Initially published by the Commission on 9 December 2015, the ACT is supportive of providing consumers with cross-border portability (subject to the appropriate safeguards) and represents the main actors who will be key in delivering this objective. In its current form the proposal lacks clarity in certain key areas and these imprecisions are a source of legal risk and operational uncertainty requiring urgent resolution. Absent this, ACT companies will not be in a position to deliver portability when the Proposal enters into force. These challenges are compounded by the very short – six month – duration of the transition period within which businesses will have to implement any necessary changes.
Main points ACT members ask for are the following:
For the full position paper, please open the attachment.
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Gregoire Polad | ACT Director GeneralT: +32 2 736 00 52 | E: email@example.com
ACT Director General