Electronic Services Card (E-Card) (Directive/Regulation)

By introducing an electronic services card (E-Card), the EU Commission wants to facilitate the cross-border provision of services. This voluntary electronic proof is intended to reduce red tape for service providers from other EU countries and strengthen the internal market. cep finds this to be questionable and the E-Card to be unlawful under EU law because it is in part disproportionate.


In cep’s view, the proposed Directive and Regulation on the introduction of an E-Card forces Member States to implement, in addition to the Point of Single Contact, a second organisational structure for the registration and approval under commercial law of service providers from other EU countries. In addition, the proposed Regulation is unlawful because it cannot be based on Art. 114 TFEU but only on Art. 53 and 62 TFEU, and the latter only authorise the adoption of Directives.