The German Social Insurance takes a detailed look at the European Commission's proposal.

KL – 04/2018

The European Commission is planning to establish a Digital Single Gateway at European level. According to the European Commission's proposal, the Gateway will promote the digitalisation of public administrative procedures and make it possible for citizens to communicate with authorities across borders. 

Position of the German Social Insurance

The umbrella associations of Germany's social insurance system have scrutinised the European Commission's initiative. They generally see the initiative as positive and welcome Brussels' objective of making it easier for citizens and businesses to access the information, procedures, and assistance and problem-solving services that they need to use. However, the associations have pointed out that, from the point of view of Germany's social security system, the texts under discussion need to be further analysed and improved. 

Multiple languages

According to the European Commission's proposal, information on the rights and obligations of citizens and companies regarding social security is to be provided online by the Member States in several languages, both in the national language and in one of the other official languages of the EU. 


However, the German Social Insurance is of the opinion that providing information in another official EU language, depending on how comprehensive this has to be, is associated with considerable additional effort and cost. The question is whether this can be borne by the systems in the Member States given the constant costs of maintaining a website and the costs for translations and suitable content management systems (CMS). 

Assumption of translation costs

The European Commission's proposal for a Regulation includes the use of EU funds to cover initial translation costs only. The German Social Insurance is in favour of EU funds being used for all translation costs arising from the proposal to establish a Digital Single Gateway as the social insurance institutions have determined that there is a clear discrepancy in terms of costs. This is the only way to prevent the resulting costs from being unilaterally imposed on the people who pay contributions to social insurance. 


The negotiating position adopted by the Council in November provides for the assumption of translation costs, subject to an annual ceiling amount. The German Social Insurance is strongly for this. 

Online administrative procedures

The European Commission wants it to be compulsory for the Member States to offer certain administrative procedures online and with cross-border access. The specific procedures are set out in Annex II of the proposal for a Regulation. These include applying for social benefits, registering companies and workers in public pension and insurance systems, and paying social security contributions on behalf of employees. 


Although the Council's amendment of November 2017 has already significantly mitigated the obligations of the Member States, the German Social Insurance is critical of this part of the legislative initiative. It stresses the need to ensure that the proposed Regulation does not interfere with existing national procedures, in particular procedures related to social security contributions and reporting. In addition, it must be ensured that the proposed Regulation does not raise issues in existing procedures that cannot be resolved at national level (e.g. the issue of electronically authenticating legal persons in reporting and notification procedures). 


However, the European Parliament has been pursuing other goals which are likely to extend the catalogue of procedures (see our article 03/2018). 

Transitional periods

Due to the effort needed to adapt the administrative processes of the Member States, the German Social Insurance recommends that the Regulation include provisions for appropriate transitional periods (up to seven years). 

What next?

In the legislative process, the German Social Insurance calls upon the European Parliament to make the necessary changes to the European Commission’s proposals. The Parliament's negotiations with the Council and the European Commission will restart at the end of April 2018. 


A Summary of the comments by the German Social Insurance from 12 March 2018 is available here