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 – SAs have a preference for cooperation via informal workflows in the IMI system

Article(s) involved (national, EU, or other): Articles 60, 61 and 62 GDPR.


SAs tend to make more often use from informal workflows in the IMI system rather than formal workflows – e.g., requesting information via voluntary mutual assistance, without legal deadlines and legal consequences when the request is not adhered to.

Ideal Solution

The regulation should provide when SAs should make use of formal requests (formal mutual assistance, joint operations and formal consultation) so that legal deadlines and legal consequences cannot be ignored. In general, the IMI system should be more user-friendly: SAs have to send each other emails about important notifications (e.g., information requests) as such notifications may disappear in the enormous amount of notifications that SAs get from the IMI system regarding their cases (causing a huge chaos in tracking down the status of a particular case, for instance, because each new step within one case may be linked to a different case number). 

Proposed Solution

Concepts 8 to 12 should addresses this issue.

National Issues

National Issues