Ms Valentina Superti
Director - Tourism and Proximity,
Digitalisation Our Ref: 11.12.2023 No 24.1-1/2023/5028-
1
European Commission, DG GROW
SDG Team
European Commission, DG GROW
Single Digital Gateway implementation
Dear Ms Superti,
Dear SDG Team,
We would like to thank you for the hard work you have been doing with Single Digital Gateway
(SDG) and Once-Only Technical System (OOTS).
We strongly share the European Commission´s belief that SDG will not only boost the digital
transformation of public administrations, but also will make a difference by ensuring long-term
competitiveness for businesses (particular for SMEs) and for a well-functioning of EU Single
Market.
Unfortunately, as we have pointed out several times in working groups, we have to notify that our
implementation of the OOTS is delayed due to the fact that the Commission Implementing
Regulation (EU) No 2022/1463 was adopted more than a year later than expected and we could
not start the developments nor the necessary procurements without it. In addition, regarding the
current version of eIDAS Regulation (Regulation (EU) No 910/2014), it is not obligatory to notify
legal person´s eIDs. In Estonia, we do not use legal person’s eIDs as such. We only have natural
person´s eIDs. According to our national law, the legal person’s management board or the body
that substitutes for the management board is deemed to be the statutory representative of the legal
person in relations with other persons. First, we identify the natural person behind the company
and then verify his/her rights regarding the business, e.g. we make sure that this person is in the
management board and has representational rights towards the company. Thus, we see a need for
the solution for verifying representational rights at the EU level. In our view, this solution could
be done in synergy and cooperation with Business Registry Information System (BRIS). In
addition, the answer is also needed for cases where natural person is representing another natural
person. Without these solutions, unfortunately, the system will be usable only for citizens acting
on behalf of themselves.
Nevertheless, we are happy to notify that by present date we have successfully finished
procurement procedure and found a development partner as well as we have already started
developments with this partner. Furthermore, we have enlarged our national SDG technical core
Suur-Ameerika 1 / 10122 Tallinn / ESTONIA
Phone: +372 625 6342 / Fax: +372 631 3660 / E-mail:
[email protected] / http://www.mkm.ee
team to better support the developments and optimization of the building the OOTS from our side.
The technical development is progressing swiftly. We are developing OOTS components gradually
– component by component. Today we already have a functioning Access Point that has been tested
with several other Member States and we can gladly confirm that it works in test environment. If
everything goes well, we expect all other central national OOTS components to be ready in 2024.
Our national competent authorities will integrate themselves to these central national components
in 2025. The information on rights, obligations and rules as well as access to assistance services
in EU single market was already made available in 2020.
We wish you a nice holiday season ahead, and a productive upcoming year of 2024!
We are open to further discussions on the OOTS topics with the Commission and other Member
States. We remain, together with the Estonian National SDG team (
[email protected]), at your disposal
for any clarification you may need.
Best regards,
(signed digitally)
Sandra Särav
Deputy Secretary General for Economy and Innovation
Ministry of Economic Affairs and Communications
Stina Avvo
+372 639 7659
[email protected]
2 (2)
Ms delta_recipientPersonName_1 \* MERGEFORMAT Valentina Superti Director - Tourism and Proximity, Digitalisation European Commission, DG GROW SDG Team European Commission, DG GROW Our Ref: delta_regDateTime \* MERGEFORMAT 11.12.2023 No delta_regNumber \* MERGEFORMAT 24.1-1/2023/5028-1 delta_docName \* MERGEFORMAT Single Digital Gateway implementation Dear Ms Superti , Dear SDG Team, We would like to t hank you for the hard work you have been doing with Single Digital Gateway (SDG) and Once-Only Technical System (OOTS). We strongly shar e the European Commission´s belief that SDG will not only boost the digital transformation of public administrations, but also will make a difference by ensuring long-term competitiveness for businesses (particular for SMEs) and for a well-functioning of EU Single M arket. Unfortunately, as we have pointed out several times in working groups, we have to notify that our implementation of the OOTS is delayed due to the fact that the Commission Implementing Regulation (EU) No 2022/1463 was adopted more than a year late r than expected and we could no t start the developments nor the necessary procurements without it. In addition, regarding the current version of eIDAS Regulation ( Regulation (EU) No 910/2014 ) , it is not obligatory to notify legal person´s eIDs. In Estonia, we do not use legal person’s eIDs as such. We only have natural person´s eIDs. According to our national law, the legal person’s management board or the body that substitutes for the management board is deemed to be the statutory representative of the legal person in relations with other persons. First, w e identi f y the natural person behind the company and then verify his/her rights regard ing the business , e.g. we make sure that this person is in the management board and has representational rights towards the company . Thus, we see a need for the solution for verifying representational rights at the EU level. In our view, this solution could be done in synergy and cooperation with Business Registry Information System (BRIS). In addition, the answer is also needed for cases where natural person is representing another natural person. Without these solutions, unfortunately, the system will be usable only for citizens acting on behalf of themselves. Nevertheless, we are happy to notify that by present date we have successfully finished procurement procedure and found a development partner as well as we have already started developments with this partner. Furthermore, we have enlarged our national SDG technical core team to better suppo rt the developments and optimization of the building the OOTS from our side. The technical development is progressing swiftly. We are developing OOTS components gradually – component by component. Today we already ha ve a functioning Access Point that has been tested with several other Member States and we can gladly confirm that it works in test environment. If everything goes well, we expect all other central national OOTS components to be ready in 2024 . O ur national competent authorities will integrate themselves to the se central national components in 2025. The information on rights, obligations and rules as well as access to assistance services in EU single market was already made available in 2020. We wish you a nice holiday season ahead, and a productive upcoming year of 2024! We are open to further discussions on the OOTS topics with the Commission and other Member States. We remain, together with the Estonian National SDG team (
[email protected]), at your disposal for any clarification you may need. B est regards, (signed digitally) delta_signerName \* MERGEFORMAT Sandra Särav Deputy Secretary General for Economy and Innovation Ministry of Economic Affairs and Communications delta_ownerName \* MERGEFORMAT Stina Avvo +372 delta_ownerPhone \* MERGEFORMAT 639 7659 delta_ownerEmail \* MERGEFORMAT
[email protected]