Why France has opted for an online system for the annual reporting of HNS
Posted: 24/06/2020
By: Ministère de la Transition écologique et solidaire
Question:
When implementing the International Convention on Liability and Compensation for Damage in Connection with the Carriage of Hazardous and Noxious Substances by Sea, 2010 (HNS Convention) in a State, what questions should the relevant administration or department responsible for the Convention consider in terms of the practical aspects of annual reporting, and, how can reporting be carried out online?
Article 21, paragraph 2 of the Convention provides that each State Party shall communicate to the Director ‘the name and address of any person who […] is liable to pay contributions […], as well as data on the relevant quantities of contributing cargo for which such a person is liable to contribute in respect of the preceding calendar year.’
So, which reporting system should be adopted?
Answer:
Early on in the process of implementing the Convention in France, the question of the practicalities of reporting arose. In many countries, the State limits the administrative burden on businesses and endeavours to make as many administrative processes as possible directly available on the internet, be it for consulting relevant regulations, downloading standard forms, or accessing online reporting services which enable individuals and businesses to submit reports at any time with maximum ease and security in terms of data processing and protection. 
Offering online processes facilitates the work of businesses and reduces their administrative burden. The State also benefits as a result, as this type of system improves the quality of reports and can increase the number of submitted reports if businesses have access to a rapid and efficient system.
In France, 2020 is the year for implementing the HNS Convention (not including ratification). Indeed, a law passed 26 December 2019 established the principle of ‘receivers reporting annually’ and an order published 27 May 2020 set out the methods for reporting. To facilitate the task for businesses, it was decided to immediately establish an online reporting system.
HNS reports can be submitted on a platform which enables administrative processes of any type to be paperless (e.g passports, driving licences, reports from businesses, etc.) and which is already well known in France. This platform is provided by a service which is common to all ministries. This service allows administrations to offer paperless administrative processes and allows the public to complete those processes online and to share the compiling of their cases with whomever they choose. It also allows administrations to examine cases with options to follow-up on cases and to engage in dialogue with the users of the service. A summary dashboard facilitates the work of administrations in tracking the number of administrative processes that have been undertaken.
In particular, administrations are able to create the online processes themselves by writing the text and creating the data fields to be completed or the documents that need uploading/downloading.
Access to the system is secured by a tool known as ‘FranceConnect’ which enables users to sign in. The system ‘FranceConnect’ uses an existing ID chosen by users. For example, for businesses, it could be a tax ID or a social security number for individuals.
The benefit of this system is twofold: it spares the users from having to create a new user account and from switching from one account to another, and it enables administrations to authenticate reporting users by matching them with an existing and secure database.
By choosing a platform that already exists at the State level, the department responsible for the HNS Convention has incurred no expense in the creation of its own reporting system. There are no annual maintenance costs either and the platform benefits from a comprehensive service to prevent cyber-attacks.
Links to website:
https://www.demarches-simplifiees.fr/commencer/declaration-snpd
Link to the presentation page on the Ministère de la Transition écologique et solidaire website.