For small undertakings, re-evaluating and re-calculating of the minimum amount of the PII on an annual basis is too frequent and too constraining.
The frequency of this review should be based on the speed of growth of the activity of the undertakings.
We agree, the formula is easy to use for both the competent authorities and the undertakings.
The geographical criterion is arbitrary and can be disproportionate to the size of the corresponding activity.
The additional amount added in case the undertaking provides its services outside the EU should be proportionate to the size of the activity performed outside of the EU.
The additional amount added in case the undertaking is engaged in other businesses should not be arbitrary, and should be proportionate to the size of the undertakings activity.
For undertakings aiming to provide AIS and/or PIS as an additional service to a small base of customer, the proposed amount is out of proportions.
We don’t see any additional criteria or indicators to consider.