UNIFE：2026年关于增值税简化立场报告（英文版）

UNIFE advocates for deletion of Article 13 “Requirements Capture” from PAVA to maintain consistency with Interoperability Directive (IOD) and avoid unnecessary regulatory burdens on applicants and CABs alike. IOD article 21 defines the need for TSI compliance evidence, without mentioning “requirement capture”. This provision oversteps regulatory scope and duplicates compliance to other “Union laws”, which exists independently and does not require separate verification.