In the past years we have identified more than 60 procedural issues that we have experienced first-hand in daily operations. We have summarized them on the page below. Many of these issues are symptoms of an underlying procedural problem.

Effective procedure – start and duration of an investigation

Article(s) involved (national, EU, or other):


The absence of any deadline regarding the start and length of an investigation may substantially delay the procedure.

Ideal Solution

The text should provide for such a deadline (with possible extensions, depending on the complexity of the case).

Proposed Solution

Concepts 9, 10, 14 and 16 should solve these issues.

National Issues

National Issues