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Content last updated: 01-05-2019

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  • Merger Control Regime
  • Merger Screening
  • Merger Filing

1. Overall description of merger control regime

1.1 Supranationality

1.1.1 Is the jurisdiction a member of/party to a supranational jurisdiction?

Yes, Romania is a part of the European Union.

1.1.2 Is the jurisdiction itself a supranational jurisdiction?

No.

1.1.3 If the answer to Section 1.1.1 and/or 1.1.2 above is in the affirmative, what are the implications hereof?

As a member State of the EU, Romania cannot apply its national legislation on competition to any concentration that has a Community dimension, as per Council Regulation no. 139/2004 of January 20, 2004 on the control of concentrations between undertakings.

Thus, should a concentration meet both the Romanian and EU merger control thresholds, it shall only be notified to the European Commission.

2. Nature of merger control regime

2.1 Mandatory or voluntary

2.1.1 Is filing mandatory or voluntary?

Should the thresholds described in Section 2.3.1 under the Merger Screening Schedule be met, filing is mandatory.

2.2 Suspensory effect

2.2.1 Must completion of the transaction await clearance by the relevant authorities?

The law provides a standstill obligation since a transaction meeting the thresholds described in Section 2.3.1 under the Merger Screening Schedule should not be implemented before obtaining clearance from the Romanian Competition Council.

The failure to comply with the standstill obligation may lead to sanctions.

However, there are certain exceptions to the standstill obligations. Thus, the standstill obligation does not prevent the implementation of a public bid or that of a series of transactions with securities accepted for trading on a stock exchange (in case the operation is swiftly notified and the voting rights are used solely for preserving the target’s economic value).

In all other cases, derogations from the standstill obligation may be granted by the Competition Council if certain conditions are met.

1. What type of transactions are caught by the merger control regime?

1.1 Concentrations

1.1.1 Type of transactions that are caught by the merger control rules?

A transaction is caught by the merger control rules where there is a change of control on a lasting basis resulting from:

a) merger of previously independent companies or parts of such companies, or

b) the acquisition of direct or indirect control over an undertaking or parts thereof by acquisition of assets, stocks or by contractual provisions, by natural persons or legal entities that already control an undertaking or by one or more companies. 

1.2 Joint ventures

1.2.1 What types of joint ventures are caught by the merger control rules?

Should the thresholds described in Section 2.3.1 under the Merger Screening Schedule be met, the creation of a full-function joint venture amounts to a merger. A full-function joint venture is defined as an undertaking established in order to function autonomously in the long term.

1.3 Definition of "control"

1.3.1 How are the concepts of "control" and "change of control" defined?

As per Romanian law, “control”, whether legal or factual, may derive from rights, contracts or any other elements that individually or collectively confer the possibility of having a determining influence over an undertaking, through:

a) ownership or usage rights over the entirety or parts of an undertaking’s assets, or

b) rights or contracts that confer a determining influence over the structure of said undertaking over the voting process or the decisions of the management bodies of such company.

Control may also be exerted in common when two or more natural or legal persons have the possibility to exert a decisive influence over an undertaking.

Only transactions that bring a lasting "change of control" to the undertakings concerned and in the structure of the market are covered by the merger control rules. Thus, transactions resulting only in a temporary change of control are not covered.

1.4 Minority shareholdings

1.4.1 Are minority and other interests less than control caught by the merger control rules?

Acquisitions of minority shareholdings can be caught by Romanian competition rules if for instance, in the context of voting rights, they grant the minority shareholder a determining influence over the target. Control may equally be taken over in common with others.

2. Establishing jurisdiction for notification of mergers

2.1 Merging parties/undertakings concerned

2.1.1 Which undertakings are considered parties to the merger ("undertakings concerned") in the various types of transactions identified under Section 1.1.1 and 1.2.1?

The “undertakings concerned” are the undertakings involved in the economic concentration, i.e. a merger or an acquisition of control.

In specific cases the following applies:

(i) in case of a merger, each of the merging entities is an undertaking concerned;

(ii) in case of acquiring sole control, the undertakings concerned are the target and the acquiring company (the seller is not an undertaking concerned);

(iii) if sole control is acquired subsequent to joint control, the undertakings concerned are the acquiring shareholder and the joint venture (the selling shareholder is not an undertaking concerned);

(iv) if joint control is acquired over a newly established joint venture, the undertakings concerned are each of the undertakings acquiring joint control (while the newly established undertaking is not considered an undertaking concerned);

(v) if joint control is acquired over a pre-existing company/commercial activity the undertakings concerned are, on one hand, each of the companies acquiring the control and, on the other hand, the pre-existing company/commercial activity;

(vi) in case of a demerger and subsequent allocation of the assets thereof to two or more companies, such operation is deemed as acquiring sole control over said assets and, hence, the undertakings concerned are, for each operation, the company acquiring control as well as the assets to be acquired;

(vii) “control” is acquired by natural persons if such persons carry out economic activities and, thus, are classified as economic undertakings or if they control one or more undertakings, as defined under the competition law; in such cases, the undertakings concerned are the target and the natural person (including the undertakings they control);

(viii) a merger or acquisition of control between two state-owned undertakings/or by the same public entity is an economic concentration if prior to the transaction the undertakings were part of different economic entities with independent decision-making powers; in such case, both companies are undertakings concerned.

It is noteworthy that the term “undertakings concerned” includes:

(a) an undertaking concerned;

(b) those undertakings in which the undertaking concerned, directly or indirectly:

(i) owns more than half the capital or business assets, or

(ii) has the power to exercise more than half the voting rights, or

(iii) has the power to appoint more than half the members of the supervisory board, the administrative board or bodies legally representing the undertakings, or

(iv) has the right to manage the undertakings' affairs;

(c) those undertakings which have in the undertaking concerned the rights or powers listed in (b);

(d) those undertakings in which an undertaking as referred to in (c) has the rights or powers listed in (b);

(e) those undertakings in which two or more undertakings as referred to in (a) to (d) jointly have the rights or powers listed in (b).

2.2 Date for establishing jurisdiction

2.2.1 Which date is relevant for concluding whether the transaction is notifiable?

The relevant date is the earlier of the following: the date of conclusion of the binding legal agreement, the date of announcement of a public bid or the acquisition of a controlling package or the date of the first notification to a national competition authority, as the case may be.

2.3 General thresholds

2.3.1 Threshold(s) for when a concentration must be notified under the general merger control regime?

Economic concentrations are subject to merger control if the following cumulative thresholds are met with respect to the preceding financial year:

(i) the cumulated global turnover of the undertakings involved exceeds the RON equivalent of EUR 10,000,000; and

(ii) each of at least two undertakings involved have obtained in Romania an individual turnover exceeding the RON equivalent of EUR 4,000,000.

2.3.2 For each threshold, can the threshold be triggered by only one party having local turnover?

No, the thresholds cannot be met when only one party has local turnover.

2.3.3 For each threshold, can the threshold be triggered without any party having local turnover?

No, the thresholds cannot be met when none of the parties has local turnover.

2.3.4 Are there any circumstances where transactions falling below these thresholds may be still investigated?

Transactions falling below the thresholds cannot be investigated by the Competition Council.

2.4 Other national thresholds for ex ante merger control (e.g. sector-specific rules)

2.4.1 Relevant thresholds for sector-specific or other ex ante merger control rules?

There are no sector specific merger control rules.

However, when an economic concentration may affect national security, an approval from the Supreme Council for National Defense is required.

2.4.2 Are any such schemes mandatory or voluntary?

Not applicable.

2.5 Foreign-to-foreign mergers

2.5.1 Do any exemptions, special thresholds etc. apply to foreign-to-foreign mergers, i.e. where none of the undertakings concerned is domiciled in the jurisdiction?

Foreign-to-foreign mergers are subject to the same treatment as local transactions.

3. Calculation and allocation of turnover, asset value, transaction value etc.

3.1 Relevant turnover

3.1.1 How is turnover defined (e.g. is income from other sources than "ordinary activities to be included, and how are rebates, taxes, internal turnover etc. treated)?

The turnover comprises the amounts derived by the undertakings concerned from the sale of products and the provision of services after deduction of turnover related tax obligations and internal (intra-group) turnover. For the Romanian turnover, aside from the deductions mentioned above there is an additional one consisting from the accounting value of exports (including deliveries in the European Union). Such deduction does not concern the worldwide turnover.

3.1.2 Identification and link to any official rules, guidance etc. on how to calculate turnover?

The rules on calculating the turnover are provided in the Law on competition no. 21 of April 10, 1996 as well as the Merger Control Regulation, enforced via Order no. 431/2017 of the President of the Competition Council and further detailed in the Instructions concerning the economic concentration, undertaking involved, full-functioning and turnover concepts, enforced via Order no. 386/2010 of the President of the Competition Council.

The documents are available in Romanian on the website of the Competition Council at the following links: http://www.consiliulconcurentei.ro/uploads/docs/items/bucket8/id8047/lege_nr21_1996_actualizata_20160303.pdf

http://www.consiliulconcurentei.ro/uploads/docs/items/bucket12/id12844/ordin_nr_431_2017_reg_conc_econ.pdf

http://www.consiliulconcurentei.ro/uploads/docs/items/bucket1/id1044/ordin_nr386_din_05082010_si_instructiuni.pdf

Enactments published on the website may not always be fully updated.

3.2 Relevant period for calculation of turnover

3.2.1 Which financial year(s) is relevant for the calculation of turnover?

The turnover is calculated based on the figures of the preceding financial year for which audited annual accounts exist.

However, if such figures are not available, the Competition Council shall consider the most recent audited figures. 

3.2.2 Should adjustments be made for e.g. divestitures, acquisitions, closings and other changes of the economic reality of the undertaking concerned made after or during the relevant financial year?

After the date of the most recent audited accounts, adjustments of the turnover should be made in order to reflect the economic realities of the undertakings concerned. 

Thus, such adjustments would be made in case of acquisitions, assignments or cessation of activities and the turnover associated with such operations shall be excluded.

3.3 Relevant undertakings for the calculation of turnover

3.3.1 The "undertakings concerned", i.e. which parties?

See Section 2.1.1 above.

3.3.2 The undertakings whose turnover is taken into account?

See the definition of the “undertakings concerned” in Section 2.1.1 above.

3.3.3 Shall the turnover of the existing seller be included in the target's group turnover?

The seller's turnover shall not be included in the target's group turnover.

3.4 Geographical allocation of turnover

3.4.1 The principles for the geographical allocation of turnover?

The allocation of the turnover is based on the localization of the customer at the moment of the transaction (the place where the services are provided or the place where the products are distributed). This entails that the turnover should be allocated to the area wherein there is competition with alternative providers.

The sale of goods may pose several difficulties, especially when the place where the customer is situated at the conclusion of the contract is different than the invoicing/delivery place. In such cases, the place where the contract is concluded and the delivery takes place weigh more than the invoicing place. Also, given that the delivery is usually the characteristic operation for the sale of goods, the delivery place has priority over the place where the customer is situated at the moment when the contract is concluded. This may vary in accordance with other specific circumstances.

As for the provision of services, the place where the services are provided to the client is usually the relevant one.

However, in case of cross-border situations there are three possibilities:

(i) the service provider is travelling for the purposes of providing the services;

(ii) the client is travelling for the purposes of providing the service;

(iii) the service is provided without the need for any of the parties to travel.

For the cases mentioned at (i) and (ii) the place where the services are provided to the client is the relevant one, while for the third category, the turnover is usually allocated to the place where the client is situated.

3.5 Valuation and allocation of assets

3.5.1 The principles for valuation and allocation of assets?

Not applicable.

3.6 Calculation of other thresholds

3.6.1 The principles for calculation of metrics for other thresholds (e.g. transaction value, market share, share of supply etc.)?

Not applicable.

3.7 Special rules

3.7.1 Do any special rules or principles apply to the calculation, allocation etc. of turnover, assets etc. for specific undertakings (e.g. State-owned undertakings, investment funds, credit and financial institutions, insurance companies, financial holding companies, others)?

Special rules for the calculation of the turnover are applied with regard to credit institutions, other financial institutions and insurance companies.

3.7.2 Does any exemptions apply?

Not applicable.

1. Practical information

1.1 Responsibility for filing

1.1.1 The parties responsible for filing?

In the case of mergers, each of the undertakings concerned is under the obligation to file a notification.

In the case of acquisition of control, it is for the party/parties who acquire(s) control to submit the notification, while in the case of public bids, the offeror is the one that has to file the notification.

1.2 Deadlines for filing

1.2.1 Are there any mandatory deadlines for filing, and, if so, how these are calculated?

There is no fixed deadline for submitting the notification.

However, with a single exception (namely related to public offers or a series of transactions with transferable securities, accepted in view of their sale on stock exchange markets), the parties may not implement the transaction before it is authorized by the Competition Council. See Section 2.2.1 under the Merger Control Regime Schedule.

1.2.2 Are there any sanctions for not filing within the deadlines?

As detailed under Section 1.2.1 above, there are no mandatory deadlines for the submission of a notification.

However, the implementation of an economic concentration before filing the notification may lead to the application of fines.

1.3 Early filing

1.3.1 Is it possible to file before the signing of merger agreement?

Yes.

As a rule, the parties are to file the notification after an agreement in principle has been signed (not necessarily the final merger agreement), the public offer has been announced or the control package has been taken over, and in all cases before the implementation of the concentration.

Thus, should the parties prove the intention to enter into an agreement or to make a public offer, such intention may constitute a basis for notifying a proposed economic concentration before a final merger agreement is signed.

1.4 Filing fees

1.4.1 Are there any fees for filing, and, if so, please describe how such fees are calculated?

The Competition Council charges a fixed fee of RON 4,775 (slightly over EUR 1,000) for registering the merger control notification form.

1.4.2 When must the filing fee must be paid?

The filing fee should be paid before the submission of the notification.

1.5 Publicity

1.5.1 When and in which format will the authority publish receiving a notification?

The Competition Council usually publishes a non-confidential summary of a notification on its website and/or in the press.

Such notification contains the names of the undertakings concerned, their countries of origin, the nature of the concentration, the main activities of the undertakings concerned as well as the date of the receipt of the notification.

Subsequent amendments to the information detailed above shall also be published.

At the request of the undertakings concerned, in justified cases, the Competition Council may decide that no information shall be published until a decision is issued. This will not be the case where the complexity and effects of the transaction require observations from third parties.

1.5.2 How will the authority in general handle the case publicly, e.g. will it usually comment in the media, send out press releases etc.?

Following the adoption of the decision, a press release is usually published by the Competition Council on its website. Subsequently, a non-confidential version of the decision is also published on the website and/or in the Official Gazette.

1.5.3 Will third parties be able to review the notification?

Access to the file is usually allowed to the notifying parties, but, if an investigation on the compatibility of the concentration with a normal competition environment is launched, other undertakings concerned (than the notifying parties) may have access to the file upon request following the circulation of the investigation report. Other undertakings concerned include participants to the transaction such as the seller and the target.

Please note that access to the file by other undertakings concerned is allowed only when the Competition Council considers that such access is required by said parties in order to formulate their observation to the investigation report.

2. Procedure and timing

2.1 Normal and simplified procedures

2.1.1. Does the regime allow for a simplified (fast track) procedure, and, if so, what are the criteria for using the simplified procedure?

There is no accelerated procedure regulated in Romania.

However, a simplified notification form may be used (which in practical terms means it takes less time to draw up the notification) if:

(i) joint control is acquired over an undertaking that does not carry out any, or it is predicted that it will not carry out any, business in Romania or carries out insignificant business in Romania (for example, the turnover obtained does not exceed EUR 4 million);

(ii) there is no horizontal overlap between the parties, provided that the parties are not active in markets in a vertical relationship;

(iii) in case of a horizontal overlap, the aggregated market share does not exceed 20% and any of the parties active on an upstream or downstream market to another party does not hold a market share exceeding 30%; or

(iv) one of the parties holding joint control over an undertaking acquires sole control over same.

It is noteworthy that the Competition Council may switch to the normal notification form at any time, when it deems at its sole discretion that more information is required to assess the merger.

On the other hand, the Competition Council is usually mindful of the time constraints related to the transaction and may help with speeding up the assessment where the parties so request and when the timing and the quality of the notification allow it.

2.2 Procedural stages (cf. timetable below)

2.2.1 The various stages of (i) a simplified procedure and (ii) a normal procedure?

There are three main stages under Romanian law (which applies equally where a simplified notification form is used):

(i) preliminary consultations (although not mandatory, they are strongly recommended);

(ii) the notification phase, in which a form and supporting documents, as well as proof of payment of the notification fee, are filed; this phase includes several steps:

(a) within seven days as of the filing, the notifying party is informed whether the form is validly filed;

(b) within 20 days as of the filing, the Competition Council may issue requests for information; and

(c) after all relevant information is gathered, the notification becomes “effective” (i.e. the formal assessment stage can commence) and the notifying party(ies) are informed in writing of the date when the notification has become effective;

(iii) the formal assessment phase, which may be further divided into two stages:

(a) Phase I assessment – within 45 days as of the effective date, the Competition Council issues a decision which can be either a non-objection decision (if there are no competition concerns or if such concerns were removed via commitments offered by the acquirer) or a decision to open an in-depth investigation;

(b) Phase II assessment –the Competition Council decides to commence an investigation after Phase I (to be closed within five months as of the effective date).

Tacit approval of a concentration occurs if the Competition Council does not adopt any decision in the prescribed deadlines, and there is no regulated suspension mechanism.

2.2.2 Is pre-notification contact with the relevant authorities customary/obligatory/encouraged/etc.?

Pre-notification contact with the Competition Council is not mandatory, but it is strongly encouraged in practice, even in straightforward cases.

2.2.3 Are there any sanctions for not filing within the deadlines?

Prior approval of the concentration before its implementation is mandatory in each case. Gun-jumping is sanctioned with fines ranging between 0.5%–10% of the annual turnover achieved in the fiscal year preceding the sanction. 

2.3 Timetable (cf. timetable below)

2.3.1 The statutory timetable/deadlines for review of a notification?

Within 30 days from the receipt of a complete notification form, the Competition Council shall inform the notifying parties in writing in case the economic concentration does not fall within the scope of the competition law.

When the transaction does fall within the scope of the competition law, the Competition Council shall issue a non-objection decision within 45 days from the receipt of a complete notification when:

(i) there are no serious concerns regarding the compatibility with a normal competition environment; or

(ii) there are serious concerns regarding the compatibility with a normal competition environment but the concerns have been relieved based on the commitments assumed by the concerned parties.

The Competition Council is to decide the commencement of an investigation (phase II assessment) within 45 days from the receipt of a complete notification form, when it considers that the economic concentration raises serious concerns as regards its compatibility with a normal competition environment (and such concerns have not been relieved via binding commitments as described above).

In case of a phase II assessment, in maximum five months from the receipt of a complete notification the Competition Council shall issue:

(i) a decision declaring the economic concentration incompatible with a normal competition environment, as it raises significant obstacles to effective competition on the Romanian market or a part thereof (in particular by creating or consolidating a dominant position);

(ii) a decision authorizing the economic concentration;

(iii) a conditional authorization decision establishing the obligations and/or conditions of the concerned parties aimed at ensuring the compliance of the parties with the commitments assumed.

Should the Competition Council not adopt a decision within the said timeframe, the economic concentration can be implemented.

Should the notification form of an economic concentration require additional information, the deadlines mentioned above are deemed to commence when the parties have provided the Competition Council with all the required information in view of completing the notification.

2.3.2 Can the statutory timetable/deadlines be suspended ("stop-the-clock"), and if so under which conditions?

If the Supreme Council for National Defense informs the Competition Council that an economic concentration may raise risks for national safety, the deadlines mentioned under 2.3.1 above are suspended from the date of such communication.

The suspension lapses at the date of the communication by the Supreme Council for National Defense of the decision prohibiting such operation or the date of the decision establishing that such operation does not raise any risks. 

2.3.3 If pre-notification with the relevant authorities contact is possible/customary, how long will the duration of such contact usually be?

The Competition Council recommends that such contacts be initiated at least two weeks before the proposed filing date of the simplified procedure. At least five days prior to the meeting, the parties should submit an agenda and all requisite information to enable useful and efficient consultation. Such information is to include at the very least: the parties involved in the concentration, the markets on which the parties are active and the relevant market shares on such markets as well as a summary of the concentration and the manner in which control is exerted.

3. Format and content of notification

3.1 Notification forms

3.1.1 Must the notifying parties use any mandatory notification forms, e.g. for simplified and normal procedures, and, if relevant, add a link to the relevant forms?

The Competition Council has mandatory forms in place for both the simplified and the normal procedures, as per the Merger Control Regulation.

The above mentioned legal enactment is available in Romanian on the website of the Competition Council at http://www.consiliulconcurentei.ro/uploads/docs/items/bucket12/id12844/ordin_nr_431_2017_reg_conc_econ.pdf. Enactments published on the website may not always be fully updated.

3.2 Supporting documentation

3.2.1 List of the supporting documentation which must as a minimum be submitted along with the notification?

Cf. checklist below.

3.3 Originals, legalization and apostillation (cf. checklist below)

3.3.1 List of all documents which must be submitted in original/legalized versions and whether any documents must be apostilled?

All supporting documents should be submitted in original or as certified copies along with the notification, while certain translations should also bear an apostille. For more details on this latter aspect please see section 3.4.2 below.

3.3.2 If the merger regime has a mandatory filing deadline, must all the documents identified under Section 3.3.1 be submitted within this deadline?

Not applicable.

3.4 Language

3.4.1 Which languages may be used for drafting and filing a notification?

The notification is to be drafted in Romanian.

3.4.2 Does translations have to be certified/legalized and apostilled?

Should any of the supporting documents be drafted in a foreign language, authorized translations thereof should be submitted as well. If there are signed documents, the translation thereof should be apostilled as well.

Statutory timetable

Step Description Time
1

Pre-notification

Pre-notification contact with the Competition Council is not mandatory, but it is strongly encouraged in practice, even in straightforward cases.

Prior to the meeting, the parties should submit an agenda and all requisite information to enable useful and efficient consultation. Such information is to include at the very least: the parties involved in the concentration, the markets on which the parties are active and the relevant market shares on such markets as well as a summary of the concentration and the manner in which control is exerted.

The Competition Council recommends that such contacts be initiated at least 2 weeks before the proposed filing date of the simplified procedure.

At least 5 days prior to the meeting, the parties should submit an agenda and all requisite information.

2

Notification phase

A form and supporting documents, as well as proof of payment of the notification fee, are filed. 

Aafter all relevant information is gathered, the notification becomes “effective” (i.e. the formal assessment stage can commence) and the notifying party(ies) are informed in writing of the date when the notification has become effective.

Within 7 days as of the filing, the notifying party is informed whether the form is validly filed.

Within 20 days as of the filing, the Competition Council may issue requests for information.

3

Formal assessment - Phase I

The Competition Council issues a decision which can be either a non-objection decision (if there are no competition concerns or if such concerns were removed via commitments offered by the acquirer) or a decision to open an in-depth investigation.

Within 30 days from the receipt of a complete notification form, the Competition Council shall inform the notifying parties in writing in case the economic concentration does not fall within the scope of the competition law.

When the transaction does fall within the scope of the competition law, the Competition Council shall issue a non-objection decision within 45 days from the receipt of a complete notification when:

(i) there are no serious concerns regarding the compatibility with a normal competition environment; or

(ii) there are serious concerns regarding the compatibility with a normal competition environment but the concerns have been relieved based on the commitments assumed by the concerned parties.

The Competition Council is to decide the commencement of an investigation (phase II assessment) within 45 days from the receipt of a complete notification form, when it considers that the economic concentration raises serious concerns as regards its compatibility with a normal competition environment (and such concerns have not been relieved via binding commitments as described above).

Please be aware that "stop-the-clock" is possible (cf. 2.3.2 above).

4

Formal assessment - Phase II

The Competition Council decides to commence an investigation after Phase I.

Tacit approval of a concentration occurs if the Competition Council does not adopt any decision in the prescribed deadlines, and there is no regulated suspension mechanism.

In maximum 5 months from the receipt of a complete notification the Competition Council shall issue:

(i) a decision declaring the economic concentration incompatible with a normal competition environment, as it raises significant obstacles to effective competition on the Romanian market or a part thereof (in particular by creating or consolidating a dominant position);

(ii) a decision authorizing the economic concentration;

(iii) a conditional authorization decision establishing the obligations and/or conditions of the concerned parties aimed at ensuring the compliance of the parties with the commitments assumed.

Should the Competition Council not adopt a decision within the said timeframe, the economic concentration can be implemented.

Should the notification form of an economic concentration require additional information, the deadlines mentioned above are deemed to commence when the parties have provided the Competition Council with all the required information in view of completing the notification.

Please be aware that "stop-the-clock" is possible (cf. 2.3.2 above).

  • Step 1 1
  • Step 2 2
  • Step 3 3
  • Step 4 4
  • > 2 weeks
  • 7 - 20 days
  • 30 - 45 days
  • < 5 months (from Step 2)

Checklist

List of the supporting documentation which must as a minimum be submitted along with the notification.

Supporting documentation

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