Cost is too restrictive

[Marco-ICTU-NL]

Cost is modeled as an amount and a currency. However, in practice many services use a price model that is more complex. For instance, in the Netherlands the cost of a building permit is a percentage of the total cost of the work. Another example: the price for a passport is different for adults and minors, and even higher for emergency delivery.

[giorgialodi]

oh yes! That's true! In the Italian model for public services we distinguished between fixed costs and variable costs. It seems to me that the "percentage of the total cost of the work" you mention is an example of variable costs. In contrast there might be cases in which there is only a fixed cost to pay in order to complete some bureaucratic procedures.

The latter case you report entails that according to the different types of end-users or targets we may have different costs (more or less as it happens for tickets to enter in a public site or to see an art exhibition). My question is: according to SDGR, all these details on costs are required? If so we may consider to include them in the SDG extended model

[barthelemyf]

Cost

Proposed resolution

We understand that the current proposition is too strict to cover all cases faced by Member States without going into a complex model.

• For the core model, we would propose to remove the Cost class.
• For the extended model, we would propose to relax the constraint by proposing alternatively to have a description as a free text where the pricing model could be indicated.
• For the operational model (to be further aligned with TOOP, CCCEV etc.) from your examples, we observe a need to relate the cost calculation to specific criteria. For example, if the age is under or above 18 years, the cost is adapted. This is something we will further investigate in collaboration with CCCEV and TOOP.

Please note that this does not cover the information about the online methods of payment (cf. description below), which could also impact the way we model cost in general.

Rationale

The SDGR clearly state in article 10 that the following information should be provided:

• “The Member States and the Commission shall, for the purposes of complying with Article 4, ensure that [...][users] have access to a sufficiently comprehensive, clear and user-friendly explanation of the following elements, where applicable, of the procedures referred to in point (b) of Article 2(2):
• the applicable fees and the online methods of payment;
• …”

Methods of payment

Looking back at the SDGR, the main concept is around the "Payment of fee" or mostly around "payment" (of fee, taxes, etc.). In particular:

In the Regulation body we have:

• (18) says: payment of fees that can only be done through systems which do not provide for cross-border payments
• (38) says: In order to facilitate the payment of fees required as part of online procedures or for the provision of assistance or problem-solving services, cross-border users should be able to use credit transfers or direct debits as specified in Regulation (EU) No 260/2012 of the European Parliament and of the Council (3 ) or other generally used crossborder payment means including debit or credit cards."
• Art 10.f says:" the applicable fees and the online methods of payment;"
• Art 11 says: "the applicable fees and the online methods of payment"
• Art 13.e says: "where the completion of a procedure requires a payment, users are able to pay any fees online through widely available cross-border payment services, without discrimination based on the place of establishment of the payment service provider, the place of issue of the payment instrument or the location of the payment account within the Union"
• Art 16 says: "where the provision of a service requires a payment, users are able to pay any fees online through widely available crossborder payment services without discrimination based on the place of establishment of the payment service provider, the place of issue of the payment instrument or the location of the payment account within the Union
• Annex I - Consumer rights says: "payments, including credit transfers, delays in cross-border payments"
• Annex I - Starting, running and closing a business says: "rights and obligations arising under contract law, including late payment interests"
• Annex I - Taxes says: "excise duties: information on the general rules, rates and exemptions, registration for excise tax purposes and payment of excise tax, obtaining a refund" and "other taxes: payment, rates, tax returns"
• Annex II - Moving says: "Receipt of toll sticker or vignette or other proof of payment" and "Receipt of emission sticker or other proof of payment"
• Annex II - Starting, running and closing a business: Payment of social contributions for employees

Having considered this, we are investigating and we are going to propose something more structured later on. This is for the extended model.