A deadline must not become a blindfold

Letter from the table · RC/RT/2026/T.5

To the Red Tape Council,

I support the Small Business Impact Standard. I also want to warn you about one part of it: a deadline for silence to count as consent must not turn into a blindfold. A deadline can protect a small business from being left in limbo. It can also create a false sense of permission if the application touches safety, accessibility, or a protected building.

In March last year, I applied for permission to put a modest sign outside the rented premises where I work in Verona. The sign was not large, and I wanted it to be visible from the street without changing the building. I submitted the application through the Comune’s designated digital channel for business-related procedures, which routes relevant matters through the SUAP, the one-stop shop for productive activities. I expected that the process might involve more than one office. What I could not tell was which office had the file, what it still needed, or when I should expect an answer.

I filed on 3 March. The receipt confirmed that the documents had arrived, but it did not give me a service time. On 18 March, I received a request for a clearer drawing and confirmation from the property owner. I sent both on 20 March. I also asked whether the sign’s position meant that another technical or heritage review was needed. The reply told me that the question had been passed on. It did not tell me who would answer or by when.

That distinction mattered. Verona has historic buildings, and the rules for work affecting a protected building are not the same as the rules for a routine business form. I did not want to assume that a lack of response meant permission to install something that might require further review. Nor could I afford to keep paying for uncertainty. I held the work, followed up, and paid for another drawing after being asked to clarify the proposal. The direct cost of the drawings and application-related preparation came to

about €640. While I waited, I also paid €900 a month in rent for premises I was trying to make easier to find.

On 7 May, I sent a concise follow-up with the earlier receipt and the date I had supplied the missing documents. I asked for either a decision or a list of the remaining steps. I received a response acknowledging the follow-up, but not a completion date. The authorization arrived on 12 June. In the end, I could proceed. The sign itself was not the hardest part. The hard part was not knowing whether I was waiting for a routine check, a missing document, or an issue that required a different authority to decide.

This is why I support the Council’s proposed direction. A small-business impact test could ask a practical question before a new rule or process is imposed: can a person working alone understand what to submit, where to submit it, what it will cost, and how long the answer should take? A one-stop digital process should mean more than one website. It should give the applicant one file reference, show which office currently has responsibility, and make it clear when a submission is incomplete. Published service times would let an owner plan rather than guess.

But I ask the Council to define the silence rule carefully. If an application is complete, the relevant authority has received it, and the matter is suitable for a time-limited decision, a missed deadline should have a consequence. Otherwise the clock is only decoration. Where a decision may affect public safety, access for others, or a protected building, the consequence should not be automatic permission to act. It should instead be a required escalation: a named office must explain the delay, identify the outstanding check, and give a firm next date. The small business should not carry the cost of an office failing to coordinate, but neither should neighbours or the public be left with an unsafe or unlawful outcome.

I am not asking for a separate rule for every street or every permit. I am asking for a process that distinguishes between a delay that can fairly be resolved by a deadline and a case that needs a reasoned decision. The application should say which kind it is, and the service-time clock should be visible from the start. If the authority needs information from another office, that should be part of its own coordination, not a mystery the applicant has to solve by sending repeated messages.