The GDV expresses its doubts about the need and logic of the proposed Regulation:
A more concrete definition of what defines a “serious difficulty” is necessary, since this would be the main condition for an information request.
The decision about whether a piece of information is confidential should ultimately be left to the recipient of the information request. In case the Commission disagrees, a court should decide.
The GDV opposes new rules that extend beyond the current reporting requirements. Instead, procedures should be adapted so that it becomes possible to link them to existing reporting requirements.
The duplicate possibility for sanctioning with fines and periodic penalty payments is not proportionate in view of the unclear prerequisites for information requests and the danger that confidentiality could be compromised. The respective article in the proposed Regulation should be deleted.
To ensure a process that is as transparent and fair as possible, only one means of procedure that is subject to judicial review should exist: the decision. Accordingly, the possibility to proceed by means of a simple request should be omitted.