A clock that starts when the file is complete

Letter from the table

To the Red Tape Council,

I support the Small Business Impact Standard, and I ask that it be amended before it advances. The principle is right: a small business should not have to guess how long a permit will take, or spend weeks discovering that one office is waiting for a paper another office already holds. But the standard must work with the procedures that exist, and distinguish a missed administrative deadline from permission to do something that may affect other people’s safety or rights.

My case is from Verona. On 4 May 2026, I submitted a request through the municipality’s online service for temporary occupation of a small section of pavement, needed for scheduled work at my premises. I was not seeking a permanent change, nor asking to close the street. I attached the location plan, dates, dimensions and the information requested about keeping a safe passage for pedestrians.

On 19 May I received a request for an additional drawing showing the arrangement from another angle. I commissioned it and uploaded it on 26 May. The request did not tell me whether the file was now complete, what the expected decision date was, or whether another office still had to review it. I called and wrote through the portal. I was not trying to hurry anyone past a safety check. I needed to know whether to confirm the work date or move it.

On 8 June I was told that the request was still being assessed. The authorization arrived on 3 July. The work could then be rearranged, but not on the original date. I paid €240 for the revised technical drawing, €96 for additional transport and storage, and about €410 in costs from

rescheduling people and equipment. These are my own costs, not a claim that each euro was caused by the municipality. The larger burden was the uncertainty: I had to keep money available and postpone other decisions without knowing whether the application was complete.

In Italy, occupation of public road space requires prior authorization under the applicable road rules. A business filing under the SCIA procedure does not, by itself, provide that authorization. The SUAP, established as a single point of contact for business-related procedures, is an important model, but it does not mean every municipal permission is issued through one desk or that every kind of application can be treated alike. The Standard should therefore require coordination and visibility across the process, not assume a single portal already has authority over every step.

I also support a published service time, with an amendment: the clock should have a clear start date. It should start when the application is complete, and the applicant should receive a dated notice identifying any missing item. If the office later finds another necessary item, it should explain why it could not reasonably have been identified earlier. The clock may pause while the applicant supplies that item, but the pause and restart dates should be visible in the same record. This would help both sides distinguish a genuine incomplete application from a file simply waiting in a queue.

A one-stop process should mean one application record and one place to follow its progress, even where more than one office must give an opinion. It should show:

• the office or offices responsible for the next step, without requiring the applicant to find them independently;
• the published service time and the date it is expected to end;
• any request for further information, the reason for it, and its effect on the clock; and
• a contact point for a status inquiry or escalation when the stated time passes.

Finally, I support a silence-is-consent deadline only with a legal and safety test built into the Standard. Article 20 of Law 241/1990 provides for silence-assent in some administrative procedures, but it has exceptions; it is not a universal rule that every uncompleted application must become an approval. The Council should ask each adopting authority to list which low-risk permits may lawfully use that mechanism, and which require an express decision. Where silence cannot lawfully create consent, the deadline should still trigger a written status notice and a prompt review by a responsible official. That is not the same as approval, but it prevents silence from becoming an invisible and indefinite outcome.

For my application, the useful change would not have been an automatic yes. It would have been one record showing that the drawing was requested, confirmation that the revised file was complete, and a reliable date for the decision. If a safety review required more time, I could have planned around that. If no further review was needed, a published deadline would have helped the administration as well as me.