans to 
perform systematically in the Czech Republic; delivery address on the territory of the 
Czech Republic; for shareholders and managers: qualification documents (for general 
business registration) 

DE  For legal persons wishing to carry the voluntary title ‘engineer’ in the company and their 

shareholders (Nordrhein-Westfalen): Name; nationality; academic degree; birth date; 
address; address of the registered office.  

DK  Structural engineering, requirements only apply to natural persons providing the 

ES 

services, which is out of scope Other engineering: not regulated. 
Legal persons, for authorization by Ministry of Development: address notifications; bank 
details 

FR  None (only for natural persons providing the services) 
IE  None (only for natural persons providing the services) 
IT 

Legal persons (general business register with which the chamber procedure is integrated, 
Milano): surname, name, date of birth, country, province and place of birth, nationality, 
passport/ID number, email address, (for invoicing:) country, name, city, address, post 
code, phone, fax, mobile phone and activity of business, Natural persons (including 
mandatory for the shareholders of voluntary partnerships), in Milano: name, nationality, 
place of birth, date of birth, city, postal code, street and house number, phone, mobile 
phone, professional address (city, postal code, street and house number, phone, fax), 
fiscal number, VAT number, current activity, university and year of graduation, 
university, session and year of State Exam, specialization and checklist 

70 I May 2017 

Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

MS  Engineering– data submission demands (branches) 
LU  Natural persons (including mandatory for shareholders): personal details, education and 

professional information 

MT  Natural persons (including mandatory for the shareholders of voluntary partnerships), for 
the Engineering Warrant: - ID data: first names, surname, date of birth, ID card number 
(passport number for non-Maltese residents), home address, email, phone number 
during day / evening, mobile phone number, nationality; - Qualifications: full title / 
degree, engineering field (e.g. electrical), issuing body (e.g. University of Malta), year of 
issue - Professional Membership: designatory letters (e.g. MIEE), issuing organisation 
and country (e.g. Institution of Electrical Engineers, UK), Grade/Class of Membership 
(e.g. Corporate Member), date in current grade (e.g. 2000) - Cumulative practical 
training of at least 1 year: start and end month/year; organisation (e.g. Umberto Calosso 
Trade School), details of training undertaken; - Cumulative 2-year post-graduate 
training: start and end month/year; company; position (e.g. Junior Engineer); concise 
details of personal experience 

PL  None (only documents) 
PT 

Legal persons: application form Natural persons (including mandatory for partners of 
voluntary partnerships): name, city of residence, phone number, email address; 
professional address, phone and email address; university, engineering specialization and 
year of graduation, professional card number, years of work experience. 

RO  Engineering is not regulated 
SK 

Information about the legal person - Company name, Legal representative person`s 
name, Contact person and his/her position, Company address, Company`s ID / Tax ID / 
VAT ID, Place of registration, Fax, Phone, E-mail, Brief description of the company (for 
voluntary registration of the firm – registration is only compulsory for natural persons); 
for shareholders: professional qualification documents (for general business registration) 
List of names of employees - authorised civil engineers 

UK  No prior authorization, only control ex post after complaints about the use of the 

chartered title in the company name 

In  most  countries  a  certified  copy  of  the  company  statutes  need  to  be  submitted  for 
authorization of a branch by the professional chamber (Table 4.10).  

In Germany (only if the firm wishes to carry the title ‘engineer’ in the company name) 
the company statutes of architecture firms need to include the details of shareholding, 
voting rights and the executive managers. In other countries documents on these can 
be submitted separately whenever they are required.  

Proof of insurance is generally not part of the registration procedure, except in Cyprus, 
Germany and Malta.  

Other  documents  that  may  be  required  are  proof  of  professional  qualifications  of 
shareholders, partners and/or managers, but these are beyond the scope of the study. 

Table  4.10  includes  information  about  the  format  in  which  documents  must  be 
submitted (for example certified or simple copies). If no information about the format 
in  which  documents  must  be  submitted  is  available,  no  information  on  this  is 
presented in Table 4.10 either. In the analysis, it will be assumed that in these cases 
simple copies are sufficient.  

In  Spain  documents  need  to  be  legalized  by  way  of  apostille,  and  in  Italy  various 
documents need to be sworn before an Italian court of law.  

Table 4.10 Engineering – Documents to be submitted (branches) 

MS  Engineering – document submission demands (branches) 
AT 

Legal persons: A) Application form must be signed by all persons who can legally 
represent the firm: original in duplicate B) Company statutes: original or certified copy C) 
Certificates of admission to the profession for all persons who can legally represent the 
firm: simple copy Natural persons (including mandatory for the executive manager): B1) 
evidence of nationality B2) proof of authorisation to practice as a civil engineer or 

May 2017 I 71 

 
MS  Engineering – document submission demands (branches) 

architect in the home country B3) certificate of authorities on reliability (extract from 
judicial record) B4) certificate of authorities on non-bankruptcy B5) certificate of 
authorities on absence of professional misconduct. B6) signed declaration  

BE  Engineering is not regulated 
CY 

Legal persons: A1) Application for company registration: authenticated copy A2) 
Certificate proving the formation of the company: authenticated copy A3) Certificate 
proving the shareholders of the company: authenticated copy …..This includes the ETEK 
registry numbers and engineering discipline of the shareholders/board of management 
A4) Certificate of registration in the Companies register: authenticated copy A5) 
Certificate of the Board of Directors: authenticated copy A6) Statute of the company: 
authenticated copy A7) Certificate of Professional Insurance: authenticated copy Natural 
persons (including mandatory for all shareholder): B1) Passport proving citizenship of an 
EU Member State; B2-1) For EU citizens: proof of marriage with a Cypriot citizen and 
proof of habitual residence in Cyprus, or alternatively B2-2) Copy of Civil Registry and 
Migration Department’s Permit or other proof of residence in the State (not clear from 
the application form that this may be any EU Member State, but confirmed by 
information on the website in English) B3) Certificate stating that he/she has adequate 
knowledge of the Greek language to practice the profession in Cyprus B4) Exact copies of 
all qualifications mentioned in your application; B5) Exact copies of all certificates with 
detailed records per year of study courses and scores for the above qualifications; B6) 
Copy of High School Diploma B7) Certificate of Competent Body or Authority stating that 
the qualifications of the applicant allow him/her to practice the profession in the country 
of issue without any limitations B8) Certificate of one year ETEK internship under the 
supervision of a civil engineer or architect B9) License to practice by the competent body 
of the country or a similar attest or certificate B10) Two passport size photographs B11) 
Registration fee of €55 (either by cash, cheque, credit card, online payment, or bank 
transfer) per field applied for 

CZ  Compliance with professional regulations is checked by the Office for Trade Licences (out 

of scope) 

DE  A) Proof of entitlement to carry the name 'architect' in the company name in the home 
country: certified copy B) Constitutive act demonstrating compliance with the German 
requirements for carrying the title 'architect' in the company name: certified copy C) 
Proof of professional indemnity insurance meeting the requirement for firms carrying the 
name 'architect' in the company name: certified copy 
C3. Proof of professional indemnity insurance meeting the requirement for firms carrying 
the name 'architect' in the company name (https://www.nrw-
ea.de/en/file/1848/download?token=v_SVag4m) 

DK  None (structural engineering: only for professionals providing the services, other 

ES 

engineering: not regulated)  
Legal persons, registration with the Ministry of Development: A1) Original public Deed of 
professional society, or where appropriate, to adapt to the Law of Professional Societies, 
if not a new constitution. (The writing should have already passed by the commercial 
register): certified copy A2) Certificate accrediting the ownership structure and 
participation of each partner in relation to the particulars thereof (name and profession 
where applicable): certified copy A3) Relationship charges of government and 
administration and people who occupy them, issued by the administrator of society: 
certified copy Legal persons, registration in the Industrial Register (Madrid): B) Social 
security certificate of the legal representative Natural persons (including mandatory for 
shareholders of voluntary partnerships, certified copies): C1) ID card or passport; C2) 
proof of professional qualifications (academic or professional title)  

FR  None (only for recognition of professional qualifications of professionals providing the 

services) 

IE  None (only for professionals providing the services) 
IT 

Registration in the general business register (with which the procedure of the chamber is 
integrated): A1) Certificate indicating the company details and the legal representatives 
of the company: The certificate must be translated into Italian by an expert and sworn 
before a court of law. A2) R Form (fill in the mandatory sections and field 6 "Scope and 
purpose of the foreign company" only) A3) Int.P. Form (relating to the legal 
representative of the foreign company) A4) UL Form A5) Fedra Form with digital 
signature of one company director Registration with the chamber: B1) Registration form: 
duly filled and stamped; B2) Company statutes and articles of incorporation: translated 
original B3) Certificate of inscription in the Company Register (they get that after the 
REA): original B4) Certificate of registration to a professional chamber of the members: 
original B5) Declaration of non incompatibility (2 forms by which the members declare to 

72 I May 2017 

Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

MS  Engineering – document submission demands (branches) 

LU 

respect the legal requirements): original B6) Proof of payment of the EUR 168 
registration tax: photocopy B7) Proof of identity: photocopy B8) Disclaimer on personal 
data: duly filled and signed; B9) List of shareholders (personal data) 
For registration with the chamber: proof of registration of the diplomas of shareholders to 
the Ministry for Higher Education and Research, registration in the general business 
register, license to the Luxembourg VAT registration (these are checked, simple copies 
suffice)  

MT  Legal persons, Periti partnership registration for a voluntary partnership: A1. Partnership 
agreement, certified copy; A2. Proof of due registration with MFSA (the general business 
register), simple copy; A3. The firm's professional indemnity Insurance Coverage, simple 
copy; A4. The registration fee (payable cheque)  

PL  Nothing applicable to legal persons 
PT  A1) Application form for the Chamber of engineers A2) identification and proof of the 

legitimacy of those who act as manager or administrators are professional engineers or 
equivalent in full exercise of their rights in the Member State of the EU or the EEA to 
request admission in accordance with Article 47 of Law no. No. 9/2009, of March 4, 
amended by Law No. 41/2012 of 28 August, and Law No. 25/2014, of May 2 A3) 
Document proving the legal existence of the entity that creates the permanent 
representation; A4) Full text and updated memorandum of the entity's statutes 
establishing the permanent representation; A5) Resolutions approving the establishment 
of permanent representation and the designation (s) of its representative (s) A6) 
Portuguese Tax Identification Number(s) of representative(s) of the Permanent 
Representation All documents need to be certified copies of certified or authenticated 
originals Natural persons (including mandatory for shareholders of voluntary 
partnerships): B1) Registration form duly completed B2) Curriculum Vitae summed up to 
2 pages to file in the registration process; B3) Statement of the competent authority of 
the country provenance, confirming the lawful exercise professional activity Engineer, 
indicating the date of registration  

RO  Engineering is not regulated 
SK  For general business registration (Slovak Trade Licence Act, § 66): Extract of criminal 

record not older than 3 months Proof of nationality Proof of nature and duration of 
activity for which the national is authorized in the home country Copy of the certificate of 
competence, giving access to the profession (in Slovakia: either university degree or 
vocational secondary education Construction of direction and three years experience in 
the field) Bank declaration on financial soundness Proof of equivalent professional 
indemnity insurance  

UK  No prior authorization, only control ex post after complaints about the use of the 

chartered title in the company name 

Austria,  Cyprus,  Denmark  and  Germany  accept  original  documents  in  the  English 
language (Table 4.11). If the original is not in English, Cyprus and Denmark accept a 
translation  into  English,  but  Austria  and  Germany  require  a  translation  into  German. 
The other countries only accept translations into a national language. The exception is 
Ireland  where  the  Chamber  of  Engineers  only  accepts  original  documents  that  are  in 
English and no translations of for example diplomas are allowed.  

In all countries translations must be certified, except in Luxembourg where a certified 
translation is customary but simple translations may also be accepted. Italy requires a 
translation  by  a  translator  who  is  sworn  before  an  Italian  court  of  law.  The  Slovak 
Chamber  of  Engineers  requires  translation  by  either  an  official  translator  from 
Slovakia, or a translation done by way of apostille.  

Table 4.11 Engineering– Translation requirements  

MS  Engineers – translation requirements 
AT  All documents: if original is not in English or German, certified translation into German, 

may be done in country of original document 

BE  None (engineering is not regulated) 
CY  Certified translation if the document is not in Greek, Turkish or English, may be done in 

any EU Member State 

CZ  General business registration (Czech Trade Act, § 5.3 and 5.4): translation into Czech, 

May 2017 I 73 

 
MS  Engineers – translation requirements 

the requirement to use a Czech translator and the requirement to verify authenticity do 
not apply to nationals from other EU Member States if there is no doubt about the 
correctness of the translation 

DE  For firms wishing to carry the voluntary title ‘engineer’ in the company name: if original 
is not in English, French or German: certified copies of certified translations into German 
(no restriction on translator) 

DK  None (structural engineering: only for professionals providing the services, other 

engineering: not regulated) 

ES  Certified copy of certified translation into Spanish, may be done in any EU Member State 
FR  None (engineering is not regulated) 
IE  None (only for professionals providing the services) 
IT 

The company statutes and the certificate of registration certificate to a professional 
chamber in the home country must be translated into Italian, either in an Italian 
embassy or consular post (apostille) or by an expert who swears the correctness of his 
translation before an Italian court of law.  

LU  Documents must be translated into Luxembourgish, French or German, a certified 

translation is customary but a simple translation is also accepted; no restrictions apply to 
the translator 

MT  For voluntary partnerships: certified translations into Maltese or English “in such manner 

as may be prescribed” 

PL  None (only for professionals providing the services) 
PT  Certified translations into Portuguese, may be done in any EU Member State 
RO  None (engineering is not regulated) 
SK  General business registration (Slovak Trade License Act, § 46.5 and § 66): certified 

translation into Slovak 

UK  No prior authorization, only control ex post after complaints about the use of the 

chartered title in the company name 

4.9  Submission demands – temporary services 

Tables 4.12 and 4.13 provide the data and documents that engineers need to submit 
for authorization of temporary services, if any. In Austria, there is no authorization or 
notification for temporary services, but clients need to be informed of certain specifics 
about the service provider before the contract is signed.  

In  ten  countries,  requirements  for  temporary  services  apply  only  to  natural  persons 
delivering the service: Cyprus, the Czech Republic, Denmark (structural engineering), 
France, Ireland, Italy, Malta, Poland, Portugal and Slovakia.  

In Luxembourg the firm needs to provide certain data, but much less than to establish 
a permanent branch and no documents are required. In Spain, the firm needs to notify 
a  regional  Chamber  and  to  provide  “light”  details  and  documents  for  one  person 
legally representing the firm.  

In  Germany,  the  same  data  and  documents  need  to  be  provided  as  for  branches  to 
carry the title ‘engineer’ in the company – however (as for branches) this is voluntary.  

In  the  remaining  three  countries,  Belgium,  Romania  and  the  United  Kingdom,  no 
authorization procedure for legal persons is in place at all.  

Table 4.12 Engineering – Data to be submitted (temporary services) 

MS  Engineering – data submission demands (temporary services) 
AT  No authorization or notification, but to be submitted to the client before signature of the 
contract: 1. Register where he is registered and identification number in this register; 2. 
Name and address of the responsible controlling authority in the country of establishment 
3. Professional body or similar organisation of which the architect/engineering consultant 
is part of 4. Professional title / formal qualification 5. Turnover tax identification Number 
6. Details about insurance protection concerning professional liability 

BE  None (engineering is not regulated) 

74 I May 2017 

 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

MS  Engineering – data submission demands (temporary services) 
CY  None (only for professionals providing the services) 
CZ  None (only for professionals providing the services) 
DE  For natural persons (including mandatory for shareholders of firms that wish to carry the 
title ‘engineer’ in the company name): and legal persons (Nordrhein-Westfalen, the 
requirements are the same as for the establishment of a branch): Name; nationality; 
academic degree; birth date; address; address of the registered office.  

DK  None (structural engineering: only for professionals providing the services, other 

ES 

engineering: not regulated)  
Legal persons, for authorization by Ministry of Development: information about any 
insurance cover or other means of personal or collective that it may have in relation to 
their professional liability protection 

FR  None (only for recognition of qualifications of professionals providing the services) 
IE  None (only for professionals providing the services) 
IT  None (only for professionals providing the services) 
LU  VAT Registration, insurance information and professional activity information 
MT  None (only for professionals providing the services) 
PL  None (only for professionals providing the services) 
PT  None (only for professionals providing the services) 
RO  None (engineering is not regulated) 
SK  None (only for professionals providing the services) 
UK  No prior authorization, only control ex post after complaints about the use of the 

chartered title in the company name 

Table 4.13 Engineering – Documents to be submitted (temporary services) 

MS  Engineering – document submission demands (temporary services) 
AT  None (only data to clients, see previous table) 
BE  None (engineering is not regulated) 
CY 

Legal persons: A1) Simple copy of company registration certificate from other EU Member 
State A2) Simple copy of professional licence from another EU Member State Certificate  

CZ  None (only for professionals providing the services) 
DE 

Legal persons, voluntarily to carry the title ‘engineer’ in the company name (the same as 
for a branch): A1) Proof of entitlement to carry the name 'engineer' in the company name 
in the home country: certified copy A2) Constitutive act demonstrating compliance with 
the German requirements for carrying the title 'engineer' in the company name: certified 
copy A3) Proof of professional indemnity insurance meeting the requirement for firms 
carrying the name 'engineer' in the company name: certified copy Natural persons 
(including mandatory for shareholders to carry the title ‘engineer’ in the company name) 
in Nordrhein-Westfalen, the requirements are the same as for a branch: B1) Higher 
education diploma B2) Certificate of residence in Nordrhein-Westfalen not older than 6 
months B3-1) Certificate of membership in the home country and Proof of good repute 
issued by the Chamber of the home country, or alternatively B3-2) Work certificates 
proving at least 2 years of full-time work in the last 10 years; Certificates of at least 80 
hours of additional training and two construction designs; B4) In other Bundesländer 
additional documents might be required: certificate of good character; certification of 
solvency; proof of professional indemnity insurance 

DK  None (structural engineering: only for professionals providing the services, other 

engineering: not regulated  

ES  Representative of a legal person, for registration with the Ministry of Development 

(certified copies of certified originals): 1- Documentation proving the nationality of a EU 
Member State; 2- Certificate certifying that the applicant is legally established in a 
Member State of the European Union in order to pursue the activities in question and the 
absence of any prohibition, at the time of making the declaration, preventing him from 
performing the profession in the State of origin, not even temporarily, issued by a 
competent authority of the home country  

FR  None (only for recognition of qualification of professionals providing the services) 
None (only for professionals providing the services) 
IE 
IT 
None (only for professionals providing the services) 
LU  Only data need to be submitted (see previous table) 
MT  None (only for professionals providing the services) 
PL  None (only for professionals providing the services) 

May 2017 I 75 

 
MS  Engineering – document submission demands (temporary services) 
PT  None (only for professionals providing the services) 
RO  None (engineering is not regulated) 
SK  None (only for professionals providing the services) 
UK  No prior authorization, only control ex post after complaints about the use of the 

chartered title in the company name 

76 I May 2017 

 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

5  ACCOUNTANCY SERVICES 

5.1  Types of authorization procedures 

Accountancy in the narrow sense of accountancy 

In  this  report  accountancy  is  defined  in  a  narrower  sense  than  usual.  Statutory 
auditing,  which  EU  Member  States  must  regulate  according  to  the  Statutory  Audits 
Directive9 2006/43/EC, is not included in the definition of accountancy services in this 
study, nor is tax consultancy.  

Access to accountancy not regulated in eight countries 

In  eight  countries  covered  by  this  study,  access  to  accountancy  services  is  not 
regulated  (see  Table  A5.11  in  Annex  5):  Cyprus,  the  Czech  Republic,  Denmark, 
Germany, Ireland, Poland, Slovakia and Spain. In Cyprus, membership of the chamber 
of  auditors  is  voluntarily  available  to  accountancy  service  providers.  In  Spain, 
voluntary  membership  of  a  professional  organisation  is  available,  especially  for  the 
purpose  of  recognition  abroad.  The  absence  of  authorization  procedures  does  not 
imply complete absence of barriers caused by regulations, even though the accounting 
principles are the same worldwide, and the principles of business income tax and VAT 
are  the  same  within  the  EU.  However,  the  tax  rates,  precise  definitions  of  the  tax 
base, exemptions and deductibles vary across Europe. Moreover, most of this changes 
every  year.  One  accountant  reported  that  investing  in  knowledge  of  the  underlying 
regulations  in  other  countries  is  only  viable  for  high-end  services  such  as  statutory 
auditing, rather than accountancy. 

Access to accountancy regulated to varying degrees in nine countries 

In  five  countries  (Belgium,  France,  Luxembourg,  Portugal  and  Romania)  accountancy 
is regulated but lighter regulations apply than for auditors. In two countries the same 
regulations  apply  to  accountancy  and  statutory  auditing:  Austria  and  Italy.  In  the 
latter  two  countries  one  may  therefore  expect  access  to  accountancy  services  to  be 
more  heavily  controlled  than  in  the  other  countries.  In  the  one  remaining  country 
(Malta),  reserved  activities  which  are  regulated  are  broader  than  auditing,  and  the 
regulations  for  these  reserved  activities  are  described  in  this  chapter  and  assuming 
that  accountancy  firms  want  to  exercise  the  reserved  activities  in  Malta  they  will  be 
included in the cost calculations, but mere bookkeeping services are not regulated in 
Malta.  

Reserved activities explicit in professional regulations in Malta and Romania 

In Malta and Romania are the reserved activities explicitly listed in the regulations of 
the  profession  (see  Table  A5.12  in  Annex  5).  In  Malta,  the  reserved  activities  are 
described as “(a) the issuing of  reports  on prospective  financial information prepared 
for  the  promotion  of  investment  in  an  entity  or  for  the  raising  of  finance  (b)  the 
issuing  of  independent  reports  on  share  valuations  or  valuations  of  businesses  (c) 
acting  as  reporting  accountants  in  prospectuses,  offering  memoranda  and  other 
similar documents intended for public subscription (d) the issuing of reports, including 
compilation or review of reports, with respect to interim or annual financial statements 
of  any  entity  but  excluding  any  reports  on  financial  statements  prepared  for  internal 
purposes  and  (e)  any  other  services  which  may  be  prescribed  by  the  Minister  or  by 
any other law.” The above activities are related to the publication of financial reports 

9   http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:32006L0043. 

May 2017 I 77 

                                                           
and reports for internal purposes are explicitly excluded. Hence the conclusion seems 
justified that mere accountancy is not regulated in Malta.  

In Romania, the following activities are reserved for ‘chartered’ accountants: 

a)  “keeps or prepare or supervise accounting and financial statements, verify and 

sign; 

b)  assists the organization and accountancy; 
c)  carries out economic and financial analysis and economic evaluation; 
d)  perform accounting works ordered by the judicial entities or requested by the 

natural or legal persons as provided by law; 

e)  performs other works with financial-accounting, administrative organization 

f) 

and informatics; 
fulfils according to the law, the tasks specified in the mandate of auditor of 
companies; 

g)  provides expert assistance for establishment and reorganization of companies; 
h)  provides for individuals and businesses that require professional accounting 

knowledge.” 

‘Certified’ accountants in Romania can exercise for individuals and businesses: 

a)  “keeps the accounts of economic and financial operations according to the 

contract; 

b)  prepares the works required for the preparation of the financial statements.” 

From the above, it can be concluded that the same requirements apply to accountants 
(activity  b  of  chartered  accountants)  and  statutory  auditors  (activity  f  of  chartered 
accountants) while both activities reserved for certified accountants can be argued to 
relate to both accountancy and statutory auditing.  

Authorization for permanent establishment of accountancy in eight countries 

In  eight  out  of  the  nine  countries  where  access  to  the  profession  is  regulated,  legal 
persons need authorization for permanent establishment (Table 5.1). The exception is 
the  United  Kingdom,  where  only  professionals  providing  (public)  services  need 
authorization.  In  the  United  Kingdom,  firms  may  carry  the  title  of  ‘chartered 
accountant’  in  the  company  name  under  certain  conditions.  However,  there  are  no 
permission  procedures  in  place  to  use  ‘chartered  accountant’  in  the  company  name. 
Rather, legal persons must independently follow the rules indicated in legislation. If a 
complaint  is  received  from  the  public  about  misleading  use  of  the  description 
‘chartered  accountant’  the  professional  control  body  ICAEW  will  investigate.  Hence, 
there  is  no  ex  ante  authorization  procedure  in  any  sense  for  accountancy  firms. 
Nevertheless,  the  data  and  document  submission  demands  for  partners  of  firms 
wishing to carry the voluntary title ‘chartered accountant’ in the company name will be 
included  because  activities  are  reserved  to  chartered  accountants  (as  opposed  to 
chartered architects and engineers).  

In Malta authorization is only needed to the extent that accountancy service providers 
are involved in preparing public financial reports and in Portugal authorization is only 
needed for voluntary professional partnerships.  

In  France,  Ordonnance  n°  45-2138  du  19,  September  194510  Art.  7  provides:  “sont 
admises  à  constituer,  pour  l'exercice  de  leur  profession,  des  sociétés  dotées  de  la 
personnalité  morale”  where  the  word  “constituer”  seems  to  exclude  the  possibility  to 

10   www.legifrance.gouv.fr/affichTexte.do?cidTexte=JORFTEXT000000698851. 
78 I May 2017 

 
 
                                                           
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

establish  a  branch.  This  interpretation  seems  justified  by  a  similar  wording  for 
architecture services in France, with the clarification that despite the use of the word 
“constituer”  it  is  possible  to  establish  an  architecture  branch.  In  addition,  no  cross-
border accountancy branch in France was identified in this study, but only subsidiaries. 
Hence for France it is concluded that the establishment of a cross-border accountancy 
branch is not possible and authorization applies to the setting up of subsidiaries.  

Authorization for temporary annual reports preparation services in Malta 

In  Malta,  authorization  for  temporary  cross-border  services  is  only  required  for 
activities  related  to  public  reports.  The  Maltese  law  provides  that  various  factors  will 
be  taken  into  account  to  decide  whether  the  services  are  indeed  temporary,  such  as 
the duration of individual services, the period of services and the frequency of services 
in that period. This suggests that authorization is typically granted for one service of a 
short duration, but not for a second service within five years (the period examined in 
establishment  procedures).  Hence  it  is  concluded  that  for  temporary  services 
authorization  is  needed  in  Malta,  but  with  the  note  that  it  only  applies  to  activities 
related to preparing annual reports.  

In  Luxembourg,  firms  with  more  than  250  employees  need  authorization  for 
temporary  cross-border  accountancy  services,  but  firms  with  fewer  employees  only 
need to notify the professional chamber. Mere notification is also needed in two other 
countries:  Belgium  and  Romania.  In  Romania,  only  authorization  to  exercise  the 
profession  in  the  home  country  needs  to  be  proven,  which  is  also  regarded  as  mere 
notification.  

In  Austria  legal  persons  no  authorization  or  notification  is  needed  but  temporary 
cross-border service providers need to inform the client about chamber membership in 
the home country and about professional indemnity insurance (PII). In Poland clients 
need  to  be  informed  about  PII  only.  However,  in  neither  country  is  this  requirement 
controlled by the professional bodies.  

Table 5.1 Accountancy - Authorization procedure 

MS  Establishment of a branch  
AT  7.Authorization 
BE  7.Authorization 
CY  1.No authorization/notice 
CZ  1.No authorization/notice 
DE  1.No authorization/notice 
DK  1.No authorization/notice 
ES  1.No authorization/notice 
FR  9.Not possible for branches, only 

subsidiaries 
1.No authorization/notice 
7.Authorization 

IE 
IT 

LU  7.Authorization 

Temporary cross-border services 
2.Only to inform client 
3.Notification 
1.No authorization/notice 
1.No authorization/notice 
1.No authorization/notice 
1.No authorization/notice 
1.No authorization/notice 
4.Authorization of professionals providing 
the services only 
1.No authorization/notice 
4.Authorization of professionals providing 
the services only 
7.Authorization for firms with more than 
250 employees 3. Notification for firms 
with 250 or fewer employees 

MT  7.Authorization (if related to public reports)  8.One-time authorization (if related to 

PL 
PT 

1.No authorization/notice 
6.Authorization for partnerships 

RO  7.Authorization 
SK  1.No authorization/notice 
UK  4.Authorization of professionals providing 

the services only 

public reports) 
2.Only to inform client 
4.Authorization of professionals providing 
the services only 
3.Notification 
1.No authorization/notice 
4.Authorization of professionals providing 
the services only 

May 2017 I 79 

 
5.2  Regulatory requirements 

Legal forms of businesses 

The legal form of a firm determines how various national laws are applied to the firm. 
Commonly used types of legal forms are sole traders, partnerships and limited liability 
firms. For accountancy in the sense of accountancy, all legal forms are allowed except 
in France where partnerships and limited partnerships are not allowed. Combined with 
the  apparent  requirement  that  an  entity  must  be  newly  established  implied  by  the 
word  “constituer”  (see  previous  section),  legal  forms  are  quite  restricted  for 
permanent  establishment  of  accountancy  services  in  France.  In  Belgium,  only  legal 
forms of that country may be used, and the court decides as part of the authorization 
procedure  if  a  foreign  legal  form  is  comparable.  Hence  for  both  countries  it  may  be 
assumed that legal form restrictions may cause administrative hassles.  

Shareholding, voting rights and management requirements 

Eight out of the nine countries that require authorization for permanent establishment 
of  accountancy  services  have  restrictions  on  voting  rights  (Table  5.2).  Shareholding 
restrictions apply to accountancy branches in general in only one country (Romania), 
and  apply  to  only  voluntary  professional  partnerships  in  two  further  countries  (Italy 
and  Portugal).  However,  where  fewer  countries  have  shareholding  requirements  for 
accountancy  compared  to  architecture  and  engineering,  more  countries  require 
managers  to  be  professionals  compared  to  the  previously  discussed  services,  namely 
in  seven  out  of  the  nine  countries  where  authorization  is  needed.  Hence,  for  the 
majority of countries where accountancy is regulated, authorization is needed for key 
staff  of  the  company  even  if  they  do  not  provide  the  cross-border  services.  In 
addition,  voting  rights and  management  requirements  exist  for  public  accountancy  in 
the  United  Kingdom,  but  use  of  the  protected  title  is  only  investigated  after 
complaints.  

For temporary services, voting/management requirements in four countries 

For temporary cross-border services, in most countries no shareholding, voting rights 
or  manager  restrictions  apply  except  for  Austria,  Belgium,  Malta  and  the  United 
Kingdom where the requirements are the same as for the establishment of a branch.  

Table  5.2  Accountancy  –  Shareholding,  voting  rights  and  manager 
requirements 

MS  Establishment of a branch 

Shareholding  Voting 
rights 
None 
50% 

AT  None 
BE  None 

CY  None 
CZ  None 
DE  None 
DK  None 
ES  None 
FR  None 
IE  None 

None 
None 
None 
None 
None 
2/3 
None; 50% 
b) 

Managers 

1 a)
50% 

None 
None 
None 
None 
None 
100% 
None; 50%
b) 

Managers 

None 
None 

Temporary cross-border services 
Shareholding  Voting 
rights 
None 
See 
branches 
None 
None 
None 
None 
None 
None 
None 

None 
See 
branches 
None 
None 
None 
None 
None 
None 
None 

None 
None 
None 
None 
None 
None 
None 

2/3 c); none  

IT 
LU  None 
MT  None 

2/3 c); none   None 
51% 
51% 
0; 61% d)
0; 51% d) 

PL  None 
PT 

51% c); none 

None 
See 

None 
1 

None 
None 
None

None 
None 

None 
None 
See 
branches 
None 
None 

None 
None 
See 
branches 
None 
None 

80 I May 2017 

 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

MS  Establishment of a branch 

Managers 

Shareholding  Voting 
rights 
shareholding  accountant
51% 
None 
None; 50% 
b) 

None 
None 
None; 50%
b) 

RO  51% 
SK  None 
UK  None 

Temporary cross-border services 
Shareholding  Voting 
rights 

Managers 

None 
None 
None 

None 
None 
See 
branches 

None 
None 
See 
branches 

a) 

In Austria the manager of the company (Gewerberechtlichte Geschäftsführer) needs to be a 
qualified accountant and have three years of experience in the field of accountancy and to have 
passed exams relevant for the entire bandwidth of accountancy services of the company; 
Ireland and the United Kingdom: 50% requirement only applies for chartered status; 

b) 
c)  For voluntary professional partnerships (Italy, Portugal); 
d) 

In Malta, mere accountancy is not regulated, the percentages apply for the reserved activities of 
accountants and auditors; 
In Portugal, at least one of the managers or directors of the professional partnership that performs 
executive functions, must be registered with the Portuguese Chamber. 

e) 

Voting  rights  and  management  requirements  usually  result  in  formalities  but  this  is 
not  always  the  case.  For  example  in  Ireland  there  is  no  authorization  procedure  but 
firms  that  use  the  description  ‘Chartered  Accountants’  should  clearly  distinguish  on 
their  letterhead  those  persons  named  who  are  Chartered  Accountants  from  those 
persons  named  who  are  not  entitled  to  be  so  described  by  the  use  of  designatory 
letters or otherwise. In the United Kingdom, if a complaint is received from the public 
about  misleading  use  of  the  description  ‘chartered  accountant’  the  ICAEW  will 
investigate. The ICAEW issues a written undertaking which the person misleading the 
public  must  not  breach.  The  undertaking  register  is  made  publically  available.  If  an 
undertaking is breached, the ICAEW’s solicitors will take-up the case. 

Multidisciplinary restrictions 

Multidisciplinary restrictions refer to prohibitions to combine certain services, aimed to 
avoid  conflicts  of  interest.  They  are  relevant  for  administrative  formalities  to  the 
extent  a  statement 
is  required  to  demonstrate  compliance.  Multidisciplinary 
restrictions  apply  to  accountancy  firms  in  six  countries  (Table  A5.15  in  Annex  5): 
Belgium  and  France  for  all  firms,  Italy  and  Portugal  for  voluntary  professional 
partnerships,  and  Ireland  and  the  United  Kingdom  for  a  voluntary  ‘chartered 
accountant’  status.  However,  these  multidisciplinary  restrictions  do  not  result  in 
additional  formalities  in  the  form  of  statements  to  be  made  or  collected  from 
authorities.  

Liability and insurance 

Regulations of liability and insurance were investigated in case they  have impacts  on 
administrative  formalities,  but  with  a  few  exceptions  this  is  not  the  case.  Although 
nine  countries  require  firms  to  have  professional indemnity insurance  (Figure  A5.5  in 
Annex  5,  professional  liability  periods  were  only  identified  for  Belgium  (five  years), 
Ireland  and  the  United  Kingdom  (six  years  each).  These  requirements  in  themselves 
do not result in administrative hassles. 

However,  other  insurance  requirements  result  in  administrative  formalities  in  three 
countries:  Austria,  Belgium  and  the  United  Kingdom.  In  Austria,  the  insurance 
provider  must  be  active  in  Austria.  This  implies  the  hassle  of  checking  that  the 
insurance provider is active in Austria and arranging a different insurance if that is not 
the case. In Belgium, a collective insurance can be concluded via the Belgian Chamber 
(BIBF), or a copy of insurance certificates for each natural person providing services in 
Belgium  and  not  covered  by  the  collective  insurance  of  BIBF  must  be  submitted. 
Insurance of the firm is not accepted. This implies as a minimum effort proof that the 
firm must prove insurance for each employee providing services in Belgium. And if the 
firm only has insurance at the company level, it must persuade the insurer to issue for 

May 2017 I 81 

 
 
each  employee  working  in  Belgium  a  certificate  that  he/she  is  covered  by  the  firm’s 
insurance. And in the United Kingdom, for the voluntary chartered accountant status, 
the wording of the insurance policy is prescribed. This implies the hassle to persuade 
the insurer of the home country to issue a certificate with those prescribed words.  

5.3  Procedural steps 

Some  countries  set  more  procedural  steps  to  gain  authorization  than  others.  The 
following aspects of procedures were examined: 

•  Prior requirements (e.g. e-ID or inscription in the general business register); 
•  Prior authorization of shareholders, partners or managers; 
•  Different steps within the procedure. 

As  noted  at  the  start  of  this  chapter,  in  most  countries  administrative  formalities  are 
(slightly)  lighter  than  for  architecture.  This  is  obviously  the  case  in  Belgium  and 
Romania  where  engineering  services,  contrary  to  architecture  services,  are  not 
regulated,  and  also  in  France  where  engineers  only  need  to  notify  an  office  for 
recognition of equivalent qualifications.  

Professional authorization integrated with business registration in Italy only 

Italy  is  the  only  country  where  permission  to  establish  an  accountancy  branch  is 
integrated with the general business procedure. This complicates matters because the 
procedure  starts  with  the  professional  chamber,  is  continued  with  other  authorities 
and  is  resumed  by  the  chamber  only  after  inscription  with  the  other  authorities  is 
completed. 

In  Malta,  applicants  must  prove  inscription  in  the  general  business  register  to  the 
professional chamber. However, nothing prevents a firm from starting both procedures 
at  the  same  time  and  this is  a  mere  aspect  of  submission  demands.  In  Luxembourg, 
the Chamber does a background check on prior registration with the general business 
register and the VAT authority, which does not cause additional formalities on the part 
of the applicant.  

Prior requirements - National e-IDs are not required 

A national e-ID may be used to handle procedures fully online in Italy and Malta, but 
procedures can also be handled by post in those two countries. Hence the national e-
ID  means  that  full  online  handling  is  only  available  to  nationals  but  does  not  restrict 
foreign applicants apart from having to post documents. 

Prior registration of shareholders does not seem to affect the procedure 

As  for  other  services,  there  seems  nothing  that  prevents  firms  from  starting  the 
procedure  for  authorization  of  shareholders,  partners  and/or  managers  and  the 
procedure for authorization of the firm at the same time, not even in Austria. In Malta 
(for  partnerships)  where  all  partners  need  to  be  authorized  architects,  the  procedure 
for natural and legal persons is even one and the same.  

Different steps within the procedure 

Table 5.3 presents the  different steps within the procedure for establishing a branch. 
In  three  countries,  persons  representing  the  firm  must  pass  an  interview  or  exams 
before the firm can provider accountancy services: in Belgium (legal representatives), 
Romania (shareholders) and Austria (the executive manager must have qualifications 

82 I May 2017 

 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

in  Austrian  tax  law  for  the  entire  range  of  services  that  the  firm  offers).  This  step  is 
considered  in  scope  because  it  is  an  automatic  requirement  even  if  the  relevant 
persons do not offer the cross-border services. 

This  automatic  requirement  of  examination  is  of  a  different  nature  than  conditional 
requirements, namely if qualifications are too different from national equivalents. The 
latter  type  of  examination  requirements  exists  in  Italy,  Malta  and  Portugal,  but  only 
for  voluntary  professional  partnerships  in  each of  these  three  countries.  Because  this 
examination  requirement  is  not  automatic  as  in  the  four  previously  mentioned 
countries,  this  is  regarded  as  part  of  the  professional  qualifications  and  thus  beyond 
the scope of this study.  

In  Italy the chamber forwards the application or part  of it to national authorities and 
informs the applicant of the outcome. This ensures coherent national validity and still 
has the advantage that the applicant needs to deal with only one office.  

The  procedures  of  countries  differ  mostly  with  regard  to  the  options  after  negative 
decisions.  These  were  identified  for  five  countries,  mostly  in  the  south  of  Europe: 
Austria, France, Italy and Romania. For Austria rejection seems to be final and a new 
application would be needed from scratch. In France, only missing documents need to 
be sent. In Italy, corrective measures may be required, while Romania has an appeal 
procedure.  For  the  other  countries  no  information  was  found  that  indicates  to  what 
extent a rejection is always final or if corrective measures may be demanded.  

Table 5.3 Accountancy – Procedural steps to establish a branch cross-border 

MS  Accountancy - Steps to establish a branch 
AT 

1. Written application to the point of contact (to the relevant office of the WKO), 
including the relevant evidence and documents (also in copy possible); these documents 
can be submitted by post mail, fax or scan (email) 2. WKO asks the insurance provider 
proof of professional indemnity insurance 3A. If all requirements are fulfilled the service 
provider obtains a notification and a document regarding the "Bestellung" (natural 
person) or "Anerkennung" (legal person) 3B. If any of the requirements is not fulfilled 
the application is rejected in writing (§ 27, 32 BiBuG). This seems to mean that the 
procedure starts from zero if one mistake is noticed. The WKO home page clarifies with 
regard to professional qualifications (also specifically required of the manager for the 
whole range of activities of the company) that no limited authorization for specific 
specializations is possible: "das BiBuG sieht im Gegensatz zur Gewerbeordnung keine 
'individuelle' (=auf bestimmte Teilgebiete bezogene) Berufsberechtigung vor.” 4. The 
fees to be paid are laid down in the Chamber's notification 5A. After the public 
“Bestellung” and in case he has a pecuniary damage liability insurance, the service 
provider (natural person) can provide accountancy services in Austria 5B. the president 
of the WKO issues a document regarding the “Bestellung”; which is recorded in the 
register and reported to the corresponding economic chamber and social security 6A. 
The prerequisite for accountancy services by a company is the recognition or 
“Anerkennung” by the president of the WKO which takes place if all requirements for the 
“Anerkennung“ are satisfied 6B. The president of the WKO issues a document regarding 
the “Anerkennung”; which is recorded in the register and reported to the corresponding 
economic chamber and social security 
Legal persons: (1) Establishment of company at a court of law, (2) Registration in the 
general business register, (3) Application for registration at the relevant chamber 
(BIBF), this includes company statutes and a financial plan. Natural persons holding 
voting rights: internship of 12 months and a subsequent State Exam or a foreign 
equivalent; the chamber may decide to interview legal representatives of foreign firms at 
a date and hour set by the chamber 
Accountancy is not regulated 
CY 
Accountancy is not regulated 
CZ 
Accountancy is not regulated 
DE 
DK  Accountancy is not regulated 
Accountancy is not regulated 
ES 
Legal persons (Paris): (1) Preparation: preparing statutes with shares and voting rights; 
FR 
arranging provisional insurance, buying or leasing premises; (2) Submission of all 

BE 

May 2017 I 83 

MS  Accountancy - Steps to establish a branch 

IE 
IT 

LU 

MT 

PL 

PT 

RO 

documents by post including pay check; (3) Verification, incomplete documents need to 
be sent again 
No procedure is in place for legal persons  
Natural persons (including mandatory for all partners of a voluntary professional 
partnership): 1. Submission of the application to the competent authority (Ministry); 2. 
The Ministry analyses the file; 3. The application is accepted and the provider is notified, 
or compensative measures can be required, usually an exam, 4. Registration with a 
regional Order of Accountants of the relevant province Legal persons (both branches and 
subsidiaries): First registration of the natural persons providing the services. Chamber of 
Commerce of the relevant province: 1. Opening of the local unit (non-legal entity) to be 
registered in Italy's Economic and Administrative Index (REA). The Chamber of 
Commerce then registers the branch or agency with the fiscal authorities, INAIL (for 
professional liability), INPS (worker pensions). 2 Registration at the Order of 
Accountants of the relevant province. 3. After the firm is registered with this chamber, 
the registration in the general business register is finalized. 
(1) Request authorisation for establishment at the public administration, (2) Register to 
the Order 
1. Mere accountancy is not regulated. To exercise any of the reserved activities of 
accountants and auditors, after registration in the general business register, the firm 
needs to register with the Malta Institute of Accountants. The applicant for the firm 
registration with the Maltese Institute of Accountants must hold a Maltese Public 
Accountant Warrant 2. Natural persons (including mandatory for all partners of a 
voluntary professional partnership), for the Public Accountant Warrant: must submit 
documents to the Board of Accountants.  
Accountancy is not regulated, apart from a requirement to inform the client about 
professional indemnity insurance 
1- Register in the Chamber of Accountants as a professional partnership (only 
compulsory if professional partnership), if accountancy company, only the technical 
director must be registered. 2- (Tacit approval) In case of no issues, in 20 days the 
professional partnership will be automatically member of the Chamber, or in 40 days if 
there were further inquiries within the first 20 days.  
The procedure has a cross-border nature and it is addressed to the foreign legal entities 
that have acquired in their home countries, the authorization as chartered accountant or 
certified accountant and require the recognition and registration in the Body. The steps 
for recognition and registration of legal entities in The Body are included in the 
Ordinance no. 65/1994, republished, article 26. According to art. 26 of O.G. 65/1994, 
republished, foreign legal entities that are not established in Romania may practice as 
chartered accountant or certified accountant under the provisions of this Ordinance: - if 
in their countries have this quality and legally exercise these activities, according to 
bilateral agreements concluded for this purpose by Romania with other states and - if 
the shareholder successfully passed the interview which tests the knowledge of national 
legislation regarding the organization and operation of companies, and regarding the 
fiscal and accounting legislation. The procedure for the recognition and registration of 
foreign legal persons in the Body aims at granting the right to provide professional 
services in Romania for foreign legal persons, following the release of the operating 
license as an accounting company. The appeal against the rejection of the application 
must be submitted within 30 days from the receipt of the notification and shall be 
resolved within 30 days from the date of registration in the CECCAR. The adopted 
decisions of CECCAR regarding the rejection of the application file may be appealed to 
the Superior Council of CECCAR, within 30 days from the date of the receipt of the 
decision and shall be resolved within 15 days from the date of registration of the appeal. 
Accountancy is not regulated 

SK 
UK  Accountants in public practice and chartered accountants (natural persons, including 

mandatory the partners to carry the voluntary title ‘chartered accountant’ in the 
company name): - must be member of ICAEW for two years; - must pass an aptitude 
test if relevant; - has undertaken to comply with professional indemnity insurance 
regulations; - must satisfy the Board on requirements of Continuing Professional 
Development, Code of Ethics, fitness and properness to hold the practicing certificate - 
must complete a "Ready to go" questionnaire which needs not be submitted but must be 
kept because ICAEW can request it at any time 

84 I May 2017 

 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

For  temporary  services  (Table  5.4),  authorization  procedures  for  firms  are  only  in 
place  in  Malta  (for  partners  of  voluntary  partnerships)  and  the  United  Kingdom  (for 
partners to carry the voluntary title ‘chartered accountant’).  

In  Austria  and  Portugal  service  providers  need  to  provide  information  to  the  client 
before  signing  a  service  contract.  In  Belgium  and  Luxembourg  foreign  firms  need  to 
notify the Chamber but they need no authorization to provide temporary services.  

Table 5.4 Accountancy – Procedural steps for temporary services 

Legal persons: written declaration at the BIBF/ Registration on the list.  

MS  Accountancy – steps for temporary services 
AT  A number of documents need to be provided to the client, otherwise no procedure applies
BE 
CY  Accountancy is not regulated 
CZ  Accountancy is not regulated 
DE  Accountancy is not regulated 
DK  Accountancy is not regulated 
ES  Accountancy is not regulated 
FR  None (only for professionals providing the services) 
IE 
IT  None (only for professionals providing the services) 
LU  Only a notification is needed 
MT  Mere accountancy: not regulated Reserved accountancy activities, legal persons: the firm 

Accountancy is not regulated 

needs to register with the Malta Institute of Accountants to exercise any of the reserved 
activities of accountants and auditors. Reserved accountancy activities, natural persons 
(including for principals and specifically the applicant for the firm registration), for the 
Maltese Public Accountant Warrant: submission of documents.  

PL  Accountancy is not regulated, apart from a requirement to inform the client about 

professional indemnity insurance 

PT  Requirements only apply to professionals providing the services, none for legal persons 
RO  No procedure applies to legal persons. 
SK  Accountancy is not regulated 
UK  Accountancy in public practice and chartered accountants (natural persons, including 

mandatory the partners to carry the voluntary title ‘chartered accountant’ in the company 
name): - must be member of ICAEW for two years; - must pass an aptitude test if 
relevant; - has undertaken to comply with professional indemnity insurance regulations; 
- must satisfy the Board on requirements of Continuing Professional Development, Code 
of Ethics, fitness and properness to hold the practicing certificate - must complete a 
"Ready to go" questionnaire which needs not be submitted but must be kept because 
ICAEW can request it at any time 

5.4  Deadlines 

The  deadlines  for  handling  the  application  procedure  vary  between  Member  States 
(Table  5.5).  The  authorization  procedure  for  natural  persons  including  shareholders 
and/or managers is assumed to run in parallel to that for legal persons. 

Table 5.5 Accountancy – Deadline for handling by authorities 

MS  Establishment of a branch 

AT   Notification regarding receipt of application and possible 
request for further clarifications within a month; decision 
regarding application at the latest three months after 
submission of complete documents 

BE  Registration with Chamber: 1 month 

CY  Accountancy is not regulated 

CZ  Accountancy is not regulated 

DE  Accountancy is not regulated 

Temporary cross-
border services 
Not applicable (no 
procedure) 

Registration with 
Chamber: 1 month 
Accountancy is not 
regulated 
Accountancy is not 
regulated 
Accountancy is not 

May 2017 I 85 

 
MS  Establishment of a branch 

DK  Accountancy is not regulated 

ES  Accountancy is not regulated 

FR 

IE 

For natural persons (none given for legal persons): For 
recognition of professional qualifications: 1 month 
(reception of the documents) then 3 months (examination 
of the file by the Board of the Order of accountants); 
applicant and regional government shall be informed of the 
decision within 10 days. Within one month after the 
notification, the applicant may appeal a refusal, or the 
regional government may appeal an entry, both appeals to 
the national chamber (§ 42 of the Ordinance). The national 
chamber must decide in six months, else the applicant must 
be entered 
Accountancy is not regulated 

IT  General business register (with which the procedure of the 
chamber is integrated): 30 days; Order of Accountants 
(both natural and legal persons): 30 days to examine 
completeness of the files, 4 months after submission to 
decide about the admission  

LU  8 working days if the dossier is complete 

MT  Mere accountancy: not regulated Reserved activities, Malta 

Institute of Accountants: 8 months from complete 
application 

PL  Accountancy is not regulated 

PT 

For accountancy professional partnerships to form part of 
the Chamber of accountants: 20 business days or 40 in the 
case of inquiries within the first 20 days or in special 
circumstances For other legal forms, in which case the firm 
is called an accountancy company ("sociedad de 
contabilidade"): 40 business days to register their technical 
director in the Chamber of accountants 

RO  30 days since submission of complete documents 

SK  Accountancy is not regulated 

UK  Accountancy in public practice and chartered accountants 

(natural persons): applications are normally processed 
within 28 days, 

Temporary cross-
border services 
regulated 
Accountancy is not 
regulated 
Accountancy is not 
regulated 
Same as for branches 

Accountancy is not 
regulated 
30 days to assess 
completeness of files, a 
further delay of max 2 
months in case of issues, 
after this tacit approval 
applies 
No procedure for legal 
persons 
Same as for branches 

Accountancy is not 
regulated 
1 month to examine 
completeness, 2 further 
months in the case of 
issues 

No procedure for legal 
persons 
Accountancy is not 
regulated 
Same as for branches 

The  deadline  to  establish  a  cross-border  accountancy  branch  is  between  28  and  40 
days in Belgium, Portugal, Romania and the United Kingdom. Procedures are longer in 
Austria  (three  months),  Malta  (eight  months)  and  France  where  the  deadline  is 
between  three  and  six  months  for  natural  persons,  including  mandatory  for  partners 
holding voting rights in the firm. Luxembourg has the shortest procedure (eight days).  

For temporary cross-border services, the procedure is equally long as for branches in 
France  and  Malta,  one  month  in  Belgium  and  the  United  Kingdom,  and  between  one 
and three months in Italy and Portugal. 

86 I May 2017 

 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

5.5  Tacit approval and validity 

In  most  countries  where  authorization  is  needed  for  accountancy  services  (in  the 
sense of accountancy), tacit approval does not apply. The exceptions are Luxembourg 
and Portugal (Table 5.6).  

Table 5.6 Accountancy – Tacit approval 

MS  Establishment of a branch 
AT  No 
BE  No 
CY  N/A (accountancy is not regulated) 
CZ  N/A (accountancy is not regulated) 
DE  N/A (accountancy is not regulated) 
DK  N/A (accountancy is not regulated) 
ES  N/A (accountancy is not regulated) 
FR  No (except for the national appeal 

period of 6 months) 

IE  N/A (accountancy is not regulated) 
IT  No 

LU  Yes 
MT  No 
PL  N/A (accountancy is not regulated) 
PT 
Yes 
RO  No 

SK  N/A (accountancy is not regulated) 
UK  No 

Temporary cross-border services 
No 
No 
N/A (accountancy is not regulated) 
N/A (accountancy is not regulated) 
N/A (accountancy is not regulated) 
N/A (accountancy is not regulated) 
N/A (accountancy is not regulated) 
No (except for the national appeal period of 6 
months) 
N/A (accountancy is not regulated) 
No (except if no decision is reached in 3 
months) 
Yes 
No 
N/A (accountancy is not regulated) 
Legal persons: N/A (no procedure) 
Legal persons: N/A (no procedure), natural 
persons: no 
N/A (accountancy is not regulated) 
No 

N/A: no authorization needed, hence tacit approval is not applicable. 

When a branch is established, authorization is in most countries indefinite (Table 5.7). 
In Malta (for reserved activities) and Romania an annual form on activities needs to be 
submitted and an annual fee needs to be paid. In Romania, in addition the firm needs 
to submit its annual accounts. In the United Kingdom, also an annual fee needs to be 
paid.  

For  temporary  cross-border  services,  the  authorization  is  valid  for  one  year  in  most 
countries and can be renewed every year. In most countries new documents need to 
be submitted, though always with the exception of proof of professional qualifications 
(of  natural  persons).  In  Romania,  a  simple  statement  suffices  to  renew  the 
authorization.  Only  in  Malta  the  authorization  for  temporary  cross-border  services 
cannot be annually renewed.  

Table 5.7 Accountancy – Time validity 

MS  Establishment of a branch 
AT 
BE 
CY 
CZ 
DE 
DK 
ES 
FR 
IE 
IT 

Indefinite 
Indefinite 
Indefinite (accountancy is not regulated) 
Indefinite (accountancy is not regulated) 
Indefinite (accountancy is not regulated) 
Indefinite (accountancy is not regulated) 
Indefinite (accountancy is not regulated) 
Indefinite 
Indefinite (accountancy is not regulated) 
Indefinite 

Indefinite 

LU 
MT  Mere accountancy: not regulated Reserved 
activities: all accountants in the firm need 
to submit an annual form and pay the 

Temporary cross-border services 
Indefinite 
1 Year; new docs required 
Indefinite (accountancy is not regulated) 
Indefinite (accountancy is not regulated) 
Indefinite (accountancy is not regulated) 
Indefinite (accountancy is not regulated) 
Indefinite (accountancy is not regulated) 
1 Year; new docs required 
Indefinite (accountancy is not regulated) 
Legal persons: no procedure, Natural 
persons: 1 Year; new docs required 
1 Year, renewable 
Mere accountancy: not regulated Reserved 
activities: depends on duration, regularity, 
periodicity, continuity of services 

May 2017 I 87 

MS  Establishment of a branch 

Temporary cross-border services 

annual fee  
Indefinite (accountancy is not regulated) 
Indefinite 

PL 
PT 
RO  Annual fees, annual submission of activities 

report and annual accounts 
Indefinite (accountancy is not regulated) 

SK 
UK  Accountancy in public practice and 

chartered accountants (natural persons): 
annual fee 

Indefinite (accountancy is not regulated) 
Legal persons: no procedure 
1 Year and renewable 

Indefinite (accountancy is not regulated) 
Accountancy in public practice and 
chartered accountants (natural persons): 
annual fee 

5.6  Fees 

Figure  5.1  presents  the  fees  charged  by  the  responsible  authorities  for  compulsory 
registration and/or  compulsory chamber  membership of the  firm and/or  shareholders 
or managers. The fees presented in Figure 5.1 are first-time fees, but the part of the 
fee  that  must  be  paid  every  year  is  marked  in  a  lighter  colour.  Fees  of  the  general 
business register are excluded as they are beyond the scope of the study, even if it is 
mandatory for branches of firms from  other  EU countries to register with the general 
business  register.  Fees  of  social  security  institutes  that  must  be  paid  as  part  of  the 
registration process with the professional chamber in Italy are also excluded. 

Also,  as  for  architects  and  engineers,  if  a  compulsory  fee  is  levied  for  at  least  one 
professional for access to the market, the fee for one professional is used (as in Italy). 

The  fees  for  cross-border  branches  are  (in  EUR  and  in  descending  order  of  total  fee 
amount): 

•  Malta: 2,903 = 25 registration fee for each application (assumed: one 

principal) and a yearly Quality Assurance Regulatory Fee (116 - 5,590) of 
which the mid-range value of 2,878 is used; 

•  Romania: EUR 500 and 400 for companies with foreign capital and mixed 

capital respectively (the former is assumed), a fixed fee of 200 = RON 800/4 
plus 1% of income from services in Romania (assumed to be EUR 200,000); 

•  United Kingdom, to carry the voluntary title ‘chartered accountant’ in the 
company name: 1,580 = ICAEW pathways fee for one principal 1,376 = £ 
1,100 / 0.8 (including first-year membership fee but annual membership does 
not seem compulsory), ICAEW annual practicing licence fee EEA residents: 204 
= £ 163 / 0.8 (excluding the Practice Assurance fee, it would be £ 333 
including this fee). Note that it is also possible to obtain the annual practicing 
licence fee from ACCA which is £ 444 and “currently free of charge” for EU 
residents not from UK or Ireland. Because this suggests that the licence will not 
remain free, the ICAEW fees are used consistently; 

•  France: 1,000 = 374 or 750 for legal persons (the higher fee of these is used) 

plus 250 for the first year for at least one principal;  

•  Portugal: 812 = 280 for legal persons (not confirmed for reasons of 

confidentiality), plus for at least one manager / shareholder: 400 = 100 for 
revision of documents, 100 for internship and 200 for an exam and 12 x 11 
monthly chamber membership fee for at least one manager / shareholder; 
•  Belgium: 625 = 150 + 125 + 350. Legal persons establishes/foreign need to 

register at the BIBF or show equivalent from their foreign country. Registration 
in case of establishment costs 150. In addition a registration fee for at least 
one principal: 125. Lastly, the annual membership fee for at least one principal 
is 350; 

•  Luxembourg: 500. No fee applies to legal persons, the registration fee for at 

• 

least one principal is 500; 
Italy: 343 = 168 registration tax (this is a national tax and the same for all 
regional chambers) + 175 annual membership fee (differs between regions, for 

88 I May 2017 

 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

example in Verona 165 for professionals up to 36 years old and 330 for older 
professionals, the 175 is the same value that is used for architects and 
engineers). This fee applies to at least one partner of a partnership, and to at 
least one professional for other legal forms of business; 

•  Austria: 281 = official registration fee plus cost of document stating the 

recognition 131, plus Chamber fee (KU 1) 0.3% of assumed EUR 200,000 
turnover minus EUR 150,000 annual turnover threshold; the family levelling 
fund (KU 2) is considered out of scope. In formula: 131 + 0.003 x (200,000 – 
150,000). 

Figure 5.1 Accountancy – First-time fees for legal persons 

5.7  Online information and procedures 

All  countries  have  a  point  of  single  contact  PSC;  however  the  Irish  and  British  PSC’s 
are not specific about procedures for authorization of professional services (Table 5.8). 
The  same  applies  to  the  German  PSC  where  almost  all  information  about  procedural 
steps can only be found by examining various regional laws, decrees and ordinances. 
In Italy the PSC describes the procedure for the general business register but does not 
inform that additional procedures are required by regional Orders of Accountants and 
the  quality  of  online  information  on  the  websites  of  Italian  Orders  of  Accountants 
varies.  

In  Belgium,  the  PSC  refers  to  commercial  service  providers  for  further  details  about 
procedures, but it does refer to the Chamber of Accountants where further information 
is available in Dutch or French. In Portugal and Spain, information about access to the 
profession is only available in the national language.  

In Poland information is available in both the national language and in English, and in 
France  even  in  many  languages,  but  this  seems  implemented  by  way  of  a  Google 
Translate machine.  

May 2017 I 89 

 
 
 
In almost all countries forms can be downloaded, but documents need to be posted. In 
Malta and Romania full electronic case handling is possible, as well as in some Italian 
regions.  Full  electronic  case  handling  in  Italy  requires  an  e-ID,  the  so-called  PEC.  In 
Austria and Portugal documents can be emailed.  

Table 5.8 Accountancy – Electronic information and procedure 

MS  PSC 

Establishment of a branch 

AT  DE, EN 

BE  NL, FR 

CY  EL, EN 

Documents can be sent per email and 
correspondence is per email 
Documents are preferably posted but can be 
emailed 
No authorization or notification 

CZ  CZ, EN 

No authorization or notification 

DE 

--- 

No authorization or notification 

DK  DK, EN 

No authorization or notification 

ES  ES 

No authorization or notification 

FR  EU* 

Forms downloadable and must be posted 

IE 

--- 

No authorization or notification 

IT 

--- 

General business register and some Orders of 
Accountants: online procedure 
FR,DE,EN  Forms downloadable and must be posted 

LU 
MT  EN 

PL 

PL, EN 

PT 
PT 
RO  RO, EN 

SK  SK, EN 

UK 

--- 

Mere accountancy: no authorization or notification. 
For reserved activities: full electronic case-
handling  
No authorization or notification 

Documents can be emailed 
Documents can be either submitted in person, or 
emailed, or submitted electronically (online 
procedure in Romanian and English) 
No authorization or notification 

Accountancy in public practice: documents must 
be posted 

Temporary cross-
border services 
No authorization or 
notification  
Same as for branches 

No authorization or 
notification 
No authorization or 
notification 
No authorization or 
notification 
No authorization or 
notification 
No authorization or 
notification 
No procedure for legal 
persons 
No authorization or 
notification 
Same as for branches 

Same as for branches 
Same as for branches 

No authorization or 
notification 
Same as for branches 
No procedure for legal 
persons 

No authorization or 
notification 
Same as for branches 

--- means: not available. 

5.8  Submission demands - branches 

All nine countries where authorization is needed for an accountancy branch demand an 
application  form  to  be  filled  in,  including  at  least  company  ID  data.  Membership 
numbers of shareholders or managers are needed in all countries where the profession 
is  regulated,  with  the  exception  of  Luxembourg  (in  France  this  information  must  be 
provided in a separate document discussed later).  

Relatively light  additional  data  are  required  on  the  application  form  in  five  countries: 
Austria  (a  few  forms  but  simple,  with  declarations  on  honour),  Luxembourg  and 
France  (professional  qualifications  of  shareholders),  Portugal  (where  in  addition  the 
tax ID number of authorized partners of voluntary partnerships is demanded) and the 
United  Kingdom.  In  the  United  Kingdom  the  application  form  is  assumed  to  be 
required in practice to carry the voluntary title ‘chartered accountant’ in the company 
name,  even  though  the  use  is  checked  only  after  complaints.  The  difference  with 

90 I May 2017 

 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

is  that  accountancy  activities  are  reserved  to 
architecture  and  engineering 
professionals  and  a  company  carrying  the  chartered  title  would  violate  the  law  (and 
not merely the house rules).  

For  Italy  many  forms  need  to  be  filled  in  which  includes  voting  rights  for  voluntary 
partnerships and more simple data on shareholders for other legal forms.  

In  three  other  countries  where  access  is  regulated,  substantial  data  on  shareholders 
need  to  be  provided  including  their  shares  of  voting  rights:  Belgium,  Malta  and 
Romania.  In  Belgium  for  managers)  and  Malta  (for  persons  holding  voting  rights)  in 
addition  their  positions  in  other  firms  must  be  filled  in.  The  same  applies  to  France, 
but then in a separate document. 

Table 5.9 Accountancy – Data to be submitted (branches) 

BE 

MS  Accountancy – data submission demands (branches) 
AT 

- company identification data - agreement that most proceedings will be done online -
existing authorizations for specific fields in accountancy with company membership 
numbers: (a) Steuerberater/Wirtschaftsprüfer (accountants / auditors) (b) 
Bilanzbuchhalter (balance accountant) (c) Personalverrechner (wage and social security 
accountant) - a declaration on honour on financial standing, namely (1) that assets are 
not sequestrated in on-going bankruptcy proceedings, (2) that in the past years not more 
than one debt structuring has occurred of which the conditions still apply and (3) that no 
outstanding debts exist from insolvency rulings in the past ten years 
Legal form, company name, registration number of the Belgian general business register, 
statutory seat contact data (phone, fax, GSM, email, website), branch contact data 
(street, number, bus, postal code, city, phone, fax, GSM, email, website), shareholder 
data (name, legal form if a legal person, number of shares, number of voting rights, 
Chamber membership number, general business registration number if a legal person), 
management data (name, Chamber membership number, management position), 
management mandates of managers in other legal persons (name of manager; name, 
legal form and general business registration number of legal person), management 
positions of managers in other legal persons (name of manager; name, legal form and 
general business registration number of legal person) 

CY  Accountancy is not regulated 
CZ  Accountancy is not regulated 
DE  Accountancy is not regulated 
DK  Accountancy is not regulated 
ES  Accountancy is not regulated 
FR 

IE 
IT 

For both natural and legal persons: personal details, education and professional 
information 
Accountancy is not regulated 
Filled-in application form and modules - for legal entities they depend on the legal form 
of the company 
Personal details, education and professional information

LU 
MT  Mere bookkeeping: not regulated Reserved activities, legal persons, application with 

Malta Institute of Accountants: - Company name, address and date of establishment - 
Legal form (checkboxes "Civil partnership", "Company" and "Other - to be specified") - 
Name, address, ID card/passport number, % of voting rights and warrant number (if 
applicable) of individuals / entities holding voting rights - Name, address, ID 
card/passport number, Telephone & Email, Warrant number (if applicable) of individuals / 
entities in the administrative or management body of the firm - Name, address, ID 
card/passport number, Telephone & Email, Warrant number (if applicable) of the 
principals - Professional indemnity insurance: name of insurer(s), policy number, period 
covered, level of coverage - All connected undertakings: company name, business 
address, Maltese registration number, Accountancy Board registration number, Names of 
principals and Services provided through connected undertaking - Signature and 

May 2017 I 91 

MS  Accountancy – data submission demands (branches) 

signature date of compliance principal Natural persons, for Certified Public Accountant 
Warrant: - Name; surname; ID Card/Passport Number; Postal Address (House Number, 
House Name, Street Name, Locality, Post Code, Country); Telephone, Mobile, Fax, Email 
- Name and address of two referees (Name, Surname, House Number, House Name, 
Street Name, Locality, Post Code, Country, Email, Phone) - Name of university or 
Accountancy Body and year when qualification was obtained - Two employers (name, 
surname, employing organisation, Postal Address, Email, Start and End dates) - 
Signature and date of signature of the applicant 

PL  Accountancy is not regulated 
PT 

RO 

Partners of voluntary partnerships: name, registration number and Portuguese tax 
number 
- statement of the legal representative; - subscription application; - statement 
concerning the functioning of the accounting expertise entity / accounting entity; - form 
for commercial entities; The requested information that must be provided in the 
application form refers to: company details, executive management, shareholders, 
employed staff, registered capital, management council, etc. The application form must 
be signed by the legal representative of the company (general director, shareholder, 
administrator, etcetera) 
SK  Accountancy is not regulated 
UK  Accountancy in public practice (to carry the voluntary title ‘chartered accountant’ in the 
company name): - ICAEW membership number - Designatory letters (e.g. ACA) - 
Registered address, Postcode / ZIP code, Country, Telephone, Fax, Email - Checkboxes 
on 2-year membership and practicing certificate fee exemption - Proposed future date of 
commencement of practice - Employees: firm name and number, office address, 
postcode/zipcode, country - Principals (directors or partners): name of practice and 
ICAEW number if relevant, registered address, postcode/zipcode, country, telephone, fax 
- Self-declaration on having read the code of ethics, having completed the "ready-to-go" 
questionnaire, maintained competence, and compliance with insurance regulations 

In  almost  all  of  the  nine  countries  where  authorization  is  needed  for  accountancy 
branches,  a  certified  copy  of  company  statutes  is  required,  with  the  exception  of  the 
United Kingdom (Table 5.10).  

Four  countries  require  proof  of  insurance:  Belgium  and  France  (an  insurance 
certificate),  Malta  (simple  copy  of  coverage  details)  and  an  insurance  policy  with 
prescribed  wording  (the  United  Kingdom).  In  a  fifth  country,  Luxembourg,  an  annual 
statement on honour regarding professional indemnity insurance suffices.  

Five  countries  require  many  other  documents  to  be  submitted:  Austria  (for  example 
social  security  extracts  for  the  executive  manager),  France  (including  statements  of 
spouses  of  associates),  Italy  (simple  documents  and  forms  but  many),  Luxembourg 
(including  social  security  certificate,  declaration  of  non-bankruptcy)  and  Romania 
(including proof of membership of a professional body in the home country).  

In  Austria,  Luxembourg,  Malta  and  Portugal  simple  copies  of  originals  or  certified 
copies suffice. In Belgium it is not specified whether copies must be certified, but the 
Chamber  could  demand  to  present  originals  during  an  interview.  In  France  it  is  not 
specified  either  whether  copies  must  be  certified.  Hence  the  French  administrative 
default is assumed: originals with three simple copies. In Italy and Romania originals 
of certified /authenticated documents are required,  except in Romania for  certificates 
of  the  firm’s  or  associates’  membership  in  the  home  country  for  which  simple  copies 
suffice.  

If no information about the format in which documents must be submitted is available, 
no  information  on  this  is  presented  in  Table  5.10  either.  In  the  analysis,  it  will  be 
assumed that in these cases simple copies are sufficient.  
92 I May 2017 

 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

In the United Kingdom, it is implicit that the one required document (insurance policy 
with prescribed wording) is an original document.  

Table 5.10 Accountancy – Documents to be submitted (branches) 

MS  Accountancy – document submission demands (branches) 
AT 

Legal persons (all simple copies of certified/authenticated originals, but in case of doubt 
the Chamber may require originals): A1. Companies deed (not older than 6 months) A2. 
Signed company constitutive act (for corporations a notarial act) A3. Forms for all 
persons with significant influence and authorized representatives including: - social 
security number, birth certificate, marriage certificate, certificate of membership A4. A 
form for the nominated company manager (gewerberechtlichen Geschäftsführer) 
including: - Chamber membership and social security number, birth certificate, marriage 
certificate, certificate of membership, certification of Austrian examination, proof of 
position in the firm, other professional activities A5. Professional indemnity insurance A6. 
Optionally: a NEUFÖG form to obtain a fee exemption Natural persons (including 
mandatory for executive manager (simple copies; originals may be required in case of 
doubt): B1. Identity proof (birth certificate, marriage and divorce certificates, certificate 
of name change if applicable) B2. Certificate of nationality B3. Passport, driving licence, 
or identity card not older than 6 months) B4. Certificate of residence if not in Austria B5-
1. Proof of notification if already a member of the professional chamber B5-2. Or else 
proof of professional qualification which authorizes to the provision of accountancy 
services (diplomas etc. and a statement of the educational institute) B6. Statements of 
previous employers or social security extract B7. Certificates of the relevant authority of 
the origin MS regarding the existence of a “special trustworthiness”, regarding orderly 
economic conditions and the non-existence of grave professional misconduct (not older 
than 3 months at the date of submission) 
(1) company statutes, (2) copy of shareholding register, (3) proof of insurance (BIBF 
collective policy or certificate issues by an insurance company of choice), no information 
could be found on document format requirements 

CY  Accountancy is not regulated 
CZ  Accountancy is not regulated 
DE  Accountancy is not regulated 
DK  Accountancy is not regulated 
ES  Accountancy is not regulated 
FR 

(1) Registration request form filled-in (2) A copy of the company statutes with the 
signature and initials of all the associates and their civil status (3) Auditor's report if any 
(4) Only for associates which are members of the Chamber and married under the 
regime of community: Spouse certificate stating that he/she is aware of the contribution 
and that he/she does not want to be personally involved (5) Only for legal persons which 
are not member of the Chamber, or are so under another profession/activity: the 
statutes must also state the shares and voting rights (6) Distribution of shares and 
voting rights (7) For all associates: function in the new establishment (8) Proof of 
ownership or lease of the premises where the company will be located (9) either 
Chamber membership number + date of entry, or proof a current professional situation 
(e.g. work certificate, Kbis certificate for executives, social security certificate or INSEE 
business certificate for legal person associates) (10) Declaration form to be filled-in by 
the legal representative of the legal person (11) Certificate of every associate member of 
the Order (natural and legal person) on their function in other companies member of the 
Order (12) Provisional insurance certificate regarding professional liability listing all the 
members of the Order which are or will be covered; any official insurance provider may 
be chosen but there is a list of suggested insurance providers (13) Payment cheque (14) 
Within one month after being entered into the Chamber: K-bis extract and final 
certificate of the insurance In principle for all documents the administrative default 
applies: an original with three simple copies 
Accountancy is not regulated 
Registration in the general business register (with which the chamber procedure is 
integrated): A1) Certificate indicating the company details and the legal representatives 
of the company: The certificate must be translated into Italian by an expert and sworn 
before a court of law. A2) R Form (fill in the mandatory sections and field 6 "Scope and 
purpose of the foreign company" only) A3) Int.P. Form (relating to the legal 
representative of the foreign company) A4) UL Form A5) Fedra Form with digital 
signature of one company director Registration with the chamber: B1) Registration form: 
duly filled and stamped; B2) Statute and articles of incorporation: translated into Italian 
by an expert and sworn before a court of law B3) Certificate of inscription in the 

May 2017 I 93 

BE 

IE 
IT 

MS  Accountancy – document submission demands (branches) 

Company Register (they get that after the REA): original B4) Certificate of registration to 
a professional chamber of the members: original B5) Declaration of non-incompatibility 
(2 forms by which the members declare to respect the legal requirements): original B6) 
Proof of payment of the EUR 168 registration tax: photocopy B7) Proof of identity: 
photocopy B8) Disclaimer on personal data: duly filled and signed; B9) List of 
shareholders (personal data) 

LU  Registration to the 'Order' (1) Form (2) Declaration of honour on insurance coverage, to 

be repeated each year (3) Copy of diploma(s) (4) Affiliation certification to the Social 
Security Common Centre (5) Only for persons not resident for the past 5 years: Extract 
of criminal record or good conduct and declaration of non-bankruptcy made on oath 
before a notary (6) Legal person: the above documents must be submitted on behalf of 
the director/manager who is the signatory authority. (7) Legal person: a registered copy 
of the Statutes, a registered copy of the decision nominating the director/manager and a 
copy of the registration to the Commerce and Companies Register of the State of origin. 
All documents: simple copies of certified/authenticated originals 

MT  Legal persons, Public Accountancy registration: A1. Partnership agreement, certified 
copy; A2. Proof of due registration with MFSA (the general business register), simple 
copy; A3. The firm's professional indemnity Insurance Coverage, simple copy; A4. The 
registration fee (payable cheque) 

PL  Accountancy is not regulated 
PT 

Legal persons (certified copies required for all documents) 1. Identification document; 2. 
Document proving their legitimacy; 3. Document proving the legal existence of the entity 
that creates the permanent representation; 4. Full text and updated the memorandum or 
the entity's statutes establishing the permanent representation; 5. Resolutions approving 
the establishment of permanent representation and the designation(s) of its 
representative(s); 6. Portuguese Tax Identification Number(s) of representative(s) of the 
Permanent Representation 

RO  1. Application form, 2. Proof of professional membership in the origin state of member of 

a professional body from the native country, 3. Ascertaining certificate, 4. Firm 
documents (registration certificate, the incorporation act, the confirmation of company 
details, the conclusion/resolution of the Trade Register Director), 5. Proof of fee payment 
6. Membership card chartered accountant, of the foreign citizen with the stamp for the 
current year 

SK  Accountancy is not regulated 
UK  Accountancy in public practice and for the voluntary title of chartered accountant in the 

company name: 1. proposed business letterhead 2. Details of Professional Indemnity 
Insurance (given the prescribed wording this is practically the draft policy) 3. Notification 
of any other partners in your firm 4. Valid payment 

If  documents  are  required  to  establish  an  accountancy  branch,  then  in  general 
certified  translations  are  required  (Table  5.11);  only  for  the  United  Kingdom 
translation requirements are not specified. 

Table 5.11 Accountancy– Translation requirements (branches) 

MS  Accountancy – translation demands (branches) 
AT  All documents: certified translation into German, may be done in country of original 

document 

BE  Registration with Chamber of Accountants: all documents: in Dutch, French, or German, 

translation requirements unknown 

CY  Accountancy is not regulated 
CZ  Accountancy is not regulated 
DE  Accountancy is not regulated 
DK  Accountancy is not regulated 
ES  Accountancy is not regulated 
FR  All documents must be accompanied by a certified translation done by a translator who is 

IE 
IT 

sworn for civil administration translations  
Accountancy is not regulated 
The company statutes and the certificate of registration certificate to a professional 
chamber in the home country must be translated into Italian, either in an Italian 
embassy or consular post (apostille) or by an expert who swears the correctness of his 
translation before an Italian court of law.  

94 I May 2017 

 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

MS  Accountancy – translation demands (branches) 
LU  Documents must be translated into Luxembourgish, French or German if requested, it 

must be a certified translation if requested, done by any translator  

MT  Certified translations into Maltese or English, no restrictions apply to the translator 
PL  Accountancy is not regulated 
PT  Certified translations into Portuguese, can be in the host country by the Authority or in 
the original country through an official translation or the Portuguese consular services 

RO  Certified translations into Romanian 
SK  Accountancy is not regulated 
UK  Translation requirements are not specified 

5.9  Submission demands – temporary services 

Tables 5.12 and 5.13 provide the data and documents that accountancy firms need to 
submit  for  authorization  of  temporary  services,  if  any.  In  Austria,  there  is  no 
authorization or notification for temporary services, but clients need to be informed of 
certain specifics about the service provider before the contract is signed.  

In three countries, requirements for temporary services apply only to natural persons 
providing  the  services:  Belgium,  Italy  and  Portugal.  In  France  in  addition  the  firm 
needs to submit a written notification declaration, and in Luxembourg the firm needs 
to provide the data for all professionals delivering the temporary services. In Romania, 
the  foreign  accountancy  firm  in  addition  needs  to  submit  insurance  data  to  provide 
temporary services.  

In  the  United  Kingdom  the  same  requirements  apply  for  temporary  services  as  for 
branches,  namely  to  carry  the  voluntary  title  ‘chartered  accountant’  in  the  company 
name.  As  for  branches,  use  of  the  title  is  only  checked  after  complaints  but 
requirements  are  included  because  accountancy  is  reserved  to  people  holding  the 
chartered  status  (as  opposed  to  architecture  and  engineering  services  in  the  United 
Kingdom).  

Malta  has  the  heaviest  requirements  for  temporary  services  of  accountancy  firms 
wishing  to  exercise  reserved  activities  related  to  the  publication  of  financial  reports 
(and mere accountancy for internal purposes is explicitly excluded from authorization 
requirements), both for the legal person and for the principals who must hold 50 per 
cent of the votes and 60 per cent of the management positions.  

Table 5.12 Accountancy – Data to be submitted (temporary services) 

MS  Accountancy – data submission demands (temporary services) 
AT  No authorization or notification, but to be submitted to the client before signature of the 
contract: 1. Register where he is registered and identification number in this register; 2. 
Name and address of the responsible controlling authority in the country of establishment 
3. Professional body or similar organisation of which the architect/engineering consultant 
is part of 4. Professional title / formal qualification 5. Turnover tax identification Number 
6. Details about insurance protection concerning professional liability 

BE  None (only for professionals providing the services) 
CY  Accountancy is not regulated 
CZ  Accountancy is not regulated 
DE  Accountancy is not regulated 
DK  Accountancy is not regulated 
ES  Accountancy is not regulated 
FR 
IE 
IT  Natural persons (nothing applicable to legal persons): written declaration in Italian 

Legal persons: a written declaration  
Accountancy is not regulated 

stating: - name and surname, address, email and phone; nationality; - profession for 
which the person is certified in its own country and profession it wishes to perform in 
Italy; - the types of services the person wants to provide and the professional liability 
insurance coverage he has. 

May 2017 I 95 

 
MS  Accountancy – data submission demands (temporary services) 
LU  Natural persons: Personal details, education and professional information Legal persons: 
the above information about the natural persons temporarily exercising the profession in 
Luxembourg 

MT  Mere accountancy: not regulated Reserved activities, legal persons, application with 

Malta Institute of Accountants: - Company name, address and date of establishment - 
Legal form (checkboxes "Civil partnership", "Company" and "Other - to be specified") - 
Name, address, ID card/passport number, % of voting rights and warrant number (if 
applicable) of individuals / entities holding voting rights - Name, address, ID 
card/passport number, Telephone & Email, Warrant number (if applicable) of individuals / 
entities in the administrative or management body of the firm - Name, address, ID 
card/passport number, Telephone & Email, Warrant number (if applicable) of the 
principals - Professional indemnity insurance: name of insurer(s), policy number, period 
covered, level of coverage - All connected undertakings: company name, business 
address, Maltese registration number, Accountancy Board registration number, Names of 
principals and Services provided through connected undertaking - Signature and 
signature date of compliance principal. 
Natural persons, for Certified Public Accountant Warrant (including mandatory for 
principals): - Name; surname; ID Card/Passport Number; Postal Address (House 
Number, House Name, Street Name, Locality, Post Code, Country); Telephone, Mobile, 
Fax, Email - Name and address of two referees (Name, Surname, House Number, House 
Name, Street Name, Locality, Post Code, Country, Email, Phone) - Name of university or 
Accountancy Body and year when qualification was obtained - Two employers (name, 
surname, employing organisation, Postal Address, Email, Start and End dates) - 
Signature and date of signature of the applicant. 

PL  Accountancy is not regulated 
PT  None (only for professionals providing the services) 
RO  For the temporary cross-border services the provider will submit a written statement 

containing the information on the services they will provide, the insurance or other 
means of personal or collective protection regarding liability 

SK  Accountancy is not regulated 
UK  Accountancy in public practice and for the voluntary title of chartered accountant in the 
company name: - ICAEW membership number - Designatory letters (e.g. ACA) - 
Registered address, Postcode / ZIP code, Country, Telephone, Fax, Email - Checkboxes 
on 2-year membership and practicing certificate fee exemption - Proposed future date of 
commencement of practice - Employees: firm name and number, office address, 
postcode/zipcode, country - Principals (directors or partners): name of practice and 
ICAEW number if relevant, registered address, postcode/zipcode, country, telephone, fax 
- Self-declaration on having read the code of ethics, having completed the "ready-to-go" 
questionnaire, maintained competence, and compliance with insurance regulations 

Table 5.13 Accountancy – Documents to be submitted (temporary services) 

MS  Accountancy – document submission demands (temporary services) 
AT  None 
BE  None (only for professionals providing the services) 
CY  Accountancy is not regulated 
CZ  Accountancy is not regulated 
DE  Accountancy is not regulated 
DK  Accountancy is not regulated 
ES  Accountancy is not regulated 
FR  None (only for professionals providing the services) 
IE 
Accountancy is not regulated 
IT  Nothing applicable to legal persons 
LU  Nothing applicable to legal persons 
MT  Legal persons, Public Accountancy registration: A1. Partnership agreement; or 

Memorandum of Association if the firm is a company: certified copy; A2. Proof of due 
registration with MFSA: simple copy; A3. The firm's professional indemnity Insurance 
Coverage: simple copy; A4. The registration fee (payable cheque, original) Natural 
persons (including mandatory for principals), for the public accountant warrant: B1. 
Academic accountancy qualifications B2. A birth certificate B3. A recent police certificate 
B4. For recognised international studies also the results of the Local Legislation and Local 
advanced taxation modules B5. A payable cheque of EUR 25. 

96 I May 2017 

 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

MS  Accountancy – document submission demands (temporary services) 
PL  Accountancy is not regulated 
PT  None (only for professionals providing the services) 
RO  None, only data (see previous table) 
SK  Accountancy is not regulated 
UK  Accountancy in public practice and for the title of chartered accountant (natural persons): 
1. proposed business letterhead 2. Details of Professional Indemnity Insurance (given the 
prescribed wording this is practically the draft policy) 3. Notification of any other partners 
in your firm 4. Valid payment 

May 2017 I 97 

 
6  INTERVIEWS WITH SERVICE PROVIDERS 

6.1  Approach 

The administrative formalities identified in the previous chapters generate costs for 
service providers that want to go cross-border on a temporary basis or set up a 
branch in another Member State. In order to estimate these costs, 52 interviews with 
service providers were carried out, which are summarized in Chapter 2 and described 
in detail in Annex 3. Architecture and engineering are covered by between two and 
four respondents per country. Accountancy is covered by at most one respondent per 
country, reflecting the potentially smaller cross-border population caused partly by the 
rarity of specialization in accountancy rather than in combination with statutory 
auditing services. 

Each interviewee was asked about the costs of the various steps needed to complete 
the procedures for cross-border services. The questionnaire is presented in Annex 2. 
The interviews were mostly conducted by people from the host country (because they 
are familiar with the formalities) but if necessary due to language difficulties by 
interviewers of the home country. Interviews were conducted either by phone or 
online, depending on the preferences of the respondent. Overall, the response rate 
was 5 per cent, which may seem low but must be expected given the topic (costs) and 
the time to complete the questionnaire (20 minutes on average but some up to one 
hour).  

The main results of these interviews are described in this section. To structure the 
interviews, and also the presentation of the results, the costs of activities can be 
grouped into four categories: 

•  The wage equivalent of staff time (at different levels) spent on formalities; 
•  Expenses on third parties; 
•  Fees of authorities; 
•  Recurrent costs. 

Firstly,  administrative  formalities  require  time  from  staff  of  the  service  provider.  In 
most  interviews,  this  was  highlighted  as  the  largest  cost  component,  with  service 
providers identifying a wide range of potentially time-consuming administrative steps. 
Secondly,  expenses  for  external  costs  include  costs  of  activities  by  third  parties  such 
as  notaries,  translators  and  (language)  trainers,  whenever  applicable.  Thirdly,  fees 
often need to be paid by the service provider to authorities in the host Member State. 
Finally, recurrent costs mainly consist of annual Chamber membership fees. 

Various  types  of  formalities  were  commonly  highlighted  by  several  service  providers 
across  different  interviews  as  being  important.  These  types  of  formalities  will  be 
described in more detail in the following sections. They include: 

•  Familiarisation with formalities; 
•  Collecting documents from authorities; 
•  Collecting data/information on shareholders and managers; 
•  Completing forms; 
•  Formalities relating to professional indemnity insurance; 
•  Translation and certification of documents; 

98 I May 2017 

 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

•  Examination of managers or shareholders and/or language skills requirements 

of managers or shareholders; 

•  Additional costs of collecting or submitting documents in person; 
•  Paying registration or membership fees. 

A  number  of  other  formalities  were  highlighted  by  service  providers  although  less 
often than those mentioned above. They include collecting specific other information, 
posting documents, travel costs, postal costs, training fees, etcetera.  

In  this  chapter,  the  costs  of  activities  are  classified  in  up  to  four  degrees  of 
complexity,  from  simple  to  very  complex.  The  main  reason  is  to  avoid  allocating 
different costs to similar or identical requirements due to random differences between 
respondents,  as  explained  later  on  this  page.  The  classification  of  costs  is  primarily 
based  on  the  range  of  costs  per  type  of  activity  across  all  countries,  sectors  and 
modes  of  cross-border  services  provision.  For  example  costs  of  familiarizing  with 
formalities are reported in clusters of 0.5 to 2 hours, 3 to 8 hours and 15 to 20 hours. 
In  this  and  most  other  cases,  three  degrees  of  complexity  are  defined:  simple, 
medium  and  complex.  The  category  “very  complex”  is  defined  only  once  for  a 
particularly  heavy  data  requirement  for  each  shareholder  that  respondents  reported 
costing an exceptional amount of time.  

In  the  cost  calculations,  the  average  costs  reported  per  degree  of  complexity  will  be 
used.  In  the  above  example,  the  same  average  of  17  hours  is  used  for  “complex 
familiarization”  for  all  countries  where  the  procedure  is  hard  to  familiarize  with, 
regardless of whether for specific countries 15 or 20 hours was reported. This has the 
disadvantage that the most burdensome formality cannot be singled out. However, it 
has  the  advantage  that  costs  are  less  sensitive  to  random  differences  in  efficiency 
between  respondents,  and  also  less  sensitive  to  conveniently  rounded  numbers 
(respondents may have conveniently rounded 17 hours to either 15 or 20 hours).  

The  degrees  of  complexity  are  related  to  the  administrative  formalities  described  in 
the  previous  chapters:  few  demands  result  in  simple  formalities,  heavy  demands 
result in complex formalities. However, the administrative formalities do not the solely 
determine  the  costs.  Other  relevant  factors  that  influence  costs  are  the  efficiency  on 
the part of the applicant (for example language proficiency) and factors such as travel 
distance.  Hence,  the  degree  of  complexity  does  not  uniquely  determine  the  actual 
costs.  For  example,  the  cost  of  demonstrating  knowledge  of  the  Greek  language  in 
Cyprus  is  zero  for  service  providers  from  Greece,  but  high  for  service  providers  from 
other EU countries.  

In addition, it is important to keep in mind that this study measures only direct costs 
of  administrative  formalities.  It  is  not  unlikely  that in  many  costs  complexity  of  rules 
and  formalities  also  generates  a  significant  amount  of  uncertainty  for  service 
providers.  This  uncertainty  might  discourage  them  from  becoming  active  across 
borders,  in  addition  to  more  direct  administrative  costs.  The  study  only  revealed  the 
cost  of  service  providers  that  have  gone  through  the  procedure  and  not  those  of 
service  providers  who  considered  going  cross-border  but  decided  against  it  (because 
they could not answer the questions about specific costs).  

The  classification  of  formalities  in  individual  countries,  for  individual  sectors  and  the 
two modes of services profession into degrees of complexity is discussed in Chapter 7. 
In  Chapter  8,  the  results  from  this  and  the  next  chapter  are  combined  to  provide  an 
overview  of  costs  per  requirement.  The  sections  below  discuss  the  classification  of 
reported hours and out-of-pocket expenses into degrees of complexity.  

May 2017 I 99 

 
6.2  Familiarisation with formalities 

Before  being  able  to  complete  certain  formalities  in  the  host  Member  State,  service 
providers  need  to  understand  the  different  procedural  steps  that  are  required.  With 
the benefit of hindsight, some respondents remarked on the difficulties of pinpointing 
formalities. For Austria the secretary of an architecture  firm remarked “It is not easy 
to say what was most burdensome here. Mr. […] only notes that, from the decision to 
start a subsidiary in Austria, it took three to four months of work of two/three persons 
(himself included) full-time to deliver all necessary documents/ examinations etc.” 

Interviews  showed  that  for  some  service  providers  it  required  relatively  little  effort 
(category:  "Simple")  to  become  familiar  with  the  required  formalities  in  the  host 
Member  State.  This  is  particularly  the  case  in  Member  States  and  sectors  with  few 
formalities  and  easily  accessible information  (for  example,  if  only  documents  need  to 
be submitted and there is a clear list of required documents). In these cases, service 
providers  reported  that  only  0.5  to  two  hours  of  staff  time  was  required  to  become 
familiar  with  requirements  of  the  host  Member  State.  This  was  typically  the  case  for 
temporary cross-border services.  

Other  interviews  showed  that  other  service  providers  had  to  undertake  more  effort 
(category:  "Medium")  to  familiarise  with  the  relevant  requirements.  This  is 
generally caused by information on applicable rules and requirements being unclear, a 
high  number  of  requirements  or  the  existence  of  a  preliminary  procedure  with  for 
example  the  general  business  register.  In  these  cases,  service  providers  reported 
three to eight hours of staff time required to familiarise with requirements of the host 
Member  State.  This  comes  on  top  of  more  indirect  and  unmeasured  costs  of  legal 
uncertainty, as mentioned above.  Most examples  of unclear information are from the 
accountancy  sector:  different  procedures  apply  for  slightly  different  activities  in 
Romania;  requirements  for  domestic  and  foreign  firms  are  presented  without  clear 
distinction in  Portugal; the  frequent  use  of  unclear  abbreviations  in  France;  etcetera. 
In Malta, it is not clear whether requirements for architecture and engineering services 
apply to natural or legal persons, two  firms reported no difficulties here but one firm 
reported 16 hours (in this case the average was used and the requirement is placed in 
the category “medium”). Examples where the procedure is simple but with unusual or 
preliminary  requirements  include  Ireland,  where  architecture  firms  wishing  to  carry 
the voluntary title in the company name must provide a number of essays written by a 
manager  –  or  Luxembourg,  where  VAT  registration  must  be  demonstrated  before  a 
branch can be established.  

Finally,  another  group  of  service  providers  highlighted  that  significant  effort 
(category: "Complex") was needed to familiarise with the required formalities. This 
is  the  case  specifically  in  Member  States  and  sectors  with  different  sequential 
procedures with local and central authorities or conflicting information. In these cases, 
service  providers  reported  15  to  20  hours  of  staff  time  required  to  familiarise  with 
requirements  of  the  host  Member  State.  This  is  typically  the  case  for  federally 
organized countries: Belgium, Germany, Italy and Spain. Some service providers even 
reported  the  need  to  contract  external  advice  given  the  overall  complexity  of  the 
procedures.  For  Germany,  the  costs  of  familiarization  is  likely  explained  by  the 
different  regulations  in  each  Bundesland,  and  the  duplication  of  required  documents 
by the municipality (for the general business register) and the Chamber (for access to 
the  profession);  also  during  the  research  it  became  clear  that  information  on 
formalities  is  scattered  (in  Nordrhein-Westfalen).  For  Spain,  a  service  provider 
remarked: “Familiarization and understanding of all the different steps to be followed 
in  the  host  country  is  complicated.  Different  options  of  establishment  (legal  form) 
were not clear enough.” 

100 I May 2017 

 
 
Administrative formalities and costs involved in accessing markets cross-border for 
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Table 6.1 Average hours spent on familiarization with formalities 

Category 
Simple 
Medium 
Complex 

Reported hours 
of staff time 
0.5 to 2 
3 to 8 
15 to 20 

Managers

Hours per staff category 
Professionals 
--
1
5

Admin. staff
-- 
1 
4 

1
2
8

6.3  Collecting supporting documents from authorities 

Service  providers  highlighted  in  several  interviews  that  they  are  required  to  collect 
supporting documents from authorities (often in the home Member State) to complete 
formalities  in  the  host  Member  State.  This  confirms  the  information  gathered  in  the 
inventories  (Chapter  3-5).  This  section  does  not  cover  the  need  to  collect  internal 
company documents, which might however further increase costs.  

Interviews  with  service  providers  showed  that  this  often  requires  relatively  little 
effort (category: "Simple"). In most countries, only up to two hours are needed to 
collect supporting documents from authorities in the home Member State, such as an 
extract  from  the  business  register  or  a  certificate  of  registration  with  a  professional 
chamber.  Requirements  for  temporary  cross-border  services  fall  in  this  category 
except  in  Germany  for  firms  that  wish  to  carry  the  voluntary  title  of  “architect”  or 
“engineer” in the company name (Table 6.2).  

Other  interviews  showed  that  in  some  cases  more  effort  (category:  "Medium") 
was required from service providers to collect supporting documents from authorities. 
This  is  the  case  when  multiple  standard  extracts  or  even  non-standard  documents 
need  to  be  collected.  This  takes  up  staff  time  ranging  from  two  to  four  hours.  For 
example,  in  Belgium  the  architecture  firm  and/or  (the  majority  of)  the  shareholders 
must  submit  both  a  certificate  of  membership  of  a  professional  body  in  the  home 
country and an attest of insurance issued by an insurance provider.  

Table  6.2  Average  hours  spent  on  collecting  supporting  documents  from 
authorities 

Category 
Simple 
Medium 

Reported hours 
of staff time 
0.5 to 2 
2 to 4 

Specific document requirements 

Hours per staff category 
Professionals 
1
1

Admin. staff
-- 
1 

Managers

--
1

Sometimes  specific  documents  or  documents  with  specific  requirements  need  to  be 
collected  that  were  reported  to  be  time  consuming.  This  adds  additional  complexity. 
These include: 

•  France, architecture and accountancy branches: proof of a professional address 
such as a rental agreement, an electricity or phone bill etc. (reported at 6 
hours); 

•  Luxembourg, architecture and engineering branches: the company statutes 

must include an advised deontological statement; 

•  Romania, accountancy branches: the firm’s scope of activity should cover the 
expert and/or licensed accountant profession. It is not specified whether this 
must be included in the firm’s registration certificate or the company statutes 
(both of which must be submitted);  

May 2017 I 101 

 
 
 
 
•  Spain for branches of voluntary professional architecture or engineering 
partnerships: the formulation of the public deed must comply with the 
requirements of the Spanish regulations of the legal form that is adopted.  

Similar  requirements  as  for  Luxembourg  and  Spain  are  also  in  place  in  Austria 
(architecture and engineering branches), Belgium (accountancy branches) and France 
(accountancy branches). However in these countries the company  statutes must also 
include  shareholder  data,  and  the  hours  reported  for  adjusting  company  statutes  are 
allocated to that requirement (in the next section). Adjustment of company statutes to 
include shareholder data is reported to cost 20 hours, and the same number of hours 
is  assumed  for  Luxembourg,  Romania  and  Spain  in  the  situations  described  in  this 
section.  

6.4  Collecting data/information on shareholders and managers 

Service providers often need to collect data/information on the shareholders and 
managers  of  the  company  to  prove  compliance  with  host  Member  States' 
requirements,  when  they  exist.  The  cost  of  collecting  this  information  depends  on 
exactly what information needs to be provided.  

In  some  cases,  service  providers  reported  that  this  requires little  effort  (category: 
"Simple")  (0.5  to  two  hours).  This includes  situations  where  limited  evidence  needs 
to  be  gathered  such  as  ID  data  (for  example,  name,  address,  registration  number, 
passport  number  and/or  specialization)  of  managers  and/or  shareholders.  Examples 
include  Cyprus  when  establishing  a  branch  for  architectural  or  engineering  services 
and Austria for accountancy services, where these data must be filled in on a form.  

In other cases, such as when additional details on the number or value of their shares 
and/or  voting  rights  are  needed,  more  effort  (category:  "Medium")  was  required 
(two  to  four  hours).  Here  examples  include  Luxembourg  for  branches  in  all 
professional services covered and Romania for accountancy services. Such data must 
typically be completed using a table template on the form. 

Moreover,  significant  effort  (category:  "Complex")  was  needed  when  the  data 
requirements  are  complex  (eight  to  12  hours).  This  is  the  case  when  the  company 
statutes  must  include  shareholder  data,  as  is  needed  for  example  for  permanent 
establishment  of  architectural  services  in  Austria  and  Belgium.  This  may  require 
redrafting  the  company  statutes  and  having  it  certified,  in  addition  to  collecting  the 
shareholder data in the first place.  

Finally, it was reported that in some cases especially significant effort (category: 
"Very  complex")  was  required  to  collect  and  provide  shareholder  data,  namely 
service  providers  are  required  to  provide  additional  data  on  positions  that  partners 
hold in other firms. It then takes between 28 and 40 hours to collect and provide such 
data. It was reported that shareholder data requirements for architects establishing a 
branch  in  France  “very  complex”,  and  the  same  applies  to  setting  up  accountancy 
branches in Belgium, France and Malta. 

Table  6.3  Average  hours  spent  on  collecting  information  on  shareholders  / 
managers  

Reported hours 
of staff time 
0.5 to 6 
10 
20 

Category 
Simple 
Medium 
Complex 

102 I May 2017 

Managers

Hours per staff category 
Professionals 
2
--
--

Admin. staff
-- 
5 
10 

1
5
10

 
 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

Category 
Very complex 

Reported hours 
of staff time 
28 to 40 

6.5  Completing forms  

Managers

17

Hours per staff category 
Professionals 
--

Admin. staff

17 

Completing forms of the host Member State does not take much time for most service 
providers  of  temporary  cross-border  services  that  were  interviewed.  On  the  other 
hand,  establishing  a  branch  cross-border  may  require  completing  a  wide  range  of 
different forms.  

Some  service  providers  reported  that  little  effort  (category:  "Simple")  was 
required  for  completing  forms.  This  is  the  case  when  the  service  providers  are 
required  to  provide  only  a  limited  amount  of  information  (for  example,  company  ID 
information  and  registration numbers),  taking from  0.5  to  two  hours.  Establishing  an 
architecture branch in Belgium, for example, requires just name and address data for 
the firm and the authority where the firm is registered.  

In other cases more effort (category: "Medium") was reported to complete forms, 
for  example  providing  more  detailed  information  on  office  space  or  experience.  This 
takes  up  staff  time  ranging  from  eight  to  ten  hours.  An  architectural  partnership 
wanting to establish a branch in Portugal would, for example, need all partners to be 
professionals,  and  those  from  other  EU  countries  would  have  to  provide  a  list  of  all 
previous  employers  with  start  and  end  dates.  This  requirement  alone  is  reported  to 
take three to six hours and comes on top of other form requirements. 

Finally,  service  providers  sometimes  needed  to  put  significant  effort  (category: 
"Complex")  into  completing  forms.  This  includes  requirements  to  complete  multiple 
forms  or documents for each manager/shareholder.  In these cases,  service providers 
reported  between  20  and  40  hours  of  work.  Establishing  an  accountancy  branch  in 
France is one example, where not only shareholders but also their spouses must sign 
a form. One architect remarked that in France the most time-consuming step was “to 
organise  references/CV's  in  the  required  language  -  burdensome  the  first  time”, 
referring to an annually recurring requirement  to submit all projects entrusted to the 
firm.  

Table 6.4 Average hours spent on completing forms  

Category 
Simple 
Medium 
Very complex 

Reported hours 
of staff time 
0.5 to 2 
8 to 10 
20 to 40 

Hours per staff category 
Professionals 

Managers
0.5
--
20

0.5
4
10

Admin. staff
-- 
5 
-- 

6.6  Certain formalities related to liability insurance 

Service  providers  going  cross-border  are  sometimes  required  to  obtain  (additional) 
professional indemnity insurance to cover activities in the host Member State, or civil 
liability  insurance.  This  may  create  a  further  administrative  burden  for  these  service 
providers.  

Again,  this  section  only  looks  into  direct  administrative  costs  of  insurance 
requirements.  Therefore,  potential  other  difficulties  faced  by  service  providers  in 
relation  to  insurance  that  are  not  direct  administrative  costs  are  not  considered.  For 
example,  this  section  does  not  include  potential  problems  such  as  getting  a  (clean) 
claims  statement  regarding  activities  in  the  home  Member  State  recognised  by  the 

May 2017 I 103 

 
 
 
 
host  Member  State  insurer.  These  types  of  hurdles  might  further  increase  costs 
significantly for service providers.  

The  formalities  covered  here  do  also  not  include  the  submission,  translation  and/or 
certification  of  insurance  documents  which  are  covered  in  other  sections,  but  only 
specific  administrative  formalities  regarding  the  formulation  or  the  provider  of 
insurance. 

Service  providers  in  a  number  of  cases  reported  that  little  effort  (category: 
"Simple") related to this formality was needed. This situation arises if a civil liability 
insurance  must  be  taken  and  proved  for  authorization,  as  is  needed  to  establish  an 
engineering  branch  in  Spain  for  accidents  of  third  persons  on  the  premises  of  the 
branch  (Madrid),  or  if  a  specific  but  simple  professional  indemnity  insurance  is 
required, as is the case in Austria for accounting services.  

In  other  cases,  service  providers  reported  that more  effort  (category:  "Medium") 
was  required.  This  might  include  requirements  such  as  complying  with  prescribed 
wording  of  an  insurance  policy.  It  usually  takes  between  four  and  eight  hours  to 
comply with these obligations. This is the case for accountancy services in the United 
Kingdom,  where  the  whole  insurance  policy  is  prescribed  and  the  chamber  of 
accountants  must  be  consulted  if  different  wording  is  desired.  Also,  some  companies 
with  insurance  at  the  company  level  in  the  home  country  reported  difficulties  to  get 
this  accepted  in  a  host  country  where  insurance  of  individual  professionals  is  usual, 
clearly requiring extra effort.  

In the last category service providers are required to put in significant effort 
(category: "Complex"). This situation may arise if the insurer must be operational 
in the host country and the insurance requirements are complex. Two service 
providers reported on average 30 hours of staff time required to establish an 
engineering branch in Austria. While professional indemnity insurance is not a legal 
requirement in Austria it is necessary because professional liability lasts ten years in 
Austria and civil liability can extend to 30 years. The multiple liabilities make it difficult 
to compare insurance policies of different insurance companies.  

Table  6.5  Average  hours  spent  on  formalities  relating  to  professional 
indemnity insurance  

Category 
Simple 
Medium 
Very complex 

Reported hours 
of staff time 
1 to 2 
4 to 8 
30 

Managers

Hours per staff category 
Professionals 
2
--
--

Admin. staff
-- 
-- 
-- 

--
6
30

6.7  Translation and certification of documents 

In  many  cases,  service  providers  are  asked  to  translate  supporting  documents 
accompanying their application. These often need to be certified, and copies forwarded 
to the host Member State – culminating in further administrative costs. 

Firstly,  service  providers  need  to  find  a  (certified)  translator.  This  was  reported  as 
requiring  little  effort  (category:  "Simple")  by  some  service  providers  (0.5  –  two 
hours), for example in Germany to carry a voluntary title in the company name: it is 
easy  to  find  a  certified translator  in  your  own  country  via  a  quick internet  search.  In 
other  cases,  this  was  reported  as  requiring  significant  efforts  (category: 
"Complex"),  for  example  in  case  the  translation  needs  to  be  carried  out  by  an 
officially  approved  translator  from  the  host  country  (five  to  12  hours).  Finding  a 
certified  translator  from  the  host  country  is  reported  at  five  to  eight  hours.  The  12-
hour example was reported by an engineer who also found "technical translations are 

104 I May 2017 

 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

not  always  the  strong  point  of  translators  -  involvement  of  technical  personnel 
required to technically control translations”.  

Table 6.6 Average hours spent on finding a certified translator 

Category 
Simple 
Complex 

Reported hours 
of staff time 
0.5 to 2 
5 to 12 

Managers

Hours per staff category 
Professionals 
--
1

Admin. staff
1 
8 

--
--

Secondly, service providers obviously need to pay for these external translation 
services. These costs are highly dependent on the Member State concerned. Costs of 
translations are often incurred for company statutes and insurance policies, and 
sometimes also for other certificates. For the purpose of the cost estimations, the 
following estimates regarding translation costs are used (when applicable) on the 
basis of what has been reported by service providers. These costs are not based on 
translation costs that were reported for individual translations, but were triangulated 
as follows. Firstly, the number of words in standard company statutes and insurance 
policies were counted and multiplied with translation rates per word. Secondly, the 
prices resulting from multiplying the number of words with translation rates were 
compared with reported costs which ranged from EUR 375 to EUR 1,000. This resulted 
in slight downward adjustments of the assumed number of words. The cost of EUR 
100 for other documents is based partly on the observation that most other 
documents are just one or two pages, and partly based on the difference between 
total costs and the costs for company statutes and insurance policies.  

Table 6.7 Average expenditures on translations  

Type of document 
Company statutes 
Insurance policy 
Other documents 

Translation 
Costs 
EUR 600
EUR 400
EUR 100 per document 

Finally, service providers are often required to present copies of supporting documents 
in a certified form. An Austrian firm has reported EUR 500 for a notary to certify filled-
in  forms  in  the  Czech  language.  In  their  words:  “Notary  sworn  statements  and 
certification  of  signatures  by  notary.  Notary  procedures  are  very  unusual  in  Western 
Europe  -  so  we  always  have  to  explain  why  the  Austrian  Notary  has  to  certify  our 
signatures  without  knowing  the  foreign  language  text  of  the  document”.  A  Belgian 
accountancy firm has reported EUR 150 to certify documents to establish a branch in 
Luxembourg:  “Attestation  of  non-bankruptcy.  A  private  person  who  never  was 
independent,  cannot  get  such  an  attestation,  and  a  solution  has  been  found  by  an 
oath  before  public  notary”.  And  for  Malta,  a  respondent  remarked  early  at  the 
interview  that  the  most  burdensome  part  was  “Authentication  of  Home  Country 
documents.”  

The main difficulty to estimate certification fees is that multiple copies are certified in 
one transaction and the fee does not depend on how many copies are certified in the 
single  transaction.  For  example,  company  statutes  need  to  be  submitted  on  multiple 
occasions.  Instead  of  visiting  a  notary  each  time  a  certified  company  statute  is 
needed,  a  company  gets  perhaps  50  certified  copies  of  the  company  statutes  in  one 
transaction. The costs of such a transaction can be up to EUR 1,500 but the cost per 
copy  would  be  only  EUR  150  or  even  only  EUR  30  depending  on  whether  10  or  50 
copies  were  certified  in  that  transaction.  The  highest  costs  therefore  arise  if  non-
standard  documents  or  documents  from  authorities  in  the  host  country  need  to  be 

May 2017 I 105 

 
 
 
 
certified. Therefore, despite the large variation in reported certification costs, a cost of 
EUR 150 was assumed whenever one or more documents need to be certified.  

A  similar  argument  applies  to  translation  certifications.  Translators  do  not  go  to  a 
notary after the translation of each single document, but have all translations done for 
all  customers  certified  in  one  transaction  that  takes  place  once  or  twice  in  a  week. 
Respondents get just one invoice for a certified translation and thus it is difficult to say 
what  part  is  for  the  actual  translation  and  what  part  for  certification  of  it.  Hence  the 
estimated cost of translation certification requirements is not based on interviews but 
on  Internet  research,  which  revealed  that  translators  typically  charge  an  additional 
EUR 50 for certification of translations and which is the assumed price. The exception 
is  Italy,  where  a  translation  must  be  sworn  before  an  Italian  court  or  in  an  Italian 
embassy. Italian embassies charge a standard fee of EUR 9.30 per page of which the 
translation  is  sworn.  Based  on  the  types  of  documents  that  must  be  translated  and 
based on examples on internet of translator who explain why certified translations into 
Italian cost so much, a fee of EUR 350 is assumed for certification of translations into 
Italian.  

Table 6.8 Average expenditures on certifications  

Type of certification 
Certification of copies
Certification of translations 
Swearing translations in a court 
of the host country 

Certification 
costs 
EUR 150
EUR 50
EUR 350

6.8  Changes to legal form and/or reallocating shares or voting rights  

Several  Member  States  require  service  providers  to  have  a  certain  legal  form  and/or 
shareholding  structure  and/or  composition  of  the  management  body.  This  is 
particularly  the  case  in  the  situation  of  secondary  establishment.  These  rules  can  be 
serious  obstacles  for  service  providers,  which  can  prevent  them  from  going  cross-
border  altogether.  Nevertheless,  they  in  any  case  require  significant  administrative 
efforts  from  service  providers.  However,  costs  of  legal  form  changes  are  quite  rarely 
reported.  The  reason  may  be  that  costs  of  legal  form  changes  have  been  incurred  in 
the general business registration procedure, which in the questionnaire was  excluded 
as being beyond the scope of the study. 

Regarding  changes  for  legal  form  requirements,  two  types  of  situations  are 
considered for the purpose of estimation of costs due to administrative formalities.  

One situation is where several legal forms are allowed and the procedure depends on 
the  legal  form.  This  is  the  case  for  example  to  establish  an  engineering  branch  in 
Spain:  “There  were  different  options  (not  clear)  to  establish  and  depending  on  the 
legal  form  selected  we  were  asked  to  comply  different  requirements  on  structure, 
shares, etc.” This requirement may cause an adjustment of the company statutes and 
the  legal  form  under  which  the  firm  is  registered  in  the  home  country.  In  these  and 
similar cases, the cost of legal form requirements was reported at six to ten hours.  

On  the  other  hand,  it  might  become  considerably  more  complicated  for  a  service 
provider  to  adapt  to  these  requirements  in  case  the  host  Member  State  accepts  only 
one or two types of legal form. This is the case for example in France for accountancy 
branches  where  legal  forms  that  grant  associates  the  status  of  “trader”  are  not 
permitted. And in the United Kingdom, this is the case for engineering firms wishing to 
carry  the  title  “chartered  civil  engineer”  or  “chartered  mechanical  engineers”  in  the 
company name. This is only possible for partnerships where all partners are members 

106 I May 2017 

 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

of  the  relevant  body.  These  type  of  requirements  were  reported  to  take  between  20 
and 50 hours. 

Lastly, the cost implied by nominative shares requirements was not asked separately 
from costs of submitting shareholder data but it obviously creates an obstacle for 
firms that do not have nominative shares. To cover this aspect, a conservative 3 hours 
is assumed to get shares on name.  

Table 6.9 Average hours spent on formalities relating to legal form 

Category 
Nominative 
shares 
Medium 
Complex 

Reported hours 
of staff time 
-- 

6 to 10 
20 to 50 

3

8
30

Managers

Hours per staff category 
Professionals 
--

Admin. staff
-- 

--
--

-- 
-- 

Regarding  rules  on  shareholding  and  voting  right  structures,  these  are  also 
important  obstacles  as  they  require  that  (a  majority  of  the)  shareholders  are 
professionals  even  if  they  do  not  provide  the  services.  Such  requirements  may  be 
practically impossible for service providers to comply with, although obviously not for 
the  cross-border  service  providers  that  were  interviewed.  However,  it  was  remarked 
by service providers that it could be a barrier for other firms.  

Even if the service provider is able to comply with these requirements, it may need to 
make  changes  in  shareholding  and  voting  right  structures,  which  creates  significant 
costs.  One  respondent  reported  time  to  comply  with  these  requirements  of  up  to  27 
hours. 

Different situations across Member States cause these changes.  

Firstly, several countries require a simple majority of 50% or 51% of shares or voting 
rights to be in the hands of professionals for all legal forms available. Assuming that a 
service  provider  is  able  to  comply  with  this  requirement,  it  is  estimated  to  require 
about five hours of work from a pure administrative point of view. This assumption is 
based  on  the  fact  that  this  requirement  exists  in  several  Member  States.  Also, 
(authorized)  professionals  are  more  likely  to  hold  a  simple  majority  than  a  qualified 
majority even in the absence  of  such a requirement.  If the same  requirements apply 
only to voluntary professional partnerships, a weight of 0.2 is applied. This results in 
an assumed one hour of work.  

Secondly, some countries require a qualified majority of more than 51% of the shares 
or  voting  rights  to  be  held  by  professionals  regardless  of  legal  form.  This  is  a  less 
common requirement and is assumed to require the maximum reported administrative 
efforts  (27  hours).  Again,  if  the  requirement  of  more  than  51%  applies  only  to 
voluntary professional partnerships, a weight of 0.2 is applied and a cost of five hours 
is assumed.  

Table  6.10  Average  hours  spent  on  formalities  relating  to  shareholding  or 
voting rights 

Reported 

Weighted hours per staff category 

Category 

hours 

Managers

Professionals

Admin. staff

50-51% for 
voluntary 
partnerships only 

-- 

1 

-- 

-- 

May 2017 I 107 

 
 
 
Reported 

Weighted hours per staff category 

Category 

hours 

Managers

Professionals

Admin. staff

50-51% for all 
legal forms 
> 51% for 
voluntary 
partnerships only 
> 51% for all 
legal forms 

-- 

-- 

4 

4 

-- 

-- 

27 

18 

1 

1 

9 

For simplification purposes, no costs have been allocated to situations where a certain 
percentage of management positions must be in the hand of professionals. However, 
this also can generate further administrative costs.  

6.9  Examination and/or language skills 

Some  countries  require  shareholders  or  managers  to  take  an  exam  in  the  host 
country.  Professional  qualifications  are  beyond  of  scope  of  this  study.  Nevertheless, 
such  examination  requirements  are  considered  to  be  an  administrative  formality  for 
legal  persons  given  that  these  shareholders  and/or  managers  need  not  actually 
provide the services in the host countries and if they do, very often already have the 
appropriate qualifications in the home country. 

Language skill requirements for shareholders or managers, even if they do not actually 
provide  the  services  in  the  host  countries,  are  also  regarded  as  an  administrative 
formality  for  legal  persons.  If  examination  in  the  host  country  is  required,  it  is 
assumed  to  be  in  the  language  of  the  host  country,  thus  spurring  shareholders  or 
managers to improve their language skills.  

Preparing  for  examinations  in  professional  skills  is  reported  to  take  from  31  to  100 
hours, which includes training and the examination itself. The 31 hours figure refers to 
the  average  hours  of  two  respondents  for  Italy,  including  one  German  engineer  who 
reported 63 hours for an examination, which in Italy may be required if qualifications 
are judged to be too different from those in the host country.  

In  Austria,  the  executive  manager  of  an  architecture  or  engineering  firm  must  know 
Austrian  tax  law,  which  was  reported  to  take  150  and  200  hours  of  training 
respectively.  Since  it  is  possible  to  pass  this  exam  with  150  hours  of  training,  these 
were the hours used in the analysis.  

Two German architects remarked on examination requirements in Austria: 

• 

• 

“As mentioned before, the examination to obtain the certificate of 
competence/proficiency was most burdensome as Mr. […] had to learn the 
Austrian legislation almost by heart, which cost him many hours” and  
“The most burdensome part for Mr. […] himself was to obtain the 
'Gewerbeberechtigung', i.e., the ' industry authorization', as it involved a 
course and much studying and an exam at the end. It was an effort to 
understand and learn the Austrian trade law framework, as there are 
differences between Germany and Austria. This procedure cost his firm 10,000 
Euros (including the fees for the examination, which were 2,000 Euros, the rest 
was paying his salary when he was not working, but actually studying for the 
exam).” 

108 I May 2017 

 
 
 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

Table 6.11 Average hours spent on examination requirements 

Type of 
Examination 
In professional skills
In tax law 

Reported hours 
of staff time 
31 to 100
150 to 200

Managers

65
150

Hours per staff category 
Professionals 
--
--

Admin. staff
-- 
-- 

Training  in  language  skills  was  reported  to  cost  between  38  and  80  hours.  The  38 
hours figure was reported by the same engineer who needed to do an exam in Italy. 
To assess the time to master a new language, Internet-based language courses were 
examined. Several courses assume 90 hours of training to reach “level 2”. Hence the 
reported maximum of 80 hours was used in the calculations.  

Lastly, some respondents reported difficulties to understand information that was not 
available  in  the  English  language.  One  respondent  reported  that  looking  up 
information would have cost 10 hours less if practical information had been available 
in English. These hours were applied whenever practical information was not available 
online in the English language.  

Table  6.12  Average  hours  spent  on  language  skills  caused  by  administrative 
formalities 

Language skills 
Requirement 
Needs to be 
proved or needed 
for an exam in the 
host country 
To understand 
information about 
the procedure 

Reported hours 
of staff time 
38 to 80 

10 

80

5

Managers

Hours per staff category 
Professionals 
--

Admin. staff
-- 

5

-- 

Besides the hours spent on acquiring knowledge of the relevant regulations of the host 
country  and/or  learning  the  language  of  the  host  country,  out-of-pocket  costs  are 
incurred  to  acquire  this,  consisting  of  the  fee  charged  by  the  trainer  and/or  the 
examiner.  If  professional  training  or  training  in  tax  law  is  required  of  shareholders 
and/or  managers  even  if  they  do  not  provide  the  services  in  the  host  country,  the 
reported  fee  of  EUR  2,000  for  Austria  is  used.  For  training  in  language  skills,  a  cost 
from  “level  1”  to  “level  2”  of  EUR  575  was  reported,  but  based  on  internet  research 
the  cost  of  a  typical  course  from  starter  to  “level  2”  is  EUR  1,000  and  this  is  the 
assumed cost.  

6.10 Collecting / submitting documents and travel tickets 

Collecting  or  submitting  documents  can  be  quite  a  low-cost  activity  if  they  can  be 
downloaded or uploaded, or received or sent by email. However, formalities regarding 
the collection or submission of data or documents may cause additional time and out-
of-pocket costs if documents need to be posted, or need to be collected or submitted 
in person in the host country. 

Regarding the time involved with posting documents, respondents report one hour at 
most; a half-hour of administrative staff-time is assumed.  

May 2017 I 109 

 
 
 
 
The  time  involved  with  collecting  or  submitting  documents  in  person  in  the  host 
country  is  reported  to  take  between  five  and  38  hours.  The  time  spent  on  collecting 
documents  in  person  was  only  reported  for  Luxembourg  (by  three  out  of  four 
respondents  for  that  country).  Three  respondents  reported  hours  of  30  and  above 
(from  Germany  to  Italy,  from  the  United  Kingdom  to  Malta  and  from  Belgium  to 
Romania).  However,  the  majority  of  firms  report  a  time  between  10  and  15  hours. 
Although travelling to for example Malta is very likely to take systematically longer on 
average  than  for  other  host  countries,  the  same  average  travelling  cost  is  used 
whenever documents need to be collected or submitted in person in the host country 
in order to allocate similar costs to similar requirements.  

Hence, the same total of 12 hours is used regardless of the host country. With regard 
to  the  staff  category,  some  reported  that  administrative  support  staff  submitted  the 
documents in person, and others that a professional or a manager did so. In this study 
no requirements were identified with regard to the staff category that needs to submit 
documents in person, and hence also the same distribution of hours by staff category 
was assumed regardless of the host country.  

Table 6.13 Average hours spent on collecting or submitting documents 

Type of 
Requirement 
Posting documents
Collecting or 
submitting in person 
in the host country 

Reported hours 
of staff time 
0.5 to 1 
5 to 38 

Managers

--
6

Hours per staff category 
Professionals 
--
3

0.5 
3 

Admin. staff

Out-of-pocket  costs  of  posting  documents  were  included in  the  questionnaire  but  not 
reported  by  anyone.  In  reality  these  costs  must  be  incurred  although  they  are  likely 
small, and a standard cost of EUR 20 is assumed.  

Out-of-pocket  costs  of  collecting  or  submitting  documents  in  person  in  the  host 
country consist of travel ticket costs. Perhaps because it was one of the last questions 
only  one  respondent  reported  these  costs,  at  EUR  175  for  travel  within  the  host 
country  (Romania).  However,  this  is  an  important  observation  because  requirements 
to  submit  documents  in  person  typically  apply  for  permanent  establishment  and  not 
for  temporary  cross-border  services.  Hence,  if  local  (administrative  support)  staff  is 
already hired or a local branch office is already arranged, only domestic travel may be 
needed to submit documents in person. Nevertheless, because domestic travel cannot 
always  be  assumed,  a  slightly  higher  travel  ticket  cost  of  EUR  250  is  assumed 
regardless of host or home country.  

Table 6.14 Average postal and travel expenses  

Type of expense 
Postal expenses 
Travel expenses 

Assumed 
Costs 
EUR 20
EUR 250

The same travel ticket cost of EUR 250 is assumed if examination in the host country 
is required.  

110 I May 2017 

 
 
 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

6.11 Paying registration or membership fees  

Firms that are authorized to provide services  are usually registered and may need to 
pay  a  registration  fee.  Alternatively,  or  in  addition,  membership  of  a  professional 
chamber and a membership fee may be required. These fees are administrative costs 
in themselves and vary considerably between Member States, as was discussed in the 
sections 3.6, 4.6 and 5.6. Respondents were also asked about the fees they paid. The 
answers were often quite accurate but if not tend to underestimate the costs. Hence, 
the official fees presented in the previous chapters were used in the cost calculations, 
and they are not presented here. However, paying fees may also cost time, depending 
on administrative formalities. 

Payment  of  fees  costs  little  effort  (category:  Simple)  if  money  can  be  transferred 
to a bank account. In this case 0.5 to one hour is reported, if any time to pay fees is 
reported at all, and an average cost of 0.5 hours is assumed. 

Some effort (category: Medium) in the range of four to ten hours was reported by 
some  respondents,  but  generally  by  only  one  respondent  per  country.  It  is  assumed 
that  this  is  related  to  difficulties  to  find  the  information  about  making  the  payment, 
since no specific barriers could be identified in these cases.  

Significant effort (category: Complex) was reported for two countries (France and 
Luxembourg), and more than once  for both. The time involved ranges from 18 to 20 
hours  with  an  outlier  of  28  hours.  In  France,  a  cheque  must  be  included  among  the 
supporting  documents  and  presumably  the  cost  refers  to  the  time  to  arrange  such  a 
cheque.  Regarding  Luxembourg:  the  fee  to  be  paid  in  advance  is  EUR  80  per 
document  (“par  dossier”)  for  architecture  and  engineering,  and  perhaps  this  causes 
confusion, for example if a document was initially missing.  

Table 6.15 Average hours spent on paying registration or membership fees 

Category 
Simple 
Medium 
Complex 

Reported hours 
of staff time 
0.5 to 1 
4 to 10 
18 to 28 

6.12 Recurrent costs 

Hours per staff category 
Professionals 

Managers

--
--
20

0.5
4
--

Admin. staff
-- 
-- 
-- 

The  last  category  of  costs  are  recurrent  costs  related  to  access  to  the  market, 
regardless  of  whether  services  are  provided.  The  main  types  of  recurrent  costs  that 
are  reported  are  an  annual  membership  fee  and  annual  submission  of  some 
documents. Annual fees are always included in the recurrent costs whenever they are 
required as documented in sections 3.6, 4.6 and 5.6.  

Formalities cost little efforts and are classified as simple when only one or two forms 
or documents need to be re-submitted and possibly an annual membership fee needs 
to be paid. Formalities relating to annual renewal of authorization were almost always 
reported to cost one hour if they were reported at all. In the end, however, it seemed 
better not to include the costs of simple recurrent efforts.  

A  requirement  that  many  or  all  of  the  same  or  similar  documents  need  to  be  re-
submitted every year is exceptional. It is observed only twice in this study, namely for 
architecture  branches  in  France  and  for  architecture  and  engineering  branches  in 
Cyprus. In this (rare) case clearly more efforts are required than for simple formalities 
and this requirement is classified as medium. The Greek architecture and engineering 
firms  operating  cross-border  in  Cyprus  could  not  indicate  the  cost  of  recurrent 
formalities since they were avoided as subcontractors in temporary services (although 

May 2017 I 111 

 
 
at  the  cost  of  having  only  a  small  share  in  the  work).  For  architecture  branches  in 
France,  one  Dutch  architect  reported  a  requirement  to  report  every  year  the  works 
entrusted  to  the  firm  to  take  24  hours  the  first  time  (including  translations)  but 
considerably less afterwards. Based on this observation and also because hours must 
be  in  between  those  of  simple  and  complex  formalities,  a  total  of  four  hours  is 
allocated to a requirement to re-submit many or all documents every year. 

In  several  Member  States  administrative  costs  are  also  recurrent  in  case  there  are 
changes in the composition of the management and/or shareholders of the company. 
For  practical  reasons,  it  is  assumed  that  this  takes  place  once  every  ten  years  after 
the  initial  authorization.  This  causes  some  administrative  formalities  to  be  complied 
with again and this falls in a category complex. They are reported in the range from 
eight  to  20  hours.  Regarding  Luxembourg,  for  example,  an  accountant  could  not 
provide  a  cost  estimate  but  remarked  that  if  the  management  changes,  “everything 
must be done over”.  

The  highest  recurrent  cost  is,  however,  reported  for  the  situation  when  the 
management  changes  and  a  new  executive  manager  needs  to  take  an  exam  in  the 
host country in order to be recognized as a professional. This situation is classified as 
very complex. The costs depends on the type of examination as discussed above in 
Section 6.9:  

•  For examination in tax law of the host country: 230 hours + EUR 3,250 

expenses; 

•  For examination in professional regulations of the host country: 145 hours + 

EUR 3,250 expenses. 

The  hours  consist  of  150  or  65  hours  of  training  in  regulations  of  the  host  country, 
plus 80 hours of language training, plus 12 hours for other administrative formalities. 
The  expenses  consist  of  training  fees  of  EUR  2,000  and  EUR  1,000  for  training  in 
regulations  of  the  host  country  and  language  skills  respectively,  plus  EUR  250  travel 
expenses.  

Since  the  questionnaire  did  not  ask  about  the  recurrent  activities  in  detail,  the 
following  assumptions  were  made  about  the  staff  category  involved:  administrative 
support  staff  for  simple  recurrent  formalities,  professionals  for  medium  recurrent 
formalities and managers for complex or very complex recurrent formalities (when the 
management changes).  

Table 6.16 Average hours and frequency of recurrent costs 

Category 
Simple 
Medium 
Complex 
Very 
complex 

Reported hours 
of staff time 
1
Some hours 
8 to 20 
Same as the first 
time 

Every … 
Years 
1
1
10
10

Hours per staff category 
Professionals 
--
4
--
--

-- 
-- 
-- 
-- 

Managers

--
--
12
157 or 242
a) 

Admin.staff

a)  242 hours if examination is in tax law, 157 if examination is in professional regulations, less 80 

hours for Ireland, Malta and the United Kingdom (because training in the English language is not 
assumed to be necessary). 

112 I May 2017 

 
 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

7  COMPLEXITY OF FORMALITIES 

7.1  Approach 

In the previous chapter, the costs of activities of service providers to gain cross-border 
access to  services were classified in up to four degrees  of complexity, with reference 
to types and the nature of administrative formalities.  

Different service providers report a range of hours for even the same activity required 
by  the  same  formality  in  the  same  country.  For  example,  one  firm  reported  that 
learning Austrian tax law cost 150 hours and another firm reported 200 hours for the 
same  requirement.  To  minimize  the  impact  of  random  differences  between  service 
providers on the allocation of costs and the comparison between countries, the same 
hours  are  allocated  to  all  administrative  formalities  of  the  same  type  and  with  the 
same  degree  of  complexity,  for  example  150  hours  to  learn  the  tax  law  of  the  host 
country.  

Building on the classifications of Chapter 6, the administrative formalities are classified 
into  the  same  degrees  of  complexity.  This  has  been  done  for  all  17  countries,  the 
three  professions  and  both  modes  of  cross-border  service  provision  covered  by  this 
study. Each administrative formality was carefully examined to determine its type and 
complexity, and in all cases this chapter provides the rationale for the classification. In 
Chapter 8, costs are allocated to individual administrative formalities depending on the 
degree of complexity determined in this chapter.  

7.2  Familiarization with formalities 

Most  respondents  reported  familiarizing  with  administrative  formalities  as  a  separate 
activity that costs time.  

For countries with a federal structure, such as Germany, Spain and Italy, high costs of 
familiarization with formalities to establish a branch have been reported, with different 
regions having different procedures, where different authorities are involved.  

In  most  other  countries  there  is  one  procedure  with  one  authority,  consisting  of 
documents  to  be  submitted.  For  establishing  a  branch,  a  further  factor  explicitly 
mentioned  in  interviews  is  that  it  is  not  always  clear  what  requirements  apply  in 
different  situations,  as  reported  for  Spain  but  also  for  accountancy  in  Romania,  and 
concluded from online information and forms for other countries.  

Another  aspect  that  seems  to  correlate  with  reported  time  to  become  familiar  with 
administrative  formalities  is  a  requirement  that  other  procedures  must  be  completed 
first. Availability of information in the English language is described in a later section 
under  language  difficulties.  In  the  absence  of  respondents  establishing  a  branch  in  a 
sector  in  a  certain  country,  the  quality  of  information  on  the  Point  of  Single  Contact 
(PSC) and the website of the relevant chamber was assessed.  

Table 7.1 Complexity of familiarization, branches 

MS  Arch. 
1 
AT 

Eng.
1

Acc.  Rationale 

1  There is only one procedure with one regional chamber of 
choice, easily accessible via the PSC. Each chamber has a 
clear description of the procedure. It is well described what 
documents are needed in which situation.  

May 2017 I 113 

 
MS  Arch. 
3 
BE 

Eng.
0

CY 

CZ 

1 

1 

1

1

Acc.  Rationale 

3  The PSC has no practical information to get authorization to 

provide services nor does it provide links to sites of 
chambers. On the sites of chambers some pieces of 
information are difficult to find, for example that company 
statutes must be in line with Belgian law. Especially for 
architectural services applicants must go from the one to 
the other authority in a specific sequence that is hard to find 
out. 

0  The procedure consists of submitting data and documents to 

one chamber which is straightforward to identify. 

0  Registration with the general business register is demanding 
but out of scope. Partners (of partnerships) or managers (of 
limited liability companies) must register as professionals 
with the Chamber which is straightforward to identify and 
which clearly lists the requirements on its website.  

DE 

3 

3

0  Aspects that make familiarization with requirements to carry 

a voluntary title in the company name difficult are the 
regional differences between laws, scattered information on 
the different (and partly duplicate) procedures to register 
with the Chamber and register in the general business 
register, insurance requirements (not covered in the 
registration procedure), and the difference in requirements 
for shareholders and other professionals is not clear. 
Reported hours: 16. 

DK 

0 

ES 

3 

0

3

0  Conflicting information about requirements for “structural 

engineers” providing the services which however are out of 
scope. Architecture, other engineering and accountancy are 
not regulated in Denmark 

0  Firms must supply an application to the Ministry of 

Development but it is not immediately clear that this must 
be done via a regional Chamber. There are different 
procedures for different legal forms, not only with the 
regional chambers but also with the general business 
register. Specifically for architecture, the different types of 
authorizations are confusing (to provide services, the visado 
and the building permit). Specifically for engineering, many 
specializations have their own chamber and the relevant one 
is hard to find out. Reported hours: 5-24 

FR 

1 

0

2  The PSC has clear information about procedures and 

requirements, and there is one procedure with one of the 
regional chambers of choice, which also have clear 
information about procedures. For accountancy, the use of 
formal language and many abbreviations slightly 
complicates the understanding of requirements 

IE 

2 

0

0  Familiarization is only needed to carry the voluntary title 

“architect” in the company name. Info on this is not on the 
PSC, and requirements to describe the organizational 
structure and the many requirements of the manager in 
control of the company take time to digest. Reported hours: 
8 

IT 

3 

3

3  The PSC does not describe the requirements of professional 

chambers which are different for each region. The procedure 
goes back and forth between multiple authorities (chamber 
and Ministry for shareholders, chamber and general 
business register for firms). Reported cost: EUR 4,000 to 

114 I May 2017 

Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

MS  Arch. 

Eng.

Acc.  Rationale 
hire advice

LU 

2 

MT 

2 

PL 

PT 

0 

1 

2

2

0

1

RO 

0 

0

SK 

1 

0

2  The PSC has relevant information. Documents need to be 
submitted to the chamber. Complication: completion of 
other procedure (general business register and VAT) must 
be proved. Reported hours: 3 

1  The PSC has no information on requirements of the 

chambers. For all three services, inscription in the general 
business register is a pre-condition. For architecture and 
engineering, requirements for voluntary professional 
partnerships may take time to digest and the websites were 
temporarily out of order during the research.  

0  Requirements only apply to natural persons providing the 

service 

2  The procedure is straightforward and consists of submitting 

documents to one authority. For accountancy, the 
application form is confusing, it is not clearly indicated that 
sections for national service providers do not apply to 
service providers from other EU countries 

2  For accountancy, it is not clear what requirements apply in 
what situation, for example for chartered and certified 
accountancy. A respondent reported time was saved by 
checking for all documents whether they were required or 
not. Reported time: 5 hours  

0  Architecture: professional requirements are checked by the 
office for the general business register which is beyond the 
scope of this study. A majority of partners of a voluntary 
professional partnership need to be an authorized 
professional for which the exam procedure is clearly 
described  

UK 

0 

0

1  For architecture and engineering, use of the voluntary title 

in the company name is only controlled ex post. For 
accountancy, the requirements for partners having voting 
rights are clearly described on the site of the Chamber 
(although not on the PSC).  

Legend: 0 = no formalities, 1 = simple (1 hour), 2 = medium (5 hours), 3 = complex (17 hours). 

For temporary cross-border services, requirements are usually straightforward and 
take one hour at most to complete. Exceptions are: 

•  Germany for architecture and engineering firms wishing to carry the voluntary 

• 

title (same complex requirements as for branches); 
Ireland for architecture (same medium requirements to carry the voluntary title 
as for branches); 

•  Spain for architecture and engineering (medium). For architectural services, a 
complication is that two types of authorization are needed for professionals 
providing the service (from the ministry for qualifications and the visado before 
carrying out any project). For engineering services, a complication remains that 
many specializations have their own chamber. 

7.3  Collecting supporting documents from authorities 

A  few  countries  require  supporting  documents  regarding  the  firm,  shareholders  or 
managers  that  are  issued  by  authorities,  typically  from  the  home  country.  Insurance 
policies  or  certificates  from  insurance  providers  are  covered  in  a  later  section.  If 
merely  the  name  of  the  relevant  authority  and  a  registration  number  must  be 

May 2017 I 115 

 
provided,  this  does  not  classify  as  a  supporting  document,  but  as  information  to  be 
filled in on a form.  

Table  7.2  gives  an  overview  of  the  countries  where  supporting  documents  from 
authorities  need  to  be  collected  for  establishing  a  branch  in  one  of  the  services 
covered by this study.  

Table 7.2 Complexity of collecting documents from authorities, branches 

MS  Arch. 
2 
AT 

Eng.
2

Acc.  Rationale 

1  Architecture and engineering: multiple standard documents 

for the executive manager: proof of authorization to 
exercise the profession in the home country, proof of non-
bankruptcy and proof of absence of professional misconduct 
must be submitted. Accountancy: a social security extract 
for the executive manager 

BE 

2 

0

0  Multiple standard documents: a certificate proving 

registration of the firm in the home country, an extract from 
the Belgian Official Gazette with publication of the company 
statutes, proof of registration with the Belgian general 
business register, and for shareholders proof of 
authorization to exercise the profession in the home country 

CY 

2 

2

0  Multiple standard documents: certificate proving the 

formation of the firm in the home country, proof of 
registration in the Cyprus general business register, for 
shareholders proof of Civil Registry and Migration 
Department’s Permit or other proof of permanent residence 
in Cyprus, certificate of authorization to exercise the 
profession in the home country without any limits, 
certificate of a one-year internship 

0  Architecture and engineering, general business registration: 

multiple standard documents 

0  To carry the voluntary title in the company name: proof of 

entitlement to carry the voluntary title in the home country, 
shareholders: certificate of membership in the home country 
and proof of good repute, and other documents depending 
on the Bundesland 

0  For shareholders in engineering, to register in the Industrial 
Register (Madrid): getting a social security certificate of the 
legal representative is reported to cost 5 hours 

2  For every accountancy associate: a certificate of work or 

social security 

2  Proof of registration in the general business register and of 

VAT registration (both in Luxembourg) 

1  Proof of registration in the general business register of Malta
2  Engineering: proof of registration in the home country, 
shareholders and at least one manager in accountancy: 
extract from social security records or equivalent 
2  Proof of chamber membership of the firm in the home 

country, general business registration certificate, for 
shareholders: membership card with the stamp of the 
current year 

0  Architecture and engineering, general business registration: 

multiple standard documents and certificates 

0  Architecture and engineering: no prior authorization, 

accountancy: only an insurance policy which is covered later 

CZ 

DE 

ES 

FR 

LU 

MT 
PT 

RO 

SK 

UK 

2 

2 

0 

0 

2 

1 
0 

0 

2 

0 

2

2

2

0

2

1
1

0

2

0

Legend: 0 = no formalities, 1 = simple (1 hour), 2 = medium (3 hours). 

116 I May 2017 

Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

For  temporary  services,  supporting  documents  issued  by  authorities  are  demanded 
only  in  Germany  to  carry  the  voluntary  title  of  “architect”  or  “engineer”  in  the 
company name. 

In  addition,  the  specific  document  requirements  for  the  establishment  of  branches 
mentioned in Section 6.3 are recapitulated here: 

•  France, architecture and accountancy: proof of address (six hours); 
•  Luxembourg (architecture and engineering), Romania (accountancy) and Spain 
(voluntary architecture and engineering partnerships): inclusion of specific 
statements or data in company statutes (20 hours). 

The  above  does  not  include  costs  of  collecting  internal  company  documents. 
Requirements  in  relation  to  these  internal  documents  might  be  numerous  (as 
explained  in  chapter  5),  further  increasing  administrative  costs.  For  simplification 
purposes, these additional costs are however not considered here.  

7.4  Collecting data/information on shareholders and managers 

Proving  compliance  with  requirements  regarding  shareholders,  partners  and/or 
managers is often required for establishing a branch. How long this takes depends on 
the information to be provided and on whether the information must be included in the 
company  statutes.  Costs  can  increase  rapidly  with  these  requirements.  For  example, 
information often needs to be provided for all shareholders. 

Information  on  these  requirements  follows  directly  from  forms  and  documents  that 
must be submitted (Table 7.3). The four categories identified in Section 6.4 are:  

•  Simple: Providing ID data (such as name, address, registration number, 

passport number and/or specialization); 

•  Medium: providing in addition (certified) data for each shareholders on the 

number / value of their shares and/or voting rights; 

•  Complex: in addition the company statutes must include the shareholder data; 
•  Very complex: Providing data on, or proving, in addition positions that partners 

hold in other firms. 

Table 7.3 Complexity of collecting shareholder/manager data, branches 

MS  Arch. 
3 
AT 
3 
BE 
1 
CY 
1 
CZ 
3 
DE 
0 
DK 

Eng.
3
0
1
1
3
0

ES 
FR 
IE 

IT 

2 
4 
2 

2 

2
0
0

2

Acc.  Rationale 

1  Follows from forms / documents to be submitted 
4  Follows from forms / documents to be submitted 
0  Follows from forms / documents to be submitted 
0  General business registration: selected works 
0  Only to carry the voluntary title in the company name 
0  For structural engineering no shareholding or management 

requirements, other professions covered by this study not 
regulated 

0  Only for voluntary professional partnerships 
4  Follows from forms / documents to be submitted 
0  Only to carry the voluntary title “architect” in the company 
name. Accountancy: no authorization procedure for 50% 
principals requirement for firms using chartered status 
2  Only for voluntary professional partnerships, for other legal 
forms only simple data are needed (category 1 simple) 

May 2017 I 117 

 
 
 
MS  Arch. 
2 
LU 
1 
MT 

Eng.
2
1

PL 
PT 
RO 
SK 

UK 

0 
2 
0 
0 

0 

0
2
0
0

0

Acc.  Rationale 

2  Follows from forms / documents to be submitted 
4  For architecture and engineering: only for voluntary 

professional partnerships. For accountancy: for all service 
providers 

0  No shareholding / management requirements 
2  Only for voluntary professional partnerships 
3  Follows from forms / documents to be submitted 
0  This is not checked by the professional chamber but by the 
office for the general business register and hence out of 
scope 

1  Architecture and engineering: only monitoring ex post or 

after receiving complaints. Accountancy: only to carry the 
voluntary title “chartered accountant” in the company name 

Legend: 0 = no formalities, 1 = simple (3 hours), 2 = medium (10 hours), 3 = complex (20 hours), 4 = 
very complex (34 hours). 

For temporary services, information on shareholders or managers is rarely required, 
and if it is the required information is the same as for branches: 

• 

• 
• 
• 

In Germany to carry the voluntary title ‘architect’ or ‘engineer’ in the company 
name; 
In Ireland to carry the voluntary title ‘architect’ in the company name; 
In Malta for accountancy; 
In the United Kingdom to carry the voluntary title ‘chartered accountant’ in the 
company name. 

7.5  Completing forms  

Apart from shareholder data, completing forms is generally reported to cost only one 
or  two  hours.  Some  forms  have  checkboxes  for  certificates  to  be  included  with  the 
application,  but  time  to  collect  those  certificates  is  classified  separately  (see  Section 
7.3  above).  Some  forms  have  tables  for  certain  data  specifically  related  to  the 
shareholding  structure  of  the  company  to  be  filled  in,  and  this  is  also  classified 
separately (see Section 7.4 above). 

Occasionally,  non-standard  information  is  required,  which  takes  time  to  research. 
Some  countries  require  that  multiple  forms  be  completed.  The  overall  cost  of 
establishing  a  branch  can  increase  considerably  if  all  shareholders  are  required  to 
complete several forms (Table 7.4). 

Table 7.4 Complexity of completing forms, branches 

MS  Arch. 
2 
AT 

Eng.
2

BE 
CY 

1 
3 

CZ 

1 

118 I May 2017 

0
3

1

Acc.  Rationale 

1  Architecture and engineering: each shareholder and the 

executive manager need to complete multiple forms, each 
with a number of checkboxes for certificates to be included. 
Reported hours both in the category simple and complex. 
Hence classified as medium. For accountancy only company 
ID data needs to be filled in 

1  Only company data needs to be filled in 
0  Shareholders must submit a lot of data including start and 

end dates of previous work experience, start and end dates 
of educational qualifications with specializations, and 
specifics of internship in Cyprus 

0  There are many requirements for registration with the 

 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

MS  Arch. 

Eng.

Acc.  Rationale 

DE 

DK 

ES 

1 

0 

1 

FR 

1 

IE 

IT 

LU 

MT 

PL 
PT 

RO 

SK 

UK 

2 

3 

1 

1 

0 
2 

0 

0 

0 

1

0

2

0

0

3

1

1

0
1

0

0

0

general business register, but the professional chamber only 
requires name and address of the firm in the Czech Republic 
0  To carry a voluntary professional title in the company name: 
ID data and the address of the firm. Reported hours: 2 
0  For structural engineering no company data need to be 

provided, other professions covered by this study are not 
regulated in Denmark 

0  Architecture: only address and bank details, engineering: 
also floor space and geographical location of the office in 
Spain need to be provided for registration in the Industrial 
Register (Madrid)  

3  Architecture: a written statement of the intention to provide 

a service in France, accountancy: associates need to 
complete many forms, including the function in the new 
establishment and a statement of the spouse (if married 
under the regime of community). Reported hours: 34  
0  To carry the voluntary title “architect” in the company 

name: data on all premises of the firm in Ireland, details on 
the company structure  

3  Multiple forms need to be filled in, the registration form 

needs to be duly stamped, and data to be provided in more 
detail than required in other countries. Reported hours: up 
to 40 

1  An application form with operational address in Luxembourg 

(branches) or with description of the project and the name 
of the client (temporary services) must be filled in. 
1  For the general business register where the firm must 

register first, more data and documents are needed than for 
registration with the professional chamber, but this is 
beyond the scope of this study. For shareholders of 
voluntary partnerships only ID data are required  
0  Only forms for professionals providing the service 
1  For architecture shareholders must provide a list of previous 

employers with start and end dates 

3  For accountancy, a form must be completed with ID data on 

company, executive management, employed staff, 
registered capital and the management council. Reported at 
20 hours  

0  Forms are not needed for the professional chamber but for 

the office for the general business register and hence out of 
scope 

0  Only forms for professionals providing the service 

Legend: 0 = no formalities, 1 = simple (1 hours), 2 = medium (9 hours), 3 = complex (30 hours). 

The  forms  that  need  to  be  filled  in  for  temporary  services  require  only  standard  ID 
data and ID/registration numbers.  

7.6  Certain formalities related to liability insurance  

The main administrative formality relating to professional indemnity insurance is the 
submission of an insurance policy or an attestation of the insurance provider, which 
are discussed in the next section. This section mainly builds on specific costs that were 
reported in the interviews. Because there are few other requirements, they are 
summarized in bullet points rather than in a table: 

May 2017 I 119 

 
•  Austria, architecture and engineering, to establish a branch: the combination of 
a 10-year professional liability and a 30-year civil liability make insurance de 
facto mandatory and difficult to compare insurance policies (complex, reported 
to cost 30 hours); 

•  Austria, accountancy: a requirement to use an insurer that is active in Austria 
is an important barrier. However from an administrative point of view this is a 
simple insurance with a low minimum amount to be covered (simple: two 
hours); 

•  Belgium, accountancy (both branches and temporary services): a collective 

insurance can be concluded via the chamber, or a copy of insurance certificates 
for each natural person providing services in Belgium (and not covered by the 
collective insurance) must be submitted. Insurance of the firm is not accepted 
(medium: six hours); 

•  Germany, architecture and engineering, to carry a voluntary professional title 

in the company name (both branches and temporary services): getting 
insurance of a firm instead of professionals accepted was reported to costs time 
(medium: 6 hours); 

•  Spain, architecture and all engineering, to establish a branch: some regional 
chambers require proof of a civil liability insurance. Given that civil liability in 
Spain goes beyond that of most other EU countries, it is assumed that this 
must be arranged separately, however it is a simple insurance and weighted 
with 50% because not all regional chamber require this (simple: two hours); 

•  United Kingdom, accountancy (both branches and temporary services): the 
wording of the insurance policy is prescribed and the chamber needs to be 
consulted before a different wording is used (medium: six hours). 

7.7  Translation and certification of documents 

Translation  costs  are  assumed  to  be  incurred  for  each  document  for  which  not  all 
languages  are  accepted,  except  if  English  and  another  non-national  language  are 
accepted and no certified translation is required. Cyprus and Germany accept English 
and  another  non-national  language  (for  architectural  and  engineering  services) 
including  French,  Greek  and  Turkish.  However,  if  documents  are  not  in  one  of  those 
languages,  a  certified  translation  is  required.  Hence,  translation  costs  of  required 
documents  were  in  the  end  included  in  full  for  all  countries  including  Cyprus  and 
Germany.  

Hence,  in  practice  translation  costs  are  included  for  all  countries  and  vary  between 
countries depending on the number of documents involved, regardless of the language 
of  origin  of  the  documents.  This  reflects  the  fact  that  no  country  accepts  documents 
in,  for  example,  Bulgarian,  Lithuanian,  Portuguese  or  Romanian  as  a  non-native 
language.  

Applicability of translation and certification requirements is documented in Annex 4 in 
the following rows: 

•  Finding any certified translator (one hour if yes); 
•  Finding a certified translator from the host country (nine hours if yes); 
•  Company statutes need to be submitted (EUR 600 if yes); 
•  An insurance policy needs to be submitted (EUR 400 if yes); 
•  Other certificates need to be submitted (EUR 100 each if yes); 
•  Translation certification is required (EUR 50 if yes); 
•  The translation must be sworn before a court in the host country or in an 

embassy of the host country (EUR 350 if yes); 

•  Certification of documents (EUR 150 if yes). 

120 I May 2017 

 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

7.8  Changes to legal form and/or reallocating shares or voting rights 

Various  countries  refer  to  national  legal  forms.  This  might  not  necessarily  prohibit 
firms from other countries to establish a branch. Only in Austria (for architecture and 
engineering)  is  this  the  case  (confirmed  by  both  the  chambers  and  by  service 
providers).  Here,  foreign  firms  are  required  to  set  up  a  subsidiary  for  permanent 
establishment  (branches  are  not  allowed),  with  specific  costs  that  are  discussed  in  a 
later section.  

In some countries, major groups of legal forms are excluded, for one sector:  

• 

• 

in France, a firm with any legal form that grants its associates trader status 
may not establish an accountancy branch, this excludes for example 
professional partnerships; 
in the United Kingdom, limited liability companies may not carry the voluntary 
title “chartered engineer” in the company name. 

Interviews  with  service  providers  in  engineering  and  architecture  reported  costs  of 
legal form changes at 20, 22, 24, 31 and 50 hours for four countries with clearly less 
restrictive legal form limitations:  

•  Germany, where (in Nordrhein-Westfalen) the law refers to national legal forms 
for specific shareholding requirements to carry the professional title “engineer” 
or “architect” in the company name; 

•  Luxembourg, where companies with bearer or endorseable shares are not 

• 

allowed; 
Italy and Spain: different requirements exist for professional partnerships and 
different forms must be filled in depending on the legal form. All legal forms 
are allowed although the requirement that shares must be nominative is likely 
to create difficulties for anonymous companies.  

For  France  (accountancy)  and  the  United  Kingdom  (for  an  assumed  50  per  cent  of 
engineering  firms  that  wish  to  carry  voluntary  “chartered  engineer”  title  in  the 
company name) the full average 30 hours are allocated to legal form changes.  

For Germany, Italy and Luxembourg and Spain it is assumed that legal form changes 
are  only caused by the  requirement that shares must be nominative (or the majority 
of  shares  in  the  case  of  Germany),  as  well  as  in  other  countries  with  shareholding 
requirements. Since legal form changes are reported in only three out of 26 interviews 
with  firms  that  had  a  permanent  establishment  (and  four  in  52  in  total  including 
temporary services), it is assumed that such requirements cause a problem for one in 
ten  firms,  and  hence  three  hours  are  allocated  to  the  risk  of  legal  form  changes 
whenever  shareholding  requirements  exist.  When  voting  rights  requirements  exist 
instead of shareholding requirements, this is not assumed to necessitate a legal form 
change.  

Lastly,  with  regard  to  Spain,  it  was  mentioned  that  different  procedures  apply  to 
different  legal  forms,  and  that  it  was  not  clear  what  legal  form  in  the  host  country 
corresponds  to  what  legal  form  in  the  home  country,  reported  to  cost  five  hours.  In 
Poland  this  difficulty  was  mentioned  for  the  general  business  register  (beyond  the 
scope of this study) at ten hours. Because this is specifically the case in Spain where 
both  the  general  business  register  and  the  professional  chamber  have  different 
procedures for various legal forms that are not aligned, and because this issue is only 
reported  for  Spain,  this  is  assumed  as  a  particular  issue  for  that  country  alone.  This 
comes  on  top  of  the  three  hours  for  the  implicit  nominative  shares  restriction  to 
establish a branch in architecture or engineering and hence (also in line with the Polish 
out-of-scope case) a total hours of eight hours is assumed for Spain.  

May 2017 I 121 

 
 
For  other  legal  form  requirements  such  as  the  Belgian  requirement  to  use  a 
partnership or so-called “Laruelle” legal form for firms with other legal forms, no costs 
have been reported. Hence it is not sure if or how often these legal form requirements 
would  result  in  administrative  formalities,  and  if  so  what  those  administrative 
formalities  and  options  to  comply  with  them  would  be.  Hence  no  costs  of 
administrative formalities are allocated to other legal form restrictions.  

Table 7.5 Complexity of legal form requirements, branches 

MS  Arch. 
0 
AT 

Eng.
0

BE 

1 

CY 

CZ 

DE 

DK 

ES 

FR 

1 

0 

1 

0 

2 

1 

IE 

0 

0

1

0

1

0

2

0

0

Acc.  Rationale 

0  The legal form requirements in Austria are prohibitive for 

architecture and engineering and covered under 
requirements for subsidiaries discussed in a later section. 
For accountancy no legal form requirements apply 

0  A shareholder register must be submitted for architecture 

which may create difficulties for anonymous companies. For 
accountancy, voting rights requirements are in place instead 
of shareholding requirements 

0  Shareholders must be reported by name which may create 

difficulties for anonymous companies 

0  Allowance of legal forms is not restricted by professional 
regulations, and general business regulations are beyond 
the scope of this study 

0  To carry a voluntary professional title in the company name, 
the majority of shares must be nominative which might 
create difficulties for anonymous companies 

0  For structural engineering no legal form restrictions apply, 

other professions covered by this study are not regulated in 
Denmark 

0  Shares must be nominative, in addition the different options 

for various legal forms (both for the general business 
register and for the professional chamber are not clear) 
3  Architecture: shareholders must be reported by name which 

may create difficulties for anonymous companies. 
Accountancy: legal forms that grant the “trader” status to 
associates are excluded 

0  To carry the voluntary title “architect” in the company name 
no shareholding requirements apply, only that the company 
is controlled by a head architect. For accountancy, voting 
rights requirements are in place instead of shareholding 
requirements 

IT 

0 

0

0  For voluntary professional partnerships shares must be 

nominative, but that is implied by the legal form. No other 
requirement of professional chambers that may necessitate 
a change of legal form was identified, and requirements of 
the general business register are beyond the scope of this 
study 

1  Accountancy: firms with bearer or endorseable shares are 

not allowed 

0  For voluntary professional partnerships in architecture and 

engineering, shares must be nominative, but that is implied 
by the legal form. For accountancy, voting rights 
requirements are in place instead of shareholding 
requirements 

0  Requirements apply only to professional providing the 

service, not to legal persons 

0  For voluntary professional partnerships shares must be 

LU 

MT 

PL 

PT 

0 

0 

0 

0 

0

0

0

0

122 I May 2017 

Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

MS  Arch. 

Eng.

Acc.  Rationale 

RO 

SK 

UK 

0 

0 

0 

0

0

3

nominative, but that is implied by the legal form 

1  Shareholders must be reported by name which may create 

difficulties for anonymous companies 

0  Allowance of legal forms is not restricted by professional 
regulations, and general business regulations are beyond 
the scope of this study 

0  To carry the voluntary title “architect” in the company name 
no shareholding requirements apply, only that the company 
is controlled by a head architect. Limited liability companies 
cannot use the title “chartered civil engineer” or “chartered 
mechanical engineer” in the company name. For 
accountancy voting rights requirements are in place instead 
of shareholding requirements 

Legend: 0 = no formalities, 1 = nominative shares nominative (3 hours), 2 = unclear differences between 
legal forms (8 hours), 3 = major groups of legal forms not allowed (30 hours). 

For  temporary  services,  legal  form  restrictions  apply  only  in  Germany  to  carry  the 
voluntary title of “architect” or “engineer” in the company name, and are the same as 
for branches. 

For  shareholding  requirements,  the  complexity  is  determined  straightforwardly  from 
Tables 3.2, 4.2 and 5.2. As discussed in Section 6.8, if more than 51 per cent of the 
shares or voting rights must be in the hand of professionals regardless of legal form, 
the  chances  that  shares  or  voting  rights  must  be  reallocated  /  renegotiated  is 
classified  as  high-frequent.  If  requirements  only  apply  to  voluntary  professional 
partnerships and 50 or 51 per cent of the shares or voting rights must be in the hands 
of  professionals,  this  is  classified  as  rare.  All  other  majority  shareholding  or  voting 
rights  requirements  are  classified  as  low-frequent.  As  discussed  in  Section  6.8,  no 
costs have been allocated to management requirements for simplification purposes.  

Table 7.6 Complexity of shareholding/voting rights requirements, branches 

MS  Arch. 
2 
AT 
3 
BE 

Eng.
2
0

CY 
CZ 

DE 

DK 
ES 
FR 

IE 

IT 

LU 

3 
2 

2 

0 
2 
2 

0 

2 

3 

3
2

2

0
2
0

0

2

3

Acc.  Rationale 

0  51% of the shares
2  Architecture: 60% of the shares and voting rights, 

accountancy: 50% of the voting rights  
0  All shareholders must be professionals 
0  All partners of a voluntary professional partnership must be 

professionals 

0  To carry the voluntary professional title in the company 

name, 50% of the shares and voting rights  
0  No shareholding/voting rights requirements 
0  51% of the shares and voting rights 
3  Architecture: 51% of the shares and voting rights, 

accountancy: 2/3 of the voting rights  

2  Architecture: that the firm must be controlled by a head 

architects is considered to be a management requirement 
(similar as in Austria). Accountancy: 50% of the voting 
rights to carry the voluntary “chartered accountant” in the 
company name 

2  Voluntary professional partnerships: 2/3 of the shares and 

voting rights 

2  Architecture and engineering, legal proposal: 75% of the 
shares and voting rights, accountancy: 51% of the voting 
rights 

May 2017 I 123 

 
MS  Arch. 
2 
MT 

Eng.
2

PL 
PT 
RO 
SK 

UK 

0 
1 
0 
1 

0 

0
1
0
1

3

Acc.  Rationale 

2  Architecture and engineering: all partners of voluntary 

professional partnerships must be professionals. 
Accountancy: 51% of the voting rights, that 61% of the 
management positions must be in the hand of professionals 
is not reported to require a change of management 

0  No shareholding/voting rights requirements 
1  Voluntary professional partnerships: 51% of the shares 
2  Accountancy: 51% of the shares and voting rights 
0  Architecture and engineering: a majority of shareholders of 
voluntary professional partnerships must be professionals 

2  Architecture: that the firm must be controlled by a head 

architects is considered to be a management requirement 
(similar as in Austria). To carry the voluntary title 
“chartered civil engineer” or “chartered mechanical 
engineer” in the company name, all partners must be 
professionals (even though this is only controlled ex post). 
Accountancy: 50% of the voting rights to carry the 
voluntary “chartered accountant” in the company name 

Legend: 0 = no formalities, 1 = rare (1 hour), 2 = low-frequent (5 hours), 3 = high-frequent (27 hours). 

For  temporary  services,  shareholding  and  voting  rights  requirements  exist  in  a  few 
countries for a few sectors: 

•  Germany, architecture and engineering: to carry the voluntary professional title 

• 

in the company name (same as for branches); 
Ireland and the United Kingdom, accountancy: to carry the voluntary title 
“chartered accountant” in the company name (same as for branches); 

•  Malta, accountancy (same as for branches). 

7.9  Examination and/or language skills 

If  a  shareholder  or  manager  needs  to  take  an  examination  regardless  of  whether 
he/she  provides  services  in  the  host  country,  this  is  a  clear  example  of  an 
administrative  formality.  However,  it  is  less  straightforward  to  link  this  to  a 
requirements if an examination in the host country “may” be required. In such cases, 
whether costs are allocated to such a requirement depends on the formulation of the 
requirement.  

If  shareholders  are  examined  to  assess  their  ability  to  manage  a  business  because 
they do not hold the corresponding diploma of the host country, it is judged to be an 
administrative  formality  and  the  same  applies  to  compulsory  examination  of  skills 
related  to  the  profession  even  if  the  manager  or  shareholder  does  not  provide  the 
services  and  is  qualified  in  the  home  country.  In  the  case  of  examination  in  skills 
related  to  the  profession,  an  average  of  65  hours  is  reported;  in  the  case  of 
examination in other skills 150 to 200 hours is reported (and 150 is usually regarded 
as sufficient).  

Examinations  for  shareholders  or  managers  are  required  in  only  a  handful  of 
countries: 

•  Austria, permanent establishment in architecture or engineering: the executive 

manager must take an exam in Austrian tax law (150 hours); 

•  Austria, accountancy branches: the manager of the company needs to pass 

exams in Austrian relevant for the entire bandwidth of accountancy services of 
the company even if not all services would be provided in Austria (65 hours); 

124 I May 2017 

 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

•  Belgium, accountancy branches: the Chamber can decide to interview legal 

• 

representatives at a date and hour determined by the Chamber. The fact that 
this information is only available in the local language is an indication that this 
interview is likely not be in the English language (65 hours); 
Ireland, architecture branches and temporary services: to carry the voluntary 
title “architect” in the company name, RIAI may request any other data to 
assess qualifications and may request an interview (with professionals, 
including the head architect) (65 hours); 

•  Malta, architecture and engineering branches: the Board may subject 

professionals (including partners) to additional tests as is deemed necessary 
(65 hours); 

•  Romania, accountancy branches: in order for a foreign citizen to acquire the 

right to exercise the accounting profession on Romanian territory (also required 
of shareholders), it is necessary to register him or her for the interview related 
to the recognition of the accounting profession title. The aim of the interview is 
to review the understanding of Romanian current laws, in the field of company 
organization and functioning, in the accounting and financial field (65 hours); 

•  Slovakia, architecture branches: a majority of shareholders of a voluntary 

professional partnership needs to be an authorized professional and 
professionals must do an exam on architecture in Slovakia for authorization. 

Language skills may be explicitly required to meet requirements, or implicitly to do an 
examination in the host country (80 hours). As a simplification, the possibility of doing 
an  examination  in  English  is  assumed  to  not  generate  administrative  efforts  even 
though  not  all  service  providers  will  be  able  to  communicate  in  English.  Also, 
understanding information that is not available in the English language is reported to 
cost an additional ten hours.  

Table 7.7 Complexity of language skills requirements, branches 

MS  Arch. 
2 
AT 

Eng.
2

BE 

1 

0

CY 

CZ 
DE 

DK 

ES 

FR 

IE 
IT 

2 

1 
1 

0 

1 

0 

0 
1 

2

1
1

0

1

0

0
1

Acc.  Rationale 

2  The executive manager must do an exam in the German 

language 

2  Architecture: much information on the website is available 
in the English language but some important pieces of 
information only in the Dutch or French language. 
Accountancy: implicitly required legal representatives of the 
firms to do an interview 

0  Shareholders must prove sufficient knowledge of the Greek 

language 

0  Little information is available in the English language 
0  Little or no practical information available in the English 
language on the website of the professional chambers 

0  For structural engineering, knowledge of the Danish 

language is only required for professional providing the 
service (beyond the scope of this study). The other 
professions of this study are not regulated 

0  No information on the website of the professional chambers 

is available in the English language 

0  Much practical information about admission procedures 
available on the Point of Single Contact website with 
machine translations, though not on the websites of the 
professional chambers (but in development for architecture) 

0  By default 0 (because English is the native language). 
1  The Point of Single Contact has general information in 

English, and it was also noted that the Order of Architects in 
Milan has practical information in English. However most 

May 2017 I 125 

 
MS  Arch. 

Eng.

Acc.  Rationale 

LU 

MT 

PL 

PT 
RO 

SK 

UK 

0 

0 

0 

1 
0 

2 

0 

0

0

0

1
0

0

0

websites of regional chambers have no information in 
English 

0  No language or examination requirements and all practical 

information is available in English 

0  Additional tests (for architecture and engineering) are in 

Maltese or English  

0  Requirements only apply to professionals providing the 

services 

1  No practical information is available in English 
2  An interview about current Romanian law suggests that it 

will be held in the Romanian language only 

0  Architecture: a majority of shareholders of voluntary 

professional partnerships must do an exam in the Slovak 
language 

0  By default 0 (because English is the native language). 

Legend: 0 = no formalities, 1 = simple (10 hours), 2 = complex (80 hours). 

For  temporary  services,  no  language  skills  are  required  either  explicitly  or  implicitly 
because of an examination. However some language difficulties may still exist due to 
non-availability  of  information  in  the  English  language.  Given  that,  in  addition, 
requirements apply only to professionals providing the services in many countries (and 
their administrative formalities are beyond the scope of this study), the language skills 
requirements for temporary services are summarized in a table as well (Table 7.8). 

Table 7.8 Complexity of language skills requirements, temporary services 

MS  Arch. 
0 
AT 
0 
BE 
1 
CY 
1 
CZ 

Eng.
0
0
1
1

DE 

DK 

ES 

FR 

IE 
IT 
LU 
MT 
PL 
PT 
RO 
SK 

UK 

1 

0 

1 

0 

0 
0 
0 
0 
0 
0 
0 
0 

0 

1

0

1

0

0
0
0
0
0
0
0
0

0

Acc.  Rationale 

0  No access formalities for temporary services 
0  Requirements only for professionals providing the services
0  Application forms in Greek only
0  Requirements for professionals providing the services only 

but little information is available in English on the website of 
the chamber a) 

0  Little or no practical information available in the English 
language on the website of the professional chambers 

0  For structural engineering, knowledge of the Danish 

language is only required for professional providing the 
service (beyond the scope of this study). The other 
professions of this study are not regulated 

0  No information on the website of the professional chambers 

is available in the English language 

0  Much practical information about admission procedures 
available on the Point of Single Contact website with 
machine translations, though not on the websites of the 
professional chambers (but in development for architecture) 

0  Requirements for professionals providing the services only
0  Requirements for professionals providing the services only
0  All practical information is available in English 
0  Requirements for professionals providing the services only
0  Requirements for professionals providing the services only
0  Requirements for professionals providing the services only
0  Requirements for professionals providing the services only
0  Requirements only apply to professionals providing the 

services 
0  By default 0.

Legend: 0 = no formalities, 1 = simple (10 hours), 2 = complex (80 hours). 

126 I May 2017 

Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

a)  Even though no authorization formalities only apply to natural persons instead of legal persons to 
provide architecture or engineering services in the Czech Republic, this is difficult to find out due to 
insurance  requirements  and  options,  guest  requirements  for  temporary  cross-border  services  and 
difficulties  to  find  out  what  applies  to  professionals,  professional  partnerships  and  other  legal 
forms. 

7.10 Collecting / submitting documents 

If  specific  requirements  exist  regarding  the  collection  or  submission  of  documents, 
they are usually unambiguous: documents must be posted or they must be submitted 
in  person.  For  those  countries  where  documents  can  be  emailed,  no  costs  of 
submitting documents have been reported.  

In those countries where full electronic case handling is possible besides the option to 
submit  documents  by  post,  this  is  mostly  only  available  to  national  citizens 
(architecture in Belgium, Malta for all services covered, and in Italy depending on the 
region).  In  Cyprus,  full  electronic  case  handling  is  available  but  the  link  was  out  of 
order  during  the  study,  and  the  posting  of  documents  to  the  provided  address  is  the 
assumed option.  

If documents can be emailed, this is the assumed delivery mode even if other options 
are  available  because  it  is  the  alternative  with  the  lowest  cost.  For  example  in 
Romania  documents  can  be  emailed,  uploaded  or  delivered  in  person  to  establish  an 
accountancy branch. No submission costs are allocated in this example because none 
are reported for emailing documents.  

Italy is one exception where higher costs are allocated to the submission of documents 
than  follows  from  the  formal  requirements.  No  requirement  to  submit  documents  in 
person were identified for the reference region in this country (Milan) but three out of 
four  respondents  did  deliver  documents  in  person,  perhaps  in  regions  other  than 
Milan.  

In Luxembourg, documents must be posted, but one of the required documents must 
be  collected  in  person  (the  VAT  registration  form),  and  hence  for  this  country  both 
costs  for  collecting  documents  in  person  and  costs  for  delivering  documents  by  post 
are included.  

Table  7.9  gives  an  overview  of  the  complexity  of  collecting  and/or  submitting 
documents. 

Table 7.9 Complexity of collecting / submitting documents, branches 

MS  Arch.  Eng.
1
AT 

1 

BE 

CY 

CZ 
DE 
DK 

ES 
FR 
IE 

1 

1 

1 
1 
0 

2 
1 
0 

0

1

1
1
0

2
0
0

Acc.  Rationale 

0  Architecture and engineering: documents must be posted, 

accountancy: documents can be emailed 

0  Architecture: documents must be posted, accountancy: 

documents can be emailed 

0  Documents must be posted (full electronic case handling is 
available but the link did not work at the time of the study) 

0  Documents must be posted
0  Documents must be posted
0  Structural engineering: requirements only apply to 

professionals providing the services, other professions covered: 
not regulated 

0  Documents must be submitted in person
1  Documents must be posted
0  Requirements only for professionals providing the services (out 

of scope) 

May 2017 I 127 

 
MS  Arch.  Eng.
3
IT 

3 

Acc.  Rationale 

3  Documents must be posted. There is no formal requirement to 

submit documents in person but 3 out of 4 respondents for Italy 
did so.  

LU 

3 

3

3  Documents must be posted (although further case handling is 

MT 

PL 

PT 
RO 

1 

0 

0 
0 

1

0

0
0

SK 

0 

0

electronic), in addition a VAT registration form must be 
collected in person (also reported by 3 out of 4 respondents for 
Luxembourg) 

0  Architecture and engineering: documents must be posted, 

accountancy: documents can be emailed 

0  Requirements only for professionals providing the services (out 

of scope) 

0  Documents can be emailed
0  Architecture and engineering: requirements only for 

professionals providing the services (out of scope). 
Accountancy: submission in person, by email or via full 
electronic case handling 

0  Architecture: submission requirements for legal persons only for 
the general business register, for the majority of shareholders 
of a voluntary professional partnership the submission demands 
only apply to professional qualifications (both out of scope) 

UK 

0 

0

1  Architecture and engineering: only control ex post. 

Accountancy: documents must be posted. 

Legend: 0 = no formalities, 1 = posting documents (0.5 hours + EUR 20), 2 = collecting or submitting 
documents in person (12 hours + EUR 250), 3 = both (12.5 hours + EUR 270). 

For  temporary  services,  there  is  no  need  to  collect  documents  anywhere,  as  is  the 
case  for  branches  in  Luxembourg.  For  the  submission  of  documents,  the  required 
delivery mode is generally the same as for branches, except in four countries: Austria, 
Italy,  Luxembourg  and  Malta.  In  these  four  countries,  no  costs  are  included  for  the 
submission  of  documents  or  data  for  temporary  services  because  legal  persons  in 
those countries do not need authorization to provide temporary cross-border services. 
In  Austria,  documents  need  to  be  submitted  to  the  customer  but  this  is  excluded 
because it is not an access formality. In Italy, Luxembourg and Malta documents only 
need  to  be  submitted  for  professionals  providing  the  services,  which  also  is  out  of 
scope of this study.  

7.11 Paying registration or membership fees  

For  gaining  access  to  the  market,  firms  may  have  to  pay  registration  and/or 
compulsory  membership  fees.  The  fees  themselves  vary  by  country  and  sector  and 
have been covered in Sections 3.6, 4.6 and 5.6. Paying membership fees is an activity 
that  for  most  country  takes  little  time,  with  a few  exceptions  as  discussed  in  Section 
6.11.  

Table  7.10  summarizes  the  information  of  Section  6.11.  It  is  the  one  requirement 
where the classification of complexity in individual countries and sectors also depends 
on  the  interview  responses  instead  of  the  requirements  alone.  Between  18  and  28 
hours were reported more than once for France and Luxembourg, and hence payment 
in  those  countries  are  regarded  as  very  complex  –  for  France  this  is  related  to  the 
requirement to arrange payment by cheque and for Luxembourg it relates to a lack of 
information on the chamber website about the amount to be paid and how to arrange 
it.  

128 I May 2017 

 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

Some extra time to make a payment was also reported for Portugal and Spain by one 
service  provider.  This  could  not  be  linked  to  specific  payment  requirements  and  the 
allocation of four hours in these cases is entirely based on interview responses. 

Table 7.10 Complexity of paying registration or membership fees, branches 

MS  Arch.  Eng.
1
AT 
0
BE 

1 
1 

Acc.  Rationale 

1  Fee required, no difficulties reported
1  Fee required, no difficulties reported (engineering: not 

CY 

CZ 

DE 

DK 

ES 

FR 

IE 
IT 
LU 

MT 
PL 

PT 

RO 

SK 

UK 

1 

1 

1 

0 

2 

3 

1 
0 
3 

0 
0 

2 

1 

1 

1 

1

1

1

0

2

0

0
0
3

0
0

2

0

1

1

regulated) 

0  Fee required, no difficulties reported (accountancy: not 

regulated) 

0  Fee required, no difficulties reported (accountancy: not 

regulated) 

0  Fee required, no difficulties reported (accountancy: not 

regulated) 

0  Structural engineering: requirements only apply to 

professionals providing the services, other professions covered: 
not regulated 

0  One of three respondents reported time to make the payment: 

10 hours (accountancy: not regulated) 

3  Architecture: 20 hours reported 2x, proof of payment must be 
posted, engineering: not regulated, accountancy: payable 
check must be posted 

0  Architecture: fee required, no difficulties reported 
0  Fee required, no difficulties reported 
3  18 - 28 hours were reported for paying registration fees. 

Information about the amount of the fee could not be found on 
the website of the professional chamber of any service covered 

0  Payable check required but no difficulties reported 
0  No fee required (not even for professionals providing the 

service) 

2  One of three respondents reported time to make the payment: 

3 hours 

1  Fee for professionals providing the services, no difficulties 

reported 

0  Fee for professionals providing the services, no difficulties 

reported 

1  Architecture and engineering: fee for professionals providing 
the services, accountancy: fee for partners of the firm, no 
difficulties reported 

Legend: 0 = no formalities, 1 = simple (0.5 hours), 2 = medium (4 hours), 3 = complex (20 hours). 

7.12 Recurrent costs 

For branches, registration and/or compulsory membership are in principle indefinite or 
conditional on annual payment of the fee. In these cases, most respondents report 
that no time is required to comply with formalities, while some report one hour. Given 
that invoices are usually paid in batches, the time involved is assumed to be absent in 
this case. 

Mostly for the above reasons, there are no recurrent costs in nine countries: the Czech 
Republic, Denmark,  Germany, Italy, Poland, Portugal, Slovakia, Spain and the United 
Kingdom (Table 7.11).  

May 2017 I 129 

 
In  Cyprus,  architecture  and  engineering  firms  need  to  submit  documents  every  year 
and in  France  architecture  firms  need  to  submit  a list  of  all  projects  entrusted  to  the 
firm every year, and these requirements are classified as having medium complexity. 

Specifically  in  Luxembourg,  legislation  requires  that  a  new  application  must  be 
undertaken  if  the  management  changes,  which  is  clearly  a  more  complex  formality. 
However,  because  management  is  assumed  to  change  only  once  after  ten  years,  its 
total impact on costs is less than that of the “medium” annual requirements in Cyprus 
and France.  

Lastly, a very complex requirement exists if new partners or managers need to do an 
exam,  as  is  required  in  Austria  (branches  in  all  services  covered),  Ireland  (head 
architect),  Malta  (branches  of  voluntary  professional  partnerships  in  architecture  and 
engineering)  and  Romania  (accountancy  branches).  For  Belgium,  the  information 
suggests that the representative of an accountancy firm establishing a branch may be 
invited for an interview regarding the first application only, and hence only annual fees 
are regarded as recurrent costs in this country.  

Table 7.11 Complexity of recurrent costs, branches 

MS  Arch.  Eng.
4
AT 

4 

Acc.  Rationale 

4  Examination of the executive manager required if management 

BE 
CY 
CZ 

DE 
DK 

ES 
FR 

IE 

IT 
LU 

MT 

PL 
PT 

RO 
SK 

UK 

1 
2 
1 

0 
0 

1 
2 

4 

1 
3 

4 

0 
1 

0 
4 

1 

0
2
1

0
0

1
0

0

1
3

4

0
1

0
0

1

changes 

1  Annual payments of fees
0  Documents need to be submitted every year 
0  Annual payment of the fee for managers (limited liability) or

partners (partnership) 

0  Membership is in principle indefinite
0  Structural engineering: requirements only apply to 

professionals providing the services, other professions covered: 
not regulated 

0  Annual payment of the fee for shareholders 
0  Architecture: annual submission of a list of projects entrusted 

to the firm and an insurance policy. Accountancy: membership 
is in principle indefinite 

0  Examination of the head architect required if management 
changes, to carry the voluntary professional title in the 
company name 

1  Annual payment of the fee
3  The whole application needs to be done again if management 

changes 

1  Architecture and engineering: examination of any new partners 

in a voluntary professional partnership 

0  No administrative requirements
0  Architecture and engineering: annual payment of the fee, 

accountancy: membership is in principle indefinite 
4  Accountancy: examination of any new shareholder 
0  Architecture: examination of a new shareholder of a voluntary 
professional partnership required if his authorization is needed 
for the majority requirement 

1  Annual payment of the fee for the head architect or at least 

one chartered professional 

Legend: 0 = no formalities, 1 = simple (0 hours), 2 = medium (4 hours), 3 = complex (12 hours), 4 = very 
complex (157 hours, or for architecture and engineering 242 hours if examination is in tax law). 

130 I May 2017 

 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

8  COSTS 

8.1  Approach 

Section  8.2  discusses  the  wage  rates  applied  to  the  staff  time  spent  on  formalities. 
Section  8.3  discusses  how  formalities  are  weighted  that  do  not  apply  to  all  firms. 
Section  8.4  discusses  the  calculated  costs  per  sector  and  Member  State  concerned. 
Section  8.5  makes  an  assessment  based  on  extrapolation  of  the  potential  total  costs 
involved with the identified administrative formalities.  

8.2  Wage rates of staff involved in administrative formalities 

The  wage  costs  of  staff  involved  in  administrative  formalities  are  usually  incurred  by 
staff  from  the  home  country,  although  some  cross-border  service  providers  recruit 
staff from the host country to complete administrative formalities. Therefore, the wage 
costs of the staff involved in administrative formalities was analysed per home country 
(and not per host country).  

In the survey conducted for this study, cross-border operating firms were asked about 
the  wage  rates  of  managers,  professionals  and  administrative  staff  involved  in  the 
administrative  formalities.  Roughly  half  of  the  firms  (28  out  of  52)  reported  the 
relevant  wage  rates.  This  implies  that  the  wage  rates  of  the  survey  are  not 
representative for the EU28, leave alone for individual countries.  

To  estimate  the  relevant  wage  rates,  the  wage  rates  were  compared  to  Eurostat 
statistics  and  a  weighted  average  was  used.  From  Eurostat,  statistics  are  available 
about  the  wage  rates  (gross  hourly  earning)  of  managers,  professionals  and  clerical 
support staff in the professional services industry (reference year: 2014). For Croatia 
and Greece, the latest available data are from 2010 which were multiplied with the EU 
wage  inflation  rates  of  the  relevant  professions  in  the  professional  services  industry. 
For  four  smaller  countries,  the  wage  rates  of  managers  was  not  available  for  the 
professional  services  industry  and  the  managers’  rates  of  the  whole  economy  was 
used:  Croatia,  Cyprus,  Estonia  and  Luxembourg,  and  for  Malta  the  administrative 
staff’s wage rates of the whole economy was used (first row of Table 8.1).  

The  professional  services  include  not  only  architecture,  engineering  and  accountancy 
services, but also legal, auditing and research activities. Also, the Eurostat figures are 
averages per employee in firms of ten employees or more. However, if firms in some 
countries employ a lot of administrative support staff, they were likely not all involved 
with cross-border access formalities. Hence, one member of staff from each category 
(managers,  professionals  and  administrative  staff)  was  assumed  to  be  involved  and 
the  wage  rates  of  countries  were  weighted  with  the  number  of  firms  in  architecture 
and engineering combined (second row of Table 8.1).11  

To  the  gross  hourly  earnings,  an  estimate  of  the  employer’s  social  security 
contributions  was  added.  The  estimates  were  based  on  OECD  rates  (reference  year: 
2015) calculated for people earning 167 per cent of the median wage (by assumption 
the  managers  and  professional)  and  for  people  earning  just  the  median  wage  (by 
assumption  administrative  staff).  The  OECD  rates  are  only  available  for  OECD 
countries.  For  the  non-OECD  countries  the  rates  of  geographically  close  OECD 

11   Pure  accountancy  firms  were  not  included  because  they  cannot  be  separately  identified  from  Eurostat 

statistics. 

May 2017 I 131 

 
                                                           
countries  were  used:  the  Czech  rates  for  Slovakia,  the  Estonian  rates  for  Latvia  and 
Lithuania,  the  Greek  rates  for  Cyprus,  the  Italian  rates  for  Malta,  and  the  Hungarian 
rates  for  Bulgaria  and  Romania.  The  EU  weighted  average  of  the  employer  social 
security  rates  is  23  per  cent,  resulting  in  a  mark-up  factor  of  1.23.  Multiplying  the 
gross hourly earnings with the employer social security mark-up gives an estimate of 
the labour costs per hour (third and fourth row of Table 8.1).  

Per  home  country,  the  wage  rates  reported  by  the  28  firms  in  this  study  were 
compared to the labour cost statistic. The difference between the two is an overhead 
mark-up. As a rule of the thumb the overhead mark-up is factor 2 and somewhat less 
for  managers.  For  the  overhead  mark-ups  for  home  countries  not  covered  by 
interviews  (mostly  smaller  countries)  those  of  geographically  close  countries  were 
used. The resulting overhead mark-ups vary from 0.92 to 4.35 and this range reflects 
the  spread  across  firms,  rather  than  the  spread  across  national  averages.  However, 
the EU28 weighted average mark-ups confirm the rule of the thumb (fifth row of Table 
8.1). 

Multiplying  the  labour  cost  rates  with  the  overhead  mark-ups  gives  the  staff  rates 
used  in  the  analysis  to  calculate  the  cost  of  administrative  formalities  (sixth  row  of 
Table  8.1).  These  are  lower  than  the  unweighted  average  reported  wage  rates 
(seventh and final row of Table 8.1 in italics). The higher unweighted average reflects 
that  most  interviewed  firms  originated  from  the  bigger  countries  in  the  west  of 
Europe, and are thus not representative for the EU28 as a whole.  

Table 8.1 Wage and staff rates in architecture and engineering (also assumed 
for accountancy) 

Staff category 
Managers Professionals 

Description 

EU28 hourly gross earnings 
professional services from Eurostat 
EU28 hourly gross earnings 
architecture and engineering 
Mark-up employer social security 
contributions from OECD 
EU28 hourly labour costs
Overhead mark-up from study survey
Used in analysis: staff rate per hour
Not used in analysis: unweighted 
average of survey 

A 

B 

C = A x B 
D 
E = C x D 

37.0

36.2

1.23

44.6
1.45
64.7
81.3

Admin. 
staff
14.5

23.8 

21.6 

13.0

1.23 

1.23

26.6 
1.96 
52.1 
57.4 

16.0
1.80
28.8
38.1

For all host countries the same EU28 average staff rate per hour was used (including 
overhead mark-up). The reason is that for all host countries, the cross-border service 
provider could in principle come from any of the other EU countries. Historically, most 
cross-border  service  providers  come  from  neighbouring  countries,  especially  if  the 
same language is spoken. Nevertheless, the costs that can be reduced by simplifying 
administrative  formalities  in  the  future  are  more  relevant  for  policy  making  than  the 
costs that were already sunk in the past. Therefore, this study uses a scenario that for 
all host countries, all cross-border service providers come from the same mix of home 
countries.  This  also  facilitates  comparison  of  similar  requirements  because  costs  of 
time spent on formalities are then not affected by differences in national wage rates.  

132 I May 2017 

 
 
 
 
 
 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

8.3  Weighting formalities that do not apply to all firms 

Depending  on  the  situation,  a  weight  ranging  from  zero  to  one  is  applied  to 
formalities. A  weight of one indicates that the  formality applies to all firms. A  weight 
between zero and one is used in the following situations: 

• 

• 

• 

• 

If a requirement applies only to carry a voluntary title in the company name, 
the costs are weighted with 0.5; 
If a requirement applies to limited liability companies but not to other legal 
forms, the costs are multiplied with an approximate share of 50 per cent 
among service providers covered by this study; 
If a requirement applies to partnerships but not to other legal forms, the costs 
are multiplied with an approximate share of 20 per cent among service 
providers covered by this study; 
In some countries there is a large regional variation in requirements to prove 
(professional and/or civil) liability insurance. To reflect that this requirements 
applies in some but not all regions of such a country, the costs of the formality 
to prove liability insurance is in this case weighted with 0.5.  

Annex 4 gives a full overview of not only the classification of formalities, but also the 
weights  that  have  been  applied.  The  remainder  of  this  section  describes  the  weights 
that are applied in situations where formalities do not apply to all firms.  

Rationale of weights of formalities that apply to specific legal forms only 

The assumptions that 50 per cent and 20 per cent of the firms providing the services 
covered by this study is a limited liability company and a partnership respectively, are 
based on Eurostat data (Business Demographics, 9 economic groups, legal form, NACE 
Revision  2).  Based  on  its  employer  data,  the  proportions  limited  liability  companies, 
sole  traders  and  partnerships  in  the  economic  group  “Professional,  scientific  and 
technical  activities”  are  calculated  to  be  respectively  64,  28  and  11  per  cent  in  the 
EU28.  However,  this  group  includes  not  only  the  services  covered  by  this  study  but 
also other services such as auditing, legal services and R&D. Because partnerships are 
more common among architects (covered by the study) and limited liabilities are more 
common  among  accounting  head  offices  (not  covered  by  the  study  because  they  do 
not provide services to third parties), instead the rounded percentages 50, 30 and 20 
per cent were used.  

Occurrence of formalities that apply only to professional partnerships 

Formalities that apply only to professional partnerships are usually formalities related 
to  shareholding  requirements:  the  submission  of  numbers  and  values  of  shares  per 
shareholder  and  sometimes  the  inclusion  of  shareholder  data  in  company  statutes.  A 
weight of 0.2 is only used for these formalities in the following countries: 

•  Spain (architecture and engineering branches); 
• 

Italy and Portugal (architecture, engineering and accountancy branches). 

In  Malta,  all  requirements  that  regulate  the  architecture  and  engineering  professions 
apply both to natural persons providing the services (beyond the scope of this study) 
and  to  partners  of  professional  partnerships.  Hence  the  weight  0.2  is  used  for  all 
formalities in Malta except for familiarization where unit weight was used because the 
limitation  of  requirements  to  natural  persons  and  professional  partnerships  is  not 
immediately obvious from online information.  

May 2017 I 133 

 
 
Occurrence of formalities that apply to voluntary titles in the company name 

Requirements only apply to firms wishing to carry a voluntary professional title in the 
company name in three countries: 

•  Germany for architecture and engineering branches and temporary services; 
• 
• 

Ireland for architecture branches and temporary services; 
the United Kingdom for legal form requirements of engineering branches and 
temporary services; 
the United Kingdom for accountancy branches and temporary services 
(however professional indemnity insurance requirements and hence also 
familiarization apply to all accountancy firms). 

• 

Occurrence  of  regional  differences 
insurance 

in  requirements  to  prove 

liability 

In two countries large regional differences in requirements to prove liability insurance 
were  observed.  In  Germany  and  Spain,  some  regional  professional  chambers  require 
proof  of professional liability insurance and others do not.  In addition, in Spain some 
regional  professional  chambers  require  proof  of  civil  liability  insurance  and  others  do 
not.  

8.4  The costs of formalities 

The general approach 

This  section  presents  the  costs  of  the  administrative  formalities  described  in  the 
previous  two  chapters.  For  each  formality,  the  relevant  hours  of  managers, 
professionals  and  administrative  support  staff  and  the  costs  of  Chapter  6  are  used, 
depending on the classification of the formality in Chapter 7. The hours are multiplied 
with the staff rates (labour costs plus overhead mark-up) given in Section 8.2, based 
on the “same home country mix” scenario.  

In formula, the cost of formalities of a given complexity is calculated as follows: 

• 

(Out-of-pocket costs + Hours per staff category x Staff rate) x Weight  

Examples  of  out-of-pocket  costs  include  costs  for  translation,  certification,  fees 
charged by authorities, postal and travel expenses and expenses on training courses. 
The weight is a number ranging from 0 to 1 reflecting the proportion of firms to which 
a formality applies.  

If  costs  are  different  between  countries,  the  reason  is  either  because  the  degree  of 
complexity  of  the  formality  is  different,  or  because  the  formalities  apply  to  different 
segments of the business population (and a different weight is used).  

Familiarizing with formalities 

In  several  countries,  one  or  two  hours  are  needed  to  familiarize  with  formalities 
resulting  in  a  cost  of  EUR  65  on  average  (Table  8.2).  However  when  different 
procedures with local and central authorities are involved, the costs  of familiarization 
with  the  administrative  formalities  to  establish  a  branch  increase  rapidly.  This  is 
typically  the  case  in  federally  organized  countries:  Belgium  (architects),  Germany, 
Italy and Spain.  

134 I May 2017 

 
 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

To  illustrate  the  underlying  calculation,  the  example  of  Germany  (architecture  and 
engineering) is used. For reasons documented in Table 7.1, familiarization is complex 
in  Germany.  From  Table  6.1,  this  costs  managers,  professionals  and  administrative 
support  staff  on  average  8,  5  and  4  hours  respectively.  Multiplying  those  hours  with 
the  staff  rates  of  Table  8.1  gives  a  cost  of  EUR  893.30.  No  out-of-pocket  costs  are 
calculated. The exception for Italy where a firm outsourced the registration (costing 1 
hour  and  EUR  4,000  expenses)  is  treated  the  same  way  as  other  situations  where 
familiarization  is  complex,  because  the  expenses  might  have  covered  other  services 
beyond the scope of the study as well. Hence, the total cost  of  familiarization is EUR 
893  for  those  firms  that  wish  to  carry  a  voluntary  title  in  the  company  name.  As 
documented in Section 8.2, a weight 0.5 is applied, resulting in the estimated average 
cost  of  EUR  447  given  in  Table  8.2.  Alternatively,  all  the  input  for  Table  8.2  can  be 
found in Annex 4. 

Table 8.2 Average Costs of Familiarization with Formalities 

Temp.Serv 

Architecture 
Branches 
65
893
65
65
447
0
893
65
105
893
210
210
0
65
0
65
0

Engineering 
Branches 
65
0
65
65
447
0
893
0
0
893
210
210
0
65
0
0
0

Temp.Serv 
65
0
65
65
447
0
210
0
0
0
65
0
0
0
0
0
0

Accountancy 
Branches 

Temp.Serv 
65
65
0
0
0
0
0
65
0
0
65
65
0
0
65
0
65

65 
893 
0 
0 
0 
0 
0 
210 
0 
893 
210 
65 
0 
210 
210 
0 
65 

65 
65 
65 
65 
447 
0 
210 
65 
0 
0 
65 
0 
0 
0 
0 
0 
0 

Collecting documents from authorities 

The  cost  of  collecting  documents  from  authorities  is  generally  not  very  high  because 
generally  at  most  one  standard  extract  is  required.  The  most  notable  exceptions  are 
those  when  specific  non-standard  documents  must  be  collected  in  certain  situations, 
such  as  proof  of  an  address  in  France,  inclusion  of  an  advised  statement  in  the 
company statutes in Luxembourg and, specifically for engineering in Spain, a Spanish 
social  security  certificate  of  the  legal  representative  for  registration  in  the  Industrial 
Register.  Costs  are  particularly  low  for  Malta  because  the  formality  only  applies  to 
voluntary professional partnerships and a weight of 0.2 was used.  

Table 8.3 Average Costs of Collecting Documents from authorities 

Temp.Serv 

Architecture 
Branches 
146
146
146
327
73
0
187
313
91

0 
0 
52 
0 
73 
0 
52 
0 
91 

Engineering 
Branches 
0
0
146
327
73
0
333
0
0

Temp.Serv 
0
0
52
0
73
0
52
0
0

Accountancy 
Branches 

Temp.Serv 
0
0
0
0
0
0
0
52
0

52 
0 
0 
0 
0 
0 
0 
458 
0 

May 2017 I 135 

MS 
AT  
BE 
CY 
CZ 
DE 
DK 
ES 
FR 
IE 
IT 
LU 
MT 
PL 
PT 
RO 
SK 
UK 

MS 
AT  
BE 
CY 
CZ 
DE 
DK 
ES 
FR 
IE 

 
 
 
MS 
IT 
LU 
MT 
PL 
PT 
RO 
SK 
UK 

Architecture 
Branches 
0
1,081
10
0
0
0
146
0

Temp.Serv 

Engineering 
Branches 
0
1,081
10
0
52
0
146
0

Temp.Serv 
0
52
0
0
0
0
0
0

Accountancy 
Branches 

0 
146 
52 
0 
146 
1,081 
0 
0 

Temp.Serv 
0
0
52
0
0
0
0
0

0 
52 
0 
0 
0 
0 
0 
0 

Collecting shareholder data 

Costs of collecting shareholder data are highest in those countries where not only the 
number  and  value  of  shares  for  each  shareholder  must  be  given,  but  they  must  also 
be in the company statutes and in addition the positions of shareholders in other firms 
must be given, as is the case for accountancy branches in Belgium, France and Malta 
and  for  architecture  branches  in  France  (Table  8.4).  A  requirement  that  company 
statutes  must  include  numbers  and  values  of  shares  per  shareholder  causes  an 
average  cost  of  EUR  935  in  Austria  (architecture  and  engineering  branches)  and 
Belgium (architecture branches). A similar requirement in Germany (architecture  and 
engineering)  applies  to  only  to  firms  wishing  to  carry  a  professional  title  in  the 
company name (weighted with 0.5). In Luxembourg the costs are caused by a lighter 
requirement  that  numbers  and  values  of  shares  per  shareholder  must  be  given  in  a 
free  format,  however  this  applies  to  all  branches  in  architecture,  engineering  and 
accountancy.  

Table 8.4 Average Costs of Collecting Shareholder Data 

MS 
AT  
BE 
CY 
CZ 
DE 
DK 
ES 
FR 
IE 
IT 
LU 
MT 
PL 
PT 
RO 
SK 
UK 

Architecture 
Branches 

935 
935 
169 
0 
468 
0 
94 
1,590 
234 
229 
468 
34 
0 
94 
0 
0 
0 

Engineering 

Accountancy 

Temp.Serv Branches Temp.Serv Branches  Temp.Serv
0
0
0
0
0
0
0
0
0
0
0
1,590
0
0
0
0
84

169 
1,590 
0 
0 
0 
0 
0 
1,590 
0 
229 
468 
1,590 
0 
94 
468 
0 
84 

0
0
0
0
468
0
0
0
0
0
0
0
0
0
0
0
0

935
0
169
0
468
0
94
0
0
229
468
34
0
94
0
0
0

0
0
0
0
468
0
0
0
234
0
0
0
0
0
0
0
0

Completing forms 

The  cost  of  completing  forms  is  usually  low.  Two  factors  that  increase  costs  are  a 
requirement that forms or data must be filled in for all shareholders and data, and the 
number of forms or data to be filled in. Costs are particularly high for architecture and 
engineering branches in Cyprus (detailed educational data with start and end dates for 
each  shareholder) and  Italy (many forms  for  each shareholder), and for accountancy 
branches in France, Italy, Luxembourg and Romania for similar reasons (Table 8.5).  

136 I May 2017 

 
 
 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

Table 8.5 Average Costs of Completing Forms 

Temp.Serv 

MS 
AT  
BE 
CY 
CZ 
DE 
DK 
ES 
FR 
IE 
IT 
LU 
MT 
PL 
PT 
RO 
SK 
UK 

Architecture 
Branches 
352
58
1,815
58
29
0
58
58
176
1,815
58
12
0
117
0
0
0

Engineering 
Branches 
352
0
1,815
58
29
0
352
0
0
1,815
58
12
0
58
0
0
0

Temp.Serv 
0
0
0
58
29
0
58
0
0
0
58
0
0
0
0
0
0

Accountancy 
Branches 

58 
58 
0 
0 
0 
0 
0 
1,815 
0 
1,815 
1,815 
58 
0 
58 
1,815 
0 
0 

Temp.Serv 
0
58
0
0
0
0
0
58
0
0
58
58
0
0
58
0
0

0 
58 
0 
58 
29 
0 
58 
58 
29 
0 
0 
0 
0 
0 
0 
0 
0 

Certain formalities related to liability insurance 

Some  countries  have  specific  requirements  with  regard  to  the  formulation  or  the 
provider  professional  indemnity  insurance  or  general  civil  liability  insurance,  which 
take  time  to  arrange  (Table  8.6).  The  costs  of  the  policy  follow  from  a  regulatory 
rather  than  administrative  requirement  and  are  beyond  the  scope  of  the  study.  In 
Spain, some regional chambers require proof of a standard civil liability insurance. In 
the United Kingdom the wording of the accountancy professional indemnity insurance 
policy  is  prescribed.  Professional  chambers  in  Belgium  (accountancy)  and  Germany 
(architecture  and  engineering,  to  carry  a  voluntary  title  in  the  company  name)  only 
accept  insurance  of  natural  persons  and  not  of  firms,  which  costs  extra  hours  to 
arrange  something  with  the  insurance  provider  and  the  professional  chamber. 
Specifically  high  costs  are  reported  for  Austria  due  to  the  existence  of  multiple 
liabilities  which  makes  it  difficult  to  compare  insurance  policies  of  different  insurance 
providers. 

Table 8.6 Average Costs of Formalities related to liability insurance 

MS 
AT  
BE 
CY 
CZ 
DE 
DK 
ES 
FR 
IE 
IT 
LU 
MT 
PL 
PT 
RO 
SK 
UK 

Architecture 
Branches 

1,941 
0 
0 
0 
194 
0 
52 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 

Engineering 

Accountancy 

Temp.Serv Branches Temp.Serv Branches  Temp.Serv
104
388
0
0
0
0
0
0
0
0
0
0
0
0
0
0
388

1,941
0
0
0
194
0
52
0
0
0
0
0
0
0
0
0
0

104 
388 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
388 

0
0
0
0
194
0
0
0
0
0
0
0
0
0
0
0
0

0
0
0
0
194
0
0
0
0
0
0
0
0
0
0
0
0

May 2017 I 137 

 
 
 
 
Translation and certification of documents 

Translation and certification costs are the sum of multiple requirements, depending on 
the  number  and  type  of  documents  that  need  to  be  translated,  whether  a  certified 
translator  or  even  one  from  the  host  country  must  be  used,  and  whether  copies  of 
documents  must  be  certified.  These  requirements  are  summarized  in Annex  4.  When 
these  costs  are  added  up,  they  range  from  EUR  100  (engineering  branches  in 
Luxembourg) to roughly EUR 1,530 (accountancy branches in Belgium and France), as 
presented in Table 8.7.  

Table 8.7 Average Costs of translation and certification requirements 

MS 
AT  
BE 
CY 
CZ 
DE 
DK 
ES 
FR 
IE 
IT 
LU 
MT 
PL 
PT 
RO 
SK 
UK 

Architecture 
Branches 

900 
1,029 
1,450 
1,200 
589 
0 
1,200 
929 
0 
1,079 
800 
230 
0 
900 
0 
950 
0 

Engineering 

Accountancy 

Temp.Serv Branches Temp.Serv Branches  Temp.Serv
0
283
0
0
0
0
0
179
0
0
0
1,150
0
0
0
0
400

1,079 
1,533 
0 
0 
0 
0 
0 
1,529 
0 
1,079 
150 
1,150 
0 
900 
1,000 
0 
400 

900
0
1,450
1,229
589
0
1,100
0
0
1,079
100
230
0
900
0
950
0

0
0
0
479
589
0
0
0
0
0
200
0
0
0
0
0
0

0
0
0
479
589
0
0
179
0
0
200
0
0
0
0
0
0

Legal form and shareholding/voting rights requirements 

A requirement that in all branches of foreign service providers more than 51 per cent 
of the shares must be in the hand of professionals may cause a costly reallocation of 
shares  and/or  voting  rights,  also  from  an  administrative  point  of  view  (Table  8.8). 
These  costs  are  mainly  caused  by  a  potential  need  of  renegotiation  between 
shareholders  and/or  partners.  Also,  required  management  changes  have  been 
excluded  from  the  cost  calculations  because  new  management  may  have  been  hired 
for other reasons as well, for simplification purposes.  

The  costs  are  highest  in  the  case  of  Belgium  (architecture  branches),  Cyprus 
(architecture  and  engineering  branches),  Germany  (to  carry  a  voluntary  title  in  the 
company  name  and  weighted  with  0.5)  and  Luxembourg  (all  branches).  Costs  are 
particularly  high  for  accountancy  branches  in  France  because  in  this  case  in  addition 
no legal forms that grant the “trade-man’s” status to associates are allowed. The high 
costs  for  engineering  in  the  United  Kingdom  are  caused  by  non-allowance  of  limited 
liability companies to carry a voluntary professional title in the company name, as well 
as a potential need to reallocate voting rights because all partners must be members 
of a relevant body.  

Table  8.8  Average  costs  of  legal  form  and  shareholding  /  voting  rights 
requirements 

MS 
AT  
BE 
CY 

Architecture 
Branches 
288
1,618
1,618

138 I May 2017 

Temp.Serv 

Engineering 
Branches 
288
0
1,618

Temp.Serv 
0
0
0

Accountancy 
Branches 

Temp.Serv 
0
0
0

0 
288 
0 

0 
0 
0 

 
 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

Temp.Serv 

MS 
CZ 
DE 
DK 
ES 
FR 
IE 
IT 
LU 
MT 
PL 
PT 
RO 
SK 
UK 

Architecture 
Branches 
288
809
0
805
482
0
326
0
288
0
65
0
65
0

Engineering 
Branches 
288
809
0
805
0
0
288
0
288
0
65
0
65
1,197

Temp.Serv 
0
809
0
0
0
0
0
0
0
0
0
0
0
1,197

Accountancy 
Branches 

0 
0 
0 
0 
2,394 
144 
288 
1,618 
288 
0 
65 
482 
0 
144 

Temp.Serv 
0
0
0
0
0
144
0
0
288
0
0
0
0
144

0 
809 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 

Examination and/or language skills 

The costs  of  examination and/or gaining language skills of  shareholders  or managers 
include  both  the  cost  of  hours  and  the  fees  of  the  trainer  or  the  course  (Table  8.9). 
Other countries may require professionals to take exams in the home country, but this 
is  out  of  scope  of  the  study.  Also,  expenses  on  travel  tickets  caused  by  examination 
requirements  are  reported  in  the  next  table,  because  travel  expenses  may  also  be 
caused by a requirement to collect or submit documents in person in the host country. 
However, travel time is included in the time involved with examination.  

The most costly examination requirement exists in Austria for the executive manager 
to  learn  Austrian  tax  law  to  establish  an  architecture  or  engineering  subsidiary  (a 
subsidiary  because  the  relevant  professional  chamber  only  recognizes  Austrian  legal 
forms).  Examination  requirements  are  also  costly  for  shareholders  to  establish  an 
accountancy  branch  in Austria,  Belgium  and Romania,  both  to learn  the  host  country 
regulations  and  the  language  skills  to  take  the  exam  in  a  foreign  language.  Similar 
examination  of  host  country  regulations  in  Ireland  and  Malta  costs  on  average  less 
because the exam can be done in the English language and because they apply only to 
part of the businesses, namely those wishing to carry the voluntary title ‘architect’ in 
Ireland and voluntary professional partnerships in Malta. Examination requirements for 
shareholders of architecture branches in Slovakia also only apply to part of the firms, 
namely for voluntary professional partnerships. The cost of EUR 6,176 for architecture 
and engineering branches in Cyprus is caused by a language skills requirement. Lastly, 
the cost  of  EUR 584 is caused by non-availability of online information in the English 
language.  

Table  8.9  Average  costs  of  examination  and/or 
shareholders or managers 

language  skills  of 

MS 
AT  
BE 
CY 
CZ 
DE 
DK 
ES 
FR 
IE 
IT 
LU 

Architecture 
Branches 
17,881
584
6,176
584
584
0
584
0
2,603
584
0

Temp.Serv 

0 
584 
584 
584 
584 
0 
584 
0 
2,603 
0 
0 

Engineering 
Branches 
17,881
0
6,176
584
584
0
584
0
0
584
0

Temp.Serv 
0
0
584
584
584
0
584
0
0
0
0

Accountancy 
Branches 

12,382 
9,382 
0 
0 
0 
0 
0 
0 
0 
584 
0 

Temp.Serv 
0
0
0
0
0
0
0
0
0
0
0

May 2017 I 139 

 
 
 
Temp.Serv 

MS 
MT 
PL 
PT 
RO 
SK 
UK 

Architecture 
Branches 
1,441
0
584
0
1,876
0

Engineering 
Branches 
1,441
0
584
0
0
0

Temp.Serv 
0
0
0
0
0
0

0 
0 
0 
0 
0 
0 

Accountancy 
Branches 

0 
0 
584 
10,382 
0 
0 

Temp.Serv 
0
0
0
0
0
0

Collecting or submitting documents and travel costs 

Costs of collecting or submitting documents in person in the host country include both 
travel time and expenses on tickets. Expenses on tickets caused by a requirement to 
do  an  exam  in  the  host  country  are  also  covered  in  Table  8.10,  but  travel  time  is 
included in time for the examination in Table 8.9.  

The  highest  cost  in  Table  8.10  is  therefore  caused  by  a  requirement  to  collect  or 
submit  documents  in  person.  In  Spain  (for  architecture  and  engineering)  and  in 
Romania  (to  establish  and  accountancy  branch)  documents  must  be  submitted  in 
person.  For  Italy  no  such  a  requirement  was  identified  but  three  out  of  four 
respondents  did  so,  and  perhaps  some  regional  chambers  require  submission  in 
person and others do not. For Luxembourg all three respondents mentioned that they 
had to collect a document, a VAT registration form. Strictly speaking this is a general 
business  register  requirement  in  Luxembourg,  but  included  because  the  Luxembourg 
chambers require proof of this.  

Costs  of  EUR 250 are caused by travel ticket expenses for  shareholders or managers 
to do an exam in the host country even if they do not provide services cross-border. 
This  is  the  case  in  Austria,  Ireland  (architecture  services  to  carry  the  voluntary  title 
‘architect’  in  the  company  name),  Romania  (accountancy  branches)  and  Slovakia 
(branches of voluntary architecture partnerships).  

Lastly, there may be a cost of EUR 34 involved with posting documents (half an hour 
for administrative support staff and postal costs of EUR 20).  

Table 8.10 Average costs of collecting or submitting documents and tickets 

Engineering 

Accountancy 

Temp.Serv Branches Temp.Serv Branches  Temp.Serv 
0
0
0
0
0
0
0
34
0
0
0
0
0
0
0
0
17

250 
0 
0 
0 
0 
0 
0 
34 
0 
915 
915 
0 
0 
0 
250 
0 
17 

0
34
34
34
17
0
881
34
135
0
0
0
0
0
0
0
0

284
0
34
34
17
0
881
0
0
915
915
57
0
0
0
20
0

0
0
34
34
17
0
881
0
0
0
0
0
0
0
0
0
0

MS 
AT  
BE 
CY 
CZ 
DE 
DK 
ES 
FR 
IE 
IT 
LU 
MT 
PL 
PT 
RO 
SK 
UK 

Architecture 
Branches 

284 
34 
34 
34 
17 
0 
881 
34 
125 
915 
915 
57 
0 
0 
0 
70 
0 

140 I May 2017 

 
 
 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

Costs of paying first-time fees charged by authorities 

Costs  of  paying  first-time  fees  consist  both  of  the  fees  themselves  (registration  fee 
and/or membership fee for the first year) and of time involved with doing the payment 
(Table 8.11). The highest fees are  observed in the United Kingdom (architecture and 
accountancy),  Malta,  Romania  (accountancy  branches)  and  Germany  (architecture 
branches), for reasons discussed previously in Sections 3.6, 4.6 and 5.6.  

For two countries, high costs were reported to make the payment and also more than 
once:  France 
for  architecture  branches  and  Luxembourg  (architecture  and 
accountancy  branches);  in  both  countries  no  fee  is  required  for  temporary  services. 
For France this may be related to a requirement to post a payable check and for this 
reason the same costs  are assumed for accountancy where a payable check  most be 
posted  as  well.  For  Luxembourg  no  information  about  even  the  amount  of  the  fee 
could be found on the website. Since the chamber for engineers and architects is the 
same  in  Luxembourg,  the  same  time  involved  with  making  the  payment  is  assumed 
for engineering services. The cost of EUR 1,294 for the time involved with making the 
payment  exceeds  the  fee  costs  in  both  countries  (ranging  from  EUR  160  for 
architecture  and  engineering  branches  in  Luxembourg  to  EUR  760  for  architecture 
branches in France).  

Table 8.11 Average costs of paying first-time fees  

Temp.Serv 

MS 
AT  
BE 
CY 
CZ 
DE 
DK 
ES 
FR 
IE 
IT 
LU 
MT 
PL 
PT 
RO 
SK 
UK 

Architecture 
Branches 
446
966
421
311
1,889
0
588
2,054
1,306
369
1,374
99
0
503
184
276
2,711

Engineering 
Branches 
346
0
421
97
713
0
616
0
0
369
1,374
67
0
823
0
374
26

Temp.Serv 
0
0
0
168
213
0
0
0
0
0
106
62
0
146
0
196
26

Accountancy 
Branches 

212 
651 
0 
0 
0 
0 
0 
2,294 
0 
369 
1,794 
2,929 
0 
888 
2,726 
0 
1,606 

Temp.Serv 
0
651
0
0
0
0
0
0
0
0
0
26
0
400
0
0
1,606

0 
126 
0 
168 
413 
0 
0 
0 
0 
0 
106 
94 
0 
26 
161 
100 
2,711 

Recurrent costs 

Recurrent  costs  consist  mostly  of  annual  fees,  but  also  of  examination  costs  for  new 
shareholders or managers, which is assumed to occur once after ten years. All future 
costs are discounted at a rate of four per cent per year.  

The  highest  recurrent  costs  are  caused  by  exceptionally  high  annual  fees  in  two 
countries as noted in Section 5.6:  

•  Malta (accountancy, an Annual Quality Review); 
•  Romania (accountancy branches, one per cent of income in Romania).  

Other  total  costs  of  recurrent  activities  in  excess  of  EUR  4,000  are  caused  by  an 
examination  requirement  for  shareholders  or  managers,  which  also  applies  for  new 

May 2017 I 141 

 
 
 
shareholders and managers. The cost of this is included under the assumption that a 
change takes place only once, namely after 10 years. This is the case in five countries: 

•  Austria (branches of all services covered); 
• 
•  Malta (architecture and engineering branches of voluntary professional 

Ireland (architecture branches for the voluntary title in the company name); 

partnerships); 

•  Romania (accountancy branches); 
•  Slovakia (branches of voluntary architecture partnerships). 

Examination costs are lower in Ireland and Malta than in Austria and Romania for two 
reasons.  Firstly,  they  only  apply  to  head  architects  of  firms  wishing  to  carry  the 
voluntary  title  ‘architect’  in  the  company  name  in  Ireland  and  only  for  partners  of  a 
voluntary  professional  partnership  in  Malta.  Secondly,  for  both  Ireland  and  Malta  no 
need  to  learn  the  native  language  is  assumed  because  examination  is  in  the  English 
language. 

For  Luxembourg  the  recurrent  costs  for  branches  consist  of  a  renewed  application  if 
the management changes, by assumption once after ten year. For France, architecture 
branches incur recurrent costs for the annual submission of a list of projects entrusted 
to the firm. In Cyprus the annual fee is quite low and a requirement to submit multiple 
documents every year causes the greater part of the recurrent costs.  

All  other  recurrent  costs  presented  in  Table  8.12  reflect  the  net  present  value  of 
annual fees.  

Table 8.12 Average Recurrent Costs  

MS 
AT  
BE 
CY 
CZ 
DE 
DK 
ES 
FR 
IE 
IT 
LU 
MT 
PL 
PT 
RO 
SK 
UK 

Architecture 
Branches 

12,604 
4,704 
3,965 
1,802 
0 
0 
3,082 
2,099 
3,352 
1,419 
525 
969 
0 
0 
0 
1,778 
507 

Engineering 

Accountancy 

Temp.Serv Branches Temp.Serv Branches  Temp.Serv
0
0
0
0
0
0
0
0
0
0
0
23,343
0
0
0
0
413

10,106 
2,839 
0 
0 
0 
0 
0 
0 
0 
1,419 
525 
23,343 
0 
0 
26,733 
0 
413 

12,604
0
3,965
601
0
0
2,206
0
0
1,419
525
960
0
973
0
1,882
507

0
0
0
601
0
0
0
0
0
0
0
0
0
973
0
0
507

0
0
0
601
0
0
0
0
0
0
0
0
0
0
0
0
507

Average total costs of administrative formalities for cross-border market 
access 

When  adding  up  the  average  costs  from  the  above  tables  and  some  minor  cost 
categories  not  presented  separately,  such  as  costs  of  searching  a  certified  translator 
or posting documents, the total average costs of the formalities to access cross-border 
market is the result. These costs are presented in Table 8.13 below.  

142 I May 2017 

 
 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

Table  8.13  Total  costs  of  administrative  formalities  to  access  markets  cross-
border (17 EU countries, 3 services and 2 delivery modes) 

Architecture 
Branches 

35,842 
10,968 
15,858 
4,670 
5,099 
0 
8,425 
7,623 
7,979 
7,630 
5,625 
3,350 
0 
2,328 
184 
5,525 
3,218 

AT 
BE 
CY 
CZ 
DE 
DK 
ES 
FR 
IE 
IT 
LU 
MT 
PL 
PT 
RO 
SK 
UK 

Engineering 

Accountancy 

Temp.Serv Branches Temp.Serv Branches  Temp.Serv 
169
1,445
0
0
0
0
0
388
144
0
123
26,572
0
400
123
0
3,118

24,476 
17,621 
0 
0 
0 
0 
0 
10,325 
144 
7,591 
7,640 
29,475 
0 
2,945 
45,146 
0 
3,118 

35,596
0
15,858
3,283
3,923
0
7,917
0
0
7,591
4,925
3,309
0
3,614
0
3,436
1,730

65
868
735
1,989
3,623
0
1,786
336
3,091
0
423
94
0
26
161
100
3,218

65
0
735
1,989
3,423
0
1,786
0
0
0
481
62
0
1,119
0
196
1,730

Firms do not necessarily face the above costs when operating cross-border, because in 
reaction  to  the  costs  of  formalities  they  may  search  for  alternative  modes  of  cross-
border  service  provision  (or  stay  in  the  home  country).  The  above  costs  must 
therefore  be  interpreted  as  the  direct  costs  caused  by  cross-border  administrative 
formalities.  However,  the  alternatives  may  appear  to  be  less  costly,  but  may  involve 
hidden  costs.  For  example,  an  alternative  could  be  to  work  as  a  subcontractor  of  a 
local  firm,  but  this  comes  at  the  cost  of  doing  smaller  shares  of  projects  (and  other 
disadvantages).  Also,  if  the  manager  of  the  branch  needs  to  be  proficient  in  the 
language of the host country, an alternative could be to employ a local manager, but 
this comes at the cost of having to pay him even when there is no work.  

8.5  Estimated aggregate costs 

Administrative costs are usually extrapolated to the Member State level by multiplying 
the average costs with the current number of firms. However, in this case this makes 
less sense for two reasons: 

•  The costs to access markets consist solely of one-off costs at the start for most 
of the countries covered by this study. This means that the costs have been 
sunk in the past and are only relevant for firms newly entering the market; 
•  The number of cross-border operating firms is difficult to identify although 

figures from Eurostat, Amadeus and scarce registration data do not suggest a 
strong current presence of cross-border branches and subsidiaries for the 
services covered by this study. 

Hence, as an alternative, the average costs were multiplied with the number of firms 
potentially interested in providing cross-border services in the future. 

According  to  the  latest  Eurostat  figures  of  2014,  there  are  close  to  310,000 
architecture  and  630,000  engineering  firms  active  in  the  EU28.  There  are  about 
600,000 providers of accounting, auditing and tax advice services. Many of these firms 
offer a mix of accounting, statutory auditing and/or tax advice services. Since in most 
EU  countries  authorization  requirements  are  heavier  for  statutory  auditing  and  tax 

May 2017 I 143 

 
 
 
 
 
advice, only firms solely offering accounting services are relevant. For the purpose of 
aggregating  costs,  it  is  assumed  that  about  10%  of  them  (60,000)  solely  provide 
accounting services.  

As  the  exact  number  of  firms  potentially  interested  in  provision  of  cross-border 
services  cannot  be  determined,  the  study  uses  three  different  scenarios  to  estimate 
these numbers: 

1.  The current population of cross-border operating firms in the three investigated 
sectors seems to be small. Therefore, the base assumption is that 1 per cent 
could be mobilized to operate cross-border. Then this would be equivalent to 
13,000 firms. Next, as the base scenario / lower range estimate, it is assumed 
each of these firms operate in just one cross-border country; 

2.  As an alternative scenario and mid-range estimate, it is assumed those 

additional firms would operate in ten EU countries each; 

3.  Finally, a third scenario / high range estimate is calculated where ten per cent 
of the architecture and engineering firms would operate in ten countries each. 
A previous study12 even shows export participation up to 24 per cent in 
professional services for companies with 10-49 employees but the high 
scenario assumes a smaller percentage because little is known about the 
greater group of micro enterprises with fewer than ten employees. 

However, the future is uncertain and the number of companies that go cross-border 
may in the end be higher or lower than in these three scenarios, which should be 
interpreted as giving a sense of the magnitude of the potential gain of simplifying 
formalities.  

The following additional assumptions are made: 

•  The number of firms going cross-border are assumed to be proportionally the 
same in all three sectors (e.g. in the lower range estimate, 1% of service 
providers in each of the three sectors covered would go cross-border); 

•  Service providers going cross-border would make a choice between permanent 
settlement and temporary services. It is assumed that this split is 50/50%;  

•  All firms face language issues in case of translation and examination 

requirements, meaning these are applied for each firm;  

•  Lastly, the host countries are weighted by the approximate size of the economy 
and population. France, Germany, Italy, Poland, Spain and the UK were each 
given five times larger weights than the majority of countries and Cyprus, 
Luxembourg and Malta were each given weight five times smaller weights than 
the majority of countries; resulting in weights of 13 per cent (for the five 
largest countries), 0.5% (for the three smallest countries) and 2.6% (for all 
other countries). The resulting weighted costs per firm are given in row 2 of 
Table 8.14.  

The aggregate cost of administrative formalities in the base scenario is the product of 
estimated  extra  number  of  cross-border  operating  firms  and  the  cost  per  firm.  The 
aggregated  cost  for  the  three  sectors  and  two  forms  of  cross-border  activity  is 
presented in row 3 of Table 8.14: a total of EUR 29.1 million.  

12   Page 83 of http://ec.europa.eu/DocsRoom/documents/6706/attachments/1/translations. 
144 I May 2017 

 
 
                                                           
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

Table  8.14  Aggregate  costs  of  additional  cross-border  firms  (lower-end 
scenario); 17 EU host countries of the study), in euros 

Architecture 

Engineering 

Accountancy 

Total

Branches, 
subsidiaries

Temp. 
Service
s 

Branches, 
subsidiari
es

Temp. 
Service
s

Branches, 
subsidiari
es 

Temp. 
Services 

Extra 
number 
of cross-
border 
operating 
firms 
MS size 
weighted 
costs 
Aggregat
e cost  

1,550

1,550 

3,150

3,150

300 

300 

10,000

6,014
9,321,486

1,331 
2,062,5
60 

4,103
12,924,440

1,040
3,275,9
34

5,256 
1,576,694 

652 

2,936
195,461  29,356,
574

In  the  second  scenario,  the  costs  become  ten  times  as  large  as  in  the  lower-end 
scenario  because  the  same  number  of  firms  incur  costs  to  operate  in  ten  host 
countries each (besides the home country). In the third scenario, both the number of 
additional  firms  and  the  number  of  countries  in  which  they  operate  are  ten  times  as 
large as in the first scenario. Table 8.15 summarizes the outcomes for the above three 
scenarios. 

Table  8.15  Aggregate  costs  of  additional  cross-border  firms  (3  scenarios;  17 
EU host countries of the study), EUR million 

Architecture 

Engineering 

Accountancy 

Total

Branches, 
subsidiaries

Temp. 
Services 

Branches, 
subsidiaries

Temp. 
Services

Branches, 
subsidiaries 

Temp. 
Services 

9.3

2.1 

12.9

3.3

1.6 

0.2 

29

93

932

21 

206 

129

1,292

33

328

16 

158 

2 

294

20  2,936

Scenario 
1 
Scenario 
2 
Scenario 
3 

Depending on the scenario, the cost  of additional cross-border  operating firms varies 
between EUR 29 million (lower-end scenario) and EUR 2.9 billion (scenario 3).  

Finally, it should be noted that even when numbers of cross-border  businesses reach 
stability,  each  year  new  enterprises  enter  the  market  and  some  old  enterprises  exit 
the  market,  with  each  new  enterprise  incurring  the  identified  costs  when  they  go 
cross-border.  

May 2017 I 145 

 
 
 
 
 
 
 
 
9  SUMMARY AND CONCLUSIONS 

Providers  of  architectural,  engineering  and  accountancy  services  often  face  many 
barriers when they want to offer services in another Member State. These barriers are 
very  diverse  in  nature,  ranging  from  regulatory  and  administrative  obstacles  or 
language differences to the ability to find business opportunities abroad.  

The objective of the study is to identify cross-border market access formalities and to 
assess the costs of the different steps that are needed to comply with them. The study 
is focused on formalities and procedural steps faced by legal entities (i.e. companies) 
providing  architectural,  civil,  mechanical  and  electrical  engineering  and  accountancy 
services. Access to cross-border markets is covered for both services on a temporary 
basis and for the set-up of a branch or an agency for secondary establishment. Given 
the  scope  of  the  study,  requirements  relating  to  services  provided  by  individual 
professionals  are  excluded.  Also,  requirements  of  general  business  registration  are 
beyond  the  scope  of  this  study,  as  well  as  regulatory  requirements  such  as 
professional indemnity insurance and multidisciplinary restrictions to avoid conflicts of 
interest. However, the administrative formalities to demonstrate compliance stemming 
from these regulatory requirements are within its scope.  

The study covers 17 EU Member States: Austria, Belgium, Cyprus, the Czech Republic, 
Denmark,  France,  Germany,  Ireland,  Italy,  Luxembourg,  Malta,  Poland,  Portugal, 
Romania, Slovakia, Spain and the United Kingdom.  

Methodological approach 

In order to estimate the costs of administrative formalities, first an inventory template 
was drafted containing a list of formalities to be investigated (thus defining the scope 
of  the  study  as  well).  The  researchers  filled  this  inventory  template  with  applicable 
formalities  for  the  selected  types  of  services  (architectural,  civil,  mechanical  and 
electrical  engineering  and  accountancy  services),  modes  of  cross-border  service 
provision (services on a temporary basis and for the set-up of a branch or an agency 
for  secondary  establishment)  and  the  17  selected  countries.  The  information  on 
applicable  formalities  was  obtained  from  the  websites  of  the  relevant  authorities 
(professional  chambers)  insofar  available.  Insofar  not  available,  information  was 
retrieved  by  analysis  of  national  legislation.  For  some  countries,  authorization  is  not 
granted  by  the  professional  chamber  or  other  authorities  are  involved  in  the 
authorization  procedure.  In  these  cases,  a  wider  legal  search  was  conducted  to  take 
stock of the formalities originating from these other organisations. The filled template 
was submitted to responsible national authorities (professional chambers) for a check. 
Although  few  of  these  authorities  provided  feedback  on  the  filled  template,  most  did 
answer specific questions over the telephone.  

After  the  inventories  were  made,  interviews  with  52  cross-border  service  providers 
were  carried  out.  They  were  asked  about  the  costs  of  the  necessary  activities  when 
going  through  a  cross-border  authorization  procedure.  These  costs  include  both 
working time from staff of the service provider and expenses paid. For working time, 
service  providers  were  asked  about  the  actual  hours  spent  by  various  levels  of  staff 
(including  managers  of  the  company).  For  expenses  paid,  service  providers  were 
asked  about  the  amounts  paid  for  fees  and  purchase  of  external  services  (such  as 
translation, certification and external advice).  

The costs for working time and, insofar applicable, expenses were then classified in up 
to four categories of “complexity”, with higher degrees of complexity corresponding to 
higher  amount  of  hours  and/or  expenses.  A  synthetic  analysis  of  the  degrees  of 
complexity  and  the  administrative  formalities  was  performed  to  assess  the  relation 

146 I May 2017 

Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

between  the  cost  levels  indicated  and  the  characteristics  of  the  procedure  or 
administrative formalities, for example the number of authorities involved or the type 
of  data  or  documents  to  be  submitted.  Next,  for  each  country,  for  each  type  of 
services,  for  each  mode  of  cross-border  service  provision,  and  for  each  formality 
within the authorization procedure, the degree of complexity was determined based on 
characteristics such as described above.  

Once  the  degree  of  complexity  was  determined,  the  average  costs  for  working  hours 
and  expenses,  as  retrieved  from  the  business  survey,  were  allocated  to  the  relevant 
formality.  The  main  purpose  of  applying  this  method  is  to  reduce  the  impact  of 
random  differences  in  efficiency  of  the  applicant,  for  example  due  to  language 
proficiency  or  travel  distance  of  the  service  provider,  on  the  allocation  of  costs  to 
specific host countries.  

Lastly,  the  aggregate  costs  of  cross-border  service  were  calculated.  Because  the 
number of cross-border service providers is hard to quantify for the services covered 
by  this  study,  the  aggregate  costs  were  calculated  using  scenario’s.  Three  scenario’s 
were  developed:  a  base  scenario  with  one  per  cent  of  the  service  providers  going 
cross-border  in  one  country  each,  a  medium  scenario  with  one  per  cent  going  cross-
border in ten countries each, and a high scenario with ten per cent going cross-border 
in  ten  countries  each.  The  aggregate  costs  calculated  are  the  estimated  total  costs 
incurred  by  all  active  companies  in  the  sector  during  the  whole  transition  period,  for 
example ten years if that would be the time for the scenarios to become reality.  

Inventory – Authorization requirements 

To  start  with  the  inventory:  in  the  17  countries  of  this  study,  there  is  a  clear 
distinction between formalities for cross-border branches or agencies on the one hand, 
and  temporary  services  on  the  other  hand.  For  cross-border  branches  or  agencies, 
legal  persons  need  to  obtain  authorization  to  provide  services  in  ten  countries  for 
architecture  services,  nine  countries  for  engineering  services  and  six  countries  for 
accountancy  services.  In  each  case,  four  less  countries  require  authorization  for 
temporary  services  (six,  five  and  two  countries  respectively).  If  no  authorization  is 
required of legal persons, it does not necessarily imply that no authorization procedure 
is  in  place  at  all.  For  example,  some  countries  require  authorization  only  of  natural 
persons  providing  the  services  but  this  is  beyond  the  scope  of  the  study.  Other 
countries  that  do  not  require  authorization  may  require  that  the  legal  person  notifies 
the  authorities  of  the  intended  services,  and  possibly  of  professional  indemnity 
insurance.  

for  compulsory  authorization.  With  some  Member  States 

Conclusion: There is a significant difference among Member States with respect to the 
requiring 
choice 
authorization,  while  other  do  not,  costs  of  formalities  may  be  expected  to  be  absent 
for  temporary  services  in  multiple  countries,  and  also  more  often  to  be  absent  for 
accountancy services than for architecture and engineering services.  

Main regulatory requirements resulting in administrative formalities 

If  authorization  is  required,  compliance  with  various  regulatory  requirements  is 
checked.  These  regulatory  requirements  are  not  administrative  formalities  in 
themselves,  but  requirements  to  demonstrate  this  compliance  are.  For  example,  the 
purchase of additional insurance is not an administrative formality, but submitting an 
insurance  policy  is.  The  types  of  regulatory  requirements  for  which  most  countries 
check the compliance before granting authorization to provide the services are:  

•  Legal form requirements; 
•  Shareholding, management and related requirements; 
•  Multidisciplinary restrictions; 
•  Professional indemnity insurance requirements. 

May 2017 I 147 

Authorization requirements of legal form  

The  legal  form  of  a  business  determines  which  of  various  regulations  apply  to  it, 
including possibly the authorization to provide services. The main legal forms in the EU 
are sole traders, partnerships and limited liability firms.  

Depending on the type of services (architecture, engineering and accountancy), up to 
six  of  the  17  countries  limit  the  possible  legal  forms  allowed  for  secondary 
establishment,  although  to  varying  degrees.  Two  countries  require  the  use  of  a  legal 
form that is only available in their territory to  establish a branch for providing cross-
border architecture services. Four other countries require the use of a commonly used 
legal  form  (sole  trader,  partnership  or  limited  liability)  for  architecture  branches.  For 
engineering  services,  five  countries  limit  the  choice  of  legal  forms,  while  for 
accountancy  services  only  France  limits  this  choice  to  exclude  traders’  forms  (sole 
traders  and  partnerships).  If  legal  forms  only  available  in  the  host  country  are 
required, it depends  on the situation whether the establishment of a branch (using a 
legal form from the home country) is possible at all, or whether a subsidiary needs to 
be set up.  

For temporary cross-border services almost no legal form restrictions were identified.  

Conclusion: the legal form might help determine who is accountable for the quality of 
services  and  decisions  of  the  service  provider  in  general.  Unfamiliarity  with  a  foreign 
legal  form  might  cause  uncertainty  about  this.  However,  one  may  reasonably  expect 
that  the  legal  form  in  the  home  country  determines  who  is  legally  accountable,  and 
other  ways  exist  to  make  certain  who  may  be  held  accountable,  for  example  a 
statement  of  an  authority  in  the  home  country.  A  majority  of  countries  seem  to  hold 
this view given the fact that legal form restrictions are not widespread for cross-border 
branches  and  virtually  absent  for  temporary  services.  To  the  extent  legal  form 
restrictions compel service providers to establish a subsidiary  cross-border instead of 
a  branch,  these  restrictions  may  cause  very  high  costs,  relating  for  example  to 
familiarizing  with  tax  laws  of  the  host  country  and  costs  of  incorporation  (the  latter 
costs are out of scope of this study).  

Authorization requirements of shareholders and managers  

Some  countries  require  that  a  minimum  percentage  of  the  shares,  voting  rights  or 
management positions is in the hands of professionals, which ranges between 50 and 
100 per cent. Demonstrating compliance involves a range of formalities, from merely 
providing membership numbers of a professional body, to providing a list of numbers 
and  values  of  shares  and  positions  in  other  firms  (the  latter  by  three  countries 
depending for accountancy and none and one country for engineering and architecture 
respectively). 

For architecture branches, nine countries analysed in the study require that a majority 
of  shares  is  held  by  professionals,  regardless  of  the  legal  form  of  the  firm.  For 
engineering services, six countries set such requirements regardless of the legal form. 
In  addition,  four  countries  have  such  a  requirement  for  branches  of  voluntary 
professional  partnerships  (both  for  architecture  and  engineering  services).13  Five 
countries  require  that  one  or  more  managers  of  an  architecture  firm  must  be  an 
architect, and a further four  countries  require  this for the voluntary title ‘architect’ in 
the company name or for voluntary professional partnerships only.  

13   Throughout the text, voluntary professional partnerships refer to a legal form that is available as one of 

various legal forms of business. 

148 I May 2017 

 
                                                           
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

For  accountancy  firms,  five  countries  require  a  majority  of  shares  or  voting  rights  to 
be held by professionals regardless  of legal form.  In addition to the  countries setting 
rules  on  any  legal  form,  four  other  countries  apply  shareholding  rules  to  voluntary 
professional partnerships only. 

For  temporary  services,  only  two  countries  have  requirements  on  shareholding  and 
managers  in  place,  and  then  only  for  legal  persons  that  with  to  carry  the  title  of 
‘architect’ or ‘engineer’ in the company name.  

Conclusion: shareholding, voting rights and management restrictions help ensure that 
decisions  regarding  the  quality  of  services  are  made  by  professionals.  It  is  debatable 
whether  this  should  be  enshrined  in  the  company  statutes  or  if  a  list  suffices.  Also, 
very few countries require a list of positions in other firms, which indicates that most 
countries do not regard this as an additional safeguard against malpractice or perhaps 
conflicts of interest, for which other restrictions might suffice (such as Chinese walls). 

Authorization requirements of multidisciplinary restrictions 

Multidisciplinary  restrictions  mean  that  some  services  may  not  be  provided  by  the 
same  legal  person,  for  example  architects  that  may  not  be  involved  with  the  sale  of 
construction products. These restrictions may be imposed to avoid conflicts of interest 
and  are  typically  formulated  broadly,  although  sometimes  illustrated  with  specific 
examples,  for  instance  the  sale  of  construction  products  or  real  estate  deals.  While 
multidisciplinary  restrictions  are  regulatory  aspects  in  themselves,  demonstrating 
compliance  may  require  formalities  in  the  form  of  a  statement,  on  honour,  in  the 
company  statutes  or  from  an  authority  in  the  home  country.  These  formalities  are 
included in this study. 

For  architectural  services,  almost  all  countries  set  multidisciplinary  restrictions  for 
branches  and  four  countries  set  restrictions  for  the  provision  of  temporary  cross-
border services. However only in five countries does this result in formalities, namely 
to include a statement in the company statutes or to collect a certificate on this from 
an  authority  in  the  home  country.  Regarding  engineering  and  accountancy  ten 
respectively  seven  countries  restrict  branches,  and  three  restrict  temporary  services. 
However, this results in additional administrative formalities in only three countries. 

Conclusion:  multidisciplinary  restrictions  appear  to  have  a  clear  purpose  as  a 
safeguard  against  conflicts  of  interest.  However,  they  need  not  cause  administrative 
formalities in the form of a statement as is the case in some countries. In some other 
countries,  ticking  off  a  checkbox  that  the  service  provider  will  abide  with  the  code  of 
conduct  of  the  host  country  and  a  signature  at  the  end  suffices,  with  much  less 
administrative costs. 

Authorization requirements of professional indemnity insurance 

If  a  profession  is  regulated,  professional  indemnity  insurance  is  almost  always 
required.  However,  the  adequacy  of  insurance  is  not  always  assessed  as  part  of  the 
authorization.  Instead,  some  countries  require  that  the  client  is  informed  of  the 
insurance  before  any  contract  for  the  provision  of  services  is  signed.  Such  a 
requirement  falls  outside  the  scope  of  this  study,  because  it  relates  to  on-going 
services  rather  than  access  to  the  market.  If  adequate  insurance  is  checked  before 
authorization  is  granted,  this  usually  results  in  the  administrative  formality  that  an 
insurance policy must be submitted, as is the case to establish a branch in up to five 
countries for each service covered by this study, such as for example France and Malta 
for architecture and accountancy. Although not part of the inventory, for two countries 
it emerged from the business survey that two countries do not accept insurance at the 
company level but only for individual professionals. 

May 2017 I 149 

Conclusion:  the  requirement  in  a  few  countries  to  submit  an  insurance  policy  or 
certificate  causes  an  administrative  burden.  On  the  other  hand,  a  sole  requirement 
that the client must be informed about the insurance causes a perhaps greater burden 
on the client to check the nature of the insurance. How this trade-off is best balanced 
is difficult to say, however non-acceptance of insurance at the company level seems to 
cause a possibly unnecessary burden.  

Obtaining authorization 

If the authorization requirements are met, legal persons need to enter into the actual 
process  to  obtain  the  authorization,  in  particular  to  prove  compliance  with  applicable 
requirements. With respect to obtaining authorization, the study addresses: 

•  Relation with the general business register; 
•  Deadlines of authorities; 
•  Tacit approval; 
•  Validity of authorizations; 
•  Fees; 
•  Electronic information and procedures; 
•  Data submission demands; 
•  Document submission demands; 
•  Certification and translation requirements; 
•  Specific recurrent requirements. 

Each of these is elaborated further below. 

Obtaining authorization – Sequential registration requirements 

Where specific rules on registration with a professional chamber, being mandatory to 
obtain authorization to provide services, are in place, timing with the general business 
registration may be a point of attention. 

In  two  countries,  these  procedures  -  registration  with  the  general  business  register 
and  the  professional  chamber  -  are  integrated  for  respectively  architecture  services 
and all three professional services investigated in this study. Given that the approval 
of the professional chamber is needed before the general business register procedure 
can be started, this complicates the authorization.  

To  establish  a  branch,  in  most  countries  inscription  in  the  general  business  register 
and  inscription  with  a  professional  chamber  are  separate  procedures  and  can  be 
followed  in  parallel.  Sequential  registration,  where  a  firm  must  first  inscribe  with  the 
general  business  register  before  it  can  inscribe  with  the  professional  chamber,  is 
applied for architectural services in two countries, for engineering also in two countries 
and for accounting services in one country.  

An  additional  step  in  the  registration  procedure  is  present  in  countries  where 
shareholders  or  managers  must  be  professionals  (see  above).  In  these  cases,  those 
shareholders  or  managers  must  be  registered  before  the  firm  can  be  registered. 
However,  in  all  these  countries  the  procedure  to  register  shareholders  and  managers 
on the one hand and procedure to register the firm on the other hand can be started 
at  the  same  time  with  the  same  authority,  and  thus  this  does  not  complicate  the 
procedure.  

For  temporary  cross-border  services,  there  is  no  requirement  to  inscribe  with  the 
general business register before authorization to provide the services is granted in any 
of the 17 countries of the study.  

150 I May 2017 

 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

Conclusion:  in  federally  organized  countries,  both  regional  and  national  authorities 
may be involved in the procedure. While this makes sense to ensure that authorization 
is  nationally  valid,  it  also  complicates  the  authorization  procedure.  The  regional 
authority  is  typically  the  starting  point  or  even  acts  as  single  point  of  contact, 
forwarding documents to a ministry or the general business authority. However, to the 
extent that companies first contact the general business authority, it makes sense for 
the latter authority to act as single point of contact, as is the case in two (not federally 
organized) countries.  

Obtaining authorization - Deadlines of authorities and tacit approval 

Authorities typically have three types of deadlines in the authorization process: one to 
indicate completeness of the submitted documents (usually one month), one to assess 
the  documents  (usually  three  or  four  months  since  submission)  and  sometimes  an 
extended  deadline  in  case  of  difficulties  such  as  assessing  the  equivalence  of 
documents  or  errors  in  the  application  form  (one  or  two  additional  months)  as  is  for 
example the case in France for architecture. In some countries the deadline means the 
decision  will  be  issued  on  the  day  of  the  deadline,  in  other  countries  the  deadline 
means as soon as possible but no later than the deadline. The deadlines are typically 
the same for cross-border branches and temporary services.  

The total time allotted for the processing of request for registration of a branch or to 
provide  temporary  services  depends  on  the  country  and  ranges  between  21  days  to 
six  months  including  a  two-month  extension.  The  longest  potential  delay  is  observed 
in  countries  where  managers  or  shareholders  must  do  an  exam  in  the  host  country 
(even  if  they  do  not  deliver  the  services)  and  the  examination is  done  only  once  per 
year.  

Tacit approval means that if the authorities have not responded at the moment of the 
deadline, authorization is deemed to have been granted. Tacit approval only pertains 
to situations where authorization is required. In most cases, tacit approval only applies 
if  the  regulations  explicitly  provide  that  this  is  the  case.  This  is  rarely  the  case,  with 
notable exceptions in up to three countries for each service covered by this study, for 
example Luxembourg (where tacit approval is applicable for all three services). 

Conclusion:  the  total  duration  of  the  process  for  granting  authorizations  can  be  very 
long, taking up to six months, and thus delaying the provision of cross-border services 
through  both  branches  and  temporary  services.  The  combination  of  long  delays  and 
absence  of  tacit  approval  make  it  particularly  important  for  authorities  to  meet  their 
handling deadlines in order not to disrupt the provision of cross-border service.  

Obtaining authorization - Validity of authorizations 

Some  formalities  may  have  a  recurrent  character,  depending  on  the  validity  of 
authorizations. Validity of the authorization within the host country may be restricted 
in terms of time and geographical scope. Time limitations are typically caused by the 
requirement  of  an  annual  fee,  which  terminates  the  authorization,  unless  the  new 
yearly  fee  is  paid.  Limitations  in  geographic  scope  are  quite  rare.  Authorization  is 
nationally  valid  in  almost  all  countries,  except  in  Germany  where  Bundesländer  have 
their  own  authorization  procedures  for  architectural  and  engineering  services,  and  in 
France  for temporary architectural services, depending on whether a  shorter  regional 
procedure or a longer national procedure is followed. 

In  light  of  the  focus  of  this  study,  formalities  for  legal  persons,  regulation  related  to 
natural  persons  fall  outside  the  scope.  Hence,  a  situation  where  requirements  apply 
only to natural persons providing the services is listed as absence of a time limitation 
(for the firm).  

May 2017 I 151 

For  establishing  a  branch,  time  limitations  exist  for  architectural  services  in  eight 
countries,  for  engineering  in  five  countries,  and  for  accounting  services  in  three 
countries.  For  temporary  services,  time  limitations  exist  for  architectural  services  in 
eight  countries,  for  engineering  in  six  countries,  and  for  accounting  services  in  five 
countries.  The  restrictions  for  temporary  services  are  typically  resulting  from 
authorization only being given for one year or for the duration of a project. After the 
validity  has  expired,  documents  typically  have  to  be  resubmitted,  although  typically 
fewer than the first time. However, in one country all documents must be resubmitted 
every year for architecture and engineering services.  

Conclusion:  authorizations  are  temporary  in  multiple  countries,  causing  services 
providers to have to repeatedly go through the same procedures. Since repeated costs 
quickly  sum  up  to  more  than  the  initial  one-off  costs,  at  least  documents  with 
permanent  validity  (such  as  qualification  certificates,  although  out  of  scope  of  this 
study) should reasonably not need to be resubmitted every year.  

Obtaining authorization - Fees 

Fees  charged  by  authorities  are  formalities  both  in  themselves  and  even  more  so  if 
only limited modes of payment are accepted. When discussing fees, it should be noted 
that in some cases, fees for professional indemnity insurance are optional, for example 
if  firms  can  choose  between  fees  including  and  excluding  this  insurance.  In  the 
reporting of fees, separate professional indemnity insurance fees are excluded. 

First-time  registration  fees  are  up  to  EUR  1,200  –  EUR  1,400  for  architectural  and 
accountancy services, with annual fees up to EUR 500 and EUR 200 respectively. For 
engineers, fees are typically lower, up to EUR  500 for first-time registration fees and 
around  EUR  100  for  annual  fees.  In  up  to  two  countries  the  first-time  fees  are 
somewhat  higher  for  cross-border  service  providers  than  for  domestic  service 
providers,  namely  for  extra  costs  to  assess  documentary  evidence  of  cross-border 
service  providers.  In  most  countries  a  check  or  a  bank  transfer  from  other  countries 
are  accepted,  but  to  establish  a  branch  in  Malta,  fees  have  to  be  paid  at  the  office 
located in Malta (reported by respondents rather than specified as a requirement).  

Conclusion:  the  fees  that  authorities  charge  can  be  up  to  EUR  1,400  for  the  initial 
authorization and up to EUR 500 annually for continuation of the registration. The fees 
are usually the same for domestic and cross-border service providers and even where 
they  are  not,  the  difference  in  fee  levels  does  not  seem  significant  enough  to  distort 
competition within the Internal Market.  

Obtaining authorization - Electronic information and procedures 

Electronic information and procedures are not formalities, but rather tools to facilitate 
easy  processing  of  formalities.  In  the  current  age  of  digitization,  it  is  rather  their 
absence  that  creates  a  burdensome  formality  to  businesses,  both  with  regard  to 
information  about  the  procedure  and  with  regard  to  electronic  submission  of 
documents.  All  countries  have  a  “Point  of  Single  Contact”  (PSC)  portal,  but  for  four 
countries  covered  in  this  study,  no  information  about  authorization  requirements 
and/or  steps  was  available  on  this  PSC  for  any  of  the  three  services  covered  in  this 
study.  In  addition,  for  another  three  countries,  such  practical  information  was 
available on the PSC portal but not in the English language.  

Also  for  submission  of  documents,  the  digital  options  are  limited  in  some  countries. 
Documents  to  establish  a  branch  needs  to  be  posted  by  mail  in  eight  countries  for 
architectural  services,  in  five  countries  for  engineering  and  in  four  countries  for 
accountancy  services.  More  extremely,  documents  must  be  delivered  in  person  in 
Spain  to  establish  a  branch  in  architecture  or  engineering.  In  other  countries 
documents can be uploaded or emailed (businesses report emailing to be simpler than 
uploading).  In  all  countries,  forms  can  be  downloaded,  although  not  necessarily  all 

152 I May 2017 

Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

forms:  in  Malta  a  national  e-ID  (available  to  residents  only)  is  required  to  download 
forms for architectural and engineering services; foreigners need to request forms via 
an online / email procedure.  

Conclusion:  the  quality  of  “Point  of  Single  Contact”  portals  varies  with  regard  to 
practical  information  and  information  in  English.  Forms  can  generally  be  downloaded 
from the websites of the chambers, but often must be posted and in one country even 
delivered in person. Thus, authorization is not fully supported electronically in this age 
of digitization.  

Obtaining authorization - Data submission demands 

To  gain  authorization  to  access  the  profession,  typically  data  needs  to  be  filled  in  on 
an  application  form,  accompanied  with  supporting  documents.  These  forms  usually 
include name and contact data, and sometimes also request the academic degree or a 
registration  number  of  shareholders  or  managers.  More  burdensome  information 
requirements include the need to provide details on the business structure; to provide 
cadastral  data  on  the  office  in  the  host  country;  or  to  provide  information  for  all 
shareholders  or  managers  on:  the  start  and  end  date  of  all  education  and  post-
education  courses  for  shareholders  or  managers,  detailed  work  experience  tables, 
tables on shares and voting rights, as well as mandates and management positions in 
other legal persons. Each of these specific requirements apply in up to three countries 
across all services covered by this study. For temporary services,  only simple data is 
requested in all countries and for all services covered by this study. 

Conclusion:  in  multiple  countries,  complicated  data  must  be  submitted  to  obtain 
authorization,  varying  from  cadastral  data  to  management  positions  in  other  firms. 
Some of these data are already registered by other authorities in the host country. In 
these  cases,  instead  of  a  requirement  to  submit  data,  a  background  check  might 
suffice, as is for example the case in Luxembourg.  

Obtaining authorization – Required documents, certification and translation 

Common  supporting  documents  that  need  to  accompany  application  forms  are 
company  statutes  and  proof  of  professional  indemnity  insurance.  To  establish  a 
branch,  company  statutes  are  required  in  most  countries  and  depending  on  the 
country  must  include  a  list  of  shareholders  and  their  shares,  or  specific  statements 
about  the  purpose  of  the  firm  or  multidisciplinary  restrictions.  Proof  of  insurance  is 
required in five, four and four countries for architecture, engineering and accountancy 
services  respectively.  In  most  countries  an  insurance  policy  is  required  as  proof. 
However,  for  accountancy  and  architecture,  two  countries  only  require  an  attest  of 
insurance (simple declaration of the insurance provider).  

Other documents that may be required include a shareholder register (for example in 
Belgium  to  establish  an  architecture  branch),  or  a  certificate  of  inscription  in  the 
general business register (for example in Luxembourg), or membership certificates of 
shareholders  or  managers  with  the  professional  chamber  (for  example  in  Austria). 
Belgium  also  requires  annual  accounts  to  be  submitted  if  available  to  establish  an 
architecture branch.  

For  temporary  services,  document  submission  demands  are  more  limited  and  most 
often  include  only  insurance  policies  or  attests,  if  any.  In  practice,  documents  are 
certified in one transaction so the number of documents to be certified has little or no 
impact on the costs.  

When  documents  are  required,  certified  copies  must  be  provided  in  almost  all 
countries.  Documents  which  are  not  in  a  language  of  the  host  country  or  in  English 
must be translated in all countries. Translations must be done by a certified translator 
in  nine,  seven  and  four  countries  for  architecture,  engineering  and  accountancy 

May 2017 I 153 

services,  which  must  be  a  translator  in  the  host  country  in  up  to  two  countries  for 
each of the services covered by this study. Translation requirements are the same for 
branches and temporary services. 

Conclusion:  company  statutes  are  commonly  required,  and  in  addition  proof  of 
professional indemnity insurance (policy or simple declaration of insurer) is required in 
multiple  countries.  As  a  rule  these  documents  must  be  certified  and  translated, 
causing additional administrative costs. However, to the extent that company statutes 
must  also  be  submitted  in  the  home  country,  an  extract  from  the  professional 
chamber  or  even  the  general  business  register  in  the  home  country  might  suffice  as 
proof of a bona fide  service provider and would significantly reduce translation costs. 
The  same  is  true  for  a  certificate  of  the  insurance  provider  instead  of  the  whole 
insurance policy.  

Obtaining authorization - Specific recurrent requirements 

In a few countries, high costs are caused by specific recurrent requirements, namely: 

•  A list of all activities of the firm for architecture services in France; 
•  An annual fee of 1% of income for accountancy services in Romania; 
•  An annual Quality Assurance Regulatory fee for accountancy services in Malta. 

Costs of formalities according to businesses 

The  business  survey  showed  a  number  of  common  formalities  causing  substantial 
costs:  

(cid:131)  Becoming familiar with formalities of the host Member State. This is a 

prerequisite for complying with formalities. This can be simple (one clear 
procedure with one authority – 1 hour), medium in one up to four countries for 
a given service (the applicable procedures depends on the legal form or the 
procedure is not clear – 5 hours) or complex (multiple procedures must be 
followed with different local and regional/national authorities, as is the case to 
establish a branch in federally organized countries such as Belgium, Germany, 
Italy and Spain – 17 hours);  

(cid:131)  Providing internal company data, for example on shareholders of the 

company – typically only to establish a branch. In a few countries, mere ID 
data and possibly registration numbers of shareholders must be submitted (3 
hours). In more countries, the values of shares and/or voting rights must be 
submitted as well (10 hours). In some countries, these data must be included 
in the company statutes (20 hours). The most complex requirement is the 
provision of positions of all shareholders and/or managers in other firms, as is 
required to establish an accountancy branch in Belgium, France and Malta and 
to establish an architecture branch in France (34 hours);  

(cid:131)  Completing forms, usually simple in the form of company ID data (1 hour), 

but with detailed information in up to three countries (e.g. cadastral data, start 
and end dates of qualifications or work experience of shareholders and/or 
managers – 9 hours) and with multiple forms and/or documents for each 
shareholder and/or manager (between two and four countries – 30 hours); 
(cid:131)  Meeting shareholder/voting rights/manager requirements, typically only 

to establish a branch. This is mostly a regulatory obstacle but also creates 
administrative costs. If it is required the cost is reported at 27 hours, but to 
how many firms it applies, depends on whether the requirement applies to all 
legal forms and the exact proportion that must be in the hands of professionals 

154 I May 2017 

 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

(50 or 51% or more). Requirements of 50 or 51% for the partnership legal 
form only apply in one or two countries and are estimated to cause changes for 
5% of the businesses across Europe (category: simple – 1 hour on average). 
Requirements of more than 51% regardless of legal form apply in up to four 
countries and are estimated to affect the majority of businesses (category: 
complex – 27 hours). Requirements in between apply in five or six countries for 
each of the services covered by this study and are estimated to affect 20% of 
the businesses (category: medium – 5 hours); 

(cid:131)  Certification and translation costs. Translation costs EUR 500 for company 

statutes (to establish a branch in a given service) in roughly half of the 
countries, insurance policies (EUR 400 in four countries to establish a branch, 
two countries for temporary services), and/or other certificates (EUR 100, four 
to seven countries to establish a branch). The calculation of costs is in this case 
not based on categories of complexity, but on the number and types of 
documents, and typically range from EUR 100 (if one simple certificate is 
required) to EUR 1,000 (if all types of documents are required); 

(cid:131)  Fees. First-time fees ranging from EUR 14 to EUR 1,400 for architecture and 
accountancy, and from EUR 14 to EUR 500 for engineering, in the majority of 
countries when authorization is required, with annual fees up to EUR 500 for 
architecture and accountancy and EUR 100 for engineering. 

Conclusion:  the  above  list  of  costs  is  far  from  exhaustive,  but  selected  because  they 
are  substantial  in  multiple  countries.  These  costs  indicate  in  which  areas  the  highest 
aggregate cost reductions across the EU might be achieved through simplifications, as 
illustrated in the earlier conclusions per requirement. Since these costs are incurred in 
multiple  host  countries,  this  suggests  a  potential  for  increased  co-ordination  and 
information  sharing  between  Member  States,  for  example  by  accepting  a  standard 
extract  from  the  professional  chamber  in  the  home  country  to  demonstrate  whether 
company statutes meet the legal requirements of the host country.  

In addition, very high costs can be involved with specific requirements that apply in a 
minority of countries, such as: 

(cid:131)  Acquiring language skills. When shareholders or managers need to prove 

mastery of the language, or when they must do an application interview in the 
host country, even if they do not provide the services in the host country, both 
tuition fees and time spent on mastering the language are in scope, as in 
Cyprus (architecture and engineering), Slovakia (architecture), Belgium and 
Romania (accountancy) and Austria (all services covered by this study). This is 
reported to cost up to 80 hours. If essential information about the procedure is 
only available online in a language of the host country, this is reported to cost 
up to 10 hours (in up to six countries); 

(cid:131)  Examination requirements. Applicable to establish an accountancy branch in 
Austria, Belgium and Romania, and depending on the situation (legal form, 
voluntary title in the company name) for architecture and/or engineering in 
Ireland, Malta and Slovakia: an average 65 hours. To establish permanently for 
architecture or engineering services in Austria, two firms reported 150 and 200 
hours of training respectively and 150 hours were used in the cost calculations; 

(cid:131)  Submitting documents in person, required in up to 3 countries depending 

on the service and mode of service provision – an average 12 hours. 

May 2017 I 155 

 
 
Conclusion: since the above requirements cause very high costs but apply in only few 
countries,  there  seems  less  opportunity  for  co-ordinated  action.  Rather,  individual 
Member  States  might  consider  the  necessity  and  costs  of  meeting  these  formalities, 
and whether these could be lightened.  

Table 9.1 summarizes the costs of administrative formalities of legal persons for each 
country,  sector  and  for  both  branches  and  temporary  services.  Excluded  from  these 
costs  are  regulatory  requirements,  such  as  additional  professional  indemnity 
insurance;  requirements  of  the  general  business  register;  and  costs  made  by 
professionals providing the service such as for example in the Czech Republic, Poland 
and Slovakia.  

The figures are weighted averages of costs made by various legal forms. For example, 
requirements that apply only to voluntary professional partnerships (as for example in 
Italy, Portugal and Spain) are weighted by 0.2, reflecting their estimated share of the 
EU’s business population. Also, requirements that only apply to firms wishing to carry 
a  professional  title  in  the  company  such  as  architecture  and  engineering  firms  in 
Germany, architecture firms in Ireland and accountancy firms in the United Kingdom, 
are  weighted  with  0.5,  reflecting  both their  voluntary  nature  and  the  actual  usage  of 
professional titles.  

Table  9.1  Administrative  costs  to  access  cross-border  markets  for  providers 
of architectural, engineering and accountancy services (EUR) 

Host 
Country 
AT 
BE 
CY 
CZ 
DE 
DK 
ES 
FR 
IE 
IT 
LU 
MT 
PL 
PT 
RO 
SK 
UK 

Architecture 
Branches 

35,842 
10,968 
15,858 
4,670 
5,099 
0 
8,425 
7,623 
7,979 
7,630 
5,625 
3,350 
0 
2,328 
184 
5,525 
3,218 

Engineering 

Accounting 

Temp.Serv Branches Temp.Serv Branches  Temp.Serv
169
1,445
0
0
0
0
0
388
144
0
123
26,572
0
400
123
0
3,118

24,476 
17,621 
0 
0 
0 
0 
0 
10,325 
144 
7,591 
7,640 
29,475 
0 
2,945 
45,146 
0 
3,118 

35,596
0
15,858
3,283
3,923
0
7,917
0
0
7,591
4,925
3,309
0
3,614
0
3,436
1,730

65
868
735
1,989
3,623
0
1,786
336
3,091
0
423
94
0
26
161
100
3,218

65
0
735
1,989
3,423
0
1,786
0
0
0
481
62
0
1,119
0
196
1,730

As Table 9.1 shows, for secondary establishment, costs range from a few hundred to 
several  thousands  of  EUR.  Examples  of  particularly  complex  formalities  with  costs  in 
excess of EUR 15,000 include: 

•  For architectural and engineering services: in Austria, for permanent 

establishment the Federal Chamber of Architects and Chartered Engineering 
Consultants only recognizes Austrian legal forms, which for cross-border firms 
necessitates setting up a subsidiary instead of a branch. To that end, the 
executive manager needs to take an examination in Austrian tax law which was 
reported to cost 150 hours. In Cyprus, the costs for establishing a branch are 
high due to a requirement that all shareholders must be professionals and must 
demonstrate adequate knowledge of the Greek language for authorization. In 
other countries, a large part of the costs to establish a branch is caused by 
providing data on shareholders for their authorization; 

156 I May 2017 

 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

•  For accountancy services: in Romania, an annual fee of 1% of income is due, 

considered to be quite costly for branches. In Malta an annual Quality 
Assurance Regulatory Fee is costly, because both are recurrent requirements. 
In addition, shareholders of accountancy firms in Malta, Belgium and Romania 
face an examination, presumably in the language of the host country, even if 
they do not provide services. This means that they have to learn both the local 
regulations and the local language which runs into the costs. However, in Malta 
these costs are only involved for accountancy services involving public financial 
reports.  

For  temporary  cross-border  services,  the  costs  of  formalities  vary  from  zero  or  very 
low  to  well  below  EUR  5,000  for  each  of  the  three  services  investigated.  The  sole 
exception  is  foreign  accountancy  firms  wishing  to  temporary  provide  accountancy 
services in Malta; their costs are close to EUR 30,000 due to the similar requirements 
as for branches including the annual Quality Assurance Regulatory Fee (again: only for 
activities related to public financial reports).  

Estimating the aggregated costs of the administrative formalities 

In  order  to  estimate  the  aggregated  costs  of  administrative  formalities,  the  cost  per 
firm needs to be extrapolated to the costs of all firms.  

As  the  exact  number  of  firms  potentially  interested  in  provision  of  cross-border 
services  cannot  be  determined,  the  study  uses  three  different  scenarios  to  estimate 
these numbers. Recapitulating from the methodology above, these are: 

1.  The base scenario assumes that an additional one per cent of operating firms in 

the three investigated sectors could be mobilized to operate cross-border, 
where it is assumed each of these firms operate in just one cross-border 
country; 

2.  As an alternative scenario and mid-range estimate, it is assumed those 

additional firms would operate in ten other EU countries each; 

3.  Finally, a third scenario / high range estimate is calculated where ten per cent 

of the architecture and engineering firms would operate in ten other EU 
countries. 

All three scenarios are uncertain and in the future an even smaller or larger number of 
companies could decide to go cross-border.  

The aggregate cost of administrative formalities in the base scenario is the product of: 

•  Assumed extra number of cross-border operating firms; 
•  Assumed number of host countries in which they operate cross-border; 
•  The host country weighted cost per authorization.  

For  accountancy,  only  firms  providing  accountancy  services  are  considered,  since 
typically stronger authorization requirements apply to auditing services, and thus also 
to service providers that offer a mix of auditing and accountancy services. For all three 
services, the split between temporary services and branches is assumed to be 50/50.  

Table 9.2 summarizes the outcomes for the above three scenarios. Depending on the 
scenario,  the  cost  of  additional  cross-border  operating  firms  varies  between  EUR  29 
million (lower-end scenario) and EUR 2.9 billion (scenario 3). 

May 2017 I 157 

 
 
 
Table  9.2  Aggregate  costs  of  additional  cross-border  firms  (3  scenarios;  17 
EU host countries of the study), EUR million 

Architecture 

Engineering 

Accountancy 

Total

Branches, 
subsidiarie
s 

Temp. 
Servic
es 

Branches, 
subsidiarie
s

Temp. 
Servic
es

Branches, 
subsidiarie
s 

Temp. 
Services 

9.3 

2.1 

12.9

3.3

1.6 

0.2 

29

93 

21 

129

33

932 

206 

1,292

328

16 

158 

2 

294

20  2,936

Scenario 
1 
Scenario 
2 
Scenario 
3 

Overall conclusion: in some countries, businesses from other EU Member States must 
incur  high  administrative  costs  involved  in  gaining  authorization  to  provide  specific 
services. This hampers the functioning of the EU Internal Market.  

On  the  other  hand,  for  each  of  the  services  considered,  there  are  two  or  more 
countries  where  legal  persons  from  other  EU  countries  do  not  require  authorization, 
thereby causing zero costs. Based on the study, this may give cause to reflect on the 
necessity  of  authorization  requirements,  and  might  even  be  argued  to  cause  an 
unequal playing field.  

All  of  the  authorization  requirements  investigated  in  this  study  appear  to  serve  clear 
purposes, but there is considerable scope to reduce the administrative requirements to 
prove  compliance,  especially  where  documents  already  have  been  assessed  in  the 
home  country,  or  even  in  the  host  country.  The  wide  variation  in  requirements 
indicates  that  in  fact  a  huge  number  of  opportunities  exist  for  simplification  of 
formalities, as illustrated in the conclusions of this report.  

158 I May 2017 

 
 
 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

ANNEX 1 LIST OF CONTACTED AUTHORITIES 

Table A1.1 Contacted authorities and results 

MS  Sector 

Authority 

Web page 

Result; Nr. 
Firms and 
Professionals 
provided and 
via web page

AT  Accountancy  Wirtschaftskammer 

www.bilanzbuchhaltung.or.at  Clarified 

Österreich 

Architecture 
Engineering 

Kammer der Architekten 
und Ingenieurkonsulenten 
für Wien, Niederösterreich 
und Burgenland 

http://wien.arching.at 

BE  Accountancy  Beroepsinstituut van 

www.bibf.be 

Erkende Boekhouders en 
Fiscalisten 

Architecture  Orde van Architecten 

www.ordevanarchitecten.be 

Engineering  None (engineers not 

--- 

regulated) 

CY  Accountancy  The Institute of Certified 

www.icpac.org.cy 

Architecture 
Engineering 

Public Accountants of 
Cyprus 
Cyprus Scientific and 
Technical Chamber 

www.etek.org.cy 

CZ  Accountancy  Komora certifikovanych 

www.komora-ucetnich.cz 

ucetnich 

Architecture  Ceska komora architektu 

www.cka.cz 

Engineering  Česká komora 

www.ckait.cz 

autorizovaných inženýrů a 
techniků činných ve 
výstavbě 

DE  Accountancy  Wirtschaftsprüferkammer 
(WPK) 

www.wpk.de 

Architecture  Bundesarchitektenkammer www.akbw.de 

Engineering  Bundesingineurkammer & 

Ingenieurkammer-Bau 
NRW 

http://bingk.de/ & 
www.ikbaunrw.de 

DK  Accountancy  Danish Business Authority  danishbusinessauthority.dk & 

Architecture  Danske Ark 

www.virk.dk 

www.danskeark.dk & 
www.virk.dk 

formalities; 
F0; F1 
Clarified 
formalities; 
F0; F0 

Completed 
part of the 
inventory; F0; 
F3 
No response; 
F0; F1 
--- 

Clarified 
formalities; 
F0; F0 
Clarified 
formalities; 
F0; F0 

Confirmed 
non-
regulation; F0; 
F0 
Clarified 
formalities; 
F0; F0 
---; F0; F0 

Confirmed 
non-
regulation; 
P0; P69 
(auditors not 
bookkeepers) 
Provided help; 
F6; P11 
Clarified 
formalities; 
F0; P11 
We confirmed 
non-regulation 
online & F0; 
F23 
We confirmed 
voluntary 
registration 
online; F0; 

May 2017 I 159 

 
 
 
 
 
 
 
 
 
 
 
 
 
MS  Sector 

Authority 

Web page 

Engineering  Danish Society of 

www.ida.dk & www.virk.dk 

Engineers (IDA) 

ES  Accountancy 

Institute of Chartered 
Accountants 

www.aece.es 

Architecture  College of architects of 
Madrid 

Engineering  Various colleges of 

engineers 

FR  Accountancy  Ordre des experts-

comptables 

www.coam.es 

www.ciccp.es/ & 
www.coice.es 
www.experts-comptables.fr 

Architecture  Ordre des architectes 

www.architectes.org 

Engineering  None (engineers not 

--- 

IE 

Accountancy 

regulated) 
IAASA; CPA; ACA; 

Architecture  Royal Institute of the 
Architects of Ireland 

www.iaasa.ie; 
www.cpaireland.ie; 
www.charteredaccountants.ie 
www.riai.ie 

Engineering  Engineers Ireland 

www.engineersireland.ie 

IT 

Accountancy  Chamber of Commerce & 
Ordine dei Commercialisti 
e Revisori Contabili 

Architecture  Chamber of Commerce & 

Order of Architects 

www.camera.it & various 
sites of regional Orders 

www.camera.it & various 
sites of regional Orders 

Engineering  Chamber of Commerce & 

Order of Engineers 

www.camera.it & various 
sites of regional Orders 

LU  Accountancy  Ordre des experts-

www.oec.lu 

comptables 

Architecture  Ordre des Architectes et 
des Ingénieurs Conseils 
Engineering 

www.oai.lu 

MT  Accountancy  Malta Institute of 

www.miamalta.org 

Accountants 

Architecture  Kamra-Tal-Periti 

http://ktp.malta.org 

Engineering  Chamber of Engineers 

www.coe.org.mt 

PL  Accountancy  Accountants Association in 
Poland  

www.skwp.pl 

Architecture  National Council of 
Architects Chamber 

www.izbaarchitektow.pl 

Engineering 

Polish Chamber of Civil 
Engineers 

www.piib.org.pl 

PT  Accountancy  Câmara dos Técnicos 

www.occ.pt 

Oficiais de Contas 

160 I May 2017 

Result; Nr. 
Firms and 
Professionals 
provided and 
via web page
P12 & F0; F25 
Clarified 
formalities; 
F0; F0 & F0; 
F91 
Confirmed 
non-
regulation; F0; 
F0 
Consulted 
online, F0; F0 
Consulted 
online; F0; F0 
Consulted 
online; F0; F0 
Provided help; 
F3; P162 
--- 

Consulted 
online; F0; F0 

Consulted 
online; F0; F0 
Consulted 
online; F0; F0 
Clarified 
formalities; 
F0; F0 
Clarified 
formalities; 
F0; F0 
Clarified 
formalities; 
F0; F0 
Clarified 
formalities; 
F0; F2 
Clarified 
formalities; 
F0; F0 
Consulted 
online; F0; 
P30 
Consulted 
online; F0; F0 
Consulted 
online; F0; F0 
Confirmed no 
regulations for 
firms; F0; F0 
Confirmed no 
regulations for 
firms; F0; F0 
Confirmed no 
regulations for 
firms; F0; F0 
Consulted 
online; F0; F0 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

MS  Sector 

Authority 

Web page 

Architecture  Ordem dos Arquitectos 

www.arquitectos.pt 

Engineering  Ordem dos Engenheiros 

www.ordemengenheiros.pt 

RO  Accountancy  CECCAR 

http://ceccar.ro 

Architecture  OAR 

www.oar.archi 

Engineering  AGIR & AICPS 

www.agir.ro & www.aicps.ro 

SK  Accountancy  Slovenská komora 
daňových poradcov 
Architecture  Slovak Chamber of 

www.skcu.sk 

www.komarch.sk 

Architects 

Engineering  Slovak Association of 

UK  Accountancy 

Mechanical Engineers & 
Chamber of Slovak 
Electricians 
Institute of Chartered 
Accountants in England 
and Wales 

www.zsvts.sk & www.sez-
kes.sk 

http://careers.icaew.com 

Architecture  Architects Registration 
Board 

www.arb.org.uk 

Engineering 

Institute of Chartered 
Engineers, Institution of 
Engineering and 
Technology & Institution 
of Mechanical Engineers 

www.ice.org.uk, 
www.theiet.org.uk & 
www.imeche.org 

Result; Nr. 
Firms and 
Professionals 
provided and 
via web page
Consulted 
online; F0; F0 
Consulted 
online; F0; F0 
Clarified 
formalities; 
F0; F0 
Clarified 
formalities; 
F0; F0 
Consulted 
online; F0; F0 
Consulted 
online; F0; F0 
Consulted 
online; F0; F0 
Consulted 
online; F0; F0 

Consulted 
online; F0; F5 

Confirmed 
non-
regulation; F0; 
P82 
Confirmed 
non-
regulation; F0; 
P58 

May 2017 I 161 

 
 
 
 
 
 
 
 
 
 
 
ANNEX 2 BUSINESS QUESTIONNAIRE 

Cross-border services formalities survey 

  Introduction 

The European Commission aims to reduce costs of cross-border services formalities. To this 
end we want to ask you what are the main costs of gaining access to markets of other EU 
countries. 

We estimate that the completing the survey takes 15 minutes. 

Your response will remain anonymous and your participation will be treated in full compliance 
with the data protection laws. 

10 Mode of cross-border services 

1 ALL COMPANIES 

INTERVIEWER CAN FILL THIS IN WITHOUT ASKING 

What is the primary country in which your company is established (home country)?  

Home country = the country of primary establishment in the EU 

(cid:137)  Austria 

(cid:137)  Belgium* 

(cid:137)  Bulgaria 

(cid:137)  Croatia 

(cid:137)  Cyprus 

(cid:137)  Estonia 

(cid:137)  Finland 

(cid:137)  France 

(cid:137)  Germany 

(cid:137)  Greece 

(cid:137)  Italy 

(cid:137)  Latvia 

(cid:137)  Lithuania 

(cid:137)  Luxembourg 

(cid:137)  Malta 

(cid:137)  Czech Republic 

(cid:137)  Hungary 

(cid:137)  Netherlands 

(cid:137)  Portugal 

(cid:137)  Romania 

(cid:137)  Slovakia 

(cid:137)  Slovenia 

(cid:137)  Spain 

(cid:137)  Sweden 

(cid:137)  Denmark 

(cid:137)  Ireland 

(cid:137)  Poland 

(cid:137)  UK 

2 ALL COMPANIES  

Has your company provided or attempted to provide any of the following services in 
other EU countries? 

More than one answer is possible 

(cid:137)  Accountancy (accountancy) 
(cid:137)  Architecture  
(cid:137)  Engineering 
(cid:137)  None of these 
(cid:137)  Do not know 

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Cross-border services formalities survey 

If Q2 = “None of these” end of questionnaire 

If Q2 = “Engineering” go to Q3 

Else go to Q4 

3 COMPANIES THAT PROVIDE OR ENGINEERING SERVICES CROSS-BORDER OR WANT 

TO 

Which types of engineering service(s) has your company provided or attempted to 
provide in other EU countries? 

More than one answer is possible 

(cid:137)  Civil engineering 
(cid:137)  Mechanical engineering 
(cid:137)  Electrical engineering 
(cid:137)  Other engineering 
(cid:137)  Do not know 

4 ALL COMPANIES 

Our study covers primarily branches and agencies (establishments without a 
separate legal entity) and temporary cross-border services.  

Subsidiaries (separate legal entities) are included but costs specific to the setting up 
of a subsidiary will be out of scope.  

Does your company have or attempted to have a branch or agency in any of the 
following countries: 

Please do not include the home country or countries where subsidiaries are established 

More than one answer possible 

(cid:137)  Austria 
(cid:137)  Belgium 
(cid:137)  Cyprus 
(cid:137)  Czech Republic 
(cid:137)  Denmark 

(cid:137)  France
(cid:137)  Germany
(cid:137)  Ireland
(cid:137)  Italy
(cid:137)  Luxembourg 

(cid:137)  Malta
(cid:137)  Poland
(cid:137)  Portugal
(cid:137)  Romania
(cid:137)  Slovakia 

(cid:137)  Spain
(cid:137)  UK 
(cid:137)  None of these
(cid:137)  Do not know

If Q4 = “None of these” or “Do not know” go to Q5 

Else go to Q6 

5 COMPANIES THAT DO NOT HAVE OR ATTEMPTED TO HAVE A CROSS-BORDER 

BRANCH OR AGENCY 

Has your company provided or attempted to provide temporary cross-border 
services in any of the following countries  

Please do not include the home country or countries where subsidiaries are established 

May 2017 I 163 

 
 
 
Cross-border services formalities survey 

More than one answer possible 

(cid:137)  Austria 

(cid:137)  Belgium 

(cid:137)  Cyprus 

(cid:137)  France 

(cid:137)  Germany 

(cid:137)  Ireland 

(cid:137)  Malta 

(cid:137)  Poland 

(cid:137)  Portugal 

(cid:137)  Spain 

(cid:137)  UK 

(cid:137)  None of these

(cid:137)  Czech Republic 

(cid:137)  Italy 

(cid:137)  Romania 

(cid:137)  Do not know 

(cid:137)  Denmark 

(cid:137)  Luxembourg 

(cid:137)  Slovakia 

If Q5 = “None of these” or “Do not know” go to Q6  

Else go to Q8 

6 COMPANIES THAT NEITHER HAVE A CROSS-BORDER BRANCH OR AGENCY, NOR HAVE 

PROVIDED TEMPORARY SERVICES, NOR ATTEMPTED EITHER 

Does your company have or attempted to have a subsidiary in any of the following 
countries (which are covered by our study): 

Please do not include the home country  

More than one answer possible 

(cid:137)  Austria 
(cid:137)  Belgium 
(cid:137)  Cyprus 

(cid:137)  France
(cid:137)  Germany
(cid:137)  Ireland 

(cid:137)  Malta
(cid:137)  Poland
(cid:137)  Portugal 

(cid:137)  Spain 
(cid:137)  UK 
(cid:137)  None of 

(cid:137)  Czech 

(cid:137)  Italy 

(cid:137)  Romania 

(cid:137)  Do not know

Repu

blic 

(cid:137)  Denmark 

(cid:137)  Luxembourg 

(cid:137)  Slovakia 

thes

e

If Q6 = “None of these” or “Do not know” go to end of questionnaire 

7 COMPANIES WITH CROSS-BORDER SUBSIDIARIES AND NOT CROSS-BORDER 

BRANCHES OR TEMPORARY SERVICES 

Did your company have any of the following reasons to establish a subsidiary 
(separate legal entity) instead of just a branch of the home company? 

(cid:137)  Setting up a branch was legally impossible 
(cid:137)  Setting up a branch would require a change of legal form of the home company 
(cid:137)  Setting up a branch would involve too major changes for the home company 

164 I May 2017 

 
 
 
 
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Cross-border services formalities survey 

(cid:137)  Setting up a branch would cause too many problems in dealings with authorities in the host 

country  
(for example because the legal form is not recognized by various authorities in the host 
country) 

(cid:137)  Which laws are applicable is clearer for subsidiaries than for branches 
(cid:137)  Other reason 1, namely … 
(cid:137)  Other reason 2, namely … 
(cid:137)  None of the above 

8 COMPANIES THAT OPERATE CROSS-BORDER IN THE EU OR ATTEMPTED TO 

Which of the following host countries will you provide the answers for? 

Please select one country you are most familiar with, or where your company most recently 
requested authorisation for services 

Only one answer possible 

(cid:137)  Austria 

(cid:137)  Belgium 

(cid:137)  Cyprus 

(cid:137)  Czech 

R
(cid:137)  Denmark 

(cid:137)  France 

(cid:137)  Germany 

(cid:137)  Ireland 

(cid:137)  Italy 

(cid:137)  Malta 

(cid:137)  Poland 

(cid:137)  Portugal 

(cid:137)  Romania 

(cid:137)  Luxembourg 

(cid:137)  Slovakia 

(cid:137)  Spain 

(cid:137)  UK 

9 COMPANIES THAT OPERATE CROSS-BORDER IN THE EU OR ATTEMPTED TO 

Did your company need authorization for temporary provision of services / to 
establish a branch / to establish a subsidiary in [country of Q8]?  

(cid:137)  Yes 
(cid:137)  No, only a notification 
(cid:137)  No 
(cid:137)  Do not know 

If [Q9] = “Yes” go to Q10 

Else go to Q13 

1 COMPANIES THAT OPERATE CROSS-BORDER IN THE EU OR ATTEMPTED TO 

When did your company request authorization for the first time? 

(cid:137)  2016 

(cid:137)  2015 

(cid:137)  2014 

(cid:137)  2013 

(cid:137)  2012 

(cid:137)  2011 

(cid:137)  2010 

(cid:137)  2000-2009 

(cid:137)  Before 2000 

May 2017 I 165 

 
 
 
 
 
 
 
 
 
 
 
Cross-border services formalities survey 

1 COMPANIES THAT OPERATE CROSS-BORDER IN THE EU OR ATTEMPTED TO 

Was the request to for authorization successful? 

(cid:137)  Yes 
(cid:137)  No the request was rejected 
(cid:137)  No we are still considering / preparing the request 
(cid:137)  No the request is still on-going 
(cid:137)  No the decision on the authorization is still pending 

If [Q11] = “Yes” go to Q13 

Else go to Q12  

1 COMPANIES THAT UNSUCCESSFULLY REQUESTED AUTHORISATION 

Does your company still wish to provide cross-border services in [country of Q8]? 

(cid:137)  Yes 
(cid:137)  No 
(cid:137)  Do not know / will not answer  

MAIN QUESTIONNAIRE REGARDING  

-  BRANCHES ESTABLISHED CROSS-BORDER  

-  TEMPORARY CROSS-BORDER SERVICES PROVIDERS (with or without 

authorisation) 

-  OR (PARENT) COMPANIES THAT REQUESTED AUTHORIZATION FOR BRANCHES 

OR TEMPORARY CROSS-BRODER SERVICES /ATTEMPTED TO PROVIDE 
TEMPORARY CROSS-BORDER SERVICES UNSUCCESSFULLY 

IN ONE SPECIFIC COUNTRY COVERED BY THE STUDY  

1 COMPANIES THAT OPERATE CROSS-BORDER IN THE EU OR ATTEMPTED TO 

The remainder of the questionnaire is about costs of authorisation or other 
formalities (prior notifications) to provide services in that country.  

In which currency do you prefer to state the costs? 

We only ask about administrative costs involved in getting access to the market.  

Administrative costs involved with on-going projects are out of scope. 

(cid:137)  Euro 
(cid:137)  Bulgarian lev (2 for 1 euro) 
(cid:137)  Croatian kuna (8 for 1 euro) 
(cid:137)  Czech koruna (28 for 1 euro) 
(cid:137)  Danish krone (7 for 1 euro) 

166 I May 2017 

 
 
 
 
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Cross-border services formalities survey 

(cid:137)  Hungarian forint (300 for 1 euro) 
(cid:137)  Norwegian krone (8 for 1 euro) 
(cid:137)  Polish zloty (4 for 1 euro) 
(cid:137)  Romanian leu (4 for 1 euro) 
(cid:137)  Swedish krona (9 for 1 euro) 
(cid:137)  Swiss franc (1.2 for 1 euro) 
(cid:137)  UK pound sterling (0.8 for 1 euro) 
(cid:137)  Other, please specify 

1 ALL CROSS-BORDER COMPANIES 

Familiarisation and data / document collection steps 

To legally start provision of services in that country, several steps are required to 
collect data and documents, apart from translations and certifications.  

Can you please indicate which of the following data collection steps are or were 
needed?  

Please provide estimates if not certain 

Please do not include additional costs that you know to be specific to establishing a subsidiary 
(incorporation), nor company registration in general business registers 

For only the selected steps: 

•  Please indicate which categories of staff managed each data collection step?  
(In-house senior manager / in-house professional / in-house administrator, outsourced to a 
third party) 

For only the selected categories of in-house staff for each selected step: 

•  How many hours does each in-house category of staff spend on the step? 

For each selected step: 

•  What are the fees of third parties and/or authorities  

Please select the relevant steps 

Fees of 
authorities 
/ third 
parties  

Authorities 
providing 
documents 

Third parties 
(if 
outsourced) 

Which category 
of staff 
managed each 
step? (more than 
one category 
possible) 

Hours 
required 
for each 
step and 
category 
of staff 

In-house senior 
manager  

In-house 
professional 

In-house 
administrator 

Outsourced to a 
third party 

a.  Identification and familiarisation 

with the requirements 

May 2017 I 167 

 
 
 
 
 
Cross-border services formalities survey 

b.  Downloading / requesting and 
completing application forms  

c.  Collecting proof from home country 
authorities that demonstrates 
equivalent requirements have been 
met  

d.  Collecting documents in person 

e.  Collating other documents that you 

had immediate access to  

f.  Collecting certificates of previous 

employment  

g.  Collecting other data on 

management/shareholders/professio
nals  

h.  Collecting any other data 

i.  Other collection procedure, (please 

describe) 

j.  Second other collection procedure 

(please describe) 

ALL CROSS-BORDER COMPANIES  

Most burdensome requirement relating to data collection steps 

Please indicate which data collection step was most burdensome and explain why  

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

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

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

ALL CROSS-BORDER COMPANIES  

Purchases of services 

Some services may need to be requested or purchased such as translation or 

certification of documents or insurance. 

Please, which of the following services needed to be purchased to legally provide services in 
that country? 

Certification of documents means a stamp, a document attesting authenticity, a sworn 
statement before a notary or a court of law, or anything else required to certify the 
truthfulness of documents 

168 I May 2017 

1

1

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

Cross-border services formalities survey 

We do not refer to certification of professionals or the company 

Please provide estimates if not certain 

Please do not include additional costs that you know to be specific to establishing a 
subsidiary(incorporation), nor company registration in general business registers 

For only the selected steps: 

•  Please indicate which categories of staff managed each purchase of services?  
(In-house senior manager / in-house professional / in-house administrator, outsourced to a 
third party) 

For only the selected categories of in-house staff for each selected step: 

•  How many hours does each in-house category of staff spend on the step? 

For each selected step: 

•  What are the fees of third parties and/or authorities  

Please select the relevant 
services 

Hours 
required 
for each 
purchase 
of 
services 
and 
category 
of staff 

Fees of 
authorities / 
third parties  

Authorities 
providing the 
service 

Third parties (if 
outsourced) 

Which category of 
staff managed each 
step? (more than 
one category 
possible) 

In-house senior 
manager  

In-house professional 

In-house 
administrator 

Outsourced to a third 
party 

a.  Identifying translators and 

translation fees 

b.  Identifying certifying authorities 

and certification fees 
c.  Purchasing additional 

professional indemnity 
insurance coverage 

d.  Other similar step (please 

describe)  

e.  Second other similar step 

(please describe) 

f.  None of the above 

ALL CROSS-BORDER COMPANIES,  

1

Most burdensome purchase of services 

Please indicate which purchase of services was most burdensome and explain why  

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

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

May 2017 I 169 

 
 
 
 
 
 
 
 
 
Cross-border services formalities survey 

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

1 ALL CROSS-BORDER COMPANIES 

Activities to meet company, organisational and competency requirements 

Sometimes the company in the home country needs to make adjustments to its 
structure, or specific requirements apply to managers and/or professionals of the 
company or the branch.  

Please, which of the following changes are or were needed to legally provide 
services in that country?  

Please provide estimates if not certain 

Please do not include additional costs that you know to be specific to establishing a subsidiary 
(incorporation), nor company registration in general business registers 

For only the selected steps: 

•  Please indicate which categories of staff were involved with these changes  
(In-house senior manager / in-house professional / in-house administrator, outsourced to a 
third party) 

For only the selected categories of in-house staff for each selected step: 

•  How many hours does each in-house category of staff spend on the step? 

For each selected step: 

•  What are the fees of third parties and/or authorities 

Please select the relevant 
services 

Which category of 
staff managed each 
step? (more than one 
category possible) 

In-house senior 
manager  

In-house professional 

In-house 
administrator 

Outsourced to a third 
party 

Hours 
required 
for each 
purchase 
of 
services 
and 
category 
of staff 

Fees of 
authorities / 
third parties  

Authorities 
(enabling or 
assisting the 
change) 

Third parties (if 
outsourced) 

a.  Legal form changes 

b.  New allocation of shares or voting 

rights 

c.  New management composition 

d.  Minimum capital requirements 

(but not the invested capital) 
e.  Securing a professional address 

in the host country  

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Cross-border services formalities survey 

f.  Extra professional training 

requirements in the host country 
g.  Examination in the host country 

h.  Acquiring language skills 

i.  Application interview  

j.  Other change for company or 

staff (please describe) 

k.  Second other change (please 

describe) 

l.  None of the above 

ALL CROSS-BORDER COMPANIES,  

1

Most burdensome change for company or staff 

Please indicate the most burdensome required change for company or staff and 

explain why  

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

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

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

2 ALL CROSS-BORDER COMPANIES 

Submission of the application and payment of authorisation fees 

The application need to be submitted with all data and documents, and typically the 
chamber or other authorising authority charges fees.  

Please indicate which of the following steps are or were needed for this part of the 
formalities?  

Please also mention any other steps we have not covered so far.  

Please provide estimates if not certain 

Please do not include additional costs that you know to be specific to establishing a 
subsidiary(incorporation), nor company registration in general business registers 

For only the selected steps: 

•  Which category of staff managed the submission and any other steps not 

covered so far?  
(In-house senior manager / in-house professional / in-house administrator, outsourced to a 
third party) 

May 2017 I 171 

 
 
 
 
 
 
 
 
 
 
 
Cross-border services formalities survey 

For only the selected categories of in-house staff for each selected step: 

•  How many hours does each in-house category of staff spend on the step? 

For each selected step: 

•  What are the fees of third parties and/or authorities 

Please review and select which 
steps apply from the drop down 
list (a to d)  

Which category of 
staff managed each 
step? (more than one 
category possible) 

In-house senior 
manager  

In-house professional 

In-house 
administrator 

Outsourced to a third 
party 

Hours 
required 
for each 
purchase 
of 
services 
and 
category 
of staff 

Fees of 
authorities 
/ third 
parties  

Authorities 
(enabling or 
assisting 
the change) 

Third 
parties (if 
outsourced) 

a.  Authorisation and/or 
registration fees 

b.  Membership fee of the 

professional body or/ chamber 

c.  Submitting the application 
electronically or by post 

d.  Submitting documents in 

person  

e.  Any other step not covered so 

far (please describe)  

f.  Second other step not covered 

so far (please describe)  

g.  None of the above 

2 ALL CROSS-BORDER COMPANIES  

Most burdensome submission demand or any other step 

Please indicate the most burdensome submission demand or any other step not 

covered so far and explain why  

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

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

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

2 ALL CROSS-BORDER COMPANIES 

Are there any recurrent steps to stay authorized and if so which, how often and 

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Cross-border services formalities survey 

what are the costs? 

Please provide estimates if you are not certain 

Currency 

E.g. euro, zloty, 

Every 
… year 

… times 
per year

Whenever 
condition 
applies 
(Yes/skip)

Hoursper 
event 

Costs 
per 
event 

a.  Renewal of authorisation  

b.  Membership fees 

c.  Training requirements 

d.  New authorization if management 

changes 

e.  Other, namely…  

f.  Second other, namely …  

g.  None of the above 

2 ALL CROSS-BORDER COMPANIES  

The next question is about the hourly average salary rates of the categories of staff 
managing the procedures. In which currency do you prefer to state the salary rates? 

(cid:137)  Euro 
(cid:137)  Bulgarian lev (2 for 1 euro) 
(cid:137)  Croatian kuna (8 for 1 euro) 
(cid:137)  Czech koruna (28 for 1 euro) 
(cid:137)  Danish krone (7 for 1 euro) 
(cid:137)  Hungarian forint (300 for 1 euro) 
(cid:137)  Norwegian krone (8 for 1 euro) 
(cid:137)  Polish zloty (4 for 1 euro) 
(cid:137)  Romanian leu (4 for 1 euro) 
(cid:137)  Swedish krona (9 for 1 euro) 
(cid:137)  Swiss franc (1.2 for 1 euro) 
(cid:137)  UK pound sterling (0.8 for 1 euro) 
(cid:137)  Other, please specify 

2 ALL CROSS-BORDER COMPANIES 

Can you please estimate the hourly average salary rate of the categories of staff 
managing the procedures? 

Please provide estimates if you are not certain 

Professional 
Category  

Salary rate 

May 2017 I 173 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Cross-border services formalities survey 

a.  Senior 

Manager  
b.  Professional  

c.  Administrator  

2 ALTERNATIVES TO AVOID OR REDUCE COSTS  

Has your company been able to avoid or significantly reduce the costs of any 
formality? 

(cid:137)  Yes 
(cid:137)  No 
(cid:137)  Do not know 

If [Q23] = Yes go to Q24 

Else go to Q25 (end of questionnaire) 

2 ALTERNATIVES TO AVOID OR REDUCE COSTS  

Please explain how your company avoided or significantly reduced the costs of 
formalities 

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

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

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

11  END OF QUESTIONNAIRE 

Please provide any final comments on the questionnaire or the topic if you wish to.  

2

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

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

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

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

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

174 I May 2017 

 
 
 
 
 
 
 
 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

Cross-border services formalities survey 

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

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

Thank you cordially for your contribution to the study! 

The  table  below  outlines  the  number  of  firms  and  persons  identified  which  have  a 
provided  temporary  services  cross-border  in  the  period  2010-2014,  or  have 
established  a  branch  or  subsidiary  cross-border.  In  total  1,930  firms  were  identified 
and 435 persons.  

Of these, some firms were out of scope for various reasons of which we list the most 
frequent below: 

-  Architecture (rarely) if a client classified for example a cost-benefit analysis of 

a construction project as architecture related; 

-  Engineering:  if  a  division  of  a  firm  such  as  oil,  gas,  offshore,  railways  or  air 
transport.  They  are  engineers  and  provide  services  cross-border,  but  the 
design  is  mostly  done  in  the  home  country.  Also  real  estate  companies 
generally proved out of scope. 

-  Accountancy: if a financial holding company (a “letterbox” company). 

As  a  result,  the  in-scope  population  of  firms  consists  of  1,688  firms,  of  which  312 
architecture firms, 1,225 engineering firms and 151 accounting firms.  

For  persons,  it  was  generally  not  possible  to  get  contact  data,  unless  they  have 
established  a  company  with  their  full  first  name  and  family  name.  If  necessary  all 
firms  (and  persons)  were  called  for  which  contact  data  were  identified,  unless  the 
target  of  four  or  five  contacts  was  reached  earlier.  In  total,  contacts  were  attempted 
with 1,087 firms and/or persons.  

Table A 3.1 Populations identified, in scope, with contact data and called  

Host 

Sector  Mode 

Nr. Identified  

In scope 

Contact data 

Called 

MS 

AT 

Arch. 

(firms & 
persons) 

(firms & 
persons) 

(firms & 
persons) 

(firms & 
persons) 

Temp 
Serv. 

Branch/
subs 

10 

0 

0

0

10

0

0

0

10

0

0 

0 

10 

0 

0

0

May 2017 I 175 

 
 
 
 
 
 
 
 
Host 

Sector  Mode 

Nr. Identified  

In scope 

Contact data 

Called 

MS 

(firms & 
persons) 

(firms & 
persons) 

(firms & 
persons) 

(firms & 
persons) 

7 

58 

2 

0 

9 

1 

18 

50 

1 

16 

10 

1 

6 

18 

1 

3 

4 

6 

0

0

0

0

1

0

0

0

3

0

0

0

0

0

0

0

97

0

7

58

1

0

9

0

12

46

1

5

10

0

6

17

1

1

3

3

0

0

0

0

1

0

0

0

3

0

0

0

0

0

0

0

97

0

7

38

0

0

9

0

12

40

1

4

10

0

5

17

1

1

3

3

0 

0 

0 

0 

1 

0 

0 

0 

3 

0 

0 

0 

0 

0 

0 

0 

5 

0 

7 

10 

0 

0 

9 

0 

12 

40 

1 

4 

10 

0 

5 

17 

1 

1 

3 

3 

0

0

0

0

1

0

0

0

3

0

0

0

0

0

0

0

5

0

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Eng. 

Acc. 

BE 

Arch. 

Eng. 

Acc. 

CY 

Arch. 

Eng. 

Acc. 

CZ 

Arch. 

176 I May 2017 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

Host 

Sector  Mode 

Nr. Identified  

In scope 

Contact data 

Called 

MS 

(firms & 
persons) 

(firms & 
persons) 

(firms & 
persons) 

(firms & 
persons) 

Eng. 

Acc. 

DE 

Arch. 

Eng. 

Acc. 

DK 

Arch. 

Eng. 

Acc. 

ES 

Arch. 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

6 

53 

1 

17 

0

0

0

0

6

53

1

12

0

0

0

0

6

22

1

8

19 

10

19

10

19

11 

0

11

0

6

19 

11

19

11

19

120 

0

118

0

61

0 

69

0

69

33 

4 

26 

5 

93 

0 

22 

1 

6 

0

0

0

0

0

0

0

0

0

11

4

25

5

91

0

21

1

6

0

0

0

0

0

0

0

0

0

0

6

4

11

5

47

0

12

1

6

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

6 

22 

1 

8 

19 

6 

19 

20 

0 

6 

4 

11 

5 

20 

0 

12 

1 

6 

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

May 2017 I 177 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Host 

Sector  Mode 

Nr. Identified  

In scope 

Contact data 

Called 

MS 

(firms & 
persons) 

(firms & 
persons) 

(firms & 
persons) 

(firms & 
persons) 

13 

62 

0 

13 

0

0

0

0

13

60

0

6

0

0

0

0

13

41

0

4

0 

0 

0 

0 

13 

41 

0 

4 

0

0

0

0

36 

156

33

156

33

20 

33 

20

8 

26 

61 

0 

22 

18 

1 

0

0

0

0

0

0

0

7

24

60

0

9

18

1

0

0

0

0

0

0

0

7

24

17

0

3

18

1

45 

36

35

36

35

24 

4 

9 

5 

4 

0

0

0

0

0

22

3

4

5

3

0

0

0

0

0

17

3

4

5

1

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

7 

24 

17 

0 

3 

18 

1 

35 

17 

3 

4 

5 

1 

0

0

0

0

0

0

0

0

0

0

0

0

0

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Eng. 

Acc. 

FR 

Arch. 

Eng. 

Acc. 

IE 

Arch. 

Eng. 

Acc. 

IT 

Arch. 

178 I May 2017 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

Host 

Sector  Mode 

Nr. Identified  

In scope 

Contact data 

Called 

MS 

(firms & 
persons) 

(firms & 
persons) 

(firms & 
persons) 

(firms & 
persons) 

Eng. 

Acc. 

LU 

Arch. 

Eng. 

Acc. 

MT 

Arch. 

Eng. 

Acc. 

PL 

Arch. 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

4 

57 

0 

24 

6 

3 

5 

21 

2 

19 

1 

1 

6 

5 

0 

0 

17 

11 

0

0

0

0

1

0

0

0

0

0

0

0

0

0

0

0

0

0

4

57

0

5

6

3

4

21

2

10

1

1

6

5

0

0

17

11

0

0

0

0

1

0

0

0

0

0

0

0

0

0

0

0

0

0

4

12

0

1

6

3

4

10

2

2

1

1

6

5

0

0

17

7

0 

0 

0 

0 

1 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

4 

12 

0 

1 

6 

3 

4 

10 

2 

2 

1 

1 

6 

5 

0 

0 

17 

7 

0

0

0

0

1

0

0

0

0

0

0

0

0

0

0

0

0

0

May 2017 I 179 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Host 

Sector  Mode 

Nr. Identified  

In scope 

Contact data 

Called 

MS 

(firms & 
persons) 

(firms & 
persons) 

(firms & 
persons) 

(firms & 
persons) 

17 

92 

0 

18 

4 

1 

2 

46 

3 

37 

1 

9 

16 

102 

0 

23 

5 

4 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Eng. 

Acc. 

PT 

Arch. 

Eng. 

Acc. 

RO 

Arch. 

Eng. 

Acc. 

SK 

Arch. 

180 I May 2017 

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

17

91

0

9

4

0

2

45

3

8

1

9

14

102

0

11

5

4

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

17

58

0

5

4

0

2

36

3

6

1

7

14

30

0

8

5

3

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

17 

58 

0 

5 

4 

0 

2 

36 

3 

6 

1 

7 

14 

30 

0 

8 

5 

3 

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

Host 

Sector  Mode 

Nr. Identified  

In scope 

Contact data 

Called 

MS 

(firms & 
persons) 

(firms & 
persons) 

(firms & 
persons) 

(firms & 
persons) 

Eng. 

Acc. 

UK 

Arch. 

Eng. 

Acc. 

Total  Arch. 

Eng. 

Acc. 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

Temp 
Serv. 

Branch/
subs 

6 

65 

0 

24 

0

0

0

0

6

64

0

14

0

0

0

0

6

36

0

5

65 

22

65

22

65

16 

0

16

0

13

64 

10

54

10

54

87 

1 

31 

0

0

0

81

1

12

0

0

0

66

1

6

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

6 

36 

0 

5 

65 

13 

54 

66 

1 

6 

0

0

0

0

0

0

0

0

0

0

215 

287

211

287

211

27 

211 

27

109 

0

100

0

69

0 

69 

265 

57

234

57

233

0 

233 

1014 

0

991

0

553

0 

457 

15 

72

13

72

12

311 

0

138

0

75

3 

0 

12 

75 

0

0

0

3

0

Total  Total 

Total 

1929 

416

1687

416

1153

30 

1057 

30

Up to three calls per firm were made, resulting in a total of 52 completed interviews, 
with the breakdown given in Table A3.2. 

May 2017 I 181 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table A3.2 Firms called, completed responses achieved and the response rate 

Host 

Profession  Mode 

Nr called

Complete 
response 

Response rate

MS 

AT 

Architecture  Temp Serv. 

Branch/subs 

Engineering 

Temp Serv. 

Branch/subs 

Accountancy Temp Serv. 

Branch/subs 

BE 

Architecture  Temp Serv. 

Branch/subs 

Engineering 

Temp Serv. 

Branch/subs 

Accountancy Temp Serv. 

Branch/subs 

CY 

Architecture  Temp Serv. 

Branch/subs 

Engineering 

Temp Serv. 

Branch/subs 

Accountancy Temp Serv. 

Branch/subs 

CZ 

Architecture  Temp Serv. 

Branch/subs 

Engineering 

Temp Serv. 

Branch/subs 

Accountancy Temp Serv. 

Branch/subs 

DE 

Architecture  Temp Serv. 

Branch/subs 

Engineering 

Temp Serv. 

182 I May 2017 

10

0

7

10

0

0

10

0

12

40

4

4

10

0

5

17

1

1

8

3

6

22

1

8

19

6

19

1 

0 

1 

2 

0 

0 

0 

0 

1 

1 

0 

0 

1 

0 

2 

1 

0 

0 

0 

1 

2 

0 

1 

0 

1 

2 

1 

10%

---

14%

20%

---

---

0%

---

8%

3%

0%

0%

10%

---

40%

6%

0%

0%

0%

33%

33%

0%

100%

0%

5%

33%

5%

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

Host 

Profession  Mode 

Nr called

Complete 
response 

Response rate

MS 

Branch/subs 

Accountancy Temp Serv. 

Branch/subs 

DK 

Architecture  Temp Serv. 

Branch/subs 

Engineering 

Temp Serv. 

Branch/subs 

Accountancy Temp Serv. 

Branch/subs 

ES 

Architecture  Temp Serv. 

Branch/subs 

Engineering 

Temp Serv. 

Branch/subs 

Accountancy Temp Serv. 

Branch/subs 

FR 

Architecture  Temp Serv. 

Branch/subs 

Engineering 

Temp Serv. 

Branch/subs 

Accountancy Temp Serv. 

Branch/subs 

IE 

Architecture  Temp Serv. 

Branch/subs 

Engineering 

Temp Serv. 

Branch/subs 

Accountancy Temp Serv. 

Branch/subs 

IT 

Architecture  Temp Serv. 

20

0

6

4

11

5

20

0

12

1

6

13

41

0

4

53

7

24

17

0

3

18

1

35

17

3

4

5

0 

0 

1 

0 

0 

1 

3 

0 

0 

0 

0 

1 

3 

0 

0 

0 

2 

1 

0 

0 

0 

1 

0 

2 

0 

0 

0 

1 

0%

---

17%

0%

0%

20%

15%

---

0%

0%

0%

8%

7%

---

0%

0%

29%

4%

0%

---

0%

6%

0%

6%

0%

0%

0%

20%

May 2017 I 183 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Host 

Profession  Mode 

Nr called

Complete 
response 

Response rate

MS 

Branch/subs 

Engineering 

Temp Serv. 

Branch/subs 

Accountancy Temp Serv. 

Branch/subs 

LU 

Architecture  Temp Serv. 

Branch/subs 

Engineering 

Temp Serv. 

1

4

12

0

1

7

3

4

Branch/subs 

10

Accountancy Temp Serv. 

Branch/subs 

MT 

Architecture  Temp Serv. 

Branch/subs 

Engineering 

Temp Serv. 

Branch/subs 

Accountancy Temp Serv. 

Branch/subs 

PL 

Architecture  Temp Serv. 

Branch/subs 

Engineering 

Temp Serv. 

Branch/subs 

Accountancy Temp Serv. 

Branch/subs 

PT 

Architecture  Temp Serv. 

Branch/subs 

Engineering 

Temp Serv. 

Branch/subs 

Accountancy Temp Serv. 

184 I May 2017 

2

2

1

1

6

5

0

0

17

7

17

58

0

5

4

0

2

36

3

0 

1 

1 

0 

0 

1 

1 

0 

0 

0 

1 

0 

1 

2 

0 

0 

0 

0 

0 

0 

1 

0 

0 

2 

0 

1 

0 

0 

0%

25%

8%

---

0%

14%

33%

0%

0%

0%

50%

0%

100%

33%

0%

---

---

0%

0%

0%

2%

---

0%

50%

---

50%

0%

0%

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

Host 

Profession  Mode 

Nr called

Complete 
response 

Response rate

MS 

Branch/subs 

RO 

Architecture  Temp Serv. 

Branch/subs 

Engineering 

Temp Serv. 

Branch/subs 

Accountancy Temp Serv. 

Branch/subs 

SK 

Architecture  Temp Serv. 

Branch/subs 

Engineering 

Temp Serv. 

Branch/subs 

Accountancy Temp Serv. 

Branch/subs 

UK 

Architecture  Temp Serv. 

Branch/subs 

Engineering 

Temp Serv. 

Branch/subs 

Accountancy Temp Serv. 

Branch/subs 

Total  Architecture  Temp Serv. 

Branch/subs 

Engineering 

Temp Serv. 

Branch/subs 

Accountancy Temp Serv. 

Branch/subs 

6

1

7

14

30

0

8

5

3

6

36

0

5

65

13

54

66

1

6

238

69

233

447

15

75

Total  Total 

Total 

1,077

0 

0 

0 

0 

2 

0 

1 

0 

1 

1 

0 

0 

0 

0 

1 

0 

1 

0 

1 

8 

9 

17 

13 

1 

4 

52 

0%

0%

0%

0%

7%

---

13%

0%

33%

17%

0%

---

0%

0%

8%

0%

2%

0%

17%

3%

13%

7%

3%

7%

5%

5%

May 2017 I 185 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 3 BUSINESS RESPONSE OVERVIEW 

The  table  below  outlines  the  number  of  firms  and  persons  identified  which  have  a 
provided  temporary  services  cross-border  in  the  period  2010-2014,  or  have 
established  a  branch  or  subsidiary  cross-border.  In  total  1,930  firms  were  identified 
and 435 persons.  

Of these, some firms were out of scope for various reasons of which we list the most 
frequent below: 

•  Architecture (rarely) if a client classified for example a cost-benefit analysis of 

a construction project as architecture related; 

•  Engineering: if a division of a firm such as oil, gas, offshore, railways or air 
transport. They are engineers and provide services cross-border, but the 
design is mostly done in the home country. Also real estate companies 
generally proved out of scope. 

•  Accountancy: if a financial holding company (a “letterbox” company). 

As  a  result,  the  in-scope  population  of  firms  consists  of  1,688  firms,  of  which  312 
architecture firms, 1,225 engineering firms and 151 accounting firms.  

For  persons,  it  was  generally  not  possible  to  get  contact  data,  unless  they  have 
established  a  company  with  their  full  first  name  and  family  name.  If  necessary  all 
firms  (and  persons)  were  called  for  which  contact  data  were  identified,  unless  the 
target  of  four  or  five  contacts  was  reached  earlier.  In  total,  contacts  were  attempted 
with 1,087 firms and/or persons.  

Table A3.1 Populations identified, in scope, with contact data and called  

Host 
MS 

Sector  Mode 

AT 

Arch. 

Eng. 

Acc. 

BE 

Arch. 

Eng. 

Acc. 

CY 

Arch. 

Eng. 

Acc. 

CZ 

Arch. 

Eng. 

Acc. 

186 I May 2017 

Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 

Nr. 
Identified  
(firms & 
persons) 
10 
0 
7 
58 
2 
0 
9 
1 
18 
50 
1 
16 
10 
1 
6 
18 
1 
3 
4 
6 
6 
53 
1 

0
0
0
0
0
0
1
0
0
0
3
0
0
0
0
0
0
0
97
0
0
0
0

In scope 
(firms & 
persons) 

Contact data 
(firms & 
persons) 

Called 
(firms & 
persons) 

10
0
7
58
1
0
9
0
12
46
1
5
10
0
6
17
1
1
3
3
6
53
1

0
0
0
0
0
0
1
0
0
0
3
0
0
0
0
0
0
0
97
0
0
0
0

10
0
7
38
0
0
9
0
12
40
1
4
10
0
5
17
1
1
3
3
6
22
1

0 
0 
0 
0 
0 
0 
1 
0 
0 
0 
3 
0 
0 
0 
0 
0 
0 
0 
5 
0 
0 
0 
0 

10 
0 
7 
10 
0 
0 
9 
0 
12 
40 
1 
4 
10 
0 
5 
17 
1 
1 
3 
3 
6 
22 
1 

0
0
0
0
0
0
1
0
0
0
3
0
0
0
0
0
0
0
5
0
0
0
0

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

Host 
MS 

Sector  Mode 

DE 

Arch. 

Eng. 

Acc. 

DK 

Arch. 

Eng. 

Acc. 

ES 

Arch. 

Eng. 

Acc. 

FR 

Arch. 

Eng. 

Acc. 

IE 

Arch. 

Eng. 

Acc. 

IT 

Arch. 

Eng. 

Acc. 

LU 

Arch. 

Eng. 

Acc. 

MT 

Arch. 

Eng. 

Acc. 

PL 

Arch. 

Eng. 

Acc. 

PT 

Arch. 

Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 

Nr. 
Identified  
(firms & 
persons) 
17 
19 
11 
19 
120 
0 
33 
4 
26 
5 
93 
0 
22 
1 
6 
13 
62 
0 
13 
36 
8 
26 
61 
0 
22 
18 
1 
45 
24 
4 
9 
5 
4 
4 
57 
0 
24 
6 
3 
5 
21 
2 
19 
1 
1 
6 
5 
0 
0 
17 
11 
17 
92 
0 
18 
4 
1 

0
10
0
11
0
69
0
0
0
0
0
0
0
0
0
0
0
0
0
156
0
0
0
0
0
0
0
36
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

In scope 
(firms & 
persons) 

Contact data 
(firms & 
persons) 

Called 
(firms & 
persons) 

12
19
11
19
118
0
11
4
25
5
91
0
21
1
6
13
60
0
6
33
7
24
60
0
9
18
1
35
22
3
4
5
3
4
57
0
5
6
3
4
21
2
10
1
1
6
5
0
0
17
11
17
91
0
9
4
0

0
10
0
11
0
69
0
0
0
0
0
0
0
0
0
0
0
0
0
156
0
0
0
0
0
0
0
36
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

8
19
6
19
61
0
6
4
11
5
47
0
12
1
6
13
41
0
4
33
7
24
17
0
3
18
1
35
17
3
4
5
1
4
12
0
1
6
3
4
10
2
2
1
1
6
5
0
0
17
7
17
58
0
5
4
0

0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
20 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
1 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 

8 
19 
6 
19 
20 
0 
6 
4 
11 
5 
20 
0 
12 
1 
6 
13 
41 
0 
4 
33 
7 
24 
17 
0 
3 
18 
1 
35 
17 
3 
4 
5 
1 
4 
12 
0 
1 
6 
3 
4 
10 
2 
2 
1 
1 
6 
5 
0 
0 
17 
7 
17 
58 
0 
5 
4 
0 

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
20
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

May 2017 I 187 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Host 
MS 

Sector  Mode 

Eng. 

Acc. 

RO 

Arch. 

Eng. 

Acc. 

SK 

Arch. 

Eng. 

Acc. 

UK 

Arch. 

Eng. 

Acc. 

Total  Arch. 

Eng. 

Acc. 

Total  Total 

Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Total 

Nr. 
Identified  
(firms & 
persons) 
2 
46 
3 
37 
1 
9 
16 
102 
0 
23 
5 
4 
6 
65 
0 
24 
65 
16 
64 
87 
1 
31 
215 
109 
265 
1014 
15 
311 
1929 

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
22
0
10
0
0
0
287
0
57
0
72
0
416

In scope 
(firms & 
persons) 

Contact data 
(firms & 
persons) 

Called 
(firms & 
persons) 

2
45
3
8
1
9
14
102
0
11
5
4
6
64
0
14
65
16
54
81
1
12
211
100
234
991
13
138
1687

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
22
0
10
0
0
0
287
0
57
0
72
0
416

2
36
3
6
1
7
14
30
0
8
5
3
6
36
0
5
65
13
54
66
1
6
211
69
233
553
12
75
1153

0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
27 
0 
0 
0 
3 
0 
30 

2 
36 
3 
6 
1 
7 
14 
30 
0 
8 
5 
3 
6 
36 
0 
5 
65 
13 
54 
66 
1 
6 
211 
69 
233 
457 
12 
75 
1057 

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
27
0
0
0
3
0
30

Up to three calls per firm were made, resulting in a total of 52 completed interviews, 
with the breakdown given in Table A3.2. 

Table A 3.2 Firms called, completed responses achieved and the response 
rate 

Profession 

Mode 

Nr called

Host 
MS 
AT 

Architecture 

Engineering 

Accountancy 

BE 

Architecture 

Engineering 

Accountancy 

CY 

Architecture 

Engineering 

Accountancy 

188 I May 2017 

Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 

10
0
7
10
0
0
10
0
12
40
4
4
10
0
5
17
1
1

Complete 
response 
1 
0 
1 
2 
0 
0 
0 
0 
1 
1 
0 
0 
1 
0 
2 
1 
0 
0 

Response 
rate
10%
---
14%
20%
---
---
0%
---
8%
3%
0%
0%
10%
---
40%
6%
0%
0%

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

Profession 

Mode 

Nr called

Host 
MS 
CZ 

Architecture 

Engineering 

Accountancy 

DE 

Architecture 

Engineering 

Accountancy 

DK 

Architecture 

Engineering 

Accountancy 

ES 

Architecture 

Engineering 

Accountancy 

FR 

Architecture 

Engineering 

Accountancy 

IE 

Architecture 

Engineering 

Accountancy 

IT 

Architecture 

Engineering 

Accountancy 

LU 

Architecture 

Engineering 

Accountancy 

MT 

Architecture 

Engineering 

Accountancy 

PL 

Architecture 

Engineering 

Accountancy 

Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 

8
3
6
22
1
8
19
6
19
20
0
6
4
11
5
20
0
12
1
6
13
41
0
4
53
7
24
17
0
3
18
1
35
17
3
4
5
1
4
12
0
1
7
3
4
10
2
2
1
1
6
5
0
0
17
7
17
58
0

Complete 
response 
0 
1 
2 
0 
1 
0 
1 
2 
1 
0 
0 
1 
0 
0 
1 
3 
0 
0 
0 
0 
1 
3 
0 
0 
0 
2 
1 
0 
0 
0 
1 
0 
2 
0 
0 
0 
1 
0 
1 
1 
0 
0 
1 
1 
0 
0 
0 
1 
0 
1 
2 
0 
0 
0 
0 
0 
0 
1 
0 

Response 
rate
0%
33%
33%
0%
100%
0%
5%
33%
5%
0%
---
17%
0%
0%
20%
15%
---
0%
0%
0%
8%
7%
---
0%
0%
29%
4%
0%
---
0%
6%
0%
6%
0%
0%
0%
20%
0%
25%
8%
---
0%
14%
33%
0%
0%
0%
50%
0%
100%
33%
0%
---
---
0%
0%
0%
2%
---

May 2017 I 189 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Host 
MS 

Profession 

Mode 

Nr called

PT 

Architecture 

Engineering 

Accountancy 

RO 

Architecture 

Engineering 

Accountancy 

SK 

Architecture 

Engineering 

Accountancy 

UK 

Architecture 

Engineering 

Accountancy 

Total  Architecture 

Engineering 

Accountancy 

Total  Total 

Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Temp Serv. 
Branch/subs 
Total 

5
4
0
2
36
3
6
1
7
14
30
0
8
5
3
6
36
0
5
65
13
54
66
1
6
238
69
233
447
15
75
1,077

Complete 
response 
0 
2 
0 
1 
0 
0 
0 
0 
0 
0 
2 
0 
1 
0 
1 
1 
0 
0 
0 
0 
1 
0 
1 
0 
1 
8 
9 
17 
13 
1 
4 
52 

Response 
rate
0%
50%
---
50%
0%
0%
0%
0%
0%
0%
7%
---
13%
0%
33%
17%
0%
---
0%
0%
8%
0%
2%
0%
17%
3%
13%
7%
3%
7%
5%
5%

190 I May 2017 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

ANNEX 4 CLASSIFICATION OF FORMALITIES 

Table A4.1 Description  

Step 

Cat 

d  Description  

Reporte

Assumed hours 

hours 

Familiarizin
g with 
formalities 

1 Simple

2 
Medium 

0.5 to 2  One procedure, few formalities, 
accessible information 

3 to 8  One procedure but which procedure or 
authority depends on the situation, or 
preliminary procedures required, or 
vague wording 

Total  Ma
n 

Pro
f

As
s

1 

5 

1 

2 

1

1

Collecting 
supporting 
documents 
from 
authorities 

Shareholde
r data 

Other 
information 

3 
Complex

15 to 20  Different sequential procedures with 

17 

8 

5

4

local and central authorities or 
conflicting information 

1 Simple

0.5 to 2  An extract from the business register or 

1 

1

a certificate of registration with a 
professional Chamber 

2 
Medium 

2 to 4  Multiple standard extracts or one non-

3 

1 

1

1

standard document (e.g. declaration of 
support) 

1 Simple

0.5 to 6  Providing ID data (such as name, 

3 

1 

2

2 
Medium 

3 
Complex
4 Very 
complex 
1 Simple

2 
Medium 

3 
Complex

address, registration number, passport 
number and/or specialization) of 
managers/shareholders regardless of 
whether they provide the cross-border 
services 

10  Providing in addition (certified) data for 
each shareholders on the number / 
value of their shares and/or voting 
rights 

10 

5 

5

20  The company statutes must include 

20 

10 

shareholder data 

28 to 40  Providing in addition data on positions 

34 

17 

that partners hold in other firms 

0.5 to 6  Selected works, CVs, or other free-

3 

2 

1

10

17

format proof of experience of 
managers/shareholders, or the 
organisational structure 

6  Proving a professional address (e.g. a 
rental agreement, an electricity or 
phone bill etc.) 

--  Adjusting company statues or company 
purpose in line with the line of the host 
country, in particular with regard to 
multidisciplinary restrictions (assumed 
hours are the reported hours for 
requirement to include shareholder data 
in the company statutes) 

6 

6

20 

10 

10

Completing  1 Simple

0.5 to 2  Company ID information and 

1  0.5  0.5

May 2017 I 191 

 
 
 
 
 
Step 

Cat 

d  Description  

Reporte

Assumed hours 

hours 

Total  Ma
n 

Pro
f

As
s

forms 

registration numbers

2 
Medium 

3 
Complex
1 Simple

2 
Medium 

3 
Complex

1 Simple
2 
Complex
1 Rare 

2 Simple

3 
Complex

1 Rare 

2 Low-
frequent 

3 High-
frequent 
Professio
nal 

Other 

Additional 
PII 

Finding a 
certified 
translator 

Legal form 
changes 

Reallocatin
g shares, 
voting 
rights 
and/or 
managers 

Examinatio
n 

192 I May 2017 

8 to 10  Detailed information on for example 

9 

4

5

office space / geographical coordinates, 
start and end dates of qualifications and 
work experience of 
managers/shareholders 

20 to 40  Multiple forms or documents for each 

30 

20 

10

manager/shareholder 

1 to 2  Arranging additional insurance, e.g. to 

2 

2

increase the insured amount or a 
general civil liability insurance on top of 
PII 

4 to 8  Prescribed wording of an insurance 

6 

6 

policy, getting insurance of a firm 
instead of professionals accepted 
30  Insurer must operate in the host 

country which necessitates comparing 
offers of insurance providers 

0.5 to 2  Any certified translator 
5 to 12  An officially approved translator from 

the host country 

--  A requirement that shares are 

nominative excludes the public limited 
liability form. No firm reported this but 
50 hours are assumed for an assumed 
5% of the professional firms that are 
public limited liabilities 

6 to 10  A change to a similar legal form that is 
recognized by the host country, 
assumed if multiple legal forms are 
recognized but not all 

1
8

1

30 

30 

1 
9 

3 

3 

8 

8 

20 to 50  A change to a different legal form, 

30 

30 

assumed if only one legal form is 
recognized 

--  If only for voluntary partnerships and 50 
or 51% must be held by professionals 
(weighted by 5%) 

--  If only for voluntary partnerships and > 
51% must be held by professionals 
(weighted by 20%), or if regardless of 
legal form but only 50-51% must be 
held by professionals 

1 

1 

5 

4 

27  If for all forms that are allowed (mostly 

27 

18 

31 to 
100 

150 to 
200 

hours spent on negotiations) 
Examination of partners/managers in 
professional regulations of the host 
country 
Examination of partners/managers (not 
necessarily those providing services) in 
other legislation of the host country 

65 

65 

150  150 

1

9

 
 
 
 
 
 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

Step 

Cat 

d  Description  

Reporte

Assumed hours 

hours 

(e.g. tax law)

Total  Ma
n 

Pro
f

As
s

1 Simple

10  To understand information that is not 

10 

5 

5

2 
Complex

available in English 

38 to 80  Only service providers who already were 

80 

80 

familiar with the language reported 
costs of training to meet the language 
skills requirement of the host country: 
one Czech and one Dutch architect 
working in Germany, one French 
architect working in Italy. However, 
most courses assume 90 hours of 
training to "level 2" 

1 Simple

0.5 to 1  A bank transfer or checks from other MS 

0.5 

  0.5

2 
Medium 
2 
Complex
-- 

are accepted 

2 to 6  Mode of payment was not clear

4 

4

20 to 28  Difficulties with payable checks or 

20 

20 

finding info on what fee to pay and how 
5 to 30  The 30 hours is an outlier (Malta), other 
firms report 5-19 hours and a five firms 
reported 10, 12 or 15 hours 

12 

6 

3

3

-- 

0.5 to 1    

0.5 

Language 
skills 

Paying 
registration 
fees 

Collecting / 
submitting 
in person 
Posting 
documents 

Certification fees 
Total translation costs 

  ---- 
--- 

375 to 
1,000 

Translation company 
statutes 
Translation insurance 
policy 
Translation other 
certificates 
Translation 
certification 
Swearing translation 

  6,000 words @ 0.10

  4,000 words @ 0.10

  1,000 words @ 0.10

  Reported as part of translation costs, 
assumed @ additional 50 if required 
  Swearing translation before a court in 

the host MS or in an embassy 

Language training fee 

  The fee of a trainer / courses to "level 

Qualification training 
fee 
Travel costs 

2" cost EUR 1,000 

2,000  This was the fee of the trainer in 

Austrian tax law and assumed elsewhere
175  Reported for domestic travel to establish 
a branch, higher average costs assumed 
because applicant need not always be in 
host country anyway 

0.
5

150
---

600

400

100

50

350

1,000

2,000

250

Postal costs 

--  Assumed @ 20 if documents need to be 

20

First-time fee 

Annual fee 

posted 
Official fees used 

12 to 
2,748 
50 to  Official fees used

May 2017 I 193 

 
 
 
 
 
 
   
Step 

Cat 

d  Description  

Reporte

Assumed hours 

hours 

2,878 

Inclusions: 

Total  Ma
n 

Pro
f

As
s

- 

First-time fee for Chamber membership in the host MS of professionals 
(besides possibly for partners or the firm), included for one professional per 
firm; 

-  Annual fee for Chamber membership in the host MS of professionals (besides 
possibly for partners or the firm), included for one professional per firm, 
discounted over 10 years at a discount rate of 4 per cent per year; 
Implicit restriction that a requirement of nominative shares excludes public 
limited liability companies. 

- 

Exclusions: 

-  General business register requirement of shareholders; 
-  Arranging insurance of professionals providing the services (not of partners or 

the firm even if they do not provide the services). 

Weights: 

-  0.5: Weight in case of voluntary reserved title in the company name; 
-  0.2: Weight based on the proportion of partnerships in the professional 

business population, used if requirements apply to partnerships but not to all 
allowed legal forms; 

-  0.5: Weight based on the proportion of limited liabilities in the professional 

business population, used for requirements that apply to limited liabilities but 
not all allowed legal forms. 

Table A4.2 Architectural services, branches 

Step 

Cat 

Familiarizi
ng with 
formalities 

1 Simple
2 Medium

A
T 

B
E 

C
Y 

C
Z

D
E

D
K ES

F
R IE IT

L
U

M
T 

P
L 

P
T 

R
O 

S
K 

U
K

1   

1  1

0

1

0  1  0  1  0

0.
5

1

1 

3 Complex

   1 

1 Simple

0   

0.
5

1

0

0

0

0

2 Medium

3 Complex
1 Simple

1  1  1  1 0.
5

  1  0

0

1

0

0.
8

1

0.
2 

0.
2 

0  0  0 

  0

  1 

0 

  0  0  0

Collecting 
supporting 
document
s from 
authorities 
Sharehold
er data 

194 I May 2017 

 
 
 
 
 
 
 
  
 
 
 
 
 
 
  
  
  
  
  
  
 
 
 
 
  
  
  
  
  
  
  
  
  
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

Step 

Cat 

A
T 

B
E 

C
Y 

C
Z

D
E

D
K ES

F
R IE IT

2 Medium

3 Complex

1  1   

0.
5

0.
2

0.
5

0.
2

L
U

1

M
T 

P
L 

P
T 

R
O 

S
K 

U
K

  0.
2 

4 Very 
complex 
1 Simple

2 Medium
3 Complex

0  0  0  1

0

0

1 Simple

   1 

  1 0.
5

0

2 Medium

1   

1

1

1

0.
2
1

0.
5

0.
5

0

0  0  0  0  0  0

1

1 0.
2 

0  0.
8 
0.
2 

0  0  0

3 Complex
1 Simple

   1 
   0  0  0

1
0

0

0

0 0.
5

0

0  0  0  0  0  0

2 Medium

3 Complex
1 Simple

2 Complex
1 Rare 

2 Simple
3 Complex
1 Rare 
2 Low-
frequent 
3 High-
frequent 

1 
Professional 
2 Other
1 Simple
2 Complex

1 Simple

2 Medium
2 Complex
-- 

0.
5

1    
0  1  0  0 0.
5

0  1  1  0 0.
5

0

0

1

0

1

0

0  0  0  0  0  0

0

0

1

1

0

0

1

0  0  0  0  0  0

0

0

  0  1  0  1  0

1   

1

1

1

1

1   

   1  1 

0.
5

   0  0  0

0

0

0

0 0.
5

0

0 0.
2 

0  0  0  0.
2 

0

1

0

1

0

0

1

0

0  0  1  0 

  0

1    
   1 
1    

   1
1 

1  1  1  1 0.
5

0

1

0.
5

0   

0.
2 

0  0  0  0

0

0

1

1

1
0

1
1

0

1

  1 

0  0  0  0  0  0

0.
2 
1  1  1

Other 
informatio
n 

Completin
g forms 

Additional 
PII 

Finding a 
certified 
translator 
Legal form 
changes 

Reallocati
ng shares, 
voting 
rights 
and/or 
managers 
Examinati
on 

Language 
skills 

Paying 
registratio
n fees 

Collecting 
/ 
submitting 
in person 
Posting 
document
s 

-- 

1  1  1  1 0.
5

0

0

1

0

1

Certification fees 

1  1  0  1

0

0

1

1

0

0

1 0.
2 

0 0.
2 

0  0  0  0  0

0  1  0  0  0

May 2017 I 195 

  
 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
 
 
 
 
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
  
  
  
 
  
  
  
  
 
 
 
 
 
 
 
 
 
A
T 

B
E 

C
Y 

C
Z

D
E

D
K ES

F
R IE IT

L
U

M
T 

P
L 

P
T 

R
O 

S
K 

U
K

Step 

Cat 

Translation company 
statutes 
Translation insurance 
policy 
Translation other 
certificates 
Translation certification

Swearing translation
Language training fee

1  1  1  0 0.
5
0  0  1  1 0.
5
1  2  4  6 0.
5
1  1  1  1 0.
5
0
0

0  0  0  0
1  0  1  0

Qualification training fee

1  0  0  0

Travel costs 

1  0  0  0

0

0

Postal costs 

First-time fee 

Annual fee  

1  1  1  1 0.
5
1  1  1  1 0.
5
0

0  1  1  1

0

1

0 0.
5
2

0

0

0
0

0

0

0

0

0

1

0
0

0

1

0

1

1

1

0

1

1

0

0

0

0

0
0
0 0.
5
0

0

0 0.
5
0

1

1 0.
5
1 0.
5

1

0

1

0

1
0

0

1

1

1

1

0  1  0  0  0

1 0.
2 
0 0.
2 
0  0  1  0  5  0

0  0  0  1  0

2

0

0  0  1  0  1  0

0  0  0  0  0  0
0  0  0  0  0

0
0 0.
2 
0 0.
2 
1 0.
2 
1 0.
2 
1 0.
2 
0 0.
2 

0  0  0  0  0

0  0  0  0.
2 

0

0  0  0  1  0

0  1  1  1  0.
5
0  0  0  0  0.
5

Table A4.3 Architectural services, temporary services 

Step 

Cat 

Familiarizi
ng with 
formalities 

1 Simple
2 Medium

Collecting 
supporting 
documents 
from 
authorities 
Sharehold
er data 

Other 
informatio
n 

Completin
g forms 

3 Complex

1 Simple
2 Medium

3 Complex

1 Simple
2 Medium

3 Complex

4 Very 
complex 
1 Simple

2 Medium
3 Complex
1 Simple

2 Medium
3 Complex

A
T 

B
E 

C
Y 

C
Z 

D
E 

D
K 

E
S 

F
R  IE

I
T 

L
U 

M
T 

P
L 

P
T 

R
O 

S
K 

U
K 

1  1  1  1

0

1

0

1

0  0  0  0  0  0

1

0.
5

0  0  1  0

0.
5

0.
5

0

1

0

0 0

1

0  0  0  0  0  0

0  0  0  0

0

0

0

0

0

0  0  0  0  0  0

0.
5

0  0  0  0

0

0

0

0.
5

0 0.
5

0

0

0  0  0  0  0  0

0  1  0  1 0.
5

0

1

1 0.
5

0

1

0  0  0  0  0  0

Additional  1 Simple

0  0  0  0

0

0

0

0 0

0

0  0  0  0  0  0

196 I May 2017 

 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

A
T 

B
E 

C
Y 

C
Z 

D
E 

D
K 

E
S 

F
R  IE

I
T 

L
U 

M
T 

P
L 

P
T 

R
O 

S
K 

U
K 

0.
5

0  0  0  1 0.
5

0  0  0  0 0.
5

0

0

1

0 0

0

0  0  0  0  0  0

0

0

0

0 0

0

0  0  0  0  0  0

0  0  0  0

0

0

0

0 0

0

0  0  0  0  0  0

0.
5

1 Professional  0  0  0  0

0

0

0

0

0

0  0  0  0  0  0

0 0.
5

0  1  1  1

1

0  1  0  1 0.
5

0

0

1

0

0

0

0 0

0 0

0

1

0  0  0  0  0  0

0  0  1  1  0  1

0  0  0  0

0

0

1

0

0 0

0

0  0  0  0  0  0

Step 

Cat 

PII 

2 Medium

3 Complex
1 Simple

2 Complex
1 Rare 

2 Simple
3 Complex
1 Rare 
2 Low-
frequent 
3 High-
frequent 

2 Other
1 Simple
2 Complex
1 Simple

2 Medium
2 Complex
-- 

-- 

Finding a 
certified 
translator 
Legal form 
changes 

Reallocatin
g shares, 
voting 
rights 
and/or 
managers 
Examinati
on 

Language 
skills 
Paying 
registratio
n fees 

Collecting 
/ 
submitting 
in person 
Posting 
documents 

Certification fees 

Translation company 
statutes 
Translation insurance 
policy 
Translation other 
certificates 
Translation certification
Swearing translation

0  1  1  1 0.
5

0  0  0  0 0.
5
0  0  0  1 0.
5
0  0  0  0 0.
5
0  0  0  1 0.
5
0
0

0  0  0  0
0  0  0  0

0

0

1

0 0

0

0  0  0  0  0  0

0

0

0

0

0
0

0
0

0

0

0

0

0

0

0

0

0
0

0
1

0

0

0

0

0

0

1

1

0 0

0 0

0 0

0 0

0 0
0

0
0 0.
5
0 0
0

0
0 0.
5
1 0.
5
0 0

0

0

0

0

0 0

0 0

0

0

2

0

0
0

0
0

0

1

0

0

0  0  0  0  0  0

0  0  0  0  0  0

0  0  0  0  0  0

0  0  0  0  0  0

0  0  0  0  0  0
0  0  0  0  0  0

0  0  0  0  0  0
0  0  0  0  0  0

0  0  0  0  0  0

0  0  1  1  0  0.
5
0  0  1  0  0  0.
5
0  0  0  0  0  0

May 2017 I 197 

Language training fee
Qualification training fee

0  0  0  0
0  0  0  0

0
0

Travel costs 

Postal costs 

First-time fee 

Annual fee  

0  1  1  1 0.
5
0  1  0  1 0.
5
0

0  1  0  1

0  0  0  0 0.
5

 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
Table A4.4 Engineering services, branches 

Step 

Cat 

Familiarizi
ng with 
formalities 

1 Simple
2 Medium
3 Complex

A
T 

B
E 

C
Y 

C
Z 

D
E 

D
K  ES

F
R 

I
E  IT

L
U 

M
T 

P
L 

P
T 

R
O 

S
K  UK 

1  0  1  1

0

0

0.
5

1 Simple

0  0 

2 Medium

3 Complex
1 Simple

2 Medium

  1  1 0.
5

  0  1  0

0

3 Complex

1 

0.
5

0 0

  0  1  0  0 

0

1

1 

0.
2 

0.
2 

1

1

1

1

0.
2

1

0

0 0

0 0 0.
8
0.
2

0  1  0 

0

  1 

0 

  0  0 

0

  0.
2 

1 Simple

  0 

  1 0.
5

0

0 0

0  0  0  1

0

0

0 0

0

0  0  0  0  0 

0

0.
2

1

1
0

0 0

0 0.
5

1

1 0.
2 

0  1  0  0 

0

0

0  0  0  0  0 

0

0

0

0 0

1

0

0  0  0  0  0 

0

0

0 0

0

1

0  0  0  0  0 

1 

   1 
   0  0  0

0.
5

1 
0  0  0  1 0.
5

0  0  1  0 0.
5

1

1

   0.2
5

0 0

0

  0  1  0  1 

1

1 

   0.5

  0 

1 

  1

0

   1 

0.
5

   0  0  0

0

0

0

0 0

0

0  0  0  0 

0

0 0.
2 

1 
   0 
1 
1  0  1  1 0.

   1 

   1

1

0

0

1

0 0

0 0

1

1

0

0  0  1  0  0 

0.

0 

  0  1 

0

1

Collecting 
supporting 
document
s from 
authorities 
Sharehold
er data 

Other 
informatio
n 

Completin
g forms 

Additional 
PII 

Finding a 
certified 
translator 
Legal form 
changes 

Reallocati
ng shares, 
voting 
rights 
and/or 
managers 
Examinati
on 

Language 
skills 
Paying 

198 I May 2017 

4 Very 
complex 
1 Simple
2 Medium
3 Complex

2 Medium
3 Complex
1 Simple

2 Medium

3 Complex
1 Simple

2 Complex
1 Rare 

2 Simple
3 Complex

1 Rare 
2 Low-
frequent 
3 High-
frequent 

1 
Professional 
2 Other
1 Simple
2 Complex
1 Simple

 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
 
 
 
 
 
 
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
  
  
  
  
  
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
  
  
  
  
  
  
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

Step 

Cat 

A
T 

B
E 

C
Y 

C
Z 

D
E 

D
K  ES

F
R 

I
E  IT

L
U 

M
T 

P
L 

P
T 

R
O 

S
K  UK 

registratio
n fees 

Collecting 
/ 
submitting 
in person 
Posting 
document
s 

5

2 Medium
2 Complex
-- 

0  0  0  0

0

0

1

1

0 0

1

1
1

2 

  1 

0  0  0  0  0 

0

-- 

1  0  1  1 0.
5

0

0

0 0

1

1 0.
2 

0  0  0  0 

0

Certification fees 

1  0  0  1

0

Translation company 
statutes 
Translation insurance 
policy 
Translation other 
certificates 
Translation certification

Swearing translation
Language training fee

1  0  1  0 0.
5
0  0  1  1 0.
5
1  0  4  6 0.
5
1  0  1  1 0.
5
0
0

0  0  0  0
1  0  1  0

Qualification training fee

1  0  0  0

Travel costs 

1  0  0  0

0

0

Postal costs 

First-time fee 

Annual fee  

1  0  1  1 0.
5
1  0  1  1 0.
5
0

0  0  1  1

0

0

0

0

0

0
0

0

0

0

0

0

1

1

0

3

1

0
0

0

1

0

1

1

0 0

0 0

0 0

0 0

0 0

0 0
0 0

0 0

0 0

0 0

0 0

0 0

0

1

0

1

0

1
0

0

1

1

1

1

Table A4.5 Engineering services, temporary services 

0

0

0

0

0

0
0

0

0

0

0  1  0  0 

0  1  0  0 

0 0.
2 
0 0.
2 
0 0.
2 
0  0  1  0  5 

0  0  0  1 

1

0

0  0  1  0  1 

0  0  0  0  0 
0  0  0  0 

0
0 0.
2 
0 0.
2 
1 0.
2 
1 0.
2 
1 0.
2 
0 0.
2 

0  0  0  0 

0  0  0  0 

0  0  0  1 

0  1  0  1  0.5

0  1  0  1  0.5

Step 

Cat 

Familiarizi
ng with 
formalities 

1 Simple
2 Medium
3 Complex

Collecting 
supporting 
documents 
from 
authorities 
Sharehold
er data 

1 Simple
2 Medium

3 Complex

1 Simple
2 Medium
3 Complex

A
T 

B
E 

C
Y 

C
Z 

D
E 

1  0  1  1

D
K 

0

E
S 

F
R 

I
E 

I
T 

L
U 

M
T 

P
L 

P
T 

R
O 

S
K  UK 

0

0 0 1

0

0  0  0  0  0

1

0  0  1  0

0.
5 

0.
5 

0

1

0

0 0 1

0

0  0  0  0  0

0  0  0

0

0

0

0 0 0

0

0  0  0  0  0

0.
5 

May 2017 I 199 

 
 
 
 
 
 
  
  
  
 
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Step 

Cat 

A
T 

B
E 

C
Y 

C
Z 

D
E 

D
K 

E
S 

F
R 

I
E 

I
T 

L
U 

M
T 

P
L 

P
T 

R
O 

S
K  UK 

4 Very 
complex 
1 Simple
2 Medium
3 Complex
1 Simple

2 Medium
3 Complex
1 Simple
2 Medium

3 Complex
1 Simple

2 Complex
1 Rare 

2 Simple
3 Complex

1 Rare 
2 Low-
frequent 
3 High-
frequent 

1 
Professional 
2 Other
1 Simple
2 Complex
1 Simple

2 Medium
2 Complex
-- 

0  0  0  0

0

0

0

0

0 0 0

0

0  0  0  0  0

0  0  0  1

0.
5 

0

1

0

0 0 1

0

0  0  0  0  0

0  0  0  0

0

0

0

0 0 0

0

0  0  0  0  0

0.
5 

0.
5 

0.
5 

0  0  0  1

0  0  0  0

0

0

0

0 0 0

0

0  0  0  0  0

0

0

0

0 0 0

0

0  0  0  0 

0  0  0  0

0

0

0

0 0 0

0

0  0  0  0 

0.
5 

0.2
5 

0.5

0  0  0  0

0

0

0

0

0 0 0

0

0  0  0  0  0

0  0  1  1

1

0  0  0  1

0.
5 

0

0

1

0

0

0

0 0 0

0 0 1

0

0

0  0  0  0  0

0  1  0  1  1

0  0  0  0

0

0

1

0

0 0 0

0

0  0  0  0  0

Other 
informatio
n 
Completin
g forms 

Additional 
PII 

Finding a 
certified 
translator 
Legal form 
changes 

Reallocatin
g shares, 
voting 
rights 
and/or 
managers 
Examinati
on 

Language 
skills 
Paying 
registratio
n fees 

Collecting 
/ 
submitting 
in person 
Posting 
documents 

-- 

0  0  1  1

Certification fees 
Translation company 
statutes 
Translation insurance 
policy 
Translation other 
certificates 
Translation certification

0  0  0  0
0  0  0  0

0  0  0  1

0  0  0  0

0  0  0  1

Swearing translation

0  0  0  0

200 I May 2017 

0

0

0

0 0 0

0

0  0  0  0  0

0
0

0

0

0

0

0
0

0

0

0

0

0
0

0

0

0

0

0 0 0
0 0 0

0 0 0

0 0 2

0 0 0

0 0 0

0
0

0

0

0

0

0  0  0  0  0
0  0  0  0  0

0  0  0  0  0

0  0  0  0  0

0  0  0  0  0

0  0  0  0  0

0.
5 

0
0.
5 
0.
5 
0.
5 
0.
5 
0.
0 

  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

Step 

Cat 

A
T 

B
E 

C
Y 

C
Z 

Language training fee
Qualification training fee
Travel costs 
Postal costs 

0  0  0  0
0  0  0  0
0  0  0  0
0  0  1  1

First-time fee 

0  0  0  1

Annual fee  

0  0  0  1

D
E 

0
0
0
0.
5 
0.
5 
0

D
K 

E
S 

F
R 

I
E 

I
T 

L
U 

M
T 

P
L 

P
T 

R
O 

S
K  UK 

0
0
0
0

0

0

0
0
1
0

0

0

0
0
0
0

0

0

0 0 0
0 0 0
0 0 0
0 0 0

0 0 1

0 0 0

0
0
0
0

0

0

0  0  0  0  0
0  0  0  0  0
0  0  0  0  0
0  0  0  0  0

0  1  0  1  0.5

0  1  0  1  0.5

Table A4.6 Accountancy services, branches 

Step 

Cat 

A
T 

B
E 

C
Y 

C
Z

D
E

D
K

E
S

F
R IE IT

L
U

M
T 

P
L 

P
T 

R
O 

S
K 

U
K

1 Simple
2 Medium
3 Complex
1 Simple
2 Medium
3 Complex

1 

0  0

0

0

0

1 

1  0  0  0

0

0

0

0

0

1

1

1 Simple

1 

0  0

0

0

0

0

1

1

1

1
0

0.
8 
0.
2 

1  0 

0  1

1  1 

1  0 

0  0

1  1 

0 

0  0.
5 

1 

0.
2 

1 

1 

0  0  0  0

0

0

0

1  1  0  0

0

0

0

1 

0  0

0

0

0

1 

1

0
1

1
0

0

0

0

0  0  0 

0  0

0

0

1
0

1
0

1  0  1 

0  0

1 

1 

0  0  0  0  0 

1

1 

0  0

0

0

0

1

0

1

0

0  0  0  0  0  0

1 

0  0  0  0

0

0

0

0

0

1

0  0  0  1  0  0

0 

0  0

0

0

0

1 

0.
5 

1

0.
5 

0  1 

0 

1

1 

1 

0.
5 

1

1  1  0  0

0

0

0

0

0

0

0

0  0  0  1  0  0

May 2017 I 201 

Familiarizi
ng with 
formalities 
Collecting 
supporting 
document
s from 
authorities 
Sharehold
er data 

Other 
informatio
n 
Completin
g forms 

Additional 
PII 

Finding a 
certified 
translator 
Legal form 
changes 

Reallocati
ng shares, 
voting 
rights 
and/or 
managers 
Examinati
on 

2 Medium

3 Complex
4 Very 
complex 
1 Simple
2 Medium
3 Complex
1 Simple
2 Medium
3 Complex
1 Simple
2 Medium
3 Complex
1 Simple
2 Complex

1 Rare 
2 Simple
3 Complex

1 Rare 
2 Low-
frequent 
3 High-
frequent 

1 
Professional 

 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
 
 
 
 
 
 
 
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
 
 
 
 
 
 
 
 
  
  
  
  
  
  
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
  
  
  
  
  
  
Step 

Cat 

A
T 

B
E 

C
Y 

C
Z

D
E

D
K

E
S

F
R IE IT

L
U

M
T 

P
L 

P
T 

R
O 

S
K 

U
K

2 Other
1 Simple
2 Complex
1 Simple
2 Medium
2 Complex
-- 

0  0

1  1 
1  1  0  0

0

0

0

0

0

0

0  0  0  0

0

0

0

0

1
0

0

0

1

1

0

0  0  1 

0  0

1 
1  0  1

1  0 

1 

0

1

1
1

0  0  0  0  0  0

-- 

0  0  0  0

0

0

0

1

0

1

1

0  0  0  0  0  0.
5 

Language 
skills 
Paying 
registratio
n fees 
Collecting 
/ 
submitting 
in person 
Posting 
document
s 

Certification fees 
Translation company 
statutes 
Translation insurance 
policy 
Translation other 
certificates 
Translation certification
Swearing translation
Language training fee
Qualification training fee
Travel costs 
Postal costs 

First-time fee 
Annual fee  

0  1  0  0
1  1  0  0

0  1  0  0

4  1  0  0

1  0  0  0
0  0  0  0
1  0  0  0
1  0  0  0
1  0  0  0
0  0  0  0

1  1  0  0
1  1  0  0

0
0

0

0

0
0
0
0
0
0

0
0

0
0

0

0

0
0
0
0
0
0

0
0

0
0

0

0

0
0
0
0
0
0

0
0

1
1

1

3

1
0
0
0
0
1

1
1

0
0

0

0

0
0
0
0
0
0

0
0

0
1

0

1

0
1
0
0
1
1

1
1

1
0

0

0

0
0
0
0
1
1

1
0

1  0  1  1  0  0
1  0  1  1  0  0

1  0  0  0  0  1

0  0  1  2  0  0

0  0  1  1  0  0
0  0  0  0  0  0
0  0  0  1  0  0
0  0  0  0  0  0
0  0  0  1  0  0
0  0  0  0  0  0.
5 
1  0  1  1  0  1
1  0  0  1  0  1

Table A4.7 Accountancy services, temporary services 

Step 

Cat 

A
T 

B
E 

C
Y 

C
Z 

D
E 

D
K 

E
S 

F
R  IE

I
T 

L
U 

M
T 

P
L 

P
T 

R
O 

S
K 

U
K 

Familiarizi
ng with 
formalities 
Collecting 
supporting 
documents 
from 
authorities 
Sharehold
er data 

Other 
informatio
n 

1  1  0  0

0

0

0

1

0

0 1

1  0  0  1  0  1

0  0  0  0

0

0

0

1

0

0 0

1  0  0  0  0  0

1 Simple
2 Medium
3 Complex
1 Simple
2 Medium
3 Complex

1 Simple

0  0  0  0

0

0

0

0

0

0 0

0  0  0  0  0.
5 

2 Medium
3 Complex
4 Very 
complex 
1 Simple
2 Medium
3 Complex

0  0  0  0

0

0

0

0

0

0 0

0  0  0  0  0  0

1 

202 I May 2017 

  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
  
  
  
  
  
  
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

Step 

Cat 

A
T 

B
E 

C
Y 

C
Z 

D
E 

D
K 

E
S 

F
R  IE

I
T 

L
U 

M
T 

P
L 

P
T 

R
O 

S
K 

U
K 

0  1  0  0

0

0

0

1

0

0 1

1  0  0  1  0  0

1 

0  0

0

0

0

0

0

0 0

0  0  0  0  0 

1 

1

0 

0  0

0

0

0

1

0

0 0

0  0  0  0  0  0

1 

0  0  0  0

0

0

0

0

0

0 0

0  0  0  0  0  0

0  0  0  0

0

0

0

0

0
0.
5 

0

0

0

0 0

0  0  0  0 

1 

0.
5 

0 0

0  0  0  0  0  0

0 0

0  0  0  0  0  0

0 0

1  0  0  0  0  1

0  0  0  0

1 Professional  0  0  0  0
2 Other
1 Simple
2 Complex
1 Simple
2 Medium
2 Complex
-- 

0  0  0  0

0  1  0  0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0 0

0  0  0  0  0  0

1 Simple
2 Medium
3 Complex
1 Simple
2 Medium
3 Complex
1 Simple
2 Complex

1 Rare 
2 Simple
3 Complex
1 Rare 
2 Low-
frequent 
3 High-
frequent 

Completin
g forms 

Additional 
PII 

Finding a 
certified 
translator 
Legal form 
changes 

Reallocatin
g shares, 
voting 
rights 
and/or 
managers 
Examinati
on 
Language 
skills 
Paying 
registratio
n fees 
Collecting 
/ 
submitting 
in person 
Posting 
documents 

-- 

0  0  0  0

0

0

0

1

0

0 0

0  0  0  0  0  0.
5 

Certification fees 
Translation company 
statutes 
Translation insurance 
policy 
Translation other 
certificates 
Translation certification
Swearing translation
Language training fee
Qualification training fee
Travel costs 

0  0  0  0
0  0  0  0

0  0  0  0

0  0  0  0

0  0  0  0
0  0  0  0
0  0  0  0
0  0  0  0
0  0  0  0

Postal costs 

0  1  0  0

First-time fee 

0  0  0  0

Annual fee  

0  0  0  0

0
0

0

0

0
0
0
0
0

0

0

0

0
0

0

0

0
0
0
0
0

0

0

0

0
0

0

0

0
0
0
0
0

0

0

0

0
0

1

1

0
0
0
0
1

0

0

0

0
0

0

0

0
0
0
0
0

0

0

0

0 0
0 0

1  0  0  0  0  0
1  0  0  0  0  1

0 0

0  0  0  0  0  0

0 0

0  0  0  0  0  0

0 0
0 0
0 0
0 0
0 0

0 0

0 0

0 0

0  0  0  0  0  0
0  0  0  0  0  0
0  0  0  0  0  0
0  0  0  0  0  0
0  0  0  0  0  0.
5 
1  0  0  0  0  0.
5 
1  0  0  0  0  0.
5 
1  0  0  0  0  0

May 2017 I 203 

 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
ANNEX 5 TABLES AND FIGURES OF REGULATORY 
ASPECTS 

Architecture 

Table A5.1 Architecture – Services covered 

MS  Services covered 

AT  All types of architecture a), and civil engineering 
BE  All types of architecture  

CY  Building and landscape architecture and civil engineering 

CZ  All types of architecture and urban planning 

DE  All types of architecture and urban planning 

DK  All types of architecture 

ES  All types of architecture 

FR 

All types of architecture 

IE 

IT 

All types of architecture 

All types of architecture 

LU  All types of architecture and engineering 

MT  All types of architecture, and civil engineering 

PL 

PT 

All types of architecture 

All types of architecture 

RO  Building design 

SK  Building and landscape architecture 

UK  All types of architecture 

a)  Building, landscape and interior design architecture. 

Table A5.2 Architecture - Reserved activities 

MS  Reserved activities 
AT  Building design 
BE  Signing and submitting building designs, and planning the construction activities 
CY  All activities of architects 
CZ  All activities of architects: Conception design and realisation of all kinds of buildings, 
including the management and the supervision. Town and regional planning, Interior 
design, Landscape architecture. 

DE  Submitting building plans and representing customers 
DK  Architecture is not regulated 
ES  All activities of architects 
FR 

Establishing the building project, consisting of plans, layout of the buildings, their 
composition, organisation and volume and the choice of building materials and colours 
Signing building plans, and inspecting and certifying works 
IE 
All activities of architects 
IT 
LU  All activities of architects  
MT  Designing and supervising the construction of building works 
PL 
PT 

All activities of architects  
Coordination, development and underwriting projects, supervision of public and private 
works and the direction of work 

RO  Drafting and signing architectural projects 
SK  All activities of architects 
UK  Architecture is not regulated 

204 I May 2017 

 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

Table A5.3 Architecture – Competent authority granting access to services 

MS  Establishment of a branch  

AT 
BE 
CY 
CZ 

Professional chamber 
Professional chamber and general business register 
Professional chamber 
Professional chamber (for managers and for partners of 
voluntary professional partnerships) 
Professional chamber (to use voluntary title) 

DE 
DK  None 
ES  Ministry, with advise of the regional chamber where the 

application is submitted 
Professional chamber 
Professional chamber 
Professional chamber and general business register 
Professional chamber 

FR 
IE 
IT 
LU 
MT  Professional chamber (for partners of voluntary professional 

partnerships) 

Temporary cross-
border services of 
legal persons 
None 
Professional chamber 
Professional chamber 
None 

See branches 
None 
See branches 

Only notification 
None 
None 
Only notification 
Professional chamber 

Professional chamber 

PL  None (professional chamber for natural persons) 
PT 
RO  None (professional chamber for natural persons) 
SK  None (professional chamber for natural persons) 
UK  None (professional chamber only checks misuse of title ex post) 

See branches 
Professional chamber 
See branches 
See branches 
See branches 

Table A5.4 Architecture – Legal form requirements 

MS  Establishment of a branch 

Partnership or Laruelle form (all forms allowed) 

AT  Only domestic forms allowed: oG, KG, GmbH, AG 
BE 
CY  Natural persons, partnerships and limited liability 
CZ  All three Czech legal forms and branches of foreign 

firms 

Temporary cross-border 
services 
All forms 
All forms 
All forms 
All forms 

DE  All forms; for title in company name: partnership or 

Same as for branches 

public corporation 

DK  All forms 
ES  All forms 
FR  All forms 
All forms 
IE 
IT 
All forms 
LU  All forms 
MT  All forms 
All forms 
PL 
PT 
All forms 
RO  All forms 
SK  All forms 
UK  All forms 

All forms 
All forms 
All forms 
All forms 
All forms 
All forms 
All forms 
All forms 
All forms 
All forms 
All forms 
All forms 

Table A5.5 Architecture – Multidisciplinary restrictions 

MS  Establishment of a branch 

AT 
a) 

Legal persons must be created with the exclusive purpose of exercising 
architectural and civil engineering activities, as proved by the company 
statutes. Shareholders exercising other activities can participate in the 
capital of such a legal person only as natural persons and are excluded 
from decisions on architectural and civil engineering matters. In a civil 
partnership with craftsmen, the latter are excluded from executive tasks 

Temporary 
services 
None 

May 2017 I 205 

 
 
MS  Establishment of a branch 

BE 

Partnerships: architects may not exercise a conflicting profession; Other 
legal forms: no shareholder (legal or natural person) may exercise a 
conflicting profession  

CZ 

CY  Companies cannot be registered as architect/engineering consultants if any 
of their shareholders or board of management members are directors, 
shareholders or employees in engineering contractor firms or land 
development firms 
Limited liability firms must be created with the sole purpose of architectural 
services. They may not issue administrative statements regarding their own 
work or engage in activities that are incompatible with the binding statutes 
of the Chamber 
To carry the title 'architect' in the company name: the other shareholders 
must be natural persons exercising a liberal profession and must contribute 
to achieving the purpose of the company through their professional training 
(§ 8.2 BauKaG NRW) 

DE 

DK  None (architects are not a regulated profession) 
ES 

Ley 2/2007 allows professional companies to exercise several professional 
activities simultaneously unless their combined pursuit is prohibited by a 
statutory by-law on conflicts of interest or incompatibilities; for 
partnerships the company statutes must be adapted to the Law on 
Professional Societies (this is checked by the general business register) 
The other professions exercised must be clearly distinct, independent and 
of public knowledge. The architect needs to declare to the regional council 
of the Order its personal and professional bounds exercising any activity 
which purpose is to make profit, directly or indirectly, from construction. 
None 
Joint professions are allowed except for cases of conflict of interest. 
Companies can offer joint exercise of professions, but professionals can 
only do one professional activity and cannot participate in more than one 
professional company. Therefore, architects may only provide architecture 
services but a company may also provide other services 

FR 

IE 
IT 

LU  Managers may not practice any activity which can be considered as conflict 
of interest such as working for a building firm or a firm selling construction 
products; to this end a specific statement in the company statues is 
recommended. At least 51% of shareholdings and voting rights must be 
owned by one or several mandatory member(s) of the Order, and at least 
26% of shareholdings and voting rights must be owned by one or several 
mandatory member(s) having the required qualification; the remaining 
25% of shareholdings and voting rights cannot be owned by one or several 
natural or legal person(s) which risk to jeopardize, directly or indirectly, the 
professional independence of the company  

Temporary 
services 
None 

None 

See 
branches 

See 
branches 

None 
None 

See braches 

None 
None 

None 

MT  All shareholders in a voluntary professional partnership must follow the 

See braches 

professional code 

PL  None for legal persons, only for professionals 
PT 

For professional partnerships: activities that constitute the exercise of other 
regulated professions or under the jurisdiction of their own public 
association of another profession are incompatible; Other legal forms: no 
multidisciplinary restrictions on firms (only for professionals) 

RO  Any disciplinary restrictions must be specified in the proof issued by the 

competent authorities of the home State 
SK  None for legal persons, only for professionals 
UK  None 

None 
None 

See 
branches 
None 
None 

a)  Only for subsidiaries, because branches of foreign architecture firms are not recognized in Austria. 

206 I May 2017 

 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

Figure A5.1 Architecture – Professional liability periods (in years)a) 

a)  Cyprus: 2 years since discovery of damage. 

Figure A5.2 Architecture – Compulsory amount covered by PII a) 

a)  PII: Professional Indemnity insurance. 

May 2017 I 207 

 
 
 
 
Engineering 

Table A5.6 Engineering – Services covered 

MS  Services covered 
AT  Civil engineering can including architecture, mechanical and electric engineering activities. 
Note: Ingenieurbüro refers to a firm registered by someone with the non-academic 
Ingenieur title and may not offer services related to building design  

BE  All types of engineering a): only use of the title is protected 
CY  Mechanical, electric, electronic, IT, chemical, mining, applied geology and agronomic-

topographic engineering, land survey and valuation, and town and spatial planning. The 
requirements for civil engineering are the same as for architects 

CZ  Chartered Engineer (structural engineer). Other types of engineering are not regulated. 
DE  All types of engineering a) 
DK  Structural engineering: the design of structures attributable to medium or high class 

ES 

documentation according to Sbi recommendation 223 such as shopping centres, hospitals 
and schools.  
For civil, electric and mechanical engineering similar requirements apply. Besides these 
more specialized chambers of engineers exist in Spain such as for weaponry, 
telecommunication, forestry etc. These are not investigated. 
All types of engineering a): only use of the title is protected 
All types of engineering a) 
All types of engineering a) 

FR 
IE 
IT 
LU  All types of engineering a). The authorization procedure for engineering is the same as for 

architecture 

MT  Mechanical and electric engineering. The regulations for civil engineering are the same as 

PL 

for architecture 
All types of engineering a) excluding surveyors (official inspectors) to whom additional 
regulations apply 
All types of engineering a) 

PT 
RO  All types of engineering a): however no law protects activities or use of the title 
SK  Civil engineering; mechanical and electric engineering are not regulated professions 
UK  All types of engineering a): only use of the chartered title (also in the company name) is 

protected 

a)  Civil, mechanical and electric engineering. 

Table A5.7 Engineering - Reserved activities 

MS  Reserved activities 
AT  Building design 
BE  No reserved activities, although the title engineer is protected  
CY  All activities of engineers 
CZ 

Processing of territorial planning documents, zoning studies, documentation for zoning 
decision and the conclusion of a public contract to replace planning and project 
documentation and performance of the building or its changes  

DE  Engineering activities in construction 
DK  The certified structural engineer carries out an independent inspection of the project and 
provides documentary evidence of the checks in accordance with specific guidelines. 

ES  All activities of engineers 
FR  Recognition of diploma (of natural persons), otherwise the profession is not regulated 
Sign-off building plans and inspect and certify works 
IE 
IT 
All activities of engineers 
LU  All activities of engineers 
MT  Activities of design, specification, development, installation, commissioning, operation, 

PL 
PT 

maintenance and decommissioning of any mechanical, electrical, chemical process, 
information and related systems 
All activities of engineers 
Research activities; design; study; design, manufacture, construction, production, 
evaluation, supervision and quality and safety control; expertise and engineering audit, 
including coordination and management of these and related activities 

RO  Not a regulated profession. The title allows exercise of the profession but no law to 

protects activities or use of the title 

208 I May 2017 

 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

MS  Reserved activities 
SK  Civil engineering activities (similar as in the Czech Republic) 
UK  No reserved activities, although the title chartered engineer is protected  

Table A5.8 Engineering – Competent authority granting access to services 

MS  Establishment of a branch  

Professional chamber 

AT 
BE  None 
CY 
CZ 

Professional chamber 
Legal persons: office for Trade Licences (beyond the scope of the 
study) Professional chamber (managers and partners of 
voluntary professional partnerships) 
Professional chamber (to use voluntary title) 

DE 
DK  None (for structural engineering the professional chamber for 

Temporary cross-
border services 
None 
None 
See branches 
None 

See branches 
See branches 

natural persons) 

ES  Ministry, with advise of the regional chamber where the 

See branches 

application is submitted 

FR  None  
IE 

None (professional chamber for natural persons) 

Professional chamber and general business register 
Professional chamber 

IT 
LU 
MT  Professional chamber (for partners of voluntary professional 

partnerships) 

Professional chamber 

PL  None (professional chamber for natural persons) 
PT 
RO  None 
SK 

Legal persons: office for Trade Licences (beyond the scope of the 
study) (professional chamber for natural persons) 

None 
No authorization 
possible 
None 
See branches 
See branches 

See branches 
Professional chamber 
None 
See branches 

UK  None (professional bodies only check misuse of the title ex post)  See branches 

Table A5.9 Engineering – Legal form requirements 

MS  Establishment of a branch 

AT  Only domestic forms allowed oG, KG, GmbH, AG 
BE  All forms 
CY  Natural persons, partnerships and limited liability 
CZ  All three Czech legal forms and branches of foreign 

firms 

Temporary cross-border 
services 
All forms 
All forms 
All forms 
All forms 

DE  All forms; for title in company name: partnership or 

See branches 

public corporation 

DK  All forms 
ES  All forms 
All forms 
FR 
All forms 
IE 
IT 
All forms 
LU  All forms 
MT  All forms 
All forms 
PL 
PT 
All forms 
RO  All forms 
SK  All forms 
UK  All forms; but limited liability companies cannot use 
the title of chartered civil engineer or chartered 
mechanical engineer in the company name 

All forms 
All forms 
All forms 
All forms 
All forms 
All forms 
All forms 
All forms 
All forms 
All forms 
All forms 
See branches 

May 2017 I 209 

 
 
 
Table A5.10 Engineering – Multidisciplinary restrictions 

MS  Establishment of a branch 

AT 
a) 

The legal persons are to be created with the exclusive purpose of 
exercising architectural and civil engineering activities. Shareholders 
exercising other activities can participate in the capital of such a legal 
person only as natural persons and are excluded from decisions on 
architectural and civil engineering matters. In the civil partnership with 
crafts, the latter are excluded from executive tasks 

Temporary 
cross-border 
services 
None 

BE  None 
CY  Companies cannot be registered as architect/engineering consultants if 
any of their shareholders or board of management members are 
directors, shareholders or employees in engineering contractor firms or 
land development firms 

None 
None 

CZ  Engineers (natural persons) may only perform work in the field in 
which they are specialized and are obliged to collaborate with 
architects and engineers in other fields if necessary.  

See branches 

See branches 

None 

None 

None 
None 
None 

None 

DE 

They may not issue administrative statements regarding their own 
work or engage in activities that are incompatible with the binding 
statutes of the Chamber 
For firms that wish to carry the title 'engineer' in the company name: 
the other shareholders must be natural persons exercising a liberal 
profession and must contribute to achieving the purpose of the 
company through their professional training (§ 33.2 BauKaG NRW) 

DK  None 

ES 

Ley 2/2007 allows professional companies to exercise several 
professional activities simultaneously unless their combined pursuit is 
prohibited by a statutory by-law on conflicts of interest or 
incompatibilities 

LU 

FR  None 
None 
IE 
Joint professions are allowed except for cases of conflict of interest. 
IT 
Companies can offer joint exercise of professions, but professionals 
working for the company can only do one professional activity to avoid 
conflict of interest. A professional cannot participate in more than one 
professional company. Therefore, architects may only provide 
architecture services but a company may also provide other services 
[B]: The same professional cannot participate in more than one 
professional company 
For managers, it is forbidden to practice any activity which can be 
considered as conflict of interest such as working for a building firm or 
a firm selling construction products. At least 51% of shareholdings and 
voting rights must be owned by one or several mandatory member(s) 
of the Order, and at least 26% of shareholdings and voting rights must 
be owned by one or several mandatory member(s) having the required 
qualification; the remaining 25% of shareholdings and voting rights 
cannot be owned by one or several natural or legal person(s) which 
risk to jeopardize, directly or indirectly, the professional independence 
of the company 
At least 26% of shareholdings and voting rights must be owned by one 
or several mandatory member(s) having the required qualification.  
(2) The remaining 25% of shareholdings and voting rights cannot be 
owned by one or several natural or legal person(s) which risk to 
jeopardize, directly or indirectly, the professional independence of the 
company. 

MT  All shareholders in a voluntary professional partnership must follow the 

None 

professional code 

PL  None 
PT 

For professional partnerships: activities that constitute the exercise of 
other regulated professions or under the jurisdiction of their own public 
association of another profession are incompatible, in accordance with 

None 
None 

210 I May 2017 

 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

MS  Establishment of a branch 

Temporary 
cross-border 
services 

Article 27, paragraph 1 of Law No. 2/2013 of 10 January; Other legal 
forms: no multidisciplinary restrictions on firms (only for professionals) 

RO  None 
SK 

In the case of joint provision of services by architects and engineers, 
the legal relationships between them arising from the joint 
performance of their tasks shall be set out in a contract 

UK  None 

None 
None 

None 

a)  Only for subsidiaries, because branches of foreign engineering firms are not recognized in Austria. 

Figure A5.3 Engineering – Professional liability periods (in years)a) 

a)  Cyprus: 2 years since discovery of damage 

May 2017 I 211 

 
 
 
Figure A5.4 Engineering – Compulsory amount covered by PII a) 

a)  PII: Professional Indemnity insurance. 

Accountancy 

Table A5.11 Accountancy – Services covered 

MS  Services covered 
AT  Buchhalter, Bilanzbuchhalter, Personalverrechner (bookkeepers, statutory auditors and 

salary administrators) 

BE  Accountancy. For statutory auditing and tax consultancy different regulations apply 
CY  Statutory auditing (and voluntary for accountancy) 
CZ  Accountancy is not regulated, only tax consultancy and statutory auditing 
DE  Accountancy is not regulated, only tax consultancy (Steuerberater) and statutory auditing 

(Wirtschaftsprüfer) 

DK  Accountancy is not regulated, only statutory auditing  
ES  Accountants and tax consultants (expertos contables y tributarios) not regulated, only 

FR 

statutory auditors (auditorías de cuenta) 
Accountancy (experts-comptables). For statutory auditors (commissaires aux comptes) 
different regulations apply 
Accountancy is not regulated, only statutory auditing 
Bookkeepers (commercialisti) and statutory auditing (revisori contabili) 

IE 
IT 
LU  Accountancy. For statutory auditing different regulations apply 
MT  Accountancy itself is not regulated but all activities related to the publication of any 

PL 

PT 

financial report are 
Accountancy is not regulated, only tax consultancy, statutory auditing and actuarial 
services 
Bookkeepers (técnicos de contas). For statutory auditors (revisores de contas) different 
regulations apply 

RO  Chartered accountants (for auditing-related activities) and certified accountants (for 

accountancy-related activities) 

SK  Accountancy is not regulated, only statutory auditing  

212 I May 2017 

 
 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

MS  Services covered 
UK  Accountancy and auditing 

Table A5.12 Accountancy - Reserved activities 

MS 
AT 

BE 

CY 

CZ 

DE 

DK 

ES 

FR 

IE 

IT 

LU 

MT 

PL 

PT 

RO 

SK 

UK 

Reserved activities 
All activities related to accountancy, auditing and tax consultancy 

All activities related to accountancy 

Accountancy (accountancy) is not regulated 

Accountancy (accountancy) is not regulated 

Accountancy (accountancy) is not regulated 

Accountancy (accountancy) is not regulated 

Accountancy (accountancy) is not regulated 

All activities related to accountancy 

Accountancy (accountancy) is not regulated 

All activities related to accountancy, auditing and tax consultancy 

All activities related to accountancy 

A list of activities related to publication of financial reports 

Accountancy (accountancy) is not regulated, apart from an insurance requirement 

All activities related to accountancy 

A list of activities related to accountancy and auditing 

Accountancy (accountancy) is not regulated 

Activities in "public practice" - typically of principals in an accountancy firm or 

d

d

Table A5.13 Accountancy – Competent authority granting access to services 

MS  Establishment of a branch 

Professional chamber 
Professional chamber and general business register 

AT 
BE 
CY  None (professional chamber for voluntary registration) 
CZ  None (professional chamber for voluntary registration) 
DE  None (accountancy is not regulated) 
DK  None (accountancy is not regulated) 
ES  None (professional chamber for voluntary registration) 
FR 
IE 
IT 
LU 
MT  Professional chamber (if services relate to public financial 

Professional chamber 
None (accountancy is not regulated) 
Professional chamber and general business register 
Professional chamber 

Temporary cross-
border services 
None 
Same as for branches 
Same as for branches 
Same as for branches 
Same as for branches 
Same as for branches 
Same as for branches 
Same as for branches 
None 
None for legal persons 
Same as for branches 
Same as for branches 

reports) 

Professional chamber (for voluntary professional partnerships) 

PL  None (accountancy is not regulated) 
PT 
RO  Professional chamber 
SK  None (professional chamber for voluntary registration of natural 

None 
Same as for branches 
None 
Same as for branches 

persons) 

UK  None (professional bodies only check misuse of the title ex post)  Same as for branches 

May 2017 I 213 

 
 
 
 
 
Table A5.14 Accountancy – Legal form requirements 

MS  Establishment of a branch 

AT  All forms 
BE  All forms according to Belgian law, the relevant court decides in 

case of doubt 

Temporary cross-
border services 
All forms 
All forms 

CY  All forms (accountancy is not regulated) 
CZ  All forms (accountancy is not regulated) 
DE  All forms (accountancy is not regulated) 
DK  All forms (accountancy is not regulated) 
ES  All forms (accountancy is not regulated) 
FR  Any form except those company forms that grant associates the 
status of "trader". This means that partnerships and limited 
partnerships are not available but limited liability firms (Sarl) 
are allowed 
All forms (accountancy is not regulated) 
IE 
IT 
All forms 
LU  All forms 
MT  All forms 
All forms (accountancy is not regulated) 
PL 
PT 
All forms 
RO  All forms 
SK  All forms (accountancy is not regulated) 
UK  All forms 

All forms 
All forms 
All forms 
All forms 
All forms 
All forms 

All forms 
All forms 
All forms 
All forms 
All forms 
All forms 
All forms 
All forms 
All forms 

Table A5.15 Accountancy – Multidisciplinary restrictions 

MS  Establishment of a branch 

AT  None 
BE  Accountancy is incompatible with certain commercial activities (finance, 

insurance and real estate)  

CY  None 
CZ  None 
DE  None 
DK  None 
ES  None 
FR 

IE 

IT 

Any activity that could harm the independence of the accountant is 
prohibited, including a position in the National auditing body (Compagnie 
nationale des commissaires aux comptes), some commercial activities and 
any mandate to receive, keep or deliver funds or to values or to give a 
quittance. 
None to exercise the profession. For chartered status, non-chartered 
accountants in the firm must have "affiliate status", e.g. be in a register 
of other financial professionals 
Joint professions are allowed except for cases of conflict of interest. 
Companies can offer joint exercise of professions, but professionals 
working for the company can only do one professional activity to avoid 
conflict of interest. A professional cannot participate in more than one 
professional company. Therefore, accountants may only provide 
accountancy services but a company may also provide other services. 
[B]: The same professional cannot participate in more than one 
professional company 

LU  No paid employment is allowed 
MT  None 
PL  None 
PT 

Professional partnerships: activities that constitute the exercise of other 
regulated professions or under the jurisdiction of their own public 
association of another profession are incompatible; Other legal forms: no 
multidisciplinary restrictions on firms (only for professionals) 

RO  None 

214 I May 2017 

Temporary 
services 
None 
See branches 

None 
None 
None 
None 
None 
None 

See branches 

None 

None 
None 
None 
None 

None 

 
Administrative formalities and costs involved in accessing markets cross-border for 
provisions of accountancy, engineering and architecture services  

MS  Establishment of a branch 

SK  None 
UK  None to exercise the profession, for chartered status 50% of income must 

derive from public practice 

Temporary 
services 
None 
See branches 

Figure A5.5 Accountancy, Compulsory amount covered by PII a) 

PII: Professional Indemnity insurance. 

a) 
* Romania: The advised insurance is 4 times the fee or 6 times the fee for services provided to an 
entity of public interest. 

May 2017 I 215 

 
 
 
 
HOW TO OBTAIN EU PUBLICATIONS 

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or calling 00 800 6 7 8 9 10 11 (freephone number from anywhere in the EU) (*). 

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doi:10.2873/3219