REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the interconnection of national centralised automated mechanisms (central registries or central electronic data retrieval systems) of the Member States on bank accounts
Date: 2019-07-24
Institutions: Directorate-General for Justice and Consumers, European Commission
Subjects: access to information, bank deposit, centralisation of information, data protection, exchange of information, fight against crime, money laundering, personal data, systems interconnection, terrorism financing

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 24.7.2019  COM(2019) 372 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the interconnection of national centralised automated mechanisms (central registries or central electronic data retrieval systems) of the Member States on bank accounts  
 
 
REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND 
THE COUNCIL 

on the interconnection of national centralised automated mechanisms (central registries 
or central electronic data retrieval systems) of the Member States on bank accounts 

1.  Introduction 

Article 32a of the Anti-Money Laundering Directive 2015/849/EU1 requires Member States 
to  put  in  place  by  10  September  2020  national  centralised  automated  mechanisms,  such  as 
central registries or central electronic data retrieval systems, which allow the identification of 
any  natural  or  legal  persons  holding  or  controlling  payments  accounts,  bank  accounts  and 
safe  deposit  boxes.  The  Anti-Money  Laundering  Directive  defines  a  minimum  set  of 
information  that  should  be  included  in  such  centralised  mechanisms.  It  also  provides  that 
Financial Intelligence Units should have immediate and unfiltered access to them, while the 
other competent authorities should also have access for fulfilling their tasks obligations under 
the Anti-Money Laundering Directive. Directive 2019/1153 on facilitating access to financial 
and  other  information2  obliges  the  Member  States  to  designate  the  national  authorities 
competent for the prevention, detection, investigation or prosecution of criminal offences that 
should  have  direct,  immediate  and  unfiltered  access  to  the  minimum  set  of  information  of 
such  centralised  mechanisms.  Those  competent  authorities  shall  include  at  least  the  Asset 
Recovery Offices. 

Access by competent authorities to central bank account registers or retrieval systems will be 
an important component in the fight against money laundering; associate predicate offences 
and  terrorist  financing,  as  well  as  more  generally  in  combatting  serious  crimes.  Bearing  in 
mind the objectives of the Anti-Money Laundering Directive and the Directive on facilitating 
access to financial and other information, a future EU-wide interconnection of bank account 
registries  and  data  retrieval  systems  would  facilitate  the  cross-border  cooperation  of  the 
competent authorities involved in the fight against money laundering, terrorist financing and 
other  serious crimes. 

Article  32a(5)  of  the  Anti-Money  Laundering  Directive  requires  the  Commission  to  assess 
the  conditions  and  the  technical  specifications  and  procedures  for  ensuring  secure  and 
efficient  interconnection  of  the  centralised  automated  mechanisms.  Therefore,  this  report 
assesses  the  various  IT  solutions  at  EU  level,  already  operational  or  being  currently  under 

1 Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of 
the use of the financial system for the purposes of money laundering or terrorist financing, amending Regulation 
(EU)  648/2012  of  the  European  Parliament  and  of  the  Council,  and  repealing  Directive  2005/60/EC  of  the 
European Parliament and of the Council and Commission Directive 2006/70/EC, OJ L 0849, 09.07.2018, p.1.  
2 Directive (EU) 2019/1153 of the European Parliament and of the Council of 20 June  2019 laying down rules 
facilitating the use of financial and other information for the prevention, detection, investigation or prosecution 
of certain criminal offences, OJ L186 of 11.7.2019, pp. 122-137. 

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development,  which  may  serve  as  models  for  a  possible  interconnection  of  the  centralised 
mechanisms.  For  an  interconnection  to  be  achieved,  a  legislative  instrument  would  be 
required. 

This  report  should  considered  in  conjunction  with  the  Commission’s  Supranational  Risk 
Assessment  report3,  the  Commission’s  report  on  Financial  Intelligence  Units4  and  the 
Commission’s  report  on  the  assessment  of  recent  alleged  anti-money  laundering  cases 
involving EU credit institutions5, which are presented in parallel. 

2.  State of play 

2.1. Centralised  registries  or  electronic  data  retrieval  systems  on  bank  accounts  in  the 

Member States  

For  the  time  being6,  centralised  mechanisms  containing  bank  account  information  are 
operational in 15 Member States7. From the replies received from the Member States, there is 
a  slight  preference  in  favour  of  the  technical  solution  of  the  central  registry:  whereas  17 
Member  States  are  having  or  going  to  have  central  registries,  9  Member  States  declared  to 
have or to envisage central data retrieval systems8. There is also a preference for the systems 
which  contain  data  additionally  to  the  minimum  set  of  information  relating  to  the  account 
profile, provided for in Article 32a(5) of the 5th Anti-Money Laundering Directive (11 replies 
to 6)9. 

3 Report from the Commission to the European Parliament and the Council on the assessment of the risk of 
money laundering and terrorist financing affecting the internal market and relating to cross-border 
activities  COM (2019) 370. 
4 Report from the Commission to the European Parliament and the Council assessing the framework for 
cooperation between Financial Intelligence Units COM(2019) 371. 
5 Report from the Commission to the European Parliament and the Council on the assessment of recent alleged 
money laundering cases involving EU credit institutions  COM(2019) 373. 

6 The information in this section is based on the replies from the Member States to a dedicated Questionnaire 
sent to them in March 2019, on the information received in the transposition workshop of 1 April 2019 held by 
the  Commission and on Annex 7 of the Impact Assessment accompanying the Proposal for a Directive of the 
European  Parliament  and  of  the  Council  on  laying  down  rules  facilitating  the  use  of  financial  and  other 
information for the prevention, detection, investigation or prosecution of certain criminal offences and repealing 
Council Decision 2000/642/JHA (SWD(2018) 114 final).  
7  Belgium,  Bulgaria,  Czechia,  Germany,  Greece,  Spain,  France,  Croatia,  Italy,  Latvia,  Lithuania,  Austria, 
Portugal,  Romania,  Slovenia.  Slovakia  has  in  place  a  centralised  electronic  data  retrieval  system,  which  is, 
however, currently accessible only for judicial officers.  
8  Finland  adds  to  both  marks  as  it  is  about  to  deploy  a  system  which  uses  both  solution.  A  central  register 
collects and contains the relevant information in one central database, whereas a central electronic data retrieval 
system  consists  of  a  central  IT  portal,  retrieving  information  from  different  underlying  databases  (maintained 
e.g. by the financial institutions).  
9 From the replies received from the Member States such additional information might include information on 
financial  contracts  concluded  by  the  owner  of  the  account,  or  on  transactions  carried  out  in  relation  to  the 
account.   

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2.2. EU systems interconnecting national decentralised electronic databases 

There are several EU projects ensuring the EU-wide decentralised interconnection of national 
electronic  databases.10  The  IT  systems  that  are  considered  relevant  for  this  report  are  the 
following: 

The  European  Criminal  Records  Information  System  (ECRIS)  became  operational  in  April 
2012  in  order  to  improve  the  exchange  of  information  on  criminal  records  throughout  the 
EU.11 All Member States are currently connected to ECRIS. ECRIS ensures that information 
on convictions is exchanged between Member States in a uniform, fast and compatible way 
and provides judges and prosecutors with  easy access  to  comprehensive  information  on the 
criminal history of persons concerned.12  

The  European  c  and  driving  licence  information  system  (EUCARIS)  connects  countries  so 
they  can  share  vehicle  and  driving  licence  information  and  other  transport  related  data. 
EUCARIS  is  a  mechanism  that  connects  the  Vehicle  and  Driving  Licence  Registration 
Authorities  in  the  Union  through  which  vehicle  owner  and  vehicle  insurance  can  be 
exchanged between National Contact Points of Member States.13 

The  EU-wide  interconnection  of  insolvency  registers  (IRI),  which  includes  two  different 
projects.  The  first  version  of  the  system  (IRI  1.0)  has  been  available  on  the  European  e-
Justice  Portal14  since  July  2014.  It  was  developed  as  a  pilot-project15  with  the  voluntary 
participation of certain Member States16. The second version (IRI 2.0) is based on Regulation 
(EU)  2015/848  on  insolvency  proceedings,  and  will  interconnect  the  national  insolvency 
registries of all Member States (with the exception of Denmark). All Member States should 
be compliant with the interconnection by June 2021. IRI 1.0 is based on a standardised secure 

10  Centralised  IT  systems  with  single  databases  at  EU  level,  such  as  the  Schengen  Information  System or the 
Visa  Information  System,  are  excluded  from  the  assessment,  as  such  systems  are  irreconcilable  with  the  pre-
existence of nationally centralised databases. 
11  Council  Framework  Decision  2009/315/JHA  of  26  February  2009  on  the  organisation  and  content  of  the 
exchange of criminal records between Member States and Council Decision 2009/316/JHA of 6 April 2009 on 
the establishment of the European Criminal Records Information System (ECRIS) in application of Article 11 of 
Framework  Decision  2009/315/JHA  -  currently  modified  by  Directive  (EU)  2019/884  of  the  European 
Parliament  and  of  the  Council  of  17  April  2019  as  regards  the  exchange  of  information  on  third-country 
nationals and as regards the European Criminal Records Information System (ECRIS). 
12  In  April  2019  a  new  legislative  framework  was  adopted  in  order  to  supplement  ECRIS  with  a  mechanism 
allowing for efficient exchange of criminal records information on third country nationals convicted on the EU 
territory. The European Criminal Records Information System for Third Country Nationals (ECRIS-TCN) will 
be a centralised hit/no hit system containing only identity information of convicted TCN and indication of the 
Member State where he/she had been previously convicted. Upon the hit, the requesting Member State will have 
to  request  the  conviction  information  via  existing  ECRIS  from  the  Member  State(s)  indicated  by  the  ECRIS-
TCN. 
13 Legal bases for the Prüm service are the -  Council  Decision  2008/615/JHA  of  23  June  2008  on  the  stepping 
up  of  cross-border  cooperation,  particularly  in  combating  terrorism  and  cross-border  crime  and  Council 
Decision 2008/616/JHA on the implementation of Decision 2008/615/JHA.  
14https://beta.e-
justice.europa.eu/246/EN/bankruptcy_amp_insolvency_registers__search_for_insolvent_firms_in_the_eu 
15 The pilot project was implemented on the basis of and executed further to the Multiannual European e-Justice 
Action Plan 2009-2013, OJ C 75, 31.3.2009, p. 1-12 and the Multiannual European e-Justice Action Plan 2014-
2018, OJ C 182, 14.6.2014, p. 2-13. 
16  Currently  Czechia,  Germany,  Estonia,  Italy,  Latvia,  the  Netherlands,  Austria,  Romania  and  Slovenia 
participate.  

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web  service  messages  (SOAP  over  HTTPS),  while  IRI  2.0  additionally  supports  data 
exchanges leveraging the Connecting Europe Facility (CEF) eDelivery building block17. 

The  Business  Registers  Interconnection  System  (BRIS)  is  the  interconnection  of  business 
registers,  allowing  business  registers  to  exchange  cross-border  messages  on  mergers  and 
branches,  and  the  users  of  the  e-Justice  portal  to  obtain  multilingual  information  on  EU 
companies. The system has been operational since June 2017, in  accordance with Directive 
(EU)  2012/17  as  regards  the  interconnection  of  central,  commercial  and  companies 
registers18. BRIS uses the Connecting Europe Facility eDelivery building block for exchanges 
of  standardised  messages.  The  system  is  decentralised  with  a  central  component  (the 
European Central Platform) storing and indexing company names and registration numbers. 

The Land Registers Interconnection (LRI) is an on-going voluntary project19, which aims to 
provide  a  single  access  point  within  the  European  e-Justice  Portal  to  the  land  registers  of 
participating EU countries. It is planned to become operational in the second quarter of 2020. 

The European Business Ownership and Control Structures (EBOCS) is a project carried out 
by  European  Business  Registries  Association  with  the  financial  support  of  the  Internal 
Security  Fund  (ISF)  Police  (Annual  Work  Programmes  2016  and  2018).  The  EBOCS 
platform  provides  simplified  and  unified  access  to  business  register  data  on  business 
ownership  and  control  structures  for  financial  analysis  and  investigation  purposes.  It  also 
provides  for  the  aggregation  of  the  results  of the  queries  in  a  visualisation  map.  It  is  noted 
that the EU does not own the intellectual property rights of this system.  

The  e-CODEX  system  (e-Justice  Communication  via  Online  Data  Exchange)  facilitates 
secure communication in civil and criminal proceedings by providing a decentralised system 
for  cross-border  electronic  messages  exchange  in  the  justice  area.20  e-CODEX  is  currently 
facilitating the electronic communication between citizens and courts, and between Member 
State  administrations  in  piloting  the  European  Order  for  Payment  and  the  European  Small 
Claims Procedure.  In the criminal  justice field,  e-CODEX is  also  the solution of choice for 
the  e-Evidence  Digital  Exchange  System21,  for  electronic  exchanges  in  the  context  of  the 
European Investigation Order (EIO) and Mutual Legal Assistance Treaties (MLATs). 

17 https://ec.europa.eu/cefdigital/wiki/display/CEFDIGITAL/eDelivery 
18 Directive (EU) 2012/17 of the European Parliament and  of the Council of 13 June 2012 amending Council 
Directive (EEC) 89/666 and Directive (EC) 2005/56 and Directive 2009/101 of the European Parliament and of 
the Council as regards the interconnection of central, commercial and companies registers, OJ L 156, 16.6.2012. 
19 There is no legal basis for the interconnection but this functions as voluntary  system  where Member States 
can opt-in. 
20  The  e-CODEX  system  consists  of  a  package  of  software  products  (CEF  eDelivery  and  the  e-CODEX 
connector),  which  can  be  used  to  set  up  an  access  point  at  national  level  for  the  purpose  of  such  secure 
communication.  It  is  not  a  system  interconnecting  national  databases  or  registries,  but  a  communication 
infrastructure ensuring secure communication and exchange of information between national IT systems and as 
such  it  is  considered  relevant  for  the  assessment  in  this  report.  e-CODEX  was  developed  between  2010  and 
2016 by 21 Member States with the participation of other countries/territories and organisations. 
21 Established further to the Council conclusions on improving criminal justice in cyberspace from 9 June 2016. 

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3.  Main parameters  

3.1. Condition for access by users 

Looking at the existing systems, it is apparent that the accessibility of the user-facing system 
interacting with  the interconnected  IT system  is  determined by the purpose it is  established 
for. Where the interconnection was established with the aim to enhance the transparency of 
information  for  businesses  in  the  internal  market  (BRIS,  IRI),  the  system  is  publicly 
accessible. Where the objective of the interconnection is to improve cross-border cooperation 
between competent authorities for law enforcement or public administrative purposes, such as 
in the case of ECRIS or the Prüm service of EUCARIS22, the access is restricted.  

The "find a company" functionality of BRIS is available in the e-Justice Portal for everyone, 
while  the  messaging  infrastructure  is  currently  restricted  by  law  for  national  business 
registers.  With  regard  to  IRI,  the  information  through  the  search  interface  is  publicly 
accessible  and  a  possibility  for  Member  States  to  restrict  the  access  to  requestors  with  a 
legitimate interest is only given in the context of "consumer insolvency proceedings". ECRIS 
is accessible only to designated central authorities of the Member States. Similarly, the access 
to the services of EUCARIS is open to public authorities via the designated national contact 
points. For EBOCS, access is restricted to the participating Counter Crime Agencies.   

System 

BRIS 

IRI 
ECRIS 

EUCARIS 

EBOCS 

LRI 

Public access  Restricted 

comments 

access 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

The "find a company" functionality of BRIS is 
available  in  the  e-Justice  Portal  for  everyone, 
while the messaging infrastructure  is currently 
restricted  by 
for  national  business 
registers. 

law 

for  central  authorities  of  the  Member  States 
especially nominated for this function 
for  the  EUCARIS  National  Contact  Points, 
through  which  public  authorities  can  get 
access,  depending  on  the  legal  basis  of  the 
cooperation  
For  the  Counter  Crime  Agencies  participating 
in the project 
advanced  features  will  be  only  available  for 
authenticated legal professionals 

Table 1: Accessibility of the user-facing system interacting with the interconnected IT system 

Under the Anti-Money Laundering Directive, the purpose of the centralised mechanisms on 
bank  accounts  is  to  improve  the  fight  against  money  laundering  and  terrorist  financing  and 
access is limited to certain public authorities. The Directive on facilitating access to financial 
and  other  information  extends  the  purpose  of  the  use  of  the  information  in  the  central 
mechanisms  to  serious  crime  and  the  access  rights  to  designated  competent  authorities. 
Finally,  the  scope  of  the  domestic  authorities  having  direct  access  to  the  national  registries 

22 While several authorities can access EUCARIS, the Prüm service of EUCARIS regulates access by law 
enforcement authorities. 
 not yet operational 

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lies  with  the  Member  States  operating  the  registries.  This  might  lead  to  a  discrepancy,  as 
certain  types  of  authorities  might  get  access  in  one  Member  State  but  not  in  another.  In  a 
cross-border  exchange  through  the  EU-wide  interconnection  system  this  could  lead  to  a 
situation where an authority is  requesting information from  the registry of another Member 
State, where that search is denied to a similar authority.  

One option could be that the same authorities, which will  be provided with direct access to 
the centralised mechanisms in accordance with the Anti-Money Laundering Directive and the 
Directive  on  facilitating  access  to  financial  and  other  information,  will  be  provided  with 
access  to  the  interconnection  platform.  Another  option  would  be  that  access  rights  to  the 
interconnection system are given to the same types of authorities in all Member States, which 
could  be  achieved  by  a  harmonised  and  closed  list  at  EU  level  of  the  types  of  authorities 
specified in accordance with the purpose of the access to the information. 

In  case  the  interconnection  is  extended  to  all  authorities  currently  granted  access  under  the 
national laws, detailed provisions on the conditions for access and searches by the competent 
national  authorities  would  be  necessary.  In  this  regard,  it  is  important  to  highlight  that  the 
Directive  on  the  use  of  financial  information  and  other  information  lays  down  strict 
conditions  for  the  access  and  for  searches  of  bank  account  information,  contained  in  the 
centralised  automated  mechanisms  by  competent  authorities,  designated  at  national  level. 
Such  conditions  include,  for  example,  the    provision  of  access  to  the  registries  and  data 
retrieval  systems  only  to  specifically  designated  and  authorised  persons  of  each  competent 
authority.  Another  measure  mitigating  the  risks  posed  by  the  enlarged  access  rights  by  the 
designated  national  authorities  could  be  the  restriction  of  the  scope  of  the  available 
information in the interconnection system to the minimum set of information relating to the 
account profile as set out in Article 32a(3) of the Anti-Money Laundering Directive.   

As  regards  the  scope,  Article  32a(3)  Anti-Money  Laundering  Directive  defines  the 
information which all centralised systems have to contain, such as the account holder, bank 
accounts  identified  by  IBAN  and  safe  deposit  boxes  held  by  a  credit  institution  within  the 
national  territory.  However.  Article  32a(4)  of  the  Directive  provides  for  the  possibility  that 
Member  States  include  other  information  in  the  registries  deemed  essential  for  Financial 
Intelligence  Unis  and  competent  authorities  for  fulfilling  their  obligations  under  the 
Directive. From a perspective of protection of personal data, it appears necessary to restrict 
the scope of the information accessible through the interconnection platform to the minimum 
mandatory  set  of  information  defined  in  Article  32a(3)  of  the  Anti-Money  Laundering 
Directive.  In  line  with  data  protection  rules,  the  access  to  personal  data  should  be 
proportionate  to  what  is  necessary  for  the  objectives  defined  in  Anti-Money  Laundering 
Directive.  A  similar  approach  is  taken  by  the  Directive  on  the  use  of  financial  and  other 
information.  Article  4(2)  of  this  Directive  clarifies  that  the  additional  information  that 
Member States include in the centralised mechanisms shall not be accessible and searchable 
by competent authorities. 

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3.2. Search functionality 

The applicable search criteria are of key importance to ensure that the interconnection of the 
automated  centralised  mechanisms  brings  added  value  for  the  users.  The  search  criteria 
should be designed in a way that reinforces the relevant authorities’ capacity to carry out their 
tasks  and  conduct  investigations  more  effectively  while  ensuring  proportionality  and 
respecting the applicable data protection requirements. 

Consideration should be given to who will be entitled to perform the search (private parties or 
public  parties)  and  to  the  data  which  can  or  cannot  be  expected  to  be  known  to  the  person 
carrying  out  the  search.  Imposing  a  requirement  that  the  search  should  contain  data  that  is 
unlikely  to  be  known  to  the  person  conducting  the  query  may  render  effective  searches 
difficult or impossible. It is also noted that there are cases where a Financial Intelligence Unit 
or a law enforcement authority from one Member State will not be aware of the date of birth 
or national identification number of a citizen of another Member State. If the interconnection 
is  made  available  to  such  additional  information  in  the  centralised  systems,  it  will  be 
important to determine whether it will also be possible to carry out searches on the basis of 
such additional information.  

The types of information constituting the harmonised minimum set of information in Article 
32a(3)  of  the  Anti-Money  Laundering  Directive  could  be  envisaged  as  search  criteria.  This 
would  make  the  interconnection  system  fit  for  original  purposes  of  the  centralised 
mechanisms.  Additional  safeguards  in  allowing  to  verify  hits  (in  particular  in  cases  where 
search results in several replies) would be needed. 

The conditions on the modalities of searches applicable are decisive on the effectiveness of 
the use of the interconnected databases. The option to run “fuzzy searches”, i.e. searches that 
will deliver broader results even if a word is misspelled or incomplete, will broaden the hit 
results, thereby increasing the probability that the requested information is accessed through 
the  search,  but  might  raise  data  protection  concerns,  as  it  might  expose  personal  data  that 
were  not  actually  concerned  by  the  search.  On  the  contrary,  an  "exact  match"  requirement 
mitigates the risks of unnecessary exposure of personal data, but will increase the probability 
that the requested information is overlooked by the search engine (in case of difference in the 
spelling of the entry or of using different transliteration rules). 

The possibility of carrying out ”fuzzy searches” would reduce the use of automatic validation 
procedures and therefore avoid or reduce the volume of erroneous hits, but would also reduce 
the operational value of the system. In case of using ”fuzzy searches” other tools to mitigate 
the risk of fishing expeditions should be considered, for example as in  IRI where there is a 
maximum limit of the number of displayed results.  

3.3. Governance structure, responsibility for maintenance  

In the case of BRIS, IRI, LRI and ECRIS the various services of the European Commission 
are responsible for maintaining the IT system, i.e. they have to ensure the availability of the 
interconnection component and they bear the costs of setting up and maintaining it. For the 
time being e-CODEX is maintained by a consortium of Member States (the CEF eDelivery 

7 

 
 
component is within the European Commission’s remit). In EUCARIS, the responsibility is 
borne  by  the  28  Member  States  and  the  participating  third  States,  while  in  EBOCS,  the 
system  is  owned  by  the  European  Business  Registers’  Association  (EBRA).  Since  these  IT 
systems  are  interconnecting  national  databases,  the  responsibility  to  maintain  the  national 
databases and to ensure their availability is for the Member States. 

For  the  governance  structure  of  a  system  interconnecting  databases,  the  competences  in 
decision making in policy and operational issues should be constructed in a way in which it 
serves the interests of the national components.  

In  BRIS,  the  BRIS  Steering  Committee  acts  as  the  Commission’s  internal  forum  for  the 
policy decisions, oversight and management of BRIS, while the Company Law Expert Group 
–  Business  Registers  (CLEG-BRIS)  acts  as  the  forum  for  the  policy  level  collaboration 
between  the  actors  involved.  A  similar  distinction  between  policymaking  and  operative 
structures can be seen with regard to  EUCARIS where the General  Assembly  consisting of 
high  representatives  of  the  government  agencies  determines  the  policy  to  be  pursued, 
endorses  the  budget  and  annual  contributions  and  makes  arrangements  for  system 
management.  

3.4. Data controllership  

The responsibility for maintaining the IT system is different from the issue of responsibility 
from  the  perspective  of  data  protection.  According  to  the  General  Data  Protection 
Regulation23,  the  data  controller  is  the  natural  or  legal  person  which,  alone  or  jointly  with 
others, determines the purposes and means of the processing of personal data, and bears the 
responsibility for the processing of personal data. The issue of controllership is complex and 
many  factors  are  relevant  for  the  assessment  of  controller,  including  but  not  limited  to  the 
question who stores the data and where).  

With  regard  to  IRI,  the  EU  platform  is  only  interconnecting  the  decentralised  national 
databases and all the data displayed in the central platform are simply “transient data”, they 
are not stored in the EU component, nor are logs from the queries run by the users through 
the  web-service  recorded  or  kept  at  the  centre.  The  situation  is  somewhat  different  with 
regard to  BRIS, which introduced a particular feature of storing the core profile data of the 
businesses  in  a  central  component  at  Commission  level,  which  the  national  registries  keep 
updating in regular intervals. The initial query is run against this central database, resulting in 
a  hit-list  with  the  names  of  the  entities.  The  requestor  can  get  detailed  data  on  a  particular 
entity by  choosing the name of that  entity  from  the  hit-list,  which action generates  a direct 
interconnection to the information in the national database.  

With regard to a possible interconnection of centralised mechanisms, consideration should be 
given  to  developing  an  IT  system,  where  the  central  routing  component  does  not  store  any 
personal data, and where all decisions on the means and purposes of data processing are taken 

23 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection 
of natural persons  with regard to the processing of personal data  and on the free movement of such data, and 
repealing Directive 95/46/EC (General Data Protection Regulation), OJ L 119, 4.5.2016. 

8 

 
 
                                                           
at  national  level.  The  objective  of  the  interconnection  service  would  be  simply  to  facilitate 
data processing on behalf of the centralised mechanisms that would remain the controllers of 
their respective data sets.   

3.5. Costs of establishment and maintenance 

Setting up a system interconnecting the national central mechanisms will generate costs both 
in terms of establishment and in terms of maintenance of the system, which costs would have 
to  be shared between the EU and its Member States.  Looking at  the sharing of costs in  the 
model examples, as a rule, the costs related to the EU component (central routing component, 
EU platform) were financed from the general budget of the EU, whereas Member States bore 
the costs needed for the adjustment of their national systems making them interoperable with 
the EU system of interconnection. In the case of BRIS, the development of the first version, 
that went live on June 2017, which included the European Central Platform, required around 
EUR  1,7  million.  As  to  IRI  which  has  a  more  simple  architecture,  the  costs  for  the 
development of the central search pilot system (IRI 1.0) were approximately EUR 280 000, 
whereas the adaptation of the central search application towards the establishment of IRI 2.0 
will  cost  approximately  EUR  170  000.  With  regard  to  ECRIS,  the  total  cost  of  the 
deployment  of  the  “Reference  Implementation”,  which  is  the  software  to  exchange  data 
concerning  criminal  records  between  Member  States,  reached  EUR  2  050  000.  The  yearly 
cost of maintenance of the system amounted to EUR 150 000. With regard to EUCARIS, a 
general fee of around EUR 20 000 is asked from each participating countries for maintenance 
purposes. 

From the figures above, it appears that the costs of establishment and maintenance of an EU-
wide interconnection system are relatively low, compared to the benefits such a project brings 
to  the  EU.  Cost  efficiency  could  be  improved  by  reusing  existing  capacities  (such  as 
eDelivery access points, Connecting Europe Facility building blocks, core vocabularies of the 
European Commission’s Directorate-General for Informatics, etc.). 

4.  Technical specifications of the systems, including data security 

4.1. Network used and data security 

The Prüm service of EUCARIS and ECRIS use the Trans European Services for Telematics 
between Administrations (TESTA), which is a private network completely separate from the 
public  internet.  The  designated  national  contact  points  have  access  to  this  private  network. 
The  TESTA  network  service  is  run  by  the  Commission,  and  provides  guaranteed 
performance and a high level of security. As to EUCARIS, use via public internet is possible, 
but currently not used. It has connections with all the EU institutions and national networks 
and  is  preferred  in  the  context  of  law  enforcement  cooperation  which  involves  sensitive 
information.  Other  secure  networks  have  also  been  developed  by  the  EU  institutions,  for 
example the Common Communications Network and Common Systems Interface (CCN/CSI) 
which is in use in the area of customs policy and taxation.  

9 

 
 
internet, 

BRIS, IRI, LRI and EBOCS use the public internet (with appropriate encryption technology 
for data flowing through the web). When it comes to the secure exchange of information over 
the  public 
the  eDelivery  building  block  enables  businesses  and  public 
administrations  to  exchange  electronic  data  and  documents  in  digital  format  in  an 
interoperable, secure, reliable and trusted way with other organisations. This is aligned with 
the definition of Electronic Registered Delivery Services (known as 'ERDS') in article 3(36) 
of the eIDAS Regulation.24  

For  the  possible  interconnection  of  centralised  systems  which  arguably  includes  sensitive 
information,  the  use  of  TESTA  could  be  envisaged.  Nevertheless,  public  internet  solutions 
could  also  be  considered.  Almost  all  national  centralised  systems  use  the  public  internet. 
From  the  perspective  of  data  security  and  integrity,  the  fact  that  the  system  will  consist  of 
decentralised  databases  will  mitigate  possible  risks,  as  decentralisation  and  distributed 
technologies  are  per  se  more  resilient  to  cyber-attacks,  since  it  is  much  more  difficult  to 
corrupt data to a general scale and much more easier to recover data after incidents.  

4.2. Central routing component 

There are two main types of architectures of IT systems, i.e. the purely decentralised systems 
and  those  that  have  a  central  platform  or  routing  component  deployed  at  EU  level,  which 
serves as "connector" between the decentralised national databases.   

In  “purely  distributed  systems”,  there  is  no  EU  platform  or  component,  but  all  countries 
communicate directly to each other, with the help of commonly agreed standards which allow 
for  direct  peer-to-peer  exchanges  between  the  connected  points  of  the  Member  States. 
Therefore,  when  a  query  is  launched,  this  is  dispatched  individually  to  each  other  national 
system, and the replies received are collected and displayed trough the web-client surface of 
the  requestor.  EUCARIS,  ECRIS  and  e-CODEX  implement  this  technology  (relying  on  a 
jointly developed application). 

In  "distributed  systems  with  a  central  routing  component"  there  is  a  centralised  platform  at 
EU  level:  a  single,  central  web-service,  maintained  and  operated  at  the  EU  level,  which  is 
connected to all national systems. Users run queries through the central  web-service, which 
collects  the  information  from  the  national  databases.  BRIS,  EBOCS  and  IRI  use  this 
technology.25 

A  solution  with  a  central  routing  component  might  be  easier  to  implement  from  a 
connectivity  point  of  view.  Where  there  is  one  single  platform,  each  Member  State  has  to 
establish and maintain only one connection between the national system and this centralised 

24 Regulation (EU) No 910/2014 of the European Parliament and of the Council of 23 July 2014 on electronic 
identification  and  trust  services  for  electronic  transactions  in  the  internal  market  and  repealing  Directive 
1999/93/EC, OJ L 257, 28.8.2014, p. 73–114. 
25 There  are  alternatives to a central component.  For example, the CEF eDelivery Service Metadata  Publisher 
(SMP) enables the participants of a  messaging infrastructure to dynamically discover each other's capabilities 
(legal,  organisational,  and  technical).  Because  of  this  distributed  architecture,  each  participant  has  to  have  a 
unique ID. A central component, called Service Metadata Locator (SML), uses these IDs to create URLs that, 
when resolved, direct the eDelivery Access Points towards the specific information about the participant. 

10 

 
 
                                                           
platform. In absence of a ‘real’ centralised platform, however, each Member State will need 
to establish, test and maintain connections to all other national systems of the Member States 
(e.g.  the  Prüm  service  of  EUCARIS  currently  counts  almost  756  connections).  A  purely 
distributed  system  has  to  deal  with  the  challenge  of  the  multiplied  number  of  connections, 
which may increase the problems in terms of management, control and audit. Nevertheless, 
there  are  technological  solutions  to  the  challenge  of  managing  large  number  of  possible 
connections. At the same time, the fact that in a central routing system the central component 
may become a single point of failure for the whole system deserves due consideration. 

4.3. Data exchange protocol 

The BRIS and e-CODEX use the CEF eDelivery solution, whereas the IRI 2,0 will use both 
the  CEF  eDelivery  and  SOAP26  communication.  The  Prüm  service  of  EUCARIS  and  the 
EBOCS use SOAP based interfaces. The LRI applies RESTful Web Sevices27.  

The CEF eDelivery Building Block helps users to exchange electronic data with one another 
in  a secure,  reliable  and  trusted way. The CEF  eDelivery solution  is  based on a distributed 
model called the “4-corner model” where the back-end systems of the users do not exchange 
data directly with each other but through Access Points. These Access Points are conformant 
to the same technical specifications and therefore capable of communicating with each other. 
Another benefit of eDelivery is that it caters for the security of the data exchanged between 
the  different  access  points,  without  the  need  for  bespoke  development.  As  a  result  of  this, 
users adopting CEF eDelivery can easily and safely exchange data even if their  IT systems 
were  developed  independently  from  each  other.  The  eDelivery  model  –  very  useful  for 
interfacing  with  multiple  back-end  systems  –  various  functionalities  can  be  centralised 
instead.  When  using  this  technology  solution,  the  Member  States  (and  optionally  the 
Commission in the case of a central routing component) would have to deploy an eDelivery 
gateway at their respective level. They can reuse their existing gateways developed for other 
services  (which  contributes  to  the  cost  effectiveness  of  the  solution).  There  is  a  compatible 
software  solution  developed  by  the  European  Commission’s  Directorate-General  for 
Informatics  and  provided  free  of  charge  under  a  European  Union  Public  Licence  (EUPL). 
However,  some  customisation  and  development  is  usually  required.  The  eDelivery  model 
follows  asynchronous  communication,  which  implicitly  generates  certain  latencies  in 
performance  (typically  of  3-10  seconds).  There  is  a  general  EU  policy  with  regard  to  CEF 
building  blocks  aiming  at  the  convergence  of  the  various  systems  developed  under  the 
different EU policy areas.  

Where synchronous SOAP – allowing for communication over a secure layer – is used, most 
often a more simple architecture is chosen, aiming at best performance. RESTful architectural 
style represents a newer solution compared to SOAP, and there is a trend emerging, whereby 
SOAP  is  supplanted  by  REST  technology.  In  both  eDelivery  and  SOAP  or  REST  based 
approaches trust is usually digital certificate-based and various checks are done. 

26 Simple Object Access Protocol. 
27 Representational State Transfer is a software architectural style that defines a set of constraints to be used for 
creating Web services. 

11 

 
 
                                                           
As for future interconnection of the centralised mechanisms, it is noted that in CEF eDelivery 
is  used  where  bilateral  exchanges  between  the  decentralised  national  databases  are  taking 
place, whereas in the systems where the communication takes place only vis-à-vis a national 
database and the central platform, the SOAP based interface (or RESTful) is sufficient.   

4.4. Working in a multilingual environment and semantic interoperability 

All assessed systems work in multilingual environment, apart from EBOCS which currently 
works in  three languages  with  the plan to  work in  all languages in  the long-term.  In BRIS, 
transliteration is carried out at EU level, whereas in IRI, LRI and EUCARIS at national level. 
With regard to  semantic interoperability (glossaries), a future interconnection of centralised 
mechanisms not require a specific vocabulary as the minimum set of information consists not 
of  national  concepts,  but  personal  data,  such  as  name,  unique  identifier  (e.g.  national  ID 
numbers) and IBAN number. A common understanding in all national systems is essential, in 
particular because the national  centralised mechanisms do not  information  on EU and third 
country  entities.  The  transliteration  rules  of  the  Schengen  Information  System  (SIS)  could 
serve as a useful example in this context.  

According  to  the  European  Interoperability  Framework  (EIF),  the  semantic  aspect  refers  to 
the  meaning  of  data  elements  and  the  relationships  between  them.  It  includes  developing 
vocabularies  and  schemata  to  describe  data  exchanges,  and  ensures  that  data  elements  are 
understood in the same way by all communicating parties.  

The system  to  interconnect  banking  registries will need to  exchange data between different 
databases,  each  with  its  own  data  models  and  semantic  standards.  Common  semantic 
standards will need to be set up, either natively in the systems or as a mapping layer between 
the  different  standards  in  the  Member  States.  However,  before  creating  any  new  semantic 
standard, reuse of already existing standards needs to be considered.  

The Core Vocabularies (Business,  Location,  Person, as well as  others) created by the  ISA2 
Programme  are  simplified,  reusable,  and  extensible  data  models  that  can  be  used  for  this 
purpose.  The  different  solutions  for  the  interconnections  of  base  registries,  such  as  BRIS 
already reuse some of the standards (for example the Core Business Vocabulary). 

5.  Next steps 

This reports sets out a number of elements to be considered for a possible interconnection of 
bank account  registries and data retrieval  systems and illustrates that the interconnection of 
those  centralised  mechanisms  is  technically  feasible.  Such  a  system  could  possibly  be  a 
decentralised system with a common platform at EU level. Technology already developed by 
the European Commission in the context of the various analysed models could be used. 

Over  the  last  years  different  systems  have  followed  the  reuse  of  common  building  blocks. 
These  building  blocks  are  essentially  a  set  of  well-known  standards  and  technical 
specifications  that  can  be  applied  to  recurrent  challenges  such  as  the  secure  exchange  of 
information.  Consistently  resorting  to  these  building  blocks  is  an  approach  advocated  by 

12 

 
 
current  digital  policy  of  the  Commission,  to  which  the  Member  States  have  committed 
themselves in the Tallinn Declaration on eGovernment28. A future interconnection of national 
centralised  automated  mechanisms  could  leverage  the  use  of  the  same  building  blocks  to 
accelerate its creation and alignment to relevant EU regulations such as eIDAS.  

Given that a future EU-wide interconnection of the centralised mechanisms would speed up 
access  to  financial  information  and  facilitate  the  cross-border  cooperation  of  the  competent 
authorities,  the  Commission  intends  to  further  consult  with  the  relevant  stakeholders, 
governments,  as  well  as  the  Financial  Intelligence  Units,  law  enforcement  authorities  and 
Asset Recovery Offices as potential "end-users" of a possible interconnection system. 

28 All the European Union Member States and EFTA countries signed the 'eGovernment Declaration' in Tallinn 
on 6 October 2017. The text of the Declaration is available at 
http://ec.europa.eu/newsroom/document.cfm?doc_id=47559  

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