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Cross-border protection of vulnerable adults

14 March 2025

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Private International Law and Judicial Cooperation in Civil Matters Ex-ante Impact Assessment

Cross-border protection of vulnerable adults

Esther Kramer with Victor Ellenbroek, Ex-Ante Impact Assessment Unit

BriefingInitial Appraisal of a European Commission Impact AssessmentLast updated: 14/03/25Reading time: 16 minutes

Two people walk together in a rural area.

Key findings

The IA supports the above proposals with a qualitative assessment of legal, social and economic impacts, complemented by quantified estimates of costs and savings of procedural and administrative costs. Impacts on fundamental rights and digitalisation are also assessed, including concerns raised by stakeholders with respect to data protection.

The IA follows a clear intervention logic and is based on solid internal and external sources and various stakeholder consultations. It clearly makes an effort to explain the methods and assumptions underlying the analysis, but could have been more coherent, clear and specific, notably when it comes to the transparency and accessibility of the cost estimates and aggregations.

The range of options assessed in the IA appears limited, given the preferred option is a combination of two out of the three options considered in addition to the baseline scenario. Impacts on small and medium-sized enterprises and competitiveness are anticipated to be minor and were therefore not further assessed. The simplification and digitalisation of protection measures for vulnerable adults in cross-border situations are at the core of the IA, which expects considerable procedural cost savings for stakeholders, while adjustment costs would be borne by the competent administrations under the preferred option.

The legislative proposals appear to follow the IA's preferred option.

Explanatory statement

This briefing provides an initial analysis of the strengths and weaknesses of the European Commission's impact assessment (IA) accompanying two complementary proposals (a regulation and a Council decision) to establish European Union legislation harmonising the rules for cross-border protection of vulnerable adults. These proposals were adopted on 31 May 2023 and referred to the Committee on Legal Affairs (JURI).

This briefing analyses whether the principal criteria laid down in the Commission's own Better Regulation Guidelines, as well as additional factors identified by the Parliament in its Impact Assessment Handbook, appear to be met by the IA. It does not attempt to deal with the substance of the proposal.

Background

Existing EU regulations harmonising rules of private international law in cross-border civil and commercial matters do not include protection measures for vulnerable adults (IA, pp. 1‑5).¹ At international level, the 2000 Hague Convention on the International Protection of Adults (HAPC) addresses cross-border protection of vulnerable adults. However, it has been ratified by (only) 13 EU Member States, despite being considered as 'largely uncontroversial', useful and effective and despite promotion by the European Commission, including through financial support for better cooperation in the field (IA, pp. 2-5).² The IA notes the initiative's complementarity with the 2006 United Nations Convention on the Rights of Persons with Disabilities (UNCRPD). The European Parliament supported EU legislative action to ratify and complement the HAPC in a June 2017 resolution. In line with the digitalisation of EU justice systems, this initiative featured in the 2022 Commission Work Programme.

Problem definition

The IA explains how vulnerable adults' protection in cross-border situations varies considerably among EU Member States, owing to different private international law rules and jurisdictions. The IA provides a balanced problem definition, illustrated in a comprehensive problem tree (IA, pp. 6‑9). In addition to the current patchwork of different private international laws, the IA points out that the HAPC covers 'core' private international law in the international context, but does not correspond to the higher EU standard in the justice area, implying that even if all Member States became contracting parties to the HAPC, the detected problems would only be partially addressed (IA, p. 7).

The IA identifies three main problems, in relation to the most affected stakeholders, as requested by the Better Regulation Guidelines (IA, pp. 7‑9):

lack of legal certainty (affecting citizens, legal practitioners, public authorities);
lengthy and costly cross-border proceedings (affecting vulnerable adults, their families and representatives and public authorities); and
non-recognition of court decisions and of established powers of representation³ (affecting vulnerable adults, their families and representatives and public authorities).

According to the IA, seven drivers cause these problems (it indicates which drivers relate to which problem(s), with most drivers contributing to several (IA, pp. 15‑20):

conflicting and complex rules on applicable law in the Member States;
conflicting rules on jurisdiction;
conflicting or complex rules on recognition of protection measures and powers of representation in another Member State;
unnecessary or complex enforcement proceedings (by the courts);
absent or limited cooperation among national competent authorities;
limited access to foreign law; and
lack of training on the HAPC and its rules on jurisdiction, recognition and cooperation.

In addition, the IA notes 'external factors' contributing to the problems, such as the ageing population (entailing an increase in mental or physical health issues), the increase in EU citizens' cross-border movements, the partial ratification of the HAPC (rather part of driver 1), language barriers, and EU-wide digitalisation in the justice area (IA, pp. 6‑7).

According to the IA, the problems and drivers have several consequences, putting the protection of vulnerable adults at risk (IA, pp. 10‑13). These include health risks (e.g. delayed necessary medical care, affected mental integrity owing to burdensome proceedings), barriers to access to justice, potential dispossession of property abroad, financial loss owing to the length and 'exorbitant' costs of complex procedures, impediments to the vulnerable adult's right to self-determination (notably in case of non-acceptance of powers of representation in another country than the one that provided it (16 Member States provide powers of representation), deterrence or hindrance to free movement in the internal market and an increased workload for competent authorities. The differences between HAPC contracting parties on the one side and non-contracting Member States on the other is noted in the IA, indicating that the problems affect EU Member States to a varying extent.

While the problem definition is clear overall, it could have been better structured, as some aspects overlap, notably in the analysis of the drivers (the problem tree features only the first five, and even the first five listed above are rather closely interlinked). Notwithstanding this weakness, the problem definition is based on solid sources and consistent references to pertinent stakeholder feedback (see section below). As regards the scope of the problems, from the outset the IA acknowledges a lack of data (on the number of vulnerable adults in the EU, relevant cross-border situations and powers of representation issued – see the section on data and methods below).⁴ Based on health data and Eurostat migration statistics, the IA assumes between 144 649 and 780 169 vulnerable adults live in a different Member State to that of their nationality, potentially experiencing problems in a cross-border context. This excludes other cross-border situations, e.g. owning property or assets abroad, which would increase this number (IA, pp. 13‑14, 72). The IA further argues that the number of affected stakeholders could be higher, since potentially all adults, their families and legal representatives in countries issuing powers of representation could be affected by the problems, therefore posing a 'grave problem in the EU' for 'the general public' (IA, pp. 14 and 72‑78). Based on stakeholder feedback, the IA stresses the 'seriousness' of the problems in their violations of fundamental rights and free movement, causing 'an urgent need to act' (IA, p. 62). Finally, against the backdrop of demographic change and increased life expectancy in the EU, the IA expects the number of dependent people and of people suffering from dementia to double by 2050, while growing mobility is expected to increase the number of vulnerable adults in cross-border situations to more than 1.1 million as early as 2030, based on (pre-pandemic) mobility/migration projections and on data on long-standing health limitations (IA, pp. 20‑21). As a consequence, in the case there is no EU action (baseline scenario), the IA anticipates all problems will not only persist, but become more relevant in the near future.

Subsidiarity/proportionality

In line with previous EU initiatives tackling civil or commercial cross-border issues, e.g. on matters of succession, the IA bases the proposed regulation to complement the HAPC on Article 81(2) of the Treaty on the functioning of the EU (TFEU) on judicial cooperation (and not on Article 81(3) – IA, p. 22). It discusses the autonomous EU concept of 'family law' in Annex 6. The proposed Council decision to oblige non-contracting Member States to ratify the HAPC is also based on Article 218(5) and (6). The IA points out that the subsidiarity principle would not apply to the proposed Council decision, given that in the case EU internal legislation exists (i.e. the proposed regulation), the EU has exclusive competence to act externally. The IA is accompanied by a subsidiarity grid for the proposed regulation, highlighting the cross-border nature of all problems considered, and the need for EU action. The IA argues that effective harmonisation and cross-border cooperation can only be achieved by EU-level action, and that the added value of an EU regulation – in addition to the mandatory ratification of the HAPC – would close gaps stemming from the HAPC's international approach, which lags behind the EU standard in the justice area (the IA analyses the limitations of the HAPC in Annexes 6 and 7, in line with the findings of Parliament's 2016 study). Proportionality is considered in the comparison of the options and reflected, e.g. in the optional nature of the certificate of representation and in the suggested data protection safeguards (IA, pp. 47, 54, 122).

The subsidiarity deadline for national parliaments was 26 October 2023. No reasoned opinion was received, but three political dialogues with exchanges of important information took place.⁵ The European Economic and Social Committee adopted an opinion on 21 November 2023.

Objectives of the initiative

The IA's general objective is to protect vulnerable adults' fundamental rights (by preventing physical and psychological abuse, dispossession or denial of access to the adult's property abroad, ensuring their access to justice self-determination, autonomy and free movement (IA, p. 25). The IA lists three specific objectives, corresponding to the three identified problems to tackle:

increase legal certainty for the general public and competent authorities involved;
facilitate the cross-border recognition of protection measures and powers of representation; and
make proceedings faster and less expensive.

While the distinction between the general and specific objectives, as determined by the Better Regulation Guidelines, could have been clearer, the IA highlights the interrelations between specific objectives (e.g. facilitating cross-border recognition of protection measures and powers of representation would positively affect legal certainty and reduce cost and length of proceedings). It includes two helpful figures, illustrating a clear intervention logic (IA, pp. 26). The IA does not present separate operational objectives, but does provide examples of 'potential evaluation indicators' that express specific, measurable, achievable, relevant, and (for some elements) time-bound (S.M.A.R.T.) deliverables for the evaluation of the objectives' achievement later on (IA, pp. 48‑50 and Annex 8, see also the section on monitoring below).⁶ Finally, the IA explains how the IA's preferred option would help achieve four Sustainable Development Goals (SDGs 1, 3, 10, and 16; IA, p. 45 and Annex 3, p. 67).

Range of options considered

The IA presents four policy options to tackle the problems identified, including a dynamic baseline scenario as option 1 (continue encouraging Member States to ratify the HAPC; IA, pp. 26‑30). The baseline is thoroughly developed, based on eight 'scenarios' (examples of various cross-border situations with which vulnerable adults can be confronted; IA, p. 37 and Annex 4, pp. 68‑80). It takes foresight into account (demographic change, increased life expectancy in the EU and the number of vulnerable adults in the future, migration and mobility projections and the 'likelihood' of other non-EU states joining the HAPC). The IA describes the broad lines of policy options 2, 3 and 4, while a 'selection of measures' to be proposed under options 3 and 4 is featured in Annex 6 only (IA, pp. 30‑34 and Annex 6, pp. 114‑118). Option 2 entails a single measure, option 3 an EU regulation comprising 15 policy measures, and option 4 is a combination of the two (the latter is the IA's preferred option). The range of options is therefore rather limited (although it does comply with the Better Regulation Guidelines).⁷

Table 1 – Overview of the retained options assessed in the IA (without option 1, baseline)
Policy Measures	Option 2	Option 3	Option 4
PM1: Mandatory ratification of the HAPC by all Member States (Council decision)	X		X
PM2: European Certificate of Representation (ECR)		X	X
PM3: Choice of jurisdiction		X	X
PM4: Limitation of the grounds for non-recognition of protection measures		X	X
PM5: Abolition of exequatur*		X	X
PM6: Recognition of confirmed powers of representation		X	X
PM7: Digitalisation 1 – Mandatory electronic communications		X	X
PM8: Digitalisation 2 – European Electronic Access Point for the general public		X	X
PM9: Digitalisation 3 – Acceptance of electronic documents and qualified electronic signatures		X	X
PM10: Digitalisation 4 – Interconnection of national registers		X	X
PM11: Legal aid in cross-border cases		X	X
PM12: Direct communication between courts		X	X
PM13: Publication of practical information on the e-Justice Portal regulation		X	X
PM14: Designation by courts of a professional representative abroad		X	X
PM15: Standardised forms for communication between authorities		X	X
PM16: European Judicial Network in civil and commercial matters (EJN-civil)		X	X

Source: Author, based on IA pp. 30-33 and Annex 6, pp. 114-118. Option 4 is the IA's preferred option.

Note: *Formal court procedure by which a foreign judgment is declared enforceable in the state where enforcement is sought.

The IA emphasises that the above measures are 'already a result of a previous analysis' and in line with the 'EU acquis in other areas of civil justice that have proven to be efficient and helpful for parties and competent authorities' (Annex 6, p. 114). Not all details of the measures are discussed, for instance the criteria for the choice of jurisdiction, the interconnection of national registers (where the IA refers to the Insolvency Regulation) and technical details concerning data processing, all to be regulated by secondary legislation. Option 3 covers EU countries, whereas options 2 and 4 cover the EU and other HAPC contracting parties. The IA discards not only non-legislative action, but explicitly also a 'staged approach', i.e. adopting a regulation after all Member States have ratified the HAPC, arguing this would create adjustment costs twice and delay the digitalisation of judicial cooperation (IA, pp. 33‑34).

Assessment of impacts

The IA's comparative assessment of the retained policy options' impacts is mostly qualitative, complemented by quantified estimations of the expected procedural, adjustment and enforcement costs for the main stakeholder groups (IA, pp. 34‑45). The IA assesses legal and fundamental rights, social, economic, digital and data-protection impacts, as well as those on non-EU countries. It does not expect the options to have any 'relevant' environmental implications (IA, p. 37). The IA tends to pre-empt findings, which gives the impression that the preferred option was somewhat predetermined (e.g. when it concludes the added value of option 4 would best achieve the objectives, before developing the assessment as such; IA, pp. 31‑33, 36).

Starting the assessment with legal impacts, the IA expects all retained options to benefit vulnerable adults, their families, representatives and the competent authorities involved in cross-border situations, in terms of fundamental rights, self-determination and autonomy, access to justice, free movement and legal certainty (IA, p. 38). Furthermore, according to the IA, the improved protection of adults in cross-border situations comes with positive social and health impacts; on their well-being, welfare, social inclusion, emotional distress, and psychological and mental health (IA, pp. 38‑39). The IA states that these benefits cannot be quantified, but it provides quantified estimates for anticipated economic impacts under each option. It estimates direct adjustment costs for administrations (average one-off cost of €304 000 per Member State for setting up a national interoperable register, and recurrent annual average maintenance costs of €204 000 (Annex 3, p. 66). Given the existing widely varying national rules, adjustment costs would be comparatively higher in Member States that are not contracting parties to the HAPC (IA, p. 37). At the same time, the IA anticipates cost savings for administrations owing to simplified rules (see section below). Vulnerable adults are not expected to incur any costs under the options, only considerable procedural cost savings. Enforcement costs for central authorities in the Member States are expected to be 'negligible' (IA, p. 42, Annex 3, p. 66).

Furthermore, the IA highlights positive impacts on digitalisation under options 3 and 4 (compared to option 2), both at EU and national level and in line with the 'digital by default principle' of the Better Regulation Guidelines and other EU initiatives to digitalise the justice area (IA, p. 44). The IA notes that the European Commission could support competent authorities with a common reference implementation software (IA, p. 43). It considers the options' impact on data protection, arguing that option 3 (included in preferred option 4) would ensure processing and protection of personal data in line with the General Data Protection Regulation and Regulation (EU) 2018/1725 on processing of personal data (with Member States and the Commission acting as data controllers). The IA addresses stakeholders' concerns raised in this context, pointing to, inter alia, the optional nature of the European certificate of representation and of the 'European electronic access point' usage. It further stresses a 'higher level of protection and confidentiality' for information about health, by allowing only competent authorities access to the interconnected system – not the wider public (IA, pp. 44, 61 and Annex 6, pp. 118‑122). According to the IA, vulnerable adults living in non-EU contracting parties would immediately benefit from increased protection under the preferred option, while third countries could be encouraged to join the HAPC (IA, p. 44‑45). Annex 7 analyses specifically which problems could be partially addressed by ratification of the HAPC by all Member States alone, concluding this would not be sufficient to tackle all problems (IA, pp. 123‑126).

Finally, the IA compares the options against the baseline and the specific objectives in terms of effectiveness, efficiency and coherence and selects option 4 as preferred option, deeming it most effective in increasing legal certainty and most coherent with the UNCRPD,⁸ and stressing its combination of external action with internal (EU) legislation, expanding the scope to non-EU contracting parties of the HAPC (IA, pp. 36, 45‑46). Overall, the total cost savings are expected to exceed costs, with a total net benefit of an estimated €2.5 billion after 10 years under the preferred option (compared to €827 288 under option 2, IA, p. 43 and p. 105). Apart from the most affected stakeholders, the IA notes that non-judicial actors, such as medical staff, social workers, banks and insurance companies would also benefit indirectly from the initiative. It warns that non-adoption would 'be a step backwards as compared to other areas of judicial cooperation in civil matters' (IA, p. 114).

SMEs/Competitiveness

The IA stresses the diversity of stakeholder groups⁹ that could be directly and indirectly affected by the initiative, including businesses, but it argues that SMEs are 'unlikely to be significantly affected' and thus, does not assess the impact on them in detail (IA, pp. 37 and Annex 3, pp. 63‑64). Similarly, the IA does not expect any impact on competitiveness. Consequently, the IA contains neither an SME-test nor a competitiveness check.

Simplification, burden reduction and other regulatory implications

Simplification and digitalisation of judicial procedures, by cooperation and mutual recognition, are at the core of this initiative and frequently referenced throughout the IA, including in the objectives and the proposed policy measures. According to the IA, the preferred option does not entail new administrative costs for citizens or businesses under the 'one in, one out' (OIOO) approach (the adjustment and enforcement costs being borne, as noted above, by administrations, which are excluded from the OIOO approach; IA, p. 47, Annex 3, pp. 65‑66 and Annex 4, pp. 105‑106). In this context, the IA highlights considerable cost savings for 'individuals', estimated at around €520 million¹⁰ over 10 to 15 years. It expects the costs incurred by administrations to be offset by the corresponding reduction of procedural costs for vulnerable adults (IA, pp. 47‑48).

Monitoring and evaluation

In addition to the existing relevant UN-related monitoring and regular meetings of the European Judicial Network in civil and commercial matters, the IA presents common monitoring provisions for both parts of the preferred option (Council decision and regulation; IA, pp. 48‑50 and Annex 8). It features a broad set of 'potential' indicators to monitor and evaluate this initiative, to be used in close cooperation between the central (national) authorities and the Commission. The indicators' description is in line with the specific objectives and was taken on board in the proposals, as was the suggestion for the Commission to carry out an evaluation of the preferred option 10 years after the entry into force of the proposed regulation.¹¹

Stakeholder consultation

The call for evidence and the open public consultation for this IA were open from 21 December 2021 to 29 March 2022 and received 8 and 42 responses, respectively. In addition, the Commission consulted associations of practitioners, academia, other (international) non-governmental organisations and the European Judicial Network in civil and commercial matters in a more targeted manner, as well as 53 experts from 24 Member States (IA, p. 62). Furthermore, the IA relies on a European Network of Justice Inspection Services fact-finding mission and two focus groups with key stakeholders.¹² Given the above-noted data gaps, stakeholder opinions are important for this IA's evidence base and referenced consistently, albeit often in a general and scattered manner, which makes it challenging to get a clear picture. The IA concludes in Annex 2 that the consultations showed 'an urgent need to act', but at the same time reports mixed stakeholder feedback. On the one hand, it states 'most stakeholders' found the preferred option to be the most effective (and the interconnection of registers one of the most useful measures); on the other hand, the IA points to conflicting views, e.g. strong 'opposition' by some Member States against a binding choice-of-court provision and concerns about data protection (IA, pp. 32, 46‑47, 52, 59 and 61‑62 and Annex 2).

Supporting data and analytical methods used

The IA builds on solid sources, starting with a 2021 legal study on cross-border protection of vulnerable adults in the EU, a 2023 support study, and earlier studies by the European Parliament and the European Law Institute. It also references as sources the European disability forum and the above-mentioned consultations. The IA used a Eurostat survey on self-perceived health problems, Eurostat migration statistics and a Eurostat population projection (IA, pp. 20‑21 and pp. 70‑80).

The IA is transparent about the lack of data on vulnerable adults in cross-border situations, both at EU and national level. It provides topical and methodological information in a comprehensive glossary, extensive footnotes on legal and judicial specifics and in the annexes. Annex 4 features quantified estimates of costs and cost savings for all options (including the baseline and explanations on how the number of vulnerable adults in the EU was estimated; IA, pp. 81‑106).¹³ However, the estimates are based on complex assumptions that could at times have been better substantiated and presented in a more structured manner. The IA does not mention models or modelling – the above-mentioned support study (pp. 59, 82) notes the Standard Cost model 'method', without going into more detail. In terms of transparency, the varying terminology used for cost categories could have been more coherent to facilitate the accessibility and comparability of the calculations and aggregations ('procedural', 'adjustment', 'compliance', 'implementation', 'enforcement', 'administrative costs' (the latter under OIOO and beyond), featured variably as 'annual costs' or 'costs over 10 or 15 years', 'cost savings', 'aggregate cost savings', 'cost reductions', 'gains' etc.). Acknowledging considerable uncertainties in the quantifications and assumptions, the IA states that the qualitative assessment was decisive for the selection of the preferred option. To corroborate the robustness of the analysis, it refers to a (partial) sensitivity analysis conducted in the context of the external support study (IA, pp. 56‑57).

Follow-up to Commission Regulatory Scrutiny Board opinion

The Regulatory Scrutiny Board (RSB) issued a positive opinion on 20 January 2023, with seven suggestions to improve the draft IA, notably as regards the range of options, discarded options and the distinction between options 3 and 4. The IA thoroughly addresses all RSB comments in Annex 1 and seems to have modified the IA accordingly. However, as indicated above, some issues with respect to the transparency of the quantified estimates (including under the OIOO approach, which was questioned by the RSB), the range of options and with respect to the clarity of the assumptions underlying the IA persist.

Coherence between IA and Commission legislative proposal

The two-fold initiative (proposals for a Council decision and a regulation) follows the IA's preferred option 4.

Endnotes

1The IA defines vulnerable adults as 'persons aged 18 or more who are not in a position to protect their interests, due to an impairment or insufficiency of their personal faculties', in line with The Hague Convention of 13 January 2000 on the International Protection of Adults. For more information on the background of this initiative see The protection of vulnerable adults in cross-border situations, EPRS, 2023.

2At the time of drafting the IA, 11 Member States had ratified the convention. The IA cites reasons for this slow ratification, e.g. fewer cases and case law than in other contentious cross-border matters and a lack of political prioritisation of the ratification by national legislators (IA, pp. 2‑3; see also the 2020 Report by the European Law Institute, p. 10).

3Powers of representation are established when the adult concerned is still in a position to protect his or her interests (full legal capacity). Depending on the applicable legislation, they do not necessarily enter into force immediately, but only when, for instance, the insufficiency of the faculties of the adult is established (IA Glossary). Owing to the different national rules and jurisdictions, powers of representation may be valid with or without confirmation or registration. According to the IA, all but six Member States had set up registries on protection measures by 2021, with cross-border access possible in only five Member States (IA, p. 5).

4Central authorities of HAPC contracting parties record cross-border cases, but only in relation to other contracting parties, and both citizens and courts often do not refer their cases to central authorities (IA, pp. 71‑72).

5The German Bundesrat finds the proposed regulation under the preferred option disproportionate, noting data protection issues and significant potential costs for the competent authorities. The Italian Chamber of Deputies raises questions about the legal basis (Article 81(3)) and the inclusion of family ties), while the Portuguese Parliament sees the initiative as in line with the subsidiarity and proportionality principles.

6The table of indicators is missing in the IA's core text, but features in Annex 8, which was added to the IA following a RSB recommendation (Annex 1, pp. 54‑55, Annex 8, p. 128).

7The Inception impact assessment presented the options as two alternatives (soft law and legislative measures).

8The coherence with the UNCPRD could have been explained more specifically in the IA.

9The IA expects the work of social workers, private lawyers, medical staff, notaries, criminal courts and prosecutors, civil, commercial and land registrars; banks, other financial institutions, insurance companies, real estate agents, and many other economic actors; to be simplified by harmonised rules (IA, p. 37).

10This seems inconsistent with Annex 3, p. 65, where cost savings under OIOO of €1.3 billion over 10 years are noted (it appears that adjustments were made following a RSB comment). The expected cost savings refer to, inter alia, medical assessments, travel, sworn translation of documents and legal assistance, avoiding duplicate procedures, better access to cross-border information, digitalisation and simpler rules (IA, p. 39).

11The IA suggests using Denmark, which does not take part in measures adopted under Article 81 TFEU, as a 'control group' to assess the effects of the legislation (IA, p. 129).

12The first focus group (Member States' competent authorities, EU level non-governmental organisations) provided information on the policy options; the second (practitioners and academic experts) on the total cost and cost savings estimates (IA, pp. 43 and 105). Annex 9 describes the consultations carried out in the context of the support study.

13The IA used statistics on the number of adults under judicial and administrative protection measures recorded in six countries. Belgium and France have openly accessible government publications, while Finland, Germany, and Italy provided data in interviews and focus groups; the IA does not reference a source for data from Switzerland (IA, Annex 4, p. 70 and Annex 9, pp. 132‑133).

Classification

Policy areas: Private International Law and Judicial Cooperation in Civil Matters | Ex-ante Impact Assessment

Regions: European Union

Committees: Legal Affairs (JURI)

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