EUROPEAN COMMISSION EUROSTAT. Directorate G :Global Business Statistics Unit G-2: Structural Business Statistics and Global Value Chains

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1 EUROPEAN COMMISSION EUROSTAT Directorate G :Global Business Statistics Unit G-2: Structural Business Statistics and Global Value Chains SBS WORKING GROUP 14 APRIL 2015 Meeting room: room Quetelet Kirchberg, Luxembourg DOC.3/EN/EUROSTAT/G2/SBS/Apr2015 Implementation of the SU Regulation (No. 696/93) in SBS Please note that for environmental purposes extra copies of the documents listed on the agenda will no longer be available in the meeting room, unless they were not made available two weeks before the meeting. Delegates are invited to bring with them the copies they received through CIRCA Website:

2 Executive summary: This document informs the SBS WG on the outcome of the written consultation launched on 15 December 2014 and further actions envisaged. The final report of the ESSnet on Consistency as well as the information coming from the Structural Business Statistics (SBS) quality reports and the annual inquiry for the Business Registers indicated that some Member States had not implemented the definition of the statistical unit enterprise in their SBS domain correctly. If that was the case, the comparability of business statistics between the European Union Member States cannot be safeguarded. To get an overview of the current state of play, Eurostat sent a letter (Ref. Ares(2014) ) to the Business Statistics Directors Group on 15 December 2014 (Annex I). In that letter, Eurostat asked for clarification of how the definition of a statistical unit "enterprise" of the current regulation on the statistical units 1 (SU-Regulation) had been implemented in the domain of the Structural Business Statistics 2. The definition of an enterprise according to the SU-Regulation is as follows: "The enterprise is the smallest combination of legal units that is an organisational unit producing goods or services, which benefits from a certain degree of autonomy in decisionmaking, especially for the allocation of its current resources. An enterprise carries out one or more activities at one or more locations. An enterprise may be a sole legal unit." In general, most of the legal units equal an enterprise. However, there are important cases where this is not the case and legal units have to be grouped together and, if necessary, characteristics have to be consolidated. The deadline for providing replies to Eurostat was 15 January Eurostat collected replies from 27 EU Member States (1 Member State did not provide any reply) and Norway. The full summary of the replies can be found in the Annex II. A very first evaluation of the situation by Eurostat led to the following distribution of countries into three groups: 1. group: fully compliant 4 countries 2. group: partially compliant 12 countries 3. group: non-compliant 12 countries Eurostat is going to closely monitor further actions of countries concerned. Compliance letters will be sent to countries that stated they were either partially compliant or noncompliant inviting them to propose a recovery plan that would enable the correct implementation of the definition "enterprise" without any necessary delay. 1 Council Regulation (EEC) No 696/93 of 15 March 1993 on the statistical units for the observation and analysis of the production system in the Community 2 Regulation (EC) No 295/2008 of the European Parliament and of the Council of 11 March 2008 concerning structural business statistics 1

3 ANNEX I EUROPEAN COMMISSION EUROSTAT Directorate G: Global Business Statistics Luxembourg, 15 December 2014 ESTAT/G0/MHF/AB/mv/D(2014) LETTER FOR THE ATTENTION OF THE BSDG MEMBERS Subject: Statistical units in Structural Business Statistics Dear Madam/Sir, As you know, the final report of the ESSnet on consistency as well as information coming from the SBS quality reports and the annual inquiry for the Business Registers indicate that there is currently in some countries a not satisfactory implementation of the statistical unit enterprise for Structural Business Statistics. If this is the case, the comparability of business statistics between EU Member States may not be fully achieved. To get a clearer picture, I am writing to you to clarify how the definition of an enterprise in the current regulation on the statistical units (Council Regulation (EEC) No 696/93 of 15 March 1993 on the statistical units for the observation and analysis of the production system in the Community) has been implemented in the domain of your Structural Business Statistics according to Council and European Parliament Regulation 295/2008. The definition of an enterprise according to the above mentioned Regulation is as follows: "The enterprise is the smallest combination of legal units that is an organisational unit producing goods or services, which benefits from a certain degree of autonomy in decisionmaking, especially for the allocation of its current resources. An enterprise carries out one or more activities at one or more locations. An enterprise may be a sole legal unit." In general, most of the legal units equal an enterprise. But there are important cases where this is not the case and legal units have to be grouped together and, if necessary, characteristics have to be consolidated. First of all, could you please provide us with the following information: 2

4 a) In my country the provisions of Regulation 696/93 are fully implemented in the area of SBS according to Regulation 295/2008. b) In my country the provisions of Regulation 696/93 are partly implemented in the area of SBS according to Regulation 295/2008.* * c) In my country the provisions of Regulation 696/93 are not implemented in the area of SBS according to Regulation 295/2008, meaning in practice that there is no grouping of legal units, even if they do not have autonomy in decision-making. * In case you have answered "partly implemented", could you please provide some specific explanations, e.g. that you cover only the largest enterprises above a certain threshold. I would appreciate an answer by 15 January It goes without saying that our default assumption is that your country is fully compliant with the SBS Regulation, unless there is some evidence coming from the above mentioned sources. So, it is in any case preferable to answer to this letter, so that we have a good overview of the situation. Yours sincerely, (e-signed) Maria Helena Figueira Director Contact: Tatiana Mrlianova, Telephone: , tatiana.mrlianova@ec.europa.eu Annex Example 1 for illustration: There are 3 separate legal units for factors of production, which in combination are used for the production of goods and services. Despite their legal identity, these legal units would not be considered autonomous in an economic sense. In fact, only the combination of legal units would have a sufficient degree of autonomy. In such a case, we would assume that you report to Eurostat on one enterprise. Example 2 for illustration: There is an enterprise that establishes a new legal unit where all the employment is going to be recorded. This unit is in fact serving other legal units belonging to the same enterprise. In such a case, we would assume that you have information, e.g. from your Business Register, from which you could recognize that the newly established legal unit is linked to the existing enterprise? We also would assume that you would report only on one enterprise. 3

5 ANNEX II CODE BE Full reply Actually in Belgium the provisions of Regulation 696/93 are not implemented in the area of SBS according to Regulation 295/2008, meaning in practice that there is no grouping of legal units, even if they do not have autonomy in decision making. However Belgium is making concrete plans, and has already taken some concrete actions, to remedy this situation in the following years. None of the three proposed options describes the real situation in Bulgaria. BG In our country the used statistical unit is enterprise = legal unit. All enterprises benefit a certain degree of autonomy in decision-making, especially for the allocation of their current resources, carry out one or more activities at one or more locations and are a sole legal unit. In this way we are fully compliant with the current definition. As regards the consolidation, we do not consolidate the data for enterprises that are formed by more than one legal unit. Therefore we can mark answer "C", with the above-mentioned clarifications. I would like to inform you that Czech Business Register fulfils the provisions of Regulation 696/93 using an assumption that legal unit is equal to enterprise. The SBS data according to Regulation 295/2008 respects the frame created from the Business Register and consequently they follow the same logic. CZ According to our view the current practice is not incompatible with the definitions according to the Regulation 696/93, whose content is relatively vague and allows various interpretations. We take a note of the current discussion on the statistical units, which shows that the equation mentioned above might not always be the best method to capture the economic reality. However, at the moment we don t see mandated to the conclusion that provisions of Regulation 696/93 are just partially or not at all implemented, what are the formulations used in your questionnaire. This statement is even strengthened by the fact that the method used had to be known to Eurostat. Equation LU=ENT is not only obvious from the datasets but it also is reported e.g. in the SBS quality report or regular annual Business Register report. In the same time the Compliance Assessments produced until 2013 shows that Eurostat was evaluating the compliance as very good for both SBS and BR. In this context we see the current discussion on statistical units as an effort the re-interpret the existing definitions. Incidentally, we see this effort as desirable. I would like to express a support to further methodological work in the field, which is aiming at reasonable, meaningful and consistent interpretation of the current provisions with a help of non-legislative instruments. I would like to stress the importance of operational rules, which according to the BSDG 4

6 opinions - the FRIBS TF should elaborate further to support the implementation of the existing Statistical Units regulation while maintaining consistency with ESA 2010 and BPM6. As regards the SBS statistics itself I believe that SBS SG will continue to assist the MSs with implementation of new methodological principles, which will represent a huge workload for many MSs. At the moment we participating in the EU grants related to the new approach to statistical units. I am convinced that outcomes from these actions will bring valuable inputs to the consideration on the way forward, including the area of SBS statistics. In Denmark the provisions of Regulation 696/93 are partly implemented in the area of SBS according to Regulation 295/2008. DK In the vast majority of cases a legal unit equals an enterprise. Only in around 40 cases we have created enterprises comprising two or more legal units. These cases represent in total approx. 100 legal units. The enterprises consolidate the accounts for the respective legal units merged into one enterprise. In order to be fully compliant with the above mentioned regulations considerable changes would have to be made in partly our Statistical Business Register partly the data collection methods. Statistics Denmark will utilize the experiences gained from our participation in the current grants covering the issue of implementing the statistical units and will partly from our own budget finance the establishing of a unit within the Business register responsible for profiling the largest and most complex enterprises. Presently, German structural business statistics applies the assumption that the enterprise corresponds with the legal unit (at least for active legal units). In general all legal units in Germany are obligated for financial/commercial accounting and consequently have a complete set of accounts. They are legally responsible for their economic activity (personal or corporate responsibility) which implies a certain degree of autonomy. DE From our data sources, especially the administrative data sources, we get no information about the organizational and economic relationship between legal units, their degree of autonomy and their potential integration as enterprises. We have participated in several European initiatives that have taken place since the setting up of the current enterprise definition to find practical ways to delineate enterprises but none of them delivered results promising to be applicable in the German statistical system. As a consequence, by lack of operational rules, solid methodology for the practical implementation (business register, structural statistics) and due to open questions regarding the harmonization with the implementation of the Institutional Unit in ESA, Germany - like many other member states - hasn t yet applied combinations of legal units as enterprises in specific cases. This practice is described transparently and has not been commented by Eurostat in 5

7 the frame of compliance evaluation of SBS. Eurostat presently from our knowledge for the first time funds grants to evaluate the actual effect of the application of the Enterprise definition in practice. They will deliver results in We appreciate that the present state of the art is scrutinized as it may not always reflect economic reality and that there is a certain need for change. Looking for improvement we actively participated in the ESSnet Profiling of complex multinational enterprise groups which has been set up by Eurostat in Unfortunately and contrary to our expectations this initiative could not foster quick progress for Germany regarding the application of the enterprise definition. On the contrary, in several task forces with the intention to develop harmonized European operational rules and a practical implementation plan during the past few years the intensive discussion about a new definition of the enterprise in Germany has somehow hampered the projected work towards the development of operational rules for an EU-wide and harmonized realization of the current definition of the enterprise of regulation 696/93. Finally, it is necessary to mention that the implementation of the enterprise as a combination of legal units will require considerable changes in the production of statistics in Germany. For further details we refer to the reporting in quality reports in the domains of business register and SBS-statistics. For Estonian SBS the most approximate is option b) In my country the provisions of Regulation 696/93 are partly implemented in the area of SBS according to Regulation 295/2008. EE Also in Estonia most of the legal units equal an enterprise. These units produce goods or services, benefit from a certain degree of autonomy in decisionmaking, have a complete set of accounts, carry out one or more activities at one or more locations. In some exceptional cases (e.g. all the employment is recorded in a legal unit serving other legal units of a group) enterprise is implemented in business register and one unit from a group (enterprise) reports consolidated characteristics to SE, including the SBS characteristics. IE Not to confuse matters too much, but for us our answer is more (a) than (b) - in the sense that our intention is that we should consolidate legal units to the level of the enterprise, but of course you could never capture every such relationship. To attempt to do so would be completely unrealistic. One must target efforts in this area on the largest enterprises/legal units - those which, in effect, impact on the SBS aggregates to the greatest degree. Your available resources are a critical input to your decision making here. At the last SBS meeting our Danish colleague mentioned this very point - you put together a reasonable resource pool (bearing in mind competing organisation priorities) and then you concentrate on the main/top enterprises which are relevant to your country. 6

8 For us in Ireland this is our practice: Ireland follows the 1993 enterprise definition and consolidates legal units to enterprise level data. We survey by enterprise. Our business register is the basis for the assignment of legal units to enterprises (based on tax data and data from our Companies registration office). Some summary statistics to highlight the impact on our statistics from the implementation of this definition: Services & Distribution: we have approx 130,000 enterprises in total in Ireland. Approx 230 of these enterprises (who represent around 2,400 legal units) account for around half of Services & Distribution turnover in Ireland. EL ES Industry: we have approx 4,500 enterprises in total. Approx 180 enterprises (who represent around 500 legal units) account for nearly 70% of industrial turnover MISSING In Spain the statistical unit used in the area of SBS is the approach enterprise=legal unit. So in SBS, we do not amalgamate two or more legal units to set up an enterprise. According to our view, the current practice is compatible with the definitions in the Regulation 696/93. All enterprises (legal units) benefit a certain degree of autonomy in decision-making and carry out one or more activities at one or more locations. Moreover, the legal units have a complete set of accounts and a balance sheet of assets and liabilities. So, this is compatible with being compliant with both, the 696/93 on Statistical Units and the 295/2008 on SBS, Regulations. We also consider that the current discussion on statistical units is a new interpretation of the existing definitions. In this context, according to the BSDG opinions, the FRIBS TF should elaborate operational rules to support the implementation of the existing Statistical Units regulation while maintaining consistency with ESA 2010 and BPM6. We would like to emphasize that these operational rules (besides being consistent with ESA 2010 and BPM6) should take into account criteria of cost efficiency in implementing the practical definition of enterprise. - France is partly applying the statistical units regulation in the area of SBS ; FR - more precisely, profiling has been implemented for 44 large groups in France, and the data of the profiled enterprises that have been defined within these groups will be taken into account for the SBS data that will be transmitted in June 2015 (concerning results of year 2013); this will lead to breaks in the series, since until now, just five groups were profiled; - we are conducting methodological studies, as technical implementation, to get in the future a way of profiling the medium and small groups, in a more algorithmic way that for the largest ones (that are profiled in a face-to-face 7

9 way), and then to introduce their results in the SBS data. HR According to the existing definition of enterprise, we are of opinion that it has been implemented in the domain of our Structural Business Statistics. Legal units used as statistical units (enterprises) in SBS production benefit from a certain degree of autonomy in decision-making and they all have their own complete set of accounts. On the other hand, as regards the consolidation, we do not group legal units. Therefore, we could mark answer "C", with previously mentioned clarifications. IT As demonstrated by the result of the ESSnet Consistency and by the results of the last annual inquiry for BR, it is clear that in most of the Countries the enterprise used in SBS corresponds to a sole legal unit. According to the existing definition, for Italy the statistical units (active units) are compliant with the 696/93 regulation, because they own a certain degree of autonomy in decision making and have a complete set of accounts. We are at the same time aware that in some cases, within the enterprise group perimeter, such legal units serve only the legal units belonging to the same group. In these cases, in practice, grouping (via profiling) of legal units is more correct to represent the reality. As long as the definition in the regulation and its explanatory notes describe, the requested information as in points a), b) and c) are formulated in an ambiguous way; according to the definition the not grouping of legal units does not mean to be NOT compliant with the regulation 696/93. Concerning this issue, our answer is yes to b) In my country the provisions of Regulation 696/93 are partly implemented in the area of SBS according to Regulation 295/2008 CY LV LT Due to the fact that we do not have full access in the administrative sources registers, we are not aware of all the cases where an enterprise consists of more than one legal unit. However, when this is known to us, the provisions of the regulation 696/93 are applied. Given the size of the enterprises in Cyprus though, one enterprise = one legal unit. This significantly reduces the size of the error. In Latvia the provisions of Regulation 696/93 are partly implemented in the area of SBS according to Regulation 295/2008. There are only a few cases in which are surveyed enterprises. Currently we are working on profiling project and number of enterprises in future will depend on the results of the project. Statistics Lithuania has just started first actions with regard to profiling. So, in our BR a few statistical units- enterprises- are identified as required in the 696/93 Regulation. However, the provisions of Regulation 696/93 are not implemented in the area of SBS and any other business surveys, meaning in practice that the enterprise 8

10 is equal to the legal unit. In Luxembourg, the provisions of Regulation 696/93 are fully implemented in the area of SBS according to Regulation 295/2008. LU Due to the recent developments in the context of FRIBS (profiling methodology), Eurostat may now have a slightly different interpretation of the Regulation 696/93 than Luxembourg as regards the operational rules this point has already been signalled in our response to the written consultation as of October 17, 2014 (your ref.: ESTAT/G2/PS/AB/mv/D(2014) ). Furthermore, you can observe that the series by KAU concept and the series by enterprise concept diverge systematically in the case of Luxembourg, even on the section level. In Hungary the provisions of Regulation 696/93 are NOT implemented in the area of SBS according to Regulation 295/2008, meaning in practice that there is no grouping of legal units, even if they do not have autonomy in decisionmaking. (e.g. point C) HU Explanations: We have used the assumption that legal unit is equal to enterprise. Now we are aware that this assumption may not be always the best solution to describe the economic reality. The fact that we use legal unit instead of enterprise was reported, inter alia, in our SBS quality report. At the same time the Eurostat s compliance reports have evaluated the compliance of Hungarian SBS as very good for years. Hungary supports Eurostat s methodological work in the field of statistical units and we have the intention to improve our SBS data compilation practice. For this reason, for example, we are participating in some EU grants related to using new statistical unit enterprise definition. MT NL NSO Malta partly implements Regulation 696/93 due to the fact that in approximately 95% of the cases, the legal unit also represents the enterprise. However, we are currently not in a position to identify enterprises that are made up of more than 1 legal unit. However, in the foreseeable future, the regulation will be applied to those enterprises that will be identifiable. We answer Yes to a) with the remark that Statistics Netherlands also defines enterprises which can consists of parts of legal units. This concerns legal units which are auxiliary for more than 1 enterprise. In Austria the provisions of Regulation 696/93 are partly implemented in the area of SBS according to Regulation 295/2008. (Option b) AT Explanations: In Austria most of the legal units are identical with an enterprise. But of course there are important units where this is not the case and legal units have to be grouped together to one enterprise. In some exceptional cases (e.g. leasing enterprises, large enterprises which have outsourced their personnel) these units are already treated in a special way to reflect the real economic situation for selected activities. This is done for SBS in very special cases in the course of data treatment. In addition Austria has country specific legal forms or combinations of them for which the operative unit is considered 9

11 in the results only. Also Legal units without turnover and persons employed (e.g. holdings) are not considered in the SBS results. Nevertheless the full implementation of the statistical unit enterprise according to Regulation 696/93 will require considerable changes in the future production of business statistics. Statistics Austria has just started first actions with regard to profiling. Experiences from these actions will help us to assess time and resources needed for the implementation process of the statistical unit enterprise. For further details we refer to the Austrian comment regarding Implementation of the definition of enterprise in Structural Business Statistics, Business Demography Statistics and Foreign Affiliates Statistics of 17 October 2014 (ESTAT/G2/PS/AB/mv/D(2014) ). PL I would like to inform you that for Poland the answer is c the definition is not implemented. In Portugal, for around 99% of units, each legal unit equals to an enterprise. For the remaining 1%, the provisions of Regulation 696/93 are not implemented in the area of SBS according to Regulation 295/2008, meaning in practice that for these units there is no grouping of legal units, even if they do not have autonomy in decision making (option c). PT In the context of the work that is being done in the grants on Steps towards implementing the revised definition of statistical units and Improvement of national BR and testing of European profiling, we have identified some (up to now, 2 cases) of legal units that need to be grouped. Final results are expected by the beginning of 2016.The output of the grants will help us to better evaluate the resources and time needed for the implementation process of the statistical units. Resources are a critical input and our resources are very limited which might imply a longer period for the implementation to take place. NIS Romania partially implemented the provisions of Regulation 696/93 in the area of SBS (Option b). In Romania, in most of the cases, the enterprise is identical with legal unit. Of course there are also large and complex units for which it is needed to aggregate several legal units. RO Nevertheless for these special cases the legal units are analysed and grouped together to one enterprise. For the SBS this is carried out during the treatment of the data. For the time being we consider that the full implementation of the Regulation 696/93 will imply considerable changes in the whole process of business statistics data production and at least for short-term supplemental resources. NIS Romania is implementing the project on profiling through Eurostat grant. The output of the project will help us to assess resources and time requested 10

12 for the implementation process of the statistical unit enterprise. We welcome all efforts and intentions of Eurostat that in the widest possible way try to settle all open issues regarding statistical units. As was already mentioned at the last SBS Steering group, the problem of the implementation of units concerns also inclusion (or exclusion) of sole proprietors and/or other physical persons or in other words various thresholds that may be used in the statistical business registers and consequently in business statistics such as SBS. SI We would also like to draw your attention on the fact that SBS is also regulated by special Commission Regulation (EC)No 250/2009 which speaks of market enterprises (currently, market enterprise is not defined by the Regulation on statistical units). The definition, together with the regulation of units, statistical business register on one hand and national accounts on the other should serve, in our opinion, as a basis for discussion on potential (non)implementation of regulation on statistical units within SBS. In our case, the statistical business register is the backbone of SBS and represents its sampling frame. We would also like to mention also that due to a very good availability and quality of administrative sources in Slovenia we have practically full coverage in SBS. In addition the enterprise in SBS equals market institutional unit in national accounts which is extremely important as the Regulation on statistical units in its explanatory notes states: "In the corporate enterprises sector, the enterprise corresponds to the institutional unit used in the ESA." Taking into account all what is mentioned above, we consider that the definition of enterprise is fully implemented in our SBS. We hope we had explained our situation detail enough, otherwise please do not hesitate to contact us again. SK In Slovakia we apply the assumption enterprise is equal to 1 legal unit. This information was included in all quality SBS reports since the first one elaborated in 2002 for SBS 1998 data supplemented with the statement the definition is fully compatible with the definition in CR (EEC) No 696/93. There was never made any remark from side of Eurostat in the frame of compliance evaluation that this assumption was not correct one. Therefore we have problems to answer simply to the options a), b) and mainly c) in your letter. We understand and support the current efforts to define operational rules that enable to reflect better the economic reality. In Finland the provisions of Regulation 696/93 are partly implemented in the area of SBS according to Regulation 295/2008. (Option b) FI Explanations: 1) In Finland most of the legal units are identical with an enterprise. They own an autonomy in decision making and have a complete set of accounts. But there are some important, large units where this is not true. In these cases grouping of legal units would be more correct to represent the reality. In some 11

13 exceptional cases (e.g. large enterprises which have outsourced their personnel, sales or real estate) these units are already treated in a special way to reflect the real economic situation for selected activities. In these cases we put the ancillary unit to the same NACE class as its main unit. Also legal units without turnover and persons employed (e.g. holdings or head offices) are not considered in the SBS results. 1) The existence of the enterprise is identified separately from legal units (i.e. administrative registers). In our database the enterprise is identified as soon as legal unit receives turnover, employment or balance>0 and in these cases we also form a LKAU or LKAUs for them. 2) Continuity of the entrepreneurship, predecessor-continuator is checked, mainly by direct questionnaires and we check the most important structural changes (for STS and SBS). When there are several legal units active during the statistical year we consolidate the cases so that only one of them is represented in the statistics. 3) What we don t do: We do not consolidate the account data and variables of complex enterprises. We do not group complex enterprises for statistical results so that number of enterprises would be effected. 4) Current actions: In principle we have already the technical readiness to implement complex enterprises in our new business statistics data system. Nevertheless the full implementation of the statistical unit enterprise according to Regulation 696/93 will still require considerable changes in the future production of our business statistics. In the implementation process we will utilize the experience of ESSnet profiling (we participated) and the actions of the ongoing grant Steps toward the implementation of statistical units. The implementation work is guided by our present national working group ( ) where several statistical domains (incl. national accounts) are represented. In Sweden the provisions of Regulation 696/93 are partly implemented in the area of SBS according to Regulation 295/2008. The Swedish Business Register contains statistical units such as Local Unit, Kind of Activity Unit, Local Kind of Activity Unit, Legal Unit and Enterprise. The situation today is that almost every Legal Unit = Enterprise = Kind of Activity Unit. There are presently 42 Enterprises that contain more than one Legal Unit. Together these enterprises represent more than 1200 legal units. SE In Sweden the most common organizational structure is to have all factors of production included in the same legal unit. Also, the legal unit uses the same identification number in all of our government administrative registers. This gives us easy access to administrative data at the legal unit level. The difficulty to obtain consolidated data from enterprises consisting of more than one legal unit is the main reason why the number of Enterprises consisting of multiple legal units is not higher. We have solved this problem by giving the units that serves another legal unit the same NACE-code as the unit they serve. The serving units are in this 12

14 way included in the correct NACE-code, but no other actions are taken. For some large enterprises the units are treated in a special way to better reflect the economic situation. This work is carried out by the group responsible for the large enterprises at Statistics Sweden. We answer yes to b) In my country the provisions of Regulation 696/93 are partly implemented in the area of SBS according to Regulation 295/2008. UK Further explanations: The UK considers that it is fully compliant with the Statistical Units Regulation, so that where necessary enterprises are set up which are amalgamations of 2 or more legal units. However for the Annual Business Survey, which provides the majority of the data for SBS estimates, selection takes place at reporting unit level. For about 98% of the sample, the reporting unit is the same as the enterprise, but for some of the larger enterprises several reporting units need to be amalgamated to arrive at the enterprise as a whole. These units have been added below the enterprise level to help enterprises, and split them into several components based on industry or geography (determined by profiling), to make it as easy as possible for them to respond. The UK will need to amend questionnaires and/or determine and implement a change to current sampling and methodology to fully comply with the SBS Regulation. Changes to the collection and collation of the financial variables in particular will be required to ensure that all reporting units linked to the enterprises are covered. NO We refer to your of 15th of December on statistical units in Structural Business Statistics (SBS). In the Norwegian SBS the provisions of Regulation 696/93 are partly implemented in SBS. For some industries we do a rough consolidation for the main enterprises and the auxiliary enterprises (in cases where we believe the consolidated accounts are available) in SBS. To use a method where we have to analyze accounts to net the transfers between units and perhaps also ask for additional information will be time consuming compared to use administrative data. 13