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The European Union’s project for ENP South Countries EUROPEAID/133918/C/SER/MULTI This project is financed By the European Union A project implemented by GIZ IS and Eurecna Enhancement of the Business Environment in the Southern Mediterranean National Seminar for Israel « E-Government for Businesses » Principle 4 of the Small Business Act for Europe Jerusalem, 17-18 September 2014

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The European Union’s project for ENP South Countries EUROPEAID/133918/C/SER/MULTI

This project is financed

By the European Union

A project implemented by

GIZ IS and Eurecna

Enhancement of the Business Environment in the Southern Mediterranean

National Seminar for Israel

« E-Government for Businesses »

Principle 4 of the Small Business Act for Europe

Jerusalem, 17-18 September 2014

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Disclaimer

This report has been prepared with financial assistance from the European Commission. The opinions expressed herein are those of the authors and may not represent the position of the Commission.

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TABLE OF CONTENT

1. INTRODUCTION ............................................................................................................. 2

2. SEMINAR OBJECTIVES .................................................................................................. 2

3. PARTICIPANTS ............................................................................................................. 3

4. SEMINAR SUMMARY/OVERVIEW .................................................................................... 3

5. SEMINAR SUMMARY ..................................................................................................... 7

6. RECOMMENDATIONS ..................................................................................................... 9

7. CONCLUDING REMARKS ............................................................................................. 11

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1. Introduction

A high level seminar entitled “Efficient e-Government for Competitive Enterprises” was organised on 17-18 September 2014 in Jerusalem, Israel, in the framework of the “Enhancement of the Business Environment in the Southern Mediterranean”, a 3-year project funded by the European Union (€3 million) which aims to promote SMEs in the Southern Mediterranean region. The seminar was organised to support the Israeli Government in implementing reforms in priority areas identified in the report “SME Policy Index: The Mediterranean Middle East and North Africa 2014, Implementation of the Small Business Act for Europe”. The report assessed SME policies in Israel and eight other economies in the Mediterranean region and provided policy recommendations to Governments to help unleash the potential of their SMEs. The assessment, conducted in the framework of the Euro-Mediterranean industrial co-operation process, was based on the “Small Business Act” for Europe (SBA), a comprehensive SME policy framework adopted by the EU to promote SMEs. With a view to improving the implementation of the Charter and its alignment to the SBA, in particular its principle 4 " Make public administration responsive to SME needs," the seminar program focused on two themes: 1) Designing a Strategy for e-Government and 2) Building an Action Plan: from Design to Implementation. The workshop was opened by Mr Ran Kiviti, Manager of the Small and Medium Business Agency, Mr Raz Heiferman, Acting Government CIO and Shared Services Division Manager and Mr Luigi Pratolongo, Head of the Trade Section of the EU Delegation to Israel. This event brought together top-level policy makers, representatives from public authorities and business associations, thought leaders to discuss ways of using ICT tools to reduce administrative burdens and improve service delivery to businesses. Drawing on practical experience of selected EU countries in designing and implementing action plans for e-Government it examined questions such as whether the goal of reducing administrative burdens is sufficient in itself for e-Government to transform public administrations. Further, how can the public sector build partnerships across levels of government to deliver ICT-enabled end-to-end services that simplify the relationship with businesses? Where Israel stands in comparison with more advanced e-Government systems such as those implemented in EU countries such as the Netherlands, the UK, Finland, Denmark and France that are at the forefront of administrative burden reduction, bureaucracy reduction, red tapes cutting, which are a major political priority and an important justification for e-Government development?

2. Seminar Objectives

The overall objective of this seminar was to enhance participant’s capacity to implement the

Small Business Act for Europe, in particular its principle 4 “Make public administration

responsive to SME needs” on a more informed basis.

More specifically, the key objectives of this seminar were to:

Introduce the best EU e-Government practices and experiences to Israel towards

further development of its e-Government frameworks;

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Overview the e-Government achievements of Israel and areas for enhancement, and share best practices and lessons learned from selected EU countries;

Strengthen skills to design and implement e-Government policies policies drawing on selected EU countries experiences;

Promote an interactive dialogue between different players in order to feed policy making process.

3. Participants

The seminar gathered 45 participants, including high state officials, representatives from public authorities and business associations to discuss ways of using ICT tools to reduce administrative burdens and improve service delivery to businesses, rather than pursuing e-Government as an end in itself. The majority of the attendees (78%) were from the public sector (e.g. Prime Minister office, Ministry of Economy, Ministry of environmental protection, Small and Medium Business Agency, Digital Israel unit, eGov unit, etc.) The private sector (22%) was represented mostly by consultants with only two identified business sector representatives (4%). In terms of professional background, the majority of attendees – according both to the position declared and the content of their speech – seem to belong to the IT word. The team of European experts really appreciated the quality of the views expressed by the seminar attendees. However, taking into account the very topic of this seminar “Efficient e-Government for Competitive Enterprises”, the audience could have been better balanced with a better representation of the private sector.

4. Seminar Summary/Overview

During the two days of seminar, fruitful discussions took place and the audience showed a great interest throughout the seminar. Every presentation was followed by a session of questions/answers; the majority of questions asked by the participants were mainly technical or organisational in nature. A recurring concern was how to structure the information flows between organisations, but many other topics related to the e-Government area were also discussed. 4.1 Topics discussed Day 1: Designing a Strategy for e-Government for Businesses

4.1.1. Approach and Strategy - New developments

The opening presentation was dedicated to set the scene for the seminar and the presentations to follow. Key take-ways presented were that e-Government services should enable businesses to grow, cut costs for administrations and in general foster a climate where the public and private sector work together to improve the life of citizens and businesses. The ability to tap into and harvest the huge potential of ICT constitutes an important corner stone in an e-Gov strategy. Some of challenges that need to be addressed are Integrity, the potential over use of monitoring capabilities, availability, E-Id, Governance and Legal aspects. Based on the Case Studies presented, this session concluded that the potential success of e-Gov efforts entails focusing on bringing many different organizations and individual success factors together at the right time. But a successful e-Gov strategy might also create huge benefits at many levels when successfully implemented and executed.

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4.1.2. Why a programme for reducing administrative burdens for businesses?

Administrative burden reduction and e-Government in the context of better services for businesses are high on the agenda in Europe. This session presented key findings from a recent study1 the Danish Technological Institute recently undertook for the European Commission in partnership with Ernst & Young. The study looked into 1) models for administrative burden reduction and e-Government and key elements of the policy context; 2) aggregate and calculate potential savings across Europe; 3) develop & consult on potential elements for a roadmap.

Consistent cost benefit analysis across Europe, in fact also within the national context, is very difficult when it comes to administrative burden reduction. But the study shows that there is significant room for savings across Europe (and other studies have come to similar conclusions). The potential advantages that might be achieved not only include cost reductions but also benefits through regulatory reform, simplification and making processes easier and putting the user first. What does this mean for Israel? The “once only” principle is one of three digital strategies to seriously consider to ease burden on businesses and to provide better services. The others are personalisation and simplification strategies as well as “digital by default” strategies. To be able to deliver administrative burden reduction for businesses however, this session concluded that strong inter-ministerial leadership is needed, supported by measurement and ICT solutions.

4.1.3. A quick approach to set a G2B methodology

Setting up an electronic government for businesses means pushing for collaboration between three actors with three different professional cultures: civil servants, entrepreneurs and IT specialists. The most important objective should be to define priorities considered as common to all stakeholders, despite the different immediate interests of each of them. To establish a policy serving interests of both parties in a government-to-business (G2B) scenario (i.e. administration and business), finding common objectives expressed in a common language and based on common reference tools are needed. This session aimed at providing an immediate understanding of the main problems encountered when designing a G2B policy in the larger frame of electronic government. It focused on practical E-Gov aspects regarding mostly enterprises, big or smaller. It proposed a practical methodology to quickly set G2B outlines: what with to start and how not to miss the most important moments taking into account both the administration interests and the business ones.

4.1.4. Electronic Government in the Netherlands

According to the UN survey (2012), the Netherlands is one of the leading e-Government countries, which is why this session presented an overview of key elements of the Dutch approach the Israeli government could learn from. The Netherlands currently have a dual focus strategy: high focus on electronic government with attention on the back-office and the savings which can be made there, combined with focus on the digital highway or the “excellent shared infrastructure”. This is a process optimisation focus – looking both at service delivery optimisation and creating benefits for the user. At the same time the Netherlands are focusing on collaborative governance: In their integrated strategy the “compact central government” cooperates with other governance actors through the

1 The report is available here: http://ec.europa.eu/digital-agenda/en/news/final-report-study-

egovernment-and-reduction-administrative-burden-smart-20120061

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“clustering [of resources] at decentralised level” to address needs and challenges at each level. This requires systems harmonisation, standardisation and the sharing and re-use of resources. Much remains a future goal, but is already leading to the re-use of data, infrastructure, service elements, etc. This session presented four key success factors from the Dutch e-Government approach: 1) the integrated strategy (iNUP); 2) examples of institutional collaboration (ICTU); 3) the Administrative Burden Watchdog; and 4) the common building blocks approach: base registries and a successful specific e-Government Business service (SBR).

4.1.5. Digital Marketplace (UK) - The G-Cloud and Digital Service Frameworks

The G-Cloud Initiative in the UK was launched to cut costs for public sector ICT investments. To achieve this, the use of Cloud Computing based services is promoted and the use of SME’s services in the public space encouraged. Programs such as Digital First and new legislation to simplify and change the Procurement frameworks were launched in order to support the G-Cloud effort. So far the G-Cloud has created a significant increase in number of procurement of SME based services as well as significantly lowering the ICT costs for public sector agencies. A key success factor has been the shift from “tailored solutions” to commodity based services. With over 17000 available services (2014), the G-Cloud program has met and exceeded the goals set for the program.

Day 2: Building an Action Plan: From Design to Implementation 4.1.6. Key steps in designing an Action Plan

The opening session of the second day focused on practical issues of an Action Plan, as contrast to the first day’s strategic and more general focus. It presented “The why, what and how’s” of an Action Plan design – key steps in designing Sustainable e-Government Action Plan, which opened three important discussions: 1) how to obtain and sustain political support for e-Government Action Plans and how to ensure the right supporting structures, 2) how to set SMART2 Objectives for communication and prioritisation and 3) role of e-policies and enabling laws.

4.1.7. Assessment of supply and demand for e-services – What could go wrong?

After the opening session on the second day of the workshop, a practical viewpoint with experiences from implementing e-services in the Danish and Norwegian governments was given. The presentation builds on concrete e-Services implemented and what impediments were discovered during the execution of the projects. The presentation led to a discussion about how governments, including the Israel government, are developing islands of e-Services, where each ministry is developing its own platforms, infrastructure and e-Services without an over-arching strategy for usage of common components, open source software, interoperable infrastructures etc.

4.1.8. Practical experience of Denmark

This session focused on the practical experience from Denmark. Through the history of e-Government strategies in Denmark since 2001 up until now, the Danish lessons learned were discussed with practical examples of the various citizen, business and health one-stop-portals in Denmark, where a “glass-plate” strategy has been applied to the various

2 SMART – Goals and/or requirements that are Specific, Measurable, Accurate or Approved, Realistic

and Timebound.

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government e-services, so that all communication with the public sector would be digitized by 2015 for businesses and 80% for the citizens also in 2015.

4.1.9. Practical experience of France in designing and implementing a G2B policy

The situation of France has dramatically changed over the past 10 years. From 25th world place in UN Survey for 2003 and 11th European rank in EU benchmark for 2009), France ranks in 2014 at 4th world place and 1st place in Europe (UN Survey). However, the cost of the administrative complexity represents 3 to 4% of GDP, according to OECD. The World Forum survey ranks France at 47th place for 2008 and 23rd for 2014. “Simplification” is an immediate priority and the new word in fashion to describe administrative reform. The understanding of electronic government has changed with years, following a path we encounter in many other countries. The starting point was a search for an improved efficiency of the state activity, i.e. a technical and internal approach of electronic governance (G2G). With time the approach logically included improvement in servicing the end users. From a granted e-Government progressively we moved to an agreed e-Government. During the next period, the successive governments discovered that e-Government does not bring only more efficiency, but is also a lever for the economy. Now it has been made evident, that electronic governance is as well a tool to boost and steer the economic growth. Moreover, the quality of e-Government becomes as an element of international competition not less important than the networking of a country with roads and railways or the quality and the cost of the workforce. The quality of a given e-Government represents now a significant part of competitiveness for a country. 4.1.10. Practical Experience from Finland

The Finnish e-Services and e-Democracy Action Programme (SADe, 2009 – 2015) was presented in this session. Finnish lesson’s learned were discussed, most important being the two level structure: top level – a programme for the whole government and bottom level – project for certain ministry and its e-services. There was a lot of interest to hear about Cyber Security experiences and ICT infrastructure consolidation Programme TORI (2011 – 2014) and the new Valtori-agency, too. The presentation included the Finnish e-Government organisation example, which nicely addressed questions raised the first seminar day including who the customer is and who should lead and in what areas of e-Gov? Finland has formulated a policy for financial arrangements of e-Government and shared infrastructure services that – set aside the financing of long term assets – all service development, implementation and running costs (including the depreciation of assets) should be paid by customer, i.e. the ministry, agency or regional/local authority who is responsible providing the service to citizens and enterprises.

4.2 Workshops and Round Table Discussions The workshops and round table discussions following the seminar presentations saw some recurring themes; marketing, organisational challenges, the need to share information across agencies and to make information available to the private sector, involving stakeholders and the need for Government to “stay relevant” by going “E” were among many of the topics covered in the seminar. General challenges, recognised by most participants in the seminar independent of country of origin, were subsequently for example overcoming organisational issues, finding the

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appropriate balance between security, integrity and privacy considerations3 on one hand and the need to share information, transparency and collaboration across organisations and sectors, on the other hand. In the Q&A and roundtable discussions the importance of linking accountability with visibility and transparency was underlined. As a spin off in the discussions related to information sharing the topics such as “information classification”, defining concepts (based on common conceptual models), standards (the use) and the importance of interoperability were all covered topics. The representation from the SME sector at the seminar was limited. On the first day of the seminar a representative raised concerns about the far from optimal business climate. As the representative stated: “The government – business environment in Israel has deteriorated over the last years”. This statement cannot of course be taken lightly. The G2B e-Services are obsolete and “correspond to the state of affairs reached in developed countries 15 years ago”. The complaint was about the lack of support from government to enterprises to become more competitive… which was namely the primary objective of this seminar. The low use of e-Commerce with a low number of on-line payment transactions is another issue area that also shows a huge potential. Some of the issues specific to Israel that were discussed during the Q&A and round-table sessions include:

Making government authorities share data that is needed to create e-Gov services (both in “ISP” and “ASP” scenarios) and to be published as OpenData.

Ensuring and fostering a well-functioning SME climate in which the public sector engages with the businesses to create opportunities using an e-Government strategy to provide relevant services to the private sector and also to enable businesses to flourish.

E-Government in Israel is clearly seen as an “in house service” – the pipes & tubes of government. Yet it was not clear whether there is sufficient openness, drive, initiative and strategy to transform government and to improve services for SMEs and businesses. With the move of e-Government into the PM office, Israel has a chance to launch an “outcome oriented” change strategy – “digital by default” – that could deliver better (and simpler) services and tap into the innovation potential of the local high tech industry.

Engaging the 260 local authorities in e-Gov and coming up with ways of doing this in a consistent and coherent way, given how different the local authorities are in terms of maturity, availability of resources and more. E-Government requires the government to think in a holistic way to be effective and produce efficiency.

Ensuring that common components and building blocks are widely adopted and utilized including;

- open source software from other leading e-Government countries, - increase the usage of a single digital e-Delivery infrastructure across

ministries, agencies and municipalities, - expand the usage of standardized payload and transactions through e-

Documents and semantic from organizations such as OASIS, CEN BII, ISO.

Making sure that e-Services are mandated through early legislation, a political and back-up and sanction by local, regional and national authorities, which will lead to better adoption and usage of the implemented e-services.

5. Seminar Summary

3 This particular consideration is sometimes referred to as ”digital footprint” and relates to concepts

such ”BYOD” (bring your own device) and the challenge of mixing personal and enteprise information across multiple devices, while retaining full security, full data and personal integrity/privacy and more.

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Despite an advanced ICT industry maturity, the seminar indicates that Israel needs to continue the efforts required in order to reach a sufficient level of exchange inside its e-Government, both in terms of data and of interconnection of services. The e-services are built on the basis of the data provided by one given administration (e.g. a ministry, an agency); and a good level of interactivity with the user can be reached. , there are, however, few interactions with other administrative entities to enrich a common fund. The first difficulty does not seem to be related to a lack of interoperability from a technical point of view (due to non-standardised formats), but from an organisational point of view (linked activities between administrative entities). Based on the Israeli presentations, it seems that some problems in framework of G2G brake down development of more effective G2C and G2B.

Below some of the seminary key points and recurring themes are presented. The lists include recommendations and considerations, as well as listed challenges and opportunities. Since a challenge typically involves a corresponding opportunity the listed entries that are assess as “challenges OR opportunities” have been labelled as “C/O”.

C/O: Making OpenData available

C/O: Exposing, creating and exploring incentives

C/O: Using Cloud Computing to offer public sector services (re Israel Private Cloud) and/or as the Procurement platform (re the UK G-Store offering)

C/O: Going from “vertical” to “horizontally” oriented organisations.

C/O: Supporting the network based landscape (“eco system” based)

C/O: Finding the right balance (in many different areas)

C/O: Changing the Procurement structure

C/O: Ensuring that Legal Frameworks are in sync with e-Gov efforts

C/O: Foster a good SME climate; engaging the SME market to foster an open, fair and competitive business domain

C/O: Providing Public-Private Partnerships

C/O: Integrating data and applications that come from different sources and that can be used across agencies

C/O: Sharing experiences to avoid reinventing the wheel

C/O: Making e-Gov Services go viral (adoption through marketing)

It is important that local authorities and central agencies collaborate. Aspects of this consideration include:

- Sharing information not only across agencies but also between public sector levels

(federal, regional, local) calls for close collaboration, understanding of key concepts

and terminology and common enterprise architecture. Utilising existing standards

where possible will reduce the need for unnecessary work and duplication.

- Differentiating between locally used services and those that can be used and shared

across different levels (local – regional – domestic – international) is necessary

- Differentiating between “classes” of services – those used within the public sector

(across agencies) and those provided by the public sector is important

Using standardized models for Life Cycle Management (LCM) and enterprise architectures (EA) will make the implementation of nation-wide e-Gov solutions less cumbersome

- The project management effort should however not be underestimated.

The widespread implementation of E-Gov typically results in changes in the business model and the way services are offered, enabling business to focus on the core business

R & D and innovation go hand in hand.

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E-Health: using technology creates huge opportunities but also demands handling resources wisely and to consider privacy aspects.

Israel: low on-line business (e-Commerce) penetration in Israel (only 2% of the business handle on-line payment). Huge potential.

Creating generic building blocks that form a “digital service infrastructure” (re e-SENS within the EU) might spur on the roll-out of reusable e-Gov services that can be further explored and used by the private sector.

Using standards and specifications to allow business to build and provide service based on specific guidelines and directives creates stability.

- Understanding and defining terminology & concepts is key aspect.

6. Recommendations

Israel is in the process of moving the CIO Office, e-Government and Shared Services units

from Ministry of Finance to Prime Minister’s Office (PMO). A Chief Digital Officer has been

appointed and Digital Israel Unit has been established in the PMO. These two national

officers CIO and CDO will work as peers. In this development it is very important to define

the roles of CIO and CDO so that they can work together successfully and even more

important to define policies pertinent to the following areas:

1) interaction with citizens, enterprises and other stakeholders; 2) governance; 3) ICT

management; 4) development; and 5) service procurement and provision, to and with other

ministries, agencies, regional and local authorities.

Horizontal knowledge sharing and structures are needed to connect authorities when

developing citizen and enterprise driven e-Government and supporting ICT.

As mentioned several times during the workshop by the different experts, the Israeli e-Government should find their own path instead of trying to replicate other nations’ action plans and e-services, as there are as many solutions to their impediments as there are e-services available, and not a single solution or e-service would be the silver-bullet solving everything. A wider usage of common components from existing e-Government service across the world is a step forward, but the Israeli e-Government need to assess how they can be adopted and made interoperable with the vast portfolio of existing e-services in Israel. The idea is not to replicate data, but to utilize data wherever it persists through OpenData initiatives. Furthermore an increased uptake and development of business-supported e-services must be put in place by the Israeli government, to foster growth and expansion of Israeli businesses. These e-services should encompass the various steps of the business life-cycle from creation of companies, taxation, e-Procurement and liquidation. Below is a list of recommendations based on the presentations, workshop result and round-table discussion (some of the entries might be seen as open-ended, but all should be regarded as recommendation in nature):

Successful e-Government requires focus on more than “just” technology, e.g. • Organization • Collaboration • Legislation • Adoption and marketing

Maturity models and evaluation / assessment frameworks are helpful

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Different classes of e-Gov services exist: • E-Gov Shared services (used by the Public Sector primarily) - G2G, ISP • E-Gov “Public services (used by the private sector and individual citizens) G2B,

G2C, ASP Categorizing classes of e-Gov services simplifies the planning, development and roll-out of e-Gov services according to a previously established e-Gov strategy and implementation plan. The plan should ultimately support prioritization, value creation and evaluation.

Action plans for G2B need to be aligned with the overarching e-Government strategy

Data privacy is a concern when providing OpenData and increasing transparency

E-Gov services provide an opportunity to act proactively

Making sure that information is made available and shared across organisations is a challenge, but also a key element to ensure e-Government success

Visions, policies and expectations should be managed, shared and commonly understood.

Communication & ensuring adoption through training is key

Making sure that the public sector organizational set-up provides the best possible ITC governance is crucial to ensure e-Gov success. This includes the clear definition of the CIO. The level of digitization Israel can reach will also depend on the empowerment of this role and associated inter-ministerial councils and steering groups.

Concretely what Israel should consider: 1. The point of view of the final user (i.e. civil servant, citizen, entrepreneur, etc.) has to be

taken into account. There is still a big step to take in linking project planning with administrative reengineering. The formulation of business processes is still a relative rarity, which means that there is little understanding that setting up e-Services is more than a question for IT people, but shall involve politicians, lawyers and representatives of the end-users in defining the final result expected before asking IT people to proceed according to terms of reference. We recommend:

Create teams which bring together staff responsible for administrative reform with IT specialists. This will help to better understand the role of e-services in the implementation of reforms.

Involve internal and external end users of e—services in their definition (civil servants and citizens)

Develop participative definition of goals before moving to implementation of compulsory instructions

2. The launch of every new e-Service must be supported by a solid promotion campaign.

The immediate objective is to convince the users of the utility of proposed online services. Notice that the users targeted are both internal AND external, i.e. civil servants at one end of the line and enterprises at the other end! The launch of services starts often without sufficient information of civil servants about the goals. Therefore the reactions of civil servants can be very formal, more in order to avoid reproaches than in order to realise something they cannot yet see the reasons for. We recommend:

The launch of the new wave of e-Gov actions in Israel should be preceded by an in-depth specific national training campaign for civil servants (more efficiency, better accountability...)

There could be a campaign for enterprises and citizens focusing on their participation in changes of society (more transparency, e-democracy, higher competitiveness...)

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3. The design of new e-Services must consider the disabled people from start. It is more cost effective to launch new services adapted to a large audience than to adapt them “ex-post” for a specific audience. Regarding the necessary adaptations for people with impaired vision, one shall consider that such eServices concern the majority of the population, not a minority of blind citizens, since with age all citizens notice a progressive deterioration of their vision. We recommend:

Adaptability standardised prerequisites for every new site or e-Service

4. Workshops, workgroups and work sessions about G2B shall involve more people from private sector, in particular from entrepreneurs’ side. We recommend:

Set up the list of the participants with business associations, chamber of commerce, trade and industry.

5. Finally, since there are two official languages in Israel and Hebrew is dominant, it is

advisable for all sites to provide information and e-Services in the two official languages to serve all citizens.

7. Concluding Remarks

Israel has a mature ICT environment including the national e-Government agency, where the different ministries have many abundant ideas and on-going programs to execute on the e-Gov strategy. Israel has already developed vast amount of e-services made available mainly to the citizens. It is clear that much have been done – but also that improvements can be made. Still, Israel is already well on its way to implementing a well-designed e-Government action plan with solid new initiatives that will only improve the already positive indications of a leading e-Government country. The issues and concerns uncovered during the seminar are in our view manageable and measures to address these issues would further strengthen the Israel e-Gov strategy and improve a public – private partnership that might significantly create additional benefits for the SME/SMB sector.

Based on the findings and discussions during the seminar, it is recommended that additional meetings are scheduled to allow for in-depth work on critical topics. The format for future meetings could be: 1) initial summary of previous seminar (based on this report); 2) break-out sessions / workshop based on previously determined topics agreed on.