Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on a public interface connected to the Internal Market Information System for the declaration of posting of workers and amending Regulation (EU) No 1024/2012
Date: 2024-11-13
Institutions: Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, European Commission
Subjects: administrative cooperation, administrative formalities, application programming interface, cross-frontier data flow, digital single market, exchange of information, information system, labour mobility, multilingualism, posted worker

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   EUROPEAN COMMISSION  Brussels, 13.11.2024  COM(2024) 531 final 2024/0301 (COD)  Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on a public interface connected to the Internal Market Information System for the declaration of posting of workers and amending Regulation (EU) No 1024/2012 {SWD(2024) 258 final}  
 
EXPLANATORY MEMORANDUM 

CONTEXT OF THE PROPOSAL 

• 

Reasons for and objectives of the proposal 

The  freedom  to  provide  services  includes  the  right  of  service  providers  established  in  a 
Member State to provide services in another Member State, to which they may post their own 
workers  temporarily  to  provide  those  services  there.  When  posting  its  workers,  the  service 
provider  needs  to  comply  with  a  set  of  defined  terms  and  conditions  of  employment,  as 
established  by  Directive  96/71/EC1,  in  the  Member  State  to  which  the  posting  takes  place. 
This is to ensure the minimum protection of the posted workers concerned. Member States are 
required  to  work  in  close  cooperation  and  provide  each  other  with  mutual  assistance  to 
facilitate  the  monitoring  of  compliance  with  these  terms  and  conditions  of  employment. 
Avoiding  unnecessary  administrative  burden  on  the  service  providers,  protecting  posted 
workers and ensuring effective monitoring should go thereby hand in hand and contribute to 
the proper functioning of the internal market. 
As  set  out  in  Article  9(1)  of  Directive  2014/67/EU2,  to  ensure  effective  monitoring  of 
compliance with  the obligations in  that Directive and  in  Directive 96/71/EC  Member States 
may only impose administrative requirements and control measures that are necessary for that 
purpose,  provided  these  are  justified  and  proportionate  in  accordance  with  EU  law.  In  this 
context, according to Article 9(1)(a) of Directive 2014/67/EU, Member States may impose an 
obligation  for  a  service  provider  established  in  another  Member  State  to  make  a  simple 
declaration  to  the  responsible  national  competent  authorities  containing  the  relevant 
information necessary in order to allow factual controls at the workplace. 
In  the  update  to  the  2020  new  industrial  strategy3,  the  Commission  announced  that  it  will 
work  with  Member  States  to  devise  a  common  form,  in  an  electronic  format,  for  the 
declaration of the posting of workers. This work shall not compromise the existing EU legal 
framework  for  the  posting  of  workers  and  the  workers’  protection  it  ensures.  Participation 
shall be voluntary.  

In its March 2024 Communication entitled ‘Labour and skills shortages in the EU: an action 
plan’4,  the  Commission  announced  that  it  will  promote  the  widespread  implementation  of  a 
common  form  of  electronic  format  for  posted  worker  declarations,  complemented  by  the 
development  of  a  digital  multilingual  portal  through  which  companies  can  submit  posting 
declarations for Member States that decide to make use of this tool. This will help reduce the 
administrative burden. 

The  announcement  followed  concerns  raised  in  the  evaluation  of  the  implementation  of 
Directive  2014/67/EU.  In  the  implementation  report  of  Directive  2014/67/EU5  the 
Commission  concluded  that  improvements  may  be  necessary  in  some  areas  that  different 

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Directive  96/71/EC  of  the  European  Parliament  and  of  the  Council of 16  December  1996  concerning 
the  posting  of  workers  in  the  framework of  the  provision of  services  (OJ  L  18,  21.1.1997, p. 1,  ELI: 
http://data.europa.eu/eli/dir/1996/71/oj). 
Directive  2014/67/EU  of  the  European  Parliament  and  of  the  Council  of  15  May  2014  on  the 
enforcement  of  Directive  96/71/EC  concerning  the  posting  of  workers  in  the  framework  of  the 
provision  of  services  and  amending  Regulation  (EU)  No  1024/2012  on  administrative  cooperation 
through  the  Internal  Market  Information  System  (‘the  IMI  Regulation’)  (OJ  L  159,  28.5.2014,  p.  11, 
ELI: http://data.europa.eu/eli/dir/2014/67/oj). 
COM(2021) 350 final. 
COM(2024) 131 final. 
COM(2019) 426 final. 

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stakeholders  had  brought  to  its  attention.  These  include  simplifying  administrative  control 
systems by, for example, introducing a single EU-wide declaration system. 

The objective of this proposal is to reduce administrative burden for businesses and national 
competent  authorities by facilitating on the one hand the submission of posting declarations 
where required, in a user-friendly way, at a distance and by electronic means, and on the other 
hand  the  administrative  cooperation  between  Member  States  as  well  as  the  effective 
monitoring of compliance with the obligation set out in Directives 2014/67/EU and 96/71/EC. 

The  proposal  will  make  it  easier  for  Member  States  to  carry  out  effective  and  adequate 
inspections on their territory, contributing to the protection of posted workers. 

Since January 2023, Member States have been advising the Commission in the expert group 
on a common electronic form for the declaration of posting of workers, with particular regard 
to the relevant information necessary in order to allow factual controls at the workplace. With 
the advice of the Member States’ experts a possible common list of information requirements 
for the declaration of posting of workers has been identified. An initial group of nine Member 
States  declared  in  the  meantime  their  commitment  to  adapting  the  information  they  request 
from  service  providers  posting  workers  to  their  territories  to  the  information  requirements 
devised in the common list of information requirements6. 

A public interface connected to the Internal Market Information System (‘IMI’) 

The  proposal  sets  up  a  multilingual  electronic  public  interface  (i.e.  a  secure  web  portal  for 
using a common electronic format and allowing automatic transfer of data) connected to the 
Internal Market Information System (‘IMI’), established by Regulation (EU) No 1024/2012 of 
the  European  Parliament  and  of  the  Council7  (‘the  public  interface’)  for  voluntary  use  by 
Member  States  receiving  posted  workers  (the  ‘host  Member  State’).  These  host  Member 
States may choose to require service providers established in other Member States to use this 
interface  to  make  a  simple  declaration  of  workers  posted  (a  ‘posting  declaration’)  to  its 
responsible national competent authorities to allow factual controls at the workplace. IMI is a 
multilingual electronic tool that allows national, regional and local authorities to communicate 
quickly and easily with their counterparts in the EU. A repository in IMI will allow national 
competent  authorities  to  check  the  details  of  posting  declarations  submitted  by  service 
providers. The use of IMI will make it possible to reuse existing IT solutions, thus helping to 
reduce the one-off costs of IT development. 

Service  providers  will  use  the  public  interface  to  submit  a  posting  declaration  to  the 
competent national authorities of the host Member State. To this end, the interface will feature 
a  standard  form.  This  standard  form  will  provide  the  relevant  information  that  may  be 
necessary  to  allow  factual  controls  at  the  workplace,  in  accordance  with  Article  9(1)(a)  of 
Directive 2014/67/EU. It will contain information related to the service provider, the posted 
worker, the posting assignment, the contact person for competent authorities and the service 
recipient.  The  specific  content  of  the  standard  form  will  be  set  out  in  an  implementing  act. 
The advice given by the Member States’ expert group regarding the relevant information to be 
contained in such form will be taken into account. 

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at 

The  declaration  was  presented 
(https://data.consilium.europa.eu/doc/document/ST-10061-2024-INIT/en/pdf.) 
Regulation (EU) No 1024/2012 of the European Parliament and of the Council of 25 October 2012 on 
administrative cooperation through the Internal Market Information System and repealing Commission 
Decision  2008/49/EC 
(OJ  L  316,  14.11.2012,  p.  1,  ELI: 
http://data.europa.eu/eli/reg/2012/1024/oj). 

the  Competitiveness  Council  of  24  May  2024 

IMI  Regulation’ 

‘the 

( 

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The Commission should be granted implementing powers to establish the standard form and 
make  subsequent  changes  to  it.  Should  Member  States  consider  that  relevant  information 
should be added or not relevant information be removed from the standard form, in or for the 
use of the public interface, they may submit proposals to the Commission for amendment of 
the  standard  form  and  inclusion  of  information  requirements  that  they  deem  necessary,  as 
long as they are justified and proportionate, to carry out effective controls at the workplace.  

Member States may decide that certain elements contained in the standard form, that they do 
not consider relevant in view of their national context and the way they organise the factual 
controls  at  the  workplace,  are  not  required  from  service  providers  posting  workers  to  their 
territory  filling  in  the  form  on  the  public  interface.  In  such  case  they  should  inform  the 
Commission.  In  the  case  of  elements  arising  from  subsequent  amendments  to  the  standard 
form, those Member States would accordingly not need to adapt their national legislation to 
include such elements. 

The setting up of the public interface with a multilingual standard form for the declaration of 
posting of workers and the making available of this interface to national competent authorities 
by  the  European  Commission  is  without  prejudice  to  the  responsibility  of  the  European 
Commission  for  overseeing  the  correct  implementation  and  application  of  Union  law  by 
Member  States,  in  accordance  with  Article  17(1)  of  the  Treaty  on  European  Union,  and  its 
powers  under  Article  258  Treaty  on  the  Functioning  of  the  European  Union  as  well  as  the 
Member States' obligation to comply with Union law.  

Reducing administrative burden for service providers 

Stakeholders  have  consistently  highlighted  that  the  obligation  and  the  requirements  for 
making a posting declaration constitute a significant reporting requirement for businesses in 
the single market. This is regarded as one of the most significant administrative barriers for 
the cross-border provision of services in the internal market. 

Streamlining  the  reporting  obligations  and  the  procedure  for  the  submission  of  posting 
declarations  will  significantly  reduce  the  administrative  burden  for  businesses,  including 
SMEs, and will facilitate that Member States carry out effective and adequate inspections. 

A multilingual public interface using a standard form will allow posting companies to make 
their posting declarations in one place and with the same set of requested information, in all 
the  participating  Member  States,  i.e.  the  Member  States  making  use  of  the  public  interface, 
they post workers to. They will be able to make the posting declaration in their own language, 
thus  overcoming  the  language  barrier  posting  companies  (service  providers)  face  regularly 
when declaring postings in the declaration system of the Member State they post workers to. 

The  proposal  provides  a  contribution  to  the  Commission’s  commitment  to  reduce  reporting 
requirements  resulting  from  EU 
its  Communication  on  ‘Long-term 
legislation.  In 
competitiveness of the EU: looking beyond 2030’8, the Commission stressed the importance 
of  a  regulatory  system  that  ensures  that  objectives  are  reached  at  minimum  costs.  It  has 
committed therefore to a fresh push to  rationalise and simplify reporting requirements, with 
the ultimate aim to reduce the associated administrative burden by 25%, without undermining 
the related policy objectives. The SME Relief Package9 further elaborated on this action and 
flagged  the  creation  of  an  electronic  format  for  the  declaration  of  posting  of  workers  as  an 
example for using digital technologies to reduce burden and improve resilience. 

Protection of workers’ rights 

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COM(2023) 168 final. 
COM(2023) 535 final. 

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The submission of posting declarations via the public interface will also allow for a better and 
more uniform application of Directive 96/71/EC. Facilitating the declaration and protection of 
posted workers is another element in EU legislation ensuring fair mobility.  

Since  service  providers  will  no  longer  need  to  comply  with  different  national  requirements 
included in the national interfaces and posting declaration forms in the participating Member 
States, the public interface using a standard form will contribute to reducing the cases of non-
compliance with the posting rules. This will also lead to increased transparency in posting.  

In this context, the initiative makes it easier for Member States to carry out effective, adequate 
and targeted inspections, contributing  to  the protection of posted workers’ rights  and  to  fair 
mobility as a whole. 

Moreover,  the  possibility  to  send  a  copy  of  the  declaration  to  the  posted  worker  will  make 
posted workers informed actors in the procedure, thus  helping them to  exercise their rights. 
This possibility does not exist today in national declaration systems. 

Reducing  administrative  burden 
administrative cooperation  

for  Member  States’  authorities  and 

facilitating 

Directive  2014/67/EU  introduced  rules  on  administrative  cooperation  between  national 
authorities  in  charge  of  monitoring  compliance  with  rules  on  the  posting  of  workers.  This 
administrative  cooperation  is  implemented  through  IMI.  IMI  therefore  plays  a  key  role  in 
supporting the strengthened administrative cooperation underpinning the Directive.   

The  Posting  of  Workers  Request  module  is  the  main  module  in  IMI  for  administrative 
cooperation  under  Directive  2014/67/EU  and  Directive  96/71/EC.  It  supports  mutual 
assistance by allowing an authority in one Member State to request information or assistance 
from an authority in another Member State.   

Today,  national  competent  authorities  seeking  mutual  assistance  from  other  Member  States 
must overcome a significant administrative burden to  launch an information  request  in  IMI. 
At present, information about a specific posting triggering a request for mutual assistance in 
IMI  needs  to  be  manually  inputted  into  IMI  by  the  competent  authorities  in  the  Member 
States, before the request for assistance can be launched. This is because the declarations are 
received in Member State systems that are not connected to IMI. To facilitate administrative 
cooperation  between  Member  States’  competent  authorities  and  to  simplify  requests  for 
mutual  assistance,  information  submitted  in  posting  declarations  should  be  made  available 
directly in IMI. This is currently the case for the road transport sector, where Directive (EU) 
2020/1057  of  the  European  Parliament  and  of  the  Council10  tasked  the  Commission  with 
developing a multilingual public interface, to which operators have access and which they can 
use to submit and update posting information and submit other relevant documents to IMI, as 
necessary.  Member  States  should  then  exchange  data  and  information,  engage  in 
administrative cooperation and provide mutual assistance via IMI.  

Aligning the administrative procedure for the declaration of posted workers in other sectors, 
for cases where such a declaration obligation would  be justified and proportionate, with  the 
procedure for posting drivers in the road transport sector would reduce administrative burden 
for  public  administrations.  Today,  competent  authorities  must  administer  and  operate  two 
different systems for their monitoring tasks, using IMI for the declaration of posting of drivers 

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Directive (EU) 2020/1057 of the European Parliament and of the Council of 15 July 2020 laying down 
specific rules with respect to Directive  96/71/EC and Directive 2014/67/EU for posting drivers in the 
road  transport  sector  and  amending  Directive  2006/22/EC  as  regards  enforcement  requirements  and 
Regulation 
ELI: 
1024/2012 
http://data.europa.eu/eli/dir/2020/1057/oj). 

31.7.2020, 

(EU) 

249, 

(OJ 

49, 

No 

p. 

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in  the  road  transport  sector  and  national  declaration  systems  for  posting  in  other  sectors. 
Aligning  the  two  systems  could  streamline  the  use  of  databases  and  internal  administrative 
procedures  for  national  competent  authorities  and  thereby  provide  for  a  more  efficient 
mechanism  for  national  competent  authorities  to  monitor  and  control  compliance  with 
applicable posting rules.  

Participating  Member  States  benefit  from  cost-  and  time-savings.  Moreover,  making  use  of 
the IMI system  allows Member States to  discontinue their self-standing national  declaration 
systems if they wish to do so, and they thus save the costs of operating and maintaining these 
systems.  A  few  Member  States  that  do  not  yet  use  digital  solutions  for  their  declaration 
obligations  can  use  the  IMI  system,  without  the  need  to  invest  time  and  resources  into  the 
development of an electronic national declaration system. Member States who maintain their 
national databases would benefit from the possibility to connect those to the public interface.  

The IMI system also allows for the generation of statistics, supporting national policy making 
and providing  a solid basis for the work of the labour inspectorates, including  for their  risk 
analysis. 

• 

Consistency with existing policy provisions in the policy area 

The  freedom  to  provide  services  is  a  fundamental  principle  of  the  internal  market  in  the 
European Union enshrined in the Treaty on the Functioning of the European Union (TFEU). 

Directive 96/71/EC implements this principle concerning the posting of workers with the aim 
to  guaranteeing  a  level  playing  field  for  businesses  and  respect  for  the  rights  of  workers. 
Article 3 of Directive 96/71/EC establishes a core set of clearly defined terms and conditions 
of employment which are required to be complied with by the service provider in the Member 
State to which the posting takes place to ensure the minimum protection of the posted workers 
concerned. 

Directive  2014/67/EU  aims  to  facilitate  the  exercise  of  the  freedom  to  provide  services  and 
the functioning of the internal market, as well as to guarantee respect for an appropriate level 
of  protection  of  the  rights  of  posted  workers  for  the  cross-border  provision  of  services,  in 
particular  as  regards  the  enforcement  of  the  core  terms  and  conditions  of  employment  that 
apply in the Member State where the service is to be provided in accordance with Article 3 of 
Directive 96/71/EC. In this context, Directive 2014/67/EU establishes a common framework 
of a set of appropriate provisions, measures and control mechanisms necessary for better and 
more uniform implementation, application and enforcement in practice of Directive 96/71/EC. 

In order to ensure the correct application of, and to monitor compliance with, the substantive 
rules  on  the  terms  and  conditions  of  employment  to  be  respected  with  regard  to  posted 
workers, Directive 2014/67/EU provides the possibility for Member States to impose certain 
administrative requirements and control measures to service providers that post workers in the 
framework of the provision of services, provided that these are justified and proportionate in 
accordance  with  Union  law.  Within  this  context,  Article  9(1)(a)  of  Directive  2014/67/EU 
allows  Member  States  to  impose  an  obligation  for  a  service  provider  established  in  another 
Member State to make a simple declaration to the responsible national competent authorities 
containing  the  relevant  information  necessary  in  order  to  allow  factual  controls  at  the 
workplace. 

The proposal is consistent with these provisions as it does not amend the legal framework for 
the  posting  of  workers,  as  established  by  Directives  2014/67/EU  and  96/71/EC,  nor  does  it 
compromise the level of workers’ protection it entails. It facilitates the submission of posting 
declarations where required, in accordance with Article 9(1)(a) of Directive 2014/67/EU and 
the procedure laid down in its Article 9(4), and facilitates administrative cooperation between 

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Member  States  and  effective  monitoring  of  compliance  with  the  obligations  in  Directive 
2014/67/EU and Directive 96/71/EC. 

The proposal complements the rules on the posting of drivers in the road transport sector. The 
new rules on posting of drivers in road transport, as established by Directive (EU) 2020/1057, 
were adopted in July 2021 as part of the Mobility Package and apply since 2 February 2022. 
The  Commission  is  operating  a  multilingual  portal  connected  to  IMI  for  road  transport 
operators  who  have  to  comply  with  these  new  rules.  The  portal  allows  the  road  transport 
operators to  submit posting declarations via IMI  to  the Member State(s)  where their drivers 
will be posted. The proposal would mirror the administrative procedure for the declaration of 
posted  workers  in  other  sectors  with  the  procedure  for  posting  drivers  in  the  road  transport 
sector. 

• 

Consistency with other Union policies 

The  proposal  contributes  to  two  of  the  priorities  of  this  Commission,  notably  creating  “a 
deeper  and  fairer  internal  market”  and  boosting  "jobs  growth  and  investment"  through  the 
simplification of the regulatory framework and rationalisation of reporting requirements. 

The proposal complements the efforts of the Single Market Enforcement Taskforce (‘SMET’) 
to  reduce  the  administrative  burden  for  posting  workers  in.  The  Commission  and  Member 
States are working together in SMET to facilitate administrative requirements on the posting 
of  workers  including  as  regards  declaration  obligations.  Best  practices  identified  in  SMET 
will be considered when developing the public interface. 

In October 2023, the European Council called on all relevant institutions to take forward work 
to  simplify regulation  and reduce the unnecessary administrative burden11.  In  April 2024, it 
also invited the Commission to significantly reduce the administrative and compliance burden 
on companies and national authorities as part of a better and smarter regulatory framework12. 

In its resolution of 17 February 2022 on tackling non-tariff and non-tax barriers in the single 
market13, the European Parliament urged the Commission to introduce a digital form for the 
declaration  of  the  posting  of  workers,  establishing  a  simple,  user-friendly  and  interoperable 
digital form that suits the needs of European companies and in particular SMEs. 

The  proposal  furthermore  responds  to  the  objective  of  the  Interoperable  Europe  Act,  which 
aims to strengthen cross-border interoperability and cooperation in the public sector across the 
EU. To cater for cross-border interoperability, the technical specifications and requirements of 
the  public  interface  are  subject  to  an  interoperability  assessment  and  consider  the  reuse  of 
common interoperability solutions.  

Finally,  the  initiative  and  the  implementation  of  the  digital  form  for  the  declaration  of  the 
posting  of workers in  the EU is  in  line with  ongoing  developments  on the European digital 
identity  framework  and  the  European  Digital  Identity  Wallet14.  Service  providers  could  for 
example use the European Digital Identity Wallet, once available, as one means of identifying 
themselves,  and  posted  workers  could  receive  a  copy  of  a  posting  of  worker  declaration  in 
their wallet. 

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EUCO 14/23. 
EUCO 12/24. 
2021/2043(INI). 
Regulation (EU) No 910/2014 as regards establishing the European Digital Identity Framework (OJ L, 
2024/1183, 30.4.2024, ELI: http://data.europa.eu/eli/reg/2024/1183/oj). 

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2. 

• 

LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY 

Legal basis 

The legal basis for the proposal, as is the case for the IMI Regulation, is Article 114 TFEU. 
The  proposal  aims  to  support  the  functioning  of  the  internal  market  (Article  26  TFEU). 
Although Member States are not required to provide for the use of the public interface set up 
by the proposal, the envisaged uptake by Member States will favour an approximation of the 
procedure  and  of  the  requirements  for  the  declaration  of  posting  of  workers  in  the 
participating  Member  States.  Moreover,  where  Member  States  do  decide  to  use  the  public 
interface, they will be required to ensure that service providers are able to comply with their 
obligation  to  make  a  declaration  of  posting  by  using  that  common  interface.  The  public 
interface as the single declaration portal and the standard form establish similar conditions for 
posting declarations in the Member States that opt to make use of the public interface. 

• 

Subsidiarity (for non-exclusive competence)  

The proposal complies with the principle of subsidiarity as set out in Article 5 of the Treaty 
on  European  Union.  The  objective  of  this  Regulation,  namely  the  establishment  of  a 
multilingual electronic public interface connected to IMI to reduce the administrative burden 
for service providers posting workers to a participating Member States, whilst also facilitating 
a  better  and  more  uniform  application  and  enforcement  of  Directive  96/71/EC,  cannot  be 
sufficiently achieved by the Member States alone and can therefore, by reason of its scale and 
effects, be better achieved at Union level. 

• 

Proportionality 

The objective of the proposal is to contribute to the proper functioning of the internal market 
by  reducing  administrative  barriers  to  the  freedom  to  provide  services,  facilitating  the 
effective monitoring by Member States of compliance with EU legislation aimed at ensuring 
the  protection  of  posted  workers,  and  supporting  the  related  administrative  cooperation 
between the national competent authorities in the Member States. 

The  proposed  action  is  an  appropriate  way  to  achieve  the  objective.  Establishing  similar 
procedures for posting declarations in the Member States that opt to make use of the public 
interface  reduces  administrative  burden,  facilitates  effective  monitoring  and  supports  the 
related administrative cooperation. While the public interface is for voluntary use by Member 
States, its objective should be achieved by the envisaged uptake by Member States, thereby 
demonstrating that delivering the benefits of the single market is a joint responsibility of the 
Commission and the Member States. 

At the same time, with its voluntary nature the proposal does not go beyond what is necessary 
to achieve the objective and it does not affect the Member States' competences in the area of 
posting of workers. Member States may require service providers to use this interface to make 
a simple declaration of posted workers to competent authorities. 

As the proposal would mirror the already established administrative and technical procedure 
for posting drivers in the road transport sector, the financial and administrative costs for the 
Union are limited and proportionate to the objective of the initiative.  

• 

Choice of the instrument 

The  proposal  includes  an  amendment  to  the  Annex  of  the  IMI  Regulation.  The  most 
appropriate  instrument  is  therefore  a  Regulation.  The  submission,  storing  and  processing  of 
the declaration in the public interface by the Commission and the exchange of information in 

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the  context  of  effective  administrative  cooperation  and  mutual  assistance  between  Member 
States must comply with the rules on personal data protection laid down in Regulations (EU) 
2016/679  and  (EU)  2018/1725  of  the  European  Parliament  and  of  the  Council  and  shall  be 
laid down in Union law. 

3. 

• 

RESULTS 
CONSULTATIONS AND IMPACT ASSESSMENTS 

EX-POST 

EVALUATIONS, 

OF 

STAKEHOLDER 

Ex-post evaluations/fitness checks of existing legislation 

In the implementation report of Directive 2014/67/EU the Commission concluded that there 
are  some  areas  that  have  been  brought  to  the  attention  of  the  Commission  by  different 
stakeholders and where improvements could be necessary. These include the simplification of 
the administrative control systems by, for example, introducing a single EU-wide declaration 
system. 

• 

Stakeholder consultations 

Stakeholder  consultations  were  held  in  the  preparation  of  a  common  form,  in  an  electronic 
format, for the declaration of the posting of workers. 

Relevant  stakeholder  groups  contributed  to  the  consultation  process:  national  authorities, 
enforcement  bodies,  business  associations.  In  particular,  the  European  social  partners  have 
been consulted. A variety of open and targeted consultation methods and tools were used in 
the context of an external study, aiming inter alia at: identifying the potential scope, format, 
structure,  and  implementation  options  for  the  e-Declaration  and  consulting  Member  States 
and  relevant  stakeholders  on 
the  concept  (i.e.  scope,  format,  and  structure)  and 
implementation options: 

– 

– 

– 

– 

– 

– 

– 

a webinar in cooperation with the European Labour Authority (ELA) on 17 February 
2022 to inform  the  Member States’ competent authorities and social partners about 
the project and to gather their feedback; 

meetings  and  interviews  with  interested  Member  States’  authorities  and  relevant 
stakeholders between February and April 2022; 

a  user  experience  workshop  on  27  April  2022  with  service  providers  identified  by 
social  partners  to  gather  information  about  administrative  experience  of  posting 
workers; 

a technical workshop with relevant representatives of the Member States’ authorities 
on 28 April 2022 to discuss implementation options; 

meetings with social partners on 30 November 2021, 8 December 2021, 8 February 
2022, 2 June 2022 and 11 May 2023; 

technical survey for Member States between 9 June and 6 July 2022 

a  social  partner  online  hearing  on  29  April  2024  dedicated  to  the  e-declaration  for 
posting of workers. 

The project of an e-Declaration for posting of workers was also discussed with Member States 
and social partners at the ELA Forum for Posting of Workers on 13 March 2023 and 11 April 
2024. 

EN 

8 

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• 

Collection and use of expertise 

This proposal has been identified following a process of internal scrutiny of existing reporting 
obligations and based on the experience from implementation of the related legislation. Since 
this is a step in the process of continuous assessment of reporting requirements arising from 
EU legislation, the scrutiny of such burdens and of their impact on stakeholders will continue. 

The Commission received input from the expert group on a common electronic form for the 
declaration  of  posting  of  workers,  which  advises  the  Commission  on  the  joint  development 
and implementation  of a common electronic form  for the declaration of  posting  of workers. 
The  work  of  the  group  is  undertaken  in  full  respect  of  Directive  96/71/EC  and  Directive 
2014/67/EU.  

• 

Impact assessment - burden reduction  

The Commission did not carry out an impact assessment (IA) for this targeted initiative. The 
Commission however carried out an analysis to measure the existing level of  administrative 
burden for declaring posted workers in the 27 EU Member States, resulting in a detailed cost 
modelling of the different declaration procedures. The analysis, laid out in the accompanying 
Staff Working Document, also looked at the potential savings in terms of time and resources 
from  the  introduction  of  a  standard  form  for  the  declaration  of  workers  to  be  posted  under 
different  implementation  options,  including  a  multilingual  electronic  interface  connected  to 
IMI, taking into account different degrees of participation by Member States. At the EU level, 
the  analysis  suggests  that  the  impact  of  a  common  system  for  declaring  posted  workers  is 
influenced  by  the  design  of  the  common  system  and  on  the  volume  of  posting  declarations 
that will be covered by the new system.  

The  average  reduction  in  the  time  required  to  complete  a  posting  declaration  using  the 
standard  form  is  estimated  to  approximately  73%  compared  to  the  average  time  currently 
required across the EU. The burden reduction varies according to the take-up of the standard 
form by Member States. 

The  average  burden  reduction  (total  cost)  for  service  providers  posting  workers  to  their 
territory is  estimated to 58% compared to  the current  situation, with  the participation  of the 
initial  group  of  nine  Member  States  that  indicated  their  readiness  so  far.  In  case  all  27 
Member  States  would  decide  to  join  this  initiative,  the  burden  reduction  at  EU  level  would 
further increase to 81% compared to the current baseline scenario. 

The  proposal  concerns  limited  and  targeted  changes  of  existing  administrative  practice,  for 
Member States who voluntarily opt for it, and of existing legislation, namely Regulation (EU) 
No 1024/2012 of the European Parliament and of the Council establishing the Internal Market 
Information  System  (‘IMI’).  The  objective  of  the  proposal  is  to  provide  for  a  multilingual 
electronic  public  interface  connected  to  IMI  for  the  declaration  of  posted  workers,  as  has 
already been done in the road transport sector, for other economic sectors, in order to facilitate 
the  implementation  of  Directive  96/71/EC  and  Directive  2014/67/EU,  which  remain 
unchanged. 

The changes proposed do not  impact  EU policy, but  only  provide grounds for developing a 
voluntary  technical  solution  (public  interface)  for  the  submission  of  declarations  of  posted 
workers,  using  a  standard  form,  and  facilitating  data  exchange  between  national 
administrations.  The  exchanges  and  evidence  collected  by  the  expert  group  on  a  common 
electronic form for the declaration of posting of workers fed into the drafting of this proposal. 
The proposal will facilitate reducing administrative burden for competent national authorities 
and businesses by increasing accessibility and exchange of data on posted workers. 

EN 

9 

  EN 

In conclusion, there was no need for an IA as the amendment is limited in scope, targeted and 
provides technical amendments to the existing legislation. 

• 

Regulatory fitness and simplification 

This  is  a REFIT proposal,  aiming  to  cut  burdens for Member States’ public administrations 
and businesses.  

The reporting requirements for the posting of workers concern a large number of companies. 
2022 data from the prior declaration tools, the most recent data available, suggest that there 
were  around  1.9  million  posted  workers,  2.3  million  posting  declarations  and  4.7  million 
postings  in  the EU. Looking  at  the evolution  of the number of postings  and posted workers 
excluding the road  freight  transport, for which declarations have to  be made now through  a 
central  EU  portal  for  road  transport  operators,  available  data  suggest  a  growth  of  14  % 
regarding the number of postings declared between 2021 and 202215.  

All  27  Member  States  established  a  prior  declaration  tool  for  service  providers  posting 
workers  to  another  Member  State.  However,  Member  States  systems  differ  in  design  and 
requirements  and  are  not  interconnected.  Compliance  with  the  required  administrative 
declaration  procedures  therefore  entails  considerable  administrative  burdens  for  the  posting 
companies.  The  resulting  increase  in  transaction  costs  may,  under  certain  conditions, 
significantly  impede  or  restrict  the  cross-border  provision  of  services  –  especially  for  small 
and medium-sized enterprises (SMEs).  

A business survey on the state of the single market carried out in 2024 found that 46.1% of 
over  1000  surveyed  companies  believed  that  problems/uncertainties  in  posting  workers 
temporarily to another country were significant16. The estimated effort required to register a 
posting ranges from 21 minutes in Estonia and Slovakia to 87 minutes in Greece. For Italy, 
the time required is 61 minutes. In a recent study on the influence of administrative burdens 
on  the  cross-border  posting  of  employees  by  SMEs  in  border  regions,  all  respondents 
identified  the  lack  of  rationalisation  of  national  posting  procedures  in  the  EU  as  one  of  the 
biggest burdens17.  

Reporting  requirements  play  a  key  role  in  ensuring  correct  enforcement  and  proper 
monitoring of legislation. Reporting requirements can however also impose disproportionate 
burdens on stakeholders, particularly affecting SMEs and micro-companies. Their cumulation 
over  time  can  result  in  redundant  or  duplicating  obligations,    or  inadequate  methods  of 
collection.  

Streamlining reporting obligations and reducing administrative burdens is therefore a priority. 
The proposal will rationalise reporting obligations by a combination of measures:  

– 

– 

15 

16 
17 

Consolidation of reporting currently performed in different systems and with varying 
requirements; 

Digitalisation of transmission of information. 

De Wispelaere, F., De Smedt L., & Pacolet, J. (2023), Posting of workers: Collection of data from the 
prior declaration tools - Reference year 2022, Network Statistics FMSSFE, on behalf of the European 
Commission. Twenty-four Member States provided (partial) data on incoming posting undertakings and 
posted workers for the collection of this data, publicly available data was used for one other Member 
State. 
2024 Single Market Survey: Overcoming Obstacles, Developing Solutions, Eurochambres, 2024 
‘Influence  of  administrative  burdens  on  the  cross-border  posting  of  employees  by  SMEs  in  border 
regions’, Michael Holz, Annette Icks, IfM-Materialien No. 299, 2023. 

EN 

10 

  EN 

 
• 

Fundamental rights 

The  proposed  Regulation  concerns  the  processing  of  personal  data.  Processing  of  personal 
data requires ensuring full compliance with fundamental rights as enshrined in the Charter of 
Fundamental Rights, and notably the rights to the protection of personal data in Article 8 of 
the Charter of Fundamental Rights of the European Union. This proposal takes full account of 
these legal requirements. 

4. 

BUDGETARY IMPLICATIONS 

The proposal  has limited budgetary implications for the Commission.  Considering  an initial 
period of five years of full implementation and maintenance of the public interface the budget 
implications mainly stem from the following work: 

– 

– 

– 

– 

– 

Solution development, EUR 1.3 million; 

Solution maintenance, EUR 0.7 million,  

Support, EUR 0.7 million, 

Training, EUR 0.2 million, 

Infrastructure, EUR 0.1 million; 

Amounting  to  approximately  EUR  3  million  for  5  years.  Running  costs  after  full 
implementation are estimated at EUR 0.5 million per year. 

In terms of staffing needs, the full implementation of the public interface will require 1.5 full-
time equivalents, the constant maintenance 0.5 full-time equivalents. 

5. 

• 

n/a 

• 

n/a 

• 

OTHER ELEMENTS 

Implementation plans and monitoring, evaluation and reporting arrangements 

Explanatory documents (for directives) 

Detailed explanation of the specific provisions of the proposal 

Article 1 – Public interface connected to the Internal Market Information System 

The  Article  provides  for  the  set  up  a  multilingual  public  interface  connected  to  IMI  for  the 
declaration of posting of workers (‘the public interface’). 

The  main  purpose  of  the  public  interface  is  to  reduce  administrative  burden  for  Member 
States  authorities  and  businesses  by  approximating  national  laws  and  procedures,  and  to 
reinforce  the  cooperation  between  Member  States  in  monitoring  compliance  with  certain 
administrative requirements applicable for posting of workers through IMI.  

The  public  interface  allows  service  providers  to  comply  with  justified  and  proportionate 
obligations to declare posting of workers, in accordance with Article 9(1) and (2) of Directive 
2014/67/EU, where Member States chose to make use of this public interface. 

Article 2 – Functionalities of the public interface 

The Article lists the main functionalities of the public interface. 

Article 3 – Making use of the public interface 

EN 

11 

  EN 

The Article sets out the procedure for Member States to make use of the public interface.  

Article 4 – Standard form 

The Article sets out the main elements of the relevant information contained in the standard 
form  that  service  providers  will  use  to  submit  a  posting  declaration  through  the  public 
interface  to  the  competent  national  authorities  of  the  host  Member  State.  It  grants 
implementing  powers  to  the  Commission  to  establish  the  standard  form  and  provides  a 
procedure for possible amendments of the standard form.  

Article 5 – Processing and retention of personal data 

The  Article  defines  the  purpose  of  the  processing  of  personal  data  as  well  as  the  data 
categories and data subjects. It furthermore clarifies the responsibilities for the processing of 
personal data submitted through the public interface. 

Article 6 – Processing of submitted information by means of IMI 

The  Article  sets  out  how  to  facilitate  administrative  cooperation  between  Member  States’ 
competent authorities and to simplify requests for mutual assistance, information submitted in 
posting  declarations  should  be  made  available  directly  in  IMI  for  the  competent  national 
authorities of the host Member States. 

Article 7 – Amendment to Regulation (EU) No 1024/2012 

The  Article  lists  the  Union  acts  that  includes  the  use  of  IMI  for  administrative  cooperation 
between  competent  authorities  of  the  Member  States  as  listed  in  the  Annex  of  the  IMI 
Regulation, in accordance with Article 3(1) IMI Regulation.  

Article 8 – Committee procedure 

The  Article  defines  the  Committee  procedure  to  be  followed  for  the  establishment  of  the 
standard form. 

Article 9 – Evaluation 

The Article instructs the Commission to evaluate the Regulation five years after its entry into 
force and to report on the experience gained in its application as well as on the achievement of 
its objectives. 

EN 

12 

  EN 

2024/0301 (COD) 

Proposal for a 

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 

on a public interface connected to the Internal Market Information System for the 
declaration of posting of workers and amending Regulation (EU) No 1024/2012 

THE EUROPEAN PARLIAMENT AND THE COUNCIL OF THE EUROPEAN UNION, 

Having  regard  to  the  Treaty  on  the  Functioning  of  the  European  Union,  and  in  particular 
Article 114 thereof, 

Having regard to the proposal from the European Commission, 

After transmission of the draft legislative act to the national parliaments, 
Having regard to the opinion of the European Economic and Social Committee18, 

Acting in accordance with the ordinary legislative procedure, 

Whereas: 

(1) 

(2) 

18 
19 

20 

21 

The Internal Market  Information System (‘IMI’), established by Regulation (EU) No 
1024/2012 of the European Parliament and of the Council19, should be used as much 
as  possible  for  the  administrative  cooperation  and  mutual  assistance,  including 
between  the  competent  authorities  of  the  Member  States  provided  for  in  Directives 
2014/67/EU20  and  96/71/EC21  of  the  European  Parliament  and  of  the  Council, 
concerning  the  posting  of  workers  in  the  framework  of  the  provision  of  services.  In 
accordance with Directive 2014/67/EU, in particular its Article 6, Member States are 
to  work  in  close  cooperation  and  provide  each  other  with  mutual  assistance  without 
undue delay in order to facilitate the implementation, application and enforcement in 
practice of that Directive and Directive 96/71/EC.  

Directive 2014/67/EU aims to facilitate the exercise of the freedom to provide services 
and  the  functioning  of  the  internal  market,  as  well  as  to  guarantee  respect  for  an 
appropriate  level  of  protection  of  the  rights  of  posted  workers  for  the  cross-border 
provision  of  services,  in  particular  as  regards  the  enforcement  of  the  terms  and 
conditions  of employment that apply  in the Member State where the service is  to  be 
provided  in  accordance  with  Article  3  of  Directive  96/71/EC.  According  to  Article 

( 

‘the 

IMI  Regulation’ 

OJ C , , p. . 
Regulation (EU) No 1024/2012 of the European Parliament and of the Council of 25 October 2012 on 
administrative cooperation through the Internal Market Information System and repealing Commission 
Decision  2008/49/EC 
(OJ  L  316,  14.11.2012,  p.  1,  ELI: 
http://data.europa.eu/eli/reg/2012/1024/oj). 
Directive  2014/67/EU  of  the  European  Parliament  and  of  the  Council  of  15  May  2014  on  the 
enforcement  of  Directive  96/71/EC  concerning  the  posting  of  workers  in  the  framework  of  the 
provision  of  services  and  amending  Regulation  (EU)  No  1024/2012  on  administrative  cooperation 
through the Internal Market Information System ( ‘the IMI Regulation’ ) (OJ L 159, 28.5.2014, p. 11, 
ELI: http://data.europa.eu/eli/dir/2014/67/oj). 
Directive  96/71/EC  of  the  European  Parliament  and  of  the  Council of 16  December  1996  concerning 
the  posting  of  workers  in  the  framework of  the  provision of  services  (OJ  L  18,  21.1.1997, p. 1,  ELI: 
http://data.europa.eu/eli/dir/1996/71/oj). 

) 

EN 

13 

  EN 

 
9(1)  of  Directive  2014/67/EU,  Member  States  may  only  impose  administrative 
requirements and control measures in so far as necessary in order to ensure effective 
monitoring  of  compliance  with  the  obligations  set  out  in  that  Directive  and  in 
Directive  96/71/EC  and  provided  that  these  are  justified  and  proportionate  in 
accordance  with  Union  law.  Where  this  is  the  case,  Article  9(1)(a)  of  Directive 
2014/67/EU  allows  Member  States  to  impose  an  obligation  for  a  service  provider 
established in  another Member State to  make a simple declaration to  the  responsible 
national  competent  authorities  in  order  to  allow  factual  controls  at  the  workplace.  It 
remains the responsibility of Member States to decide, within the limits of justification 
and  proportionality,  in  which  cases  to  demand  a  posting  declaration  and  what 
information this declaration must contain. 

All  Member  States  have  used  the  possibility  to  impose  a  declaration  obligation  for 
service  providers  posting  workers  to  their  Member  State,  with  national  systems 
differing significantly in design, requirements and functionality. Complying with these 
diverging  systems  creates  a  considerable  administrative  burden  for  the  service 
providers  posting  workers.  Stakeholders  have  consistently  highlighted  that  the 
declaration for the posting of workers constitutes a significant reporting obligation and 
is among the most important administrative barriers for the cross-border provision of 
services in the internal market. 

Reporting  requirements  play  a  key  role  in  ensuring  proper  monitoring  and  correct 
enforcement of legislation. However, it is important to streamline those requirements, 
in order to ensure that they fulfil the purpose for which they were intended and to limit 
the  administrative  burden.  The  reporting  obligations  and  requirements  in  the 
submission  of  posting  declarations  to  the  competent  authorities  of  the  host  Member 
State,  established  in  accordance  with  Article  9(1)  of  Directive  2014/67/EU  should 
therefore be simplified, in line with the Commission’s Communication on ‘Long-term 
competitiveness  of  the  EU:  looking  beyond  2030’22,  in  order  to  significantly  reduce 
the administrative burden for service providers established in other Member States and 
posting  workers  to  the  host  Member  States  as  well  as  for  national  competent 
authorities.  

Reducing  the  administrative  burden  for  service  providers  and  national  competent 
authorities  must  concur  with  the  respect  for  adequate  working  conditions  and  social 
protection for posted workers. Facilitating the effective monitoring of compliance by 
Member  States  and  reinforcing  mutual  administrative  cooperation  improves  the 
protection of workers’ rights. 

In accordance with Article 12 of Regulation (EU) No 1024/2012 technical means may 
be provided to allow external actors to interact with IMI. Such an interaction should be 
facilitated by  a multilingual  electronic public interface connected to  IMI (‘the public 
interface’) through which service providers should submit posting declarations to the 
Member  States  making  use  of  the  public  interface  (‘participating  Member  States’). 
These Member States should then, if necessary, use the information received through 
IMI  to  make  reasoned  requests  in  the  IMI  posting  modules  in  accordance  with  the 
obligation  to  provide  mutual  administrative  cooperation  and  assistance  referred  to  in 
Articles 6 and 7 of Directive 2014/67/EU. 

(3) 

(4) 

(5) 

(6) 

(7) 

A simplification of the process of sending and updating posting declarations resulting 
from the creation of such a public interface should reduce administrative barriers to the 

22 

COM(2023) 168 final. 

EN 

14 

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(8) 

(9) 

freedom to provide services, including to the right of undertakings to provide services 
in another Member State with their own workers.  

The simplification of the process of sending and updating posting declarations should 
facilitate  a  better  and  more  uniform  application  of  Directive  96/71/EC  as  well  as  its 
enforcement in practice, reducing the cases on non-compliance with the posting rules 
due to the different procedures for submitting the posting declarations. It will facilitate 
carrying out of effective and adequate inspections by the Member States, contributing 
to the protection of posted workers’ rights. 

A  simplification  of  the  process  of  sending  and  updating  posting  declarations  should 
reduce  the  administrative  burden  of  national  competent  authorities  seeking  mutual 
assistance  from  other  Member  States.  To  ensure  that  the  responsible  national 
competent  authorities  can  provide  each  other  with  mutual  assistance  without  undue 
delay and to simplify requests for mutual assistance, information submitted in posting 
declarations should be made available directly in IMI, thus facilitating the application 
in practice of Directive 2014/67/EU and Directive 96/71/EC and supporting the related 
administrative cooperation between the national competent authorities in the Member 
States contributing to the proper functioning of the internal market.  

(10)  The Commission should set up a public interface for voluntary use by Member States. 
Member  States  may  choose  to  require  service  providers  to  use  the  electronic  public 
interface  to  make  a  posting  declaration  to  its  responsible  national  competent 
authorities, in order to comply with justified and proportionate obligations imposed by 
these  Member  States  to  declare  posting  of  workers.  This  public  interface  should 
support  Member  States  in  their  task  to  ensure  that  the  procedures  and  formalities 
relating  to  the  posting  of  workers  can  be  completed  in  a  user-friendly  way  by 
undertakings,  at  a  distance  and  by  electronic  means,  facilitating  the  submission  of 
posting declarations where required.  

(11) 

Interoperable  and  reusable  solutions,  such  as  those  provided  for  in  Regulation  (EU) 
No  910/2014  as  regards  establishing  the  European  Digital  Identity  Framework23, 
should be used as they can facilitate how service providers identify themselves. Once 
available,  workers  should  be  able  to  receive  notifications  about  posting  declarations 
concerning them via the European Digital Identity Wallet24. 

(12)  The  public  interface  connected  to  IMI  is  a  technical  means  made  available  by  the 
European Commission for voluntary use by Member States. Before requiring service 
providers to declare the relevant information by way of that interface, Member States 
should  ensure  that  such  a  requirement  is  provided  for  in  national  law,  in  line  with 
Union law. In order to ensure a frictionless use of the public interface Member States 
should  communicate  to  the  Commission  their  interest  in  making  use  of  the 
multilingual electronic public interface, at any time from the date of entry into force of 
this Regulation.  

(13)  The  Commission,  in  line  with  the  UN  Convention  on  the  Rights  of  Persons  with 
Disabilities  to  which  the  Union  and  all  Member  States  are  parties,  should  ensure 
accessibility for persons with disabilities of the public interface and its content taking 

23 

24 

Regulation (EU) No 910/2014 as regards establishing the European Digital Identity Framework (OJ L, 
2024/1183, 30.4.2024, ELI: http://data.europa.eu/eli/reg/2024/1183/oj). 
Regulation (EU) No 910/2014 as regards establishing the European Digital Identity Framework (OJ L, 
2024/1183, 30.4.2024, ELI: http://data.europa.eu/eli/reg/2024/1183/oj). 

EN 

15 

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into account to the extent relevant the accessibility requirements as set out in Annex I 
of Directive (EU) 2019/88225. 

(14)  Service  providers  should  be  able  to  submit  a  posting  declaration  to  the  national 
competent authorities of a participating Member State to which a worker is posted, i.e. 
the host Member State, using a multilingual standard form of that public interface.  

(15)  The Commission received input from the expert group on a common electronic form 
for the declaration of posting of workers on the national declaration requirements and 
systems  as  well as on the relevant  information necessary to  allow  factual controls  at 
the workplace. The Commission has received advice from the expert group concerning 
the information  requirements  that it would  consider to  be appropriate to include in  a 
common  form  for  the  declaration  of  posting  of  workers.  Taking  into  account  this 
advice and in order to allow for the provision of the information that may be necessary 
to  allow  factual  controls  at  the  workplace,  the  standard  form  used  by  the  electronic 
public  interface  should  consist  of  information  related  to  the  service  provider,  the 
posted  worker,  the  posting  assignment,  the  contact  person  for  competent  authorities 
and the service recipient. The standard form should be available in all EU languages. 
Member States may decide that certain elements contained in the standard form, that 
they  do  not  consider  relevant  in  view  of  their  national  context  and  the  way  they 
organise the factual controls at the workplace, are not required from service providers 
posting workers to their territory filling in the form on the electronic public interface. 

(16) 

In  respect  of  the  establishment  of,  and  subsequent  changes  to,  the  standard  form, 
implementing powers should be conferred on the Commission. Those powers should 
be  exercised  in  accordance  with  Regulation  (EU)  No  182/2011  of  the  European 
Parliament  and  of  the  Council26.  Member  States  considering  that  certain  information 
should  be  added  to  or  removed  from  the  standard  form,  or  that  the  standard  form 
should otherwise be modified, should be allowed to request the Commission to amend 
the standard form accordingly.  

(17)  The  use  of  the  public  interface,  with  its  standard  form,  consisting  of  a  common  and 
exhaustive set of relevant information that may be necessary for factual controls at the 
workplace, will reduce the divergencies in the applicable rules and regulations of the 
Member  States.  It  should  be  sufficient  for  service  providers  to  comply  with  the 
declaration  obligations  in  Member  States  making  use  of  the  public  interface.  There 
should  be  no  additional  information  requirements  imposed  at  national  level  in  these 
Member  States.  The  setting  up  of  the  public  interface  connected  to  IMI  with  its 
standard  form  and  the  making  available  of  this  interface  to  national  competent 
authorities is instrumental and ancillary to the approximation of the legislation of the 
Member States, ensuring the functioning of the internal market.  

(18)  The establishment of a public interface provides a streamlined framework for posting 
declarations  that  offers  significant  incentives  for  Member  States  to  participate.  It 
aligns  with  Member  States'  own  interest  in  enhancing  administrative  cooperation, 
simplifying administrative procedures, and protecting workers' rights. When the public 
interface  will  be  established  and  will  show  its  usefulness  and  benefits,  all  Member 

25 

26 

Directive  (EU)  2019/882  of  the  European  Parliament  and  of  the  Council  of  17  April  2019  on  the 
accessibility  requirements  for  products  and  services 
(OJ  L  151,  7.6.2019,  p.  70,  ELI: 
http://data.europa.eu/eli/dir/2019/882/oj). 
Regulation  (EU)  No  182/2011  of  the  European  Parliament  and  of  the  Council  of  16  February  2011 
laying down the rules and general principles concerning mechanisms for control by the Member States 
of  the  Commission's  exercise  of  implementing  powers  (OJ  L  55,  28.2.2011,  p.  13,  ELI: 
http://data.europa.eu/eli/reg/2011/182/oj). 

EN 

16 

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(19) 

States  should  consider  making  use  of  the  public  interface.  The  more  Member  States 
were  to  make  use  of  the  public  interface,  the  higher  would  be  the  reduction  of 
administrative burden for service providers and national competent authorities, and the 
larger the scope for effective administrative cooperation for protecting workers’ rights. 

In  order  to  allow  factual  controls  at  the  workplace  the  relevant  information  to  be 
provided in the declaration of posting of workers may include amongst the information 
requirements  established  in  the  context  of  Article  9(1)(a)  of  Directive  2014/67/EU 
certain personal data. Processing of personal data should be carried out in accordance 
with  Union  law  on  the  protection  of  personal  data  laid  down  in  Regulations  (EU) 
2016/67927 and (EU) 2018/172528 of the European Parliament and of the Council. In 
order to clarify the responsibility for the processing of personal data submitted through 
the  public  interface,  this  Regulation  should  indicate  who  is  to  be  regarded  as  the 
controller  of  the  personal  data.  Regulation  (EU)  No  1024/2012  applies  to  the 
processing of personal data of the competent authorities in IMI. 

(20)  The  information  from  the  posting  declarations  should  be  kept  in  the  public  interface 
for the purpose of reusing it in subsequent posting declarations for a maximum period 
of 36 months after the end date of the posting period. 

(21)  The  European  Data  Protection  Supervisor  was  consulted  in  accordance  with  Article 

42(1) of Regulation (EU) 2018/1725 and delivered an opinion on 5 September 2024. 

(22)  Where social partners play a role in the monitoring of compliance with posting rules, 
competent  authorities  should  be  allowed  to  provide  national  social  partners  with  the 
relevant information which has been shared via IMI, for the sole purpose of checking 
compliance  with  posting  rules  while  respecting  Regulation  (EU)  2016/679.  The 
relevant information should be provided to social partners by other means than IMI. 

(23)  The  European  Labour  Authority  (‘ELA’)  should  support  Member  States’  national 
competent  authorities  and  service  providers  in  the  implementation  and  use  of  the 
public interface in accordance with its mandate under Regulation (EU) 2019/114929. 

(24)  This  regulation  should  be  without  prejudice  to  Directive  2014/67/EU  and  Directive 

96/71/EC. 

HAVE ADOPTED THIS REGULATION: 

1. 

27 

28 

29 

Article 1 
Public interface connected to the Internal Market Information System 

In  order  to  contribute  to  the  proper  functioning  of  the  internal  market  by  reducing 
administrative  barriers  to  the  freedom  to  provide  services,  while  facilitating  the 

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, 
p. 1, ELI: http://data.europa.eu/eli/reg/2016/679/oj). 
Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the 
protection of natural persons with regard to the processing of personal data by the Union institutions, 
bodies, offices and agencies and on the free movement of such data, and repealing Regulation (EC) No 
45/2001 
39,  ELI: 
and  Decision  No 
http://data.europa.eu/eli/reg/2018/1725/oj). 
Regulation (EU) 2019/1149 of the European Parliament and of the Council of 20 June 2019 establishing 
a European Labour Authority, amending Regulations (EC) No 883/2004, (EU) No 492/2011, and (EU) 
2016/589 and repealing Decision (EU) 2016/344 (Text with relevance for the EEA and for Switzerland) 
(OJ L 186, 11.7.2019, p. 21, ELI: http://data.europa.eu/eli/reg/2019/1149/oj) 

1247/2002/EC 

21.11.2018, 

(OJ  L 

295, 

p. 

EN 

17 

  EN 

 
effective monitoring by Member States of compliance with EU legislation aimed at 
ensuring  the  protection  of  posted  workers’  rights,  and  supporting  the  related 
administrative cooperation between the national competent authorities in the Member 
States, the Commission shall set up a multilingual public interface connected to the 
Internal  Market  Information  System  (‘IMI’),  established  by  Regulation  (EU)  No 
1024/2012, for the declaration of posting of workers (‘the public interface’).  

Member States may opt to make use of this public interface. 

The  legislation  of  a  Member  State  may  provide  for  service  providers  to  declare 
posting  of  workers,  in  accordance  with  Article  9(1)  of  Directive  2014/67/EU,  by 
submitting  a  declaration  based  on  a  multilingual  standard  form  through  the  public 
interface.  Where  a  Member  State  provides  for  the  use  of  the  public  interface,  that 
declaration shall replace any pre-existing one required under national law.  

2. 

3. 

Article 2 
Functionalities of the public interface 

1. 

The public interface shall provide functionality for: 

(a) 

creating an account for secure access to the service provider’s reserved area; 

(b) 

ensuring appropriate logging of user activity; 

(c) 

creating, submitting and managing declarations of posted workers; 

(d) 

transmitting a copy of the posting declaration to the posted worker; 

(e)  making  submitted  information  available  in  IMI  to  the  responsible  national 
competent authorities of the host Member State for administrative cooperation 
pursuant to points 6 and 7 of the Annex to Regulation (EU) No 1024/2012. 

(f) 

allowing  one  or  more  national  authorities  of  the  host  Member  State  that  are 
competent  authorities  within 
the  meaning  of  Article  3  of  Directive 
2014/67/EU, to additionally receive posting declarations directly in the national 
back-end system upon the request of that Member State. 

The  Commission  shall  be  responsible  for  the  development,  maintenance  and 
operation of the public interface. 

The Commission shall ensure accessibility for persons with disabilities of the public 
interface and its content.. 

Article 3 
Making use of the public interface by the Member States 

A  Member  State  that  opts  to  make  use  of  the  public  interface  shall  inform  the 
Commission  six  months  before  the  date  from  which  it  intends  to  use  the  public 
interface.  

A  Member  State  opting  to  make  use  of  the  public  interface  shall  adopt  the  laws, 
regulations and administrative provisions necessary to allow for the use of the public 
interface by service providers posting workers to that Member State and to comply 
with  the  requirements  of  the  public  interface  and  of  the  standard  form  of  the 
declaration of posting of workers in due time before such use.  

2. 

3. 

1. 

2. 

EN 

18 

  EN 

3. 

4. 

5. 

Member  States  making  use  of  the  public  interface  shall  not  impose  any  additional 
declaration  or  information  requirements  on  the  service  providers  submitting  the 
posting declaration through the public interface.  

The  list  of  Member  States  making  use  of  the  public  interface  as  referred  to  in 
paragraph  3  shall  be  made  publicly  available  by  the  Commission  on  the  public 
interface. 

A Member State may discontinue making use of the public interface. That Member 
State shall inform the Commission thereof six months before the intended end date of 
the use of the public interface.  

Article 4 
Standard form 

1. 

Without  prejudice  to  paragraph  5  the  standard  form  shall  consist  of  information 
related to:  

(a) 

the service provider;  

(b) 

the posted worker;  

(c) 

the posting assignment;  

(d) 

the contact person to liaise with the competent authorities;  

(e) 

the service recipient. 

The Commission shall establish the standard form referred to in paragraph 1 of this 
Article  by  way  of  implementing  acts.  Those  implementing  acts  shall  be  adopted  in 
accordance with the procedure referred to in Article 8(2). 

A Member State opting to make use of the public interface may decide not to request 
all the information contained in the standard form and shall inform the Commission 
accordingly. 

Member States may submit to the Commission suggestions for amendment(s) of the 
standard  form.  The  Commission  shall  examine  such  suggestions  with  the  view  to 
amending, where appropriate, the standard form.   

The  Commission  may,  based  on  a  suggestion  by  a  Member  State  or  on  its  own 
initiative,  propose  an  amendment  of  the  standard  form,  in  accordance  with  the 
procedure referred to in paragraph 2 of this Article. 

Article 5 
Processing and retention of personal data 

For the purpose of achieving the objectives set out in Article 1, personal data referred 
to in paragraphs 2 and 3 may be processed by the public interface. 

The Commission is to be considered as controller in accordance with Article 3(8) of 
Regulation (EU) 2018/1725 in relation to: 

(a)  Ensuring the security and availability of the public interface; 

(b)  Processing  the  identification  and  contact  details  of  the  person  submitting  the 

declaration of posting of workers,  

The service provider is to be considered as controller in accordance with Article 4(7) 
of Regulation (EU) 2016/679 for processing: 

2. 

3. 

4. 

5. 

1. 

2. 

3. 

EN 

19 

  EN 

(a) 

the identity and contact details of the service provider; 

(b) 

the identity of a posted worker; 

(c) 

an electronic notification address, such as a mail address, of a posted worker to 
inform the posted worker that a declaration has been submitted for that worker; 

(d) 

the address of the workplace of the posted worker; 

(e) 

the identity and contact details of the contact person of the service provider. 

Where a Member State receives posting declarations additionally through the public 
interface  in  its  national  back-end  system,  the  competent  national  authority  is  to  be 
considered  as  controller  in  accordance  with  Article  4(7)  of  Regulation  (EU) 
2016/679  in  respect  of  the  processing  of  personal  data  contained  in  these  posting 
declarations. 

The public interface shall ensure the automatic deletion of the information related to 
a posting which has been submitted through that public interface 36 months after the 
end date of the posting period.  

The public interface shall  allow for the deletion  of all personal  data stored in  there 
and in the service providers’ accounts when those data are no longer needed for the 
purposes for which they were collected and processed. 

 The public interface shall allow for the sending of a reminder to the service provider 
to  review  and  delete,  when  necessary,  any  personal  data  in  accordance  with 
paragraph 6. 

A  Member  State  may  allow  the  competent  national  authority  to  provide  national 
social partners by other means than IMI with relevant information available in IMI to 
the  extent  necessary  and  exclusively  for  the  purpose  of  checking  compliance  with 
posting  rules  and  in  accordance  with  national  law  and  practices,  provided  that  the 
information relates to a posting to the territory of the Member State concerned. 

4. 

5. 

6. 

7. 

8. 

Article 6 
Processing of submitted information by means of IMI  

Information  submitted  via  the  public  interface  shall  be  made  available  in  IMI  to  the 
responsible competent authorities of the host Member State to achieve the objectives set out 
in Article 1. 

Article 7 
Amendment to Regulation (EU) No 1024/2012 

In the Annex to Regulation (EU) No 1024/2012, the following new point (17) is added:  

‘17. Regulation (EU) …/… of the European Parliament and of the Council of … on a public 
interface connected to the Internal Market Information System for the declaration of posting 
of workers and amending Regulation (EU) No 1024/2012. 

Article 8 
Committee procedure 

1. 

The  Commission  shall  be  assisted  by  a  committee.  That  committee  shall  be  a 
committee within the meaning of Regulation (EU) No 182/2011. 

EN 

20 

  EN 

2. 

Where  reference  is  made  to  this  paragraph,  Article  4  of  Regulation  (EU)  No 
182/2011 shall apply. 

Article 9 
Evaluation 

The Commission shall report on the experience gained in the application of this Regulation by 
[five years after entry into force of the Regulation]. In particular the report shall examine to 
what  extent  this  Regulation  has  been  successful  in  reducing  administrative  barriers  to  the 
freedom  to  provide  services,  in  facilitating  the  effective  monitoring  by  Member  States  of 
compliance  with  EU  legislation  aimed  at  ensuring  the  protection  of  posted  workers  and  in 
supporting the related administrative cooperation between the national competent authorities 
in the Member States.  

Article 10 
Entry into force 

This Regulation shall enter into force three months following the date of its publication in the 
Official Journal of the European Union. 

This Regulation shall be binding in its entirety and directly applicable in all Member States. 

Done at Brussels, 

For the European Parliament 
The President 

For the Council 
The President 

EN 

21 

  EN 

LEGISLATIVE FINANCIAL STATEMENT 

1. 

FRAMEWORK OF THE PROPOSAL/INITIATIVE  

1.1. 

Title of the proposal/initiative 

Proposal for a Regulation of the European Parliament and of the Council on a public 
interface connected to the Internal Market Information System for the declaration of 
posting of workers 

1.2. 

Policy area(s) concerned  

Internal  Market,  Free  movement  of  services,  Competitiveness,  SME,  Employment, 
Social Protection 

1.3. 

The proposal/initiative relates to:  

 a new action  

 a new action following a pilot project/preparatory action30  

 the extension of an existing action  

 a merger or redirection of one or more actions towards another/a new action  

1.4. 

Objective(s) 

1.4.1.  General objective(s) 

Extending  the  successful  use  of  a  public  interface  connected  to  the  IMI  for  the 
purpose of posting of worker declarations in road transport to other economic sectors 

1.4.2. 

Specific objective(s) 

Specific objective No 

– 

– 

– 

Reducing administrative burden for service providers for declaring the posting 
of workers, by bringing down average compliance costs for companies posting 
workers  to  Member  States  that  are  voluntarily  using  the  public  interface 
connected to the IMI by at least 50% by end of 2026.  

Facilitate  administrative  cooperation  between  Member  States  that  require 
posting  of  worker  declarations,  by  allowing  for  a  submission  of  posting  of 
worker declarations to participating Member States through the public interface 
and  an  automated  import  of  administrative  data  on  posted  workers  in  IMI  by 
end of 2025. 

Enable  Member  States  to  realise  cost  savings  for  the  development  and 
operation  of  national  declaration  portals,  by  having  interested  Member  State 
voluntarily  make  use  of  the  public  interface  connected  to  the  IMI  by  end  of 
2026. 

1.4.3.  Expected result(s) and impact 

Specify 
the  effects  which 
beneficiaries/groups targeted. 

the  proposal/initiative 

should  have  on 

the 

For public administration and labour inspectorates in participating Member States: 

30 

As referred to in Article 58(2)(a) or (b) of the Financial Regulation. 

EN 

22 

  EN 

 
– 

– 

– 

Reduce costs for use of the IMI, since manual entering of data on postings is no 
longer needed. 

Reduce  costs  for  continuous  maintenance,  since  it  is  no  longer  necessary  to 
maintain  a  national  IT  components  with  the  same  functionality  as  the  public 
interface connected to the IMI. 

Achieve  better  compliance,  i.e.,  more  complete  and  accurate  information  on 
postings which allows for effective monitoring and control. 

For service providers:  

– 

Reduce compliance costs by putting in place a common portal and process for 
declarations  to  the  participating  Member  States,  by  reducing  the  differences 
between  required  information  fields  when  posting  workers  to  several 
participating Member States, by reducing translation costs through the use of a 
multilingual public interface connected to the IMI. 

1.4.4. 

Indicators of performance 

Specify the indicators for monitoring progress and achievements. 

– 

– 

– 

Go live of a public interface connected to the IMI by end 2025. 

At least 9 Member States covering at least one third of all EU posted workers 
as  receiving  countries  decide  to  make  voluntary  use  of  the  public  interface 
connected to the IMI by end 2026. 

At least one third of posting declarations in the EU are submitted through the 
public  interface  connected  to  the  IMI,  and  compliance  costs  for  declarations 
submitted through the public interface connected to the IMI are reduced by at 
least 50%. 

1.5. 

Grounds for the proposal/initiative  

1.5.1.  Requirement(s) to be met in the short or long term including a detailed timeline for 

roll-out of the implementation of the initiative 

By  autumn  2025:  The  Commission  adopts  an  implementing  act  to  establish  the 
standard form of the public interface connected to the IMI. 

By end of 2025:  The Commission  makes the public interface connected to the IMI 
available online. 

By mid-2026: An initial group of Member States takes a voluntary decision to make 
use of the public interface connected to the IMI and adapts their declaration systems 
and national law accordingly where needed. 

As  of  2026:    The  Commission  maintains  and  continuously  improves  the  public 
interface connected to the IMI. 

1.5.2.  Added  value  of  Union  involvement  (it  may  result  from  different  factors,  e.g. 
coordination gains, legal certainty, greater effectiveness or complementarities). For 
the purposes of this point 'added value of Union involvement' is the value resulting 
from  Union  intervention,  which  is  additional  to  the  value  that  would  have  been 
otherwise created by Member States alone. 

Reasons for action at European level (ex-ante):  

– 

Coordination of administrative cooperation between Member States 

EN 

23 

  EN 

– 

– 

Efficiency  gains  on  the  EU-level  implementation  of  a  public  interface 
connected  to  the  IMI,  instead  of  development  and  operation  of  separate 
national IT components with the same functionality 

Use of a common form by the participating  Member States through EU-level 
coordination 

Expected generated Union added value (ex-post)  

–  More  effective  protection  of  workers’  rights  due  to  efficient  cooperation 

– 

– 

between Member States through IMI 

Cost savings for Member States 

Reduced compliance costs for companies, thus reducing barriers in the Single 
Market for Services  

1.5.3.  Lessons learned from similar experiences in the past 

– 

– 

– 

– 

– 

Lessons learnt from experience from the public interface connected to the IMI 
for declaring posting of road transport worker:  

Demonstrated  the  feasibility  of  a  public  interface  connected  to  the  IMI  for 
creating, submitting and managing posting of worker declarations. 

Demonstrated  facilitation  of  the  submission  of  posting  information  to  the 
national  competent  authorities,  and  potential  for  reduction  of  administrative 
burden. 

Provides  a  blueprint  for  project  implementation,  and  a  reusable  technical 
solutions. 

Demonstrated  the  potential  for  better  compliance  with  posting  declaration 
obligations. 

1.5.4.  Compatibility  with  the  Multiannual  Financial  Framework  and  possible  synergies 

with other appropriate instruments 

The  initiative  is  funded  through  the  Single  Market  Programme,  starting  under  the 
current MFF. 

1.5.5.  Assessment  of  the  different  available  financing  options,  including  scope  for 

redeployment 

– 

Funding of the initiative had already been foreseen, as it was announced in the 
2020 update of the Industrial Strategy, and reinforced in the “Single Market at 
30”  Communication.  Therefore,  under  the  Single  Market  Programme  funding 
has already been planned for 2024 and 2025. 

– 

No need for additional budget through redeployment. 

EN 

24 

  EN 

1.6. 

Duration and financial impact of the proposal/initiative 

 limited duration  

–    in effect from [DD/MM]YYYY to [DD/MM]YYYY  

–    Financial  impact  from  YYYY  to  YYYY  for  commitment  appropriations  and 

from YYYY to YYYY for payment appropriations.  

 unlimited duration 

–  Implementation with a start-up period from 2024 to 2025, 

–  followed by full-scale operation. 

1.7.  Method(s) of budget implementation planned31  

 Direct management by the Commission 

–   by its departments, including by its staff in the Union delegations;  

–    by the executive agencies  

 Shared management with the Member States  

 Indirect management by entrusting budget implementation tasks to: 

–   third countries or the bodies they have designated; 

–   international organisations and their agencies (to be specified); 

–   the EIB and the European Investment Fund; 

–   bodies referred to in Articles 70 and 71 of the Financial Regulation; 

–   public law bodies; 

–   bodies governed by private law with a public service mission to the extent that 

they are provided with adequate financial guarantees; 

–   bodies governed by the private law of a Member State that are entrusted with 
the  implementation  of  a  public-private  partnership  and  that  are  provided  with 
adequate financial guarantees; 

–   bodies or persons entrusted with the implementation of specific actions in the 
CFSP pursuant to Title V of the TEU, and identified in the relevant basic act. 

– 

If more than one management mode is indicated, please provide details in the ‘Comments’ section. 

Comments  

31 

Details of budget implementation methods and references to the Financial Regulation may be found on 
the BUDGpedia site: https://myintracomm.ec.europa.eu/corp/budget/financial-rules/budget-
implementation/Pages/implementation-methods.aspx 

EN 

25 

  EN 

 
 
2. 

MANAGEMENT MEASURES  

2.1.  Monitoring and reporting rules  

Specify frequency and conditions. 

The  project  will  follow  a  tailored  version  of  the  PM²  Methodology.  A  project 
steering  committee  including  the  lead-DGs  of  the  project  will  oversee  the 
implementation.  The  Commission  expert  group  on  a  Common  Electronic  Form  for 
the  Declaration  of  Posting  of  Workers  will  be  kept  informed,  and  advice  the 
Commission throughout implementation. 

2.2.  Management and control system(s)  

2.2.1. 

Justification of the management mode(s), the funding implementation mechanism(s), 
the payment modalities and the control strategy proposed 

Direct management for budget implementation, and choice of the PM² Methodology 
for project implementation have been chosen for the following reasons: 

– 

– 

the  project  will  require  development,  reuse  and  adaptation/configuration  of 
existing Commission IT systems which are developed in-house; 

the  PM²  methodology  aligns  with 

the  corporate  policy  on 
Use  of 
implementation of IT projects, and is a solid choice for projects of this level of 
complexity. 

2.2.2. 

Information concerning the risks identified and the internal control system(s) set up 
to mitigate them 

Main risks identified, and control systems to mitigate them: 

– 

– 

Risk:  Changes  of  requirements  late  in  the  project  can  delay  project 
implementation 
costs.  
Mitigation: Implement workflow for change requests ensuring assessment and 
business  approval; implementation of solution  in  a phased approach followed 
by continuous improvement. 

increase 

and 

Risk:  Low  number  of  Member  States  participate  in  the  project,  reducing 
expected 
benefits. 
Mitigation: Co-creation with Member States and continuous consultation of the 
Commission  expert group on a Common Electronic Form for the Declaration 
of Posting of Workers to ensure the project results meet expectations of many 
Member States. 

2.2.3.  Estimation and justification of the cost-effectiveness of the controls (ratio of "control 
costs ÷ value of the related funds managed"), and assessment of the expected levels 
of risk of error (at payment & at closure)  

n/a 

2.3.  Measures to prevent fraud and irregularities  

Specify existing or envisaged prevention and protection measures, e.g. from the Anti-
Fraud Strategy. 

EN 

26 

  EN 

 
Standard  measures  for  fraud  prevention  applied  by  the  Commission  in  direct 
management. 

EN 

27 

  EN 

3. 

3.1. 

ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE  

Heading(s)  of  the  multiannual  financial  framework  and  expenditure  budget 
line(s) affected  

•  Existing budget lines  

In order of multiannual financial framework headings and budget lines. 

Budget line 

Type of  
expenditure 

Contribution  

Heading of 
multiannual 
financial 
framework 

Number  

03.02.01.01 

Single 
market, 
innovation 
and digital  

Diff./Non-
diff.32 

from 
EFTA 
countries
33 

from 
candidate 
countries 
and 
potential 
candidates
34 

fromother 
third 
countries 

other assigned 
revenue 

Diff. 

YES 

YES 

NO 

NO 

•  New budget lines requested  

In order of multiannual financial framework headings and budget lines. 

Budget line 

Type of 
expenditure 

Diff./Non-
diff. 

from 
EFTA 
countries 

Contribution  

from 
candidate 
countries 
and 
potential 
candidates 

from  
other 
third 
countries 

other assigned 
revenue  

Heading of 
multiannual 
financial 
framework 

Number  

N/A 

32 
33 
34 

Diff. = Differentiated appropriations / Non-diff. = Non-differentiated appropriations. 
EFTA: European Free Trade Association.  
Candidate countries and, where applicable, potential candidates from the Western Balkans. 

EN 

28 

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3.2. 

Estimated financial impact of the proposal on appropriations  

3.2.1. 

Summary of estimated impact on operational appropriations  

–    The proposal/initiative does not require the use of operational appropriations  

–    The proposal/initiative requires the use of operational appropriations, as explained below: 

Heading of multiannual financial  
framework  

Number  Single market, innovation and digital 

EUR million (to three decimal places) 

Year 
202435 

Year 
N+1 

Year 
N+2 

Year 
N+3 

Enter as many years as 
necessary to show the duration 
of the impact (see point 1.6) 

TOTAL 

DG: GROW 

 Operational appropriations  

03.02.01.0136 

Budget line 

Commitments 

Payments 

Commitments 

Payments 

(1a) 

(2a) 

(1b) 

(2b) 

1,000 
- 
- 
- 

0,500 
1,500 
- 
- 

0,500 
0,500 
- 
- 

0,500 
0,500 
- 
- 

0,500 
0,500 
- 
- 

Appropriations  of  an  administrative  nature  financed  from  the 
envelope of specific programmes37  

Budget line 

TOTAL appropriations 
for DG GROW 

Commitments 

Payments 

(3) 

=1a+1b 
+3 

=2a+2b 

+3 

- 

- 

- 

- 

- 

1,000 

0,500 

0,500 

0,500 

0,500 

- 

1,500 

0,500 

0,500 

0,500 

… 
… 
… 
… 

… 

… 

… 

3,000 
3,000 

3,000 

3,000 

35 

36 
37 

Year N is the year in which implementation of the proposal/initiative starts. Please replace "N" by the expected first year of implementation (for instance: 2021). The same for the 
following years. 
According to the official budget nomenclature. 
Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former ‘BA’ lines), indirect research, direct research. 

EN 

29 

EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 TOTAL operational appropriations  

Commitments 

Payments 

  TOTAL  appropriations  of  an  administrative  nature 
financed from the envelope for specific programmes  

(4) 

(5) 

(6) 

1,000 

- 

- 

0,500 

1,500 

0,500 

0,500 

0,500 

0,500 

0,500 

0,500 

- 

- 

- 

- 

TOTAL appropriations  
under HEADING Single market, 
innovation and digital 
of the multiannual financial framework 

Commitments 

=4+ 6 

1,000 

0,500 

0,500 

0,500 

0,500 

Payments 

=5+ 6 

- 

1,500 

0,500 

0,500 

0,500 

… 

… 

… 

… 

… 

3,000 

3,000 

3,000 

3,000 

EN 

30 

EN 

 
 
 
 
 
 
 
 
 
 
 
 
3.2.2.  Estimated output funded with operational appropriations  

Year 
2024 

Year 
N+1 

Year 
N+2 

Year 
N+3 

OUTPUTS 

Commitment appropriations in EUR million (to three decimal places) 

Enter as many years as necessary to show the 
duration of the impact (see point 1.6) 

TOTAL 

o
N

Cost 

o
N

Cost 

o
N

Cost 

o
N

Cost 

o
N

Cost  N

o

Cost 

o
N

Cost 

Total 
No 

Total 
cost 

SPECIFIC OBJECTIVE No 139: Reducing administrative burden for service providers for posting declarations  

0,800 

0,200 

0,100 

0,015 

0,300 

0,015 

0,300 

0,015 

0,300 

0,015 

SPECIFIC OBJECTIVE No 2: Facilitate administrative cooperation between Member States 

0,200 

0,100 

0,025 

0,010 

0,050 

0,125 

0,010 

0,050 

0,125 

0,010 

0,050 

0,125 

0,010 

0,050 

… 

… 

… 

… 

… 

… 

… 

… 

… 

… 

1,000 

1,000 

0,060 

0,300 

0,400 

0,040 

0,200 

Indicate 
objectives and 
outputs  

 

Type38 

Avera
ge 
cost 

IT development of the 
public interface 

IT support & 
maintenance (public 
intersace 
IT infrastructure 
(hosting, etc.) 

IT Dev 

IT S&M 

IT Infrastr 

Subtotal for specific objective No 1 

IT development of 
interfaces with MS 

IT support & 
maintenance (interfaces 
with MS) 
IT infrastructure (hosting 
etc.) 

IT Dev 

IT S&M 

IT Infrastr 

Training to MS  Trainin

Subtotal for specific objective No 2 

g 

SPECIFIC OBJECTIVE No. 3: Member States realising cost savings by using the public interface connected to the IMI instead of their own declaration portal  

N/A 

38 
39 

Outputs are products and services to be supplied (e.g.: number of student exchanges financed, number of km of roads built, etc.). 
As described in point 1.4.2. ‘Specific objective(s)…’  

EN 

31 

EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Subtotal for specific objective No 3 

0 

0 

0 

0 

0 

… 

… 

TOTALS 

1,000 

0,500 

0,500 

0,500 

0,500 

… 

… 

3,000 

EN 

32 

EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
3.2.3. 

Summary of estimated impact on administrative appropriations  

–    The proposal/initiative requires the use of appropriations of an  administrative 

nature, as explained below: 

EUR million (to three decimal places) 

Year 
2024 

Year 
N+1 

Year 
N+2 

Year 
N+3 

Enter as many years as necessary to show the 
duration of the impact (see point 1.6) 

TOTAL 

HEADING 7 
of the multiannual 
financial framework 

Human resources  

0.267 M€ 

0.267 M€ 

0.089 M€ 

0.089 M€ 

0.089 M€ 

Other administrative 
expenditure  

Subtotal HEADING 7 
of the multiannual 
financial framework  

Outside HEADING 740 
of the multiannual 
financial framework  

Human resources  

Other expenditure  
of an administrative 
nature 

Subtotal  
outside HEADING 7 
of the multiannual 
financial framework  

0 

0 

0 

0 

0 

0.267 M€ 

0.267 M€ 

0.089 M€ 

0.089 M€ 

0.089 M€ 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

… 

… 

… 

… 

… 

… 

… 

0.801 M€ 

… 

0 

… 

0.801 M€ 

… 

… 

… 

0 

0 

0 

TOTAL 

0.267 M€ 

0.267 M€ 

0.089 M€ 

0.089 M€ 

0.089 M€ 

… 

… 

0.801 M€ 

The  appropriations  required  for  human  resources  and  other  expenditure  of  an  administrative  nature  will  be  met  by 
appropriations from the DG that are already assigned to management of the action and/or have been redeployed within the 
DG,  together  if  necessary  with  any  additional  allocation  which  may  be  granted  to  the  managing  DG  under  the  annual 
allocation procedure and in the light of budgetary constraints. 

3.2.3.1.  Estimated requirements of human resources  

–    The proposal/initiative does not require the use of human resources.  

–    The  proposal/initiative  requires  the  use  of  human  resources,  as  explained 

below: 

Estimate to be expressed in full time equivalent units 

Year 
2024 

Year 
N+1 

Year 
N+2 

Year 
N+3 

Enter as many years as 
necessary to show the duration 

40 

Technical  and/or  administrative  assistance  and  expenditure  in  support  of  the  implementation  of  EU programmes 
and/or actions (former ‘BA’ lines), indirect research, direct research. 

EN 

33 

  EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
of the impact (see point 1.6) 

 Establishment plan posts (officials and temporary staff) 

20 01 02 01 (Headquarters and Commission’s Representation 
Offices) 

1.5 

1.5 

0.5 

0.5 

0.5 

20 01 02 03 (Delegations) 

01 01 01 01  (Indirect research) 

 01 01 01 11 (Direct research) 

Other budget lines (specify) 

 External staff (in Full Time Equivalent unit: FTE)41 

20 02 01 (AC, END, INT from the ‘global envelope’) 

20 02 03 (AC, AL, END, INT and JPD in the delegations) 

XX 01  xx yy zz  42 

- at Headquarters 

- in Delegations  

- 

- 

01 01 01 02 (AC, END, INT - Indirect research) 

 01 01 01 12 (AC, END, INT - Direct research) 

Other budget lines (specify) 

TOTAL 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

1.5 

1.5 

0.5 

0.5 

0.5 

… 

… 

… 

… 

… 

… 

… 

… 

… 

… 

… 

… 

… 

… 

… 

… 

… 

… 

… 

… 

… 

… 

… 

… 

… 

… 

XX is the policy area or budget title concerned. 

The human resources required will be met by staff from the DG who are already assigned to management of the 
action  and/or  have  been  redeployed  within  the  DG,  together  if  necessary  with  any  additional  allocation  which 
may  be  granted  to  the  managing  DG  under  the  annual  allocation  procedure  and  in  the  light  of  budgetary 
constraints. 

Description of tasks to be carried out: 

Officials and temporary staff 

-  Manage  &  oversee  the  implementation  of  the  public  interface 

connected to the IMI 

-  Engage  with  the  Commission  expert  group  on  a  Common  Electronic 

Form for the Declaration of Posting of Workers 

-  Communication and outreach 
-  Manage stakeholder relations 
-  Management of the legal act 

External staff 

- 

41 

42 

AC=  Contract  Staff;  AL  =  Local  Staff;  END=  Seconded  National  Expert;  INT  =  agency  staff; 
JPD= Junior Professionals in Delegations.  
Sub-ceiling for external staff covered by operational appropriations (former ‘BA’ lines). 

EN 

34 

  EN 

 
 
 
 
 
3.2.4.  Compatibility with the current multiannual financial framework  

The proposal/initiative: 

–    can be fully financed through redeployment within the relevant heading of the 

Multiannual Financial Framework (MFF). 

Funding for the implementation of the common electronic form for posting of worker declarations has 
already been programmed due to the Commission’s commitment in the 2020 update of the Industrial 
Strategy. 

–    requires use of the unallocated margin under the relevant heading of the MFF 

and/or use of the special instruments as defined in the MFF Regulation. 

- 

–    requires a revision of the MFF. 

- 

3.2.5.  Third-party contributions  

The proposal/initiative: 

–    does not provide for co-financing by third parties 

–    provides for the co-financing by third parties estimated below: 

Appropriations in EUR million (to three decimal places) 

Year 
N43 

Year 
N+1 

Year 
N+2 

Year 
N+3 

Enter as many years as necessary 
to show the duration of the 
impact (see point 1.6) 

Total 

Specify  the  co-financing 
body  

TOTAL appropriations 
co-financed  

43 

Year N is the year in which implementation of the proposal/initiative starts. Please replace "N" by the 
expected first year of implementation (for instance: 2021). The same for the following years. 

EN 

1 

  EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
3.3. 

Estimated impact on revenue  

–    The proposal/initiative has no financial impact on revenue. 

–    The proposal/initiative has the following financial impact: 

–   on own resources  

–   on other revenue 

– 

please indicate, if the revenue is assigned to expenditure lines  

Appropriations 
available for 
the current 
financial year 

Budget revenue line: 

Article …………. 

     EUR million (to three decimal places) 

Impact of the proposal/initiative44 

Year 
N 

Year 
N+1 

Year 
N+2 

Year 
N+3 

Enter as many years as necessary to show 
the duration of the impact (see point 1.6) 

For assigned revenue, specify the budget expenditure line(s) affected. 

Other  remarks  (e.g.  method/formula  used  for  calculating  the  impact  on  revenue  or  any  other 
information). 

44 

As regards traditional own resources (customs duties, sugar levies), the amounts indicated must be net 
amounts, i.e. gross amounts after deduction of 20 % for collection costs. 

EN 

2 

  EN