Consultation response: Staff ledger and identification number with impact assessment
The referral was received from the Swedish Tax Agency
Since 2007, traders in certain sectors have been obliged to keep a personnel register. On April 1, 2013, the legislation was extended to include the laundry industry. Constitutional amendments that will enter into force on January 1, 2016 will also cover the construction industry. For the construction industry, unlike other industries, the personnel register will be kept electronically.
The Swedish Tax Agency's proposed regulations on personnel ledgers and on identification numbers for a construction site constitute implementing regulations for the rules on personnel ledgers in the Tax Procedure Act and the Tax Procedure Ordinance.
In the regulation, the Swedish Tax Agency proposes that an identification number in accordance with Chapter 2, section 2a, first paragraph of the Tax Procedure Ordinance (2011:1261) for a construction site shall consist of 13 alphanumeric characters in the format A-Z and 0-9.
IT&Telecom companies' response to the consultation
The proposal is based on a solution with a single personnel register for which the developer is responsible and individual personnel registers to be kept by each subcontractor. These should be able to communicate with each other. The developer will be obliged to provide individual personnel registers.
In the absence of clarity on how communication between the collective and individual personnel files will take place and defined interfaces, the proposal risks not working as intended, e.g. personnel files that cannot communicate and incomplete information.
IT&Telekomföretagen therefore recommends that the proposal be amended so that the collective staff register only records which subcontractors are present at the workplace. This will eliminate problems with interfaces and incompatibilities between systems.