TKG, IT Security Act: Associations criticize tight deadlines

In an open letter, industry associations and civil society organizations criticize the tight deadlines that the federal government has set for the participation of interest representatives in important legislative projects. The 15 undersigned organizations call on the “dear Federal Ministers” to “pursue association participation as an important tool of democratic participation more seriously in the future”.

The signatories – including the Bundesverband IT-Mittelstand (BITMi), the Chaos Computer Club, the Digitale Gesellschaft, the eco-Verband and the Gesellschaft für Informatik – describe the comment period of 28 hours for the Wednesday on the way as a “sad low point” IT Security Act 2.0 and the two-day deadline for the amendment of the Telecommunications Act. When the controversial Network Enforcement Act was changed, the notification was sent to the EU when the associations’ statements were still being received.

The associations criticize that the participation of the specialist public becomes a simulation. By doing letter published on Friday They insist on the “as early as possible” forwarding to associations as stipulated in §47 of the Joint Rules of Procedure of the Federal Ministries (GGO) and demand “reasonable deadlines instead of sham participation”. This is the only way for them to deliver really well-founded feedback from their respective specialist areas to the legislature. At least four weeks are necessary for this.

Further demands of the letter relate to the facilitation of comments, for example by making synopses of different versions of the drafts available and, like all drafts of the speakers, published.

In the opinion of the organizations, real participation by civil society requires further steps towards opening up the legislative processes. “Following the example of the online consultation procedure of the European Union, in addition to the publication of all drafts of the drafts and synopses, the possibility of commenting should also be opened up for other civil society actors. So far it has been an opaque selection by the leading ministries”, write the associations.


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