Permit procedures require a common European framework

Companies are confronted with a multitude of directives, regulations, and national implementation rules, some of which overlap or impose different requirements. This results in complex procedures with a high administrative burden, particularly for infrastructure projects and industrial facilities.

A European regulation establishing uniform procedural standards for permitting and notification procedures could eliminate this unnecessary complexity. This regulation is intended to harmonize existing sector-specific requirements—such as the Industrial Emissions Directive (IED), the Environmental Impact Assessment (EIA), and the Water Framework Directive (WFD)—in terms of procedural law. The goal is to establish a clear framework that creates comparable processes across all member states and makes investment decisions easier to plan.

The BDI specifically calls for:

• an EU-wide regulation with uniform procedural standards for permitting and notification procedures,
• fully digital application and public participation procedures via central data platforms,
• binding deadlines for completeness reviews and public participation,
• an “improvement permit” that allows for environmental improvements to facilities through a notification process rather than a comprehensive permitting procedure,
• greater planning certainty through clear deadlines for the relevant factual and legal situation.

Accelerating Investments in Transformation and Competitiveness

Another reform proposal concerns the early commencement of measures. Companies should be able to start a project even before the final approval decision is made if there is a public or legitimate interest and sufficient safeguards are in place. This will allow important transformation projects to be implemented more quickly without compromising the protection of public interests.

In addition, industry needs a permit for improvements to measures that reduce environmental impacts, increase energy or resource efficiency, or support industrial transformation. If no significant new environmental impacts are expected, a notification to the authorities should suffice. This would facilitate investment in modern facilities and significantly reduce the regulatory burden.

A uniform European procedural law would make permits more predictable and accelerate the implementation of industrial investments. This is an important location factor for growth, innovation, and transformation.

Streamlining Public Participation and Regulatory Procedures

Public notices and public comment periods must be conducted consistently in digital format. Instead of extensive collections of documents, a clear and informative summary of the project should be published. Those directly affected will continue to have access to the relevant documents.

The involvement of other authorities should also be more strictly bound by deadlines. Comments should be submitted electronically within one month. If no response is received, this is considered a waiver of the right to comment. This is intended to reduce delays that currently often arise from parallel reviews by different agencies.

Digital procedures and fixed deadlines increase planning certainty

The industry’s proposal calls for the end-to-end digitization of procedures. Applications and documents are to be submitted electronically. A central data platform is intended to consolidate communication between companies and authorities and integrate further procedural steps.

Of particular relevance is the provision regarding completeness checks. Authorities are to verify within one month whether application documents are complete. Only in justified exceptional cases would a one-time extension of two weeks be possible. If documents are missing, the authorities must specify exactly which information needs to be submitted subsequently. Technical inquiries must not result in procedures remaining permanently stuck in an early review phase.

This approach creates greater reliability. Companies gain clarity on the status of the process at an early stage and can better prepare their investments.