Business to business recommendations summary
Commonwealth business-to-business connectivity cluster co-chairs: International Chamber of Commerce (UK), COMSEA Business Council


The 2019 Commonwealth Trade Ministers Meeting recognised Ministers’ desire for private sector input into modern policy challenges facing Commonwealth trade and investment.

The 2nd Meeting of the Commonwealth Connectivity Agenda’s (CCA) Business-to- Business Connectivity Cluster in 2020 agreed that sustained dialogue and collaboration with the private sector be established to co-develop practical solutions to overcome policy impediments affecting the Commonwealth business environment.

The Meeting agreed the following areas must be built on to improve competitiveness, strengthen private sector engagement, improve market access, and reduce the costs of trade across the Commonwealth:

  • Require digital export documentation be provided in an electronic format.
  • Accept digital import documentation across all government departments.
  • Adopt electronic transferable records/adopt UNCITRAL Model Law on Electronic Transferrable Records.
  • Accelerate single window and digitised customised initiatives to remove red tape and speed up cross-border trade in goods.
  • Improve digital skills, particular for women-owned business, through Commonwealth mechanisms.

Four recommendations that advance these outcomes, address modern trade and investment challenges in the Commonwealth, and respond to post-Covid-19 realities have thus been co-developed with private sector  associations in the B2B Cluster of the Connectivity Agenda: namely the International Chamber of Commerce (UK) and COMESA Business Council.


RECOMMENDATION 1: Increase acceptance of digital import and export documentation and align domestic legal frameworks to UNCITRAL Model Law on Electronic Transferrable Records (MLETR)

Digitising trade relies on the efficient exchange of digital import and export documentation, as well as ensuring digital documentation enjoys the same legal recognition and effect as traditional paper documentation.

However significant barriers remain to the acceptance of digital documentation by national authorities in many Commonwealth countries and are a hindrance to advancing digitised trade.

Reduce barriers to acceptance of digital import and export documentation

Joint private sector working groups should be established and led by domestic law commissions, private sector legal experts, and international business organisations such as the International Chamber of Commerce to assist Commonwealth member governments in reviewing legal structures, identifying barriers, and establishing international equivalence for digital documentation.

The Commonwealth Secretariat can play a convening and coordinating role in the process.


The working groups should assist member governments in identifying barriers to aligning their legal frameworks to UNCITRAL’s MLETR and to start the process of preparing for legislation change.

They would be responsible for identifying and discussing barriers to alignment with MLETR and making practical recommendations to remove them.

This will assist Commonwealth member governments in reviewing national legislation and identifying how to best align with MLETR. Doing so would lead to aligned legal frameworks across the Commonwealth, thereby strengthening the ‘Commonwealth Advantage’ by enhancing digital connectivity and reducing barriers to trade and investment.

The Covid-19 pandemic necessitates the need to digitise faster. Giving electronic documents legal force by adopting the MLETR is a crucial step in facilitating paperless and digital trade in the post-pandemic period.

This recommendation builds on the agreed outcomes of the 2nd Meeting of the Business to Business Connectivity Cluster: “Requiring digital export documentation to be provided in electronic format” and “accepting digital import documentation across all government departments”, as well as “Adopting electronic transferrable records – adopt UNCITRAL Model Law on Electronic Transferable Records”.


RECOMMENDATION 2: Advance single window interoperability across the Commonwealth through experience sharing and best practice learnings

Trade facilitation reform is both a
digital opportunity and a coordination challenge. Sharing experiences around the  development of national single windows and in particular the challenges of interoperability will promote pan- Commonwealth best practice learnings and advance discussions around facilitation of interoperable single windows.

It will also improve the quality of cooperation and information exchange among various government agencies, customs departments and border control posts. Considering the demand for technical assistance in establishing single windows across the Commonwealth, this may also assist in establishing systems that are interoperable from the start.

The Commonwealth Secretariat can consult with representatives from trade departments and customs agencies across the Commonwealth to determine the most useful avenue for sharing experiences on single window interoperability through the B2B Connectivity Cluster.

The outcomes of these consultations can be collated into a report that outlines preferred approaches to best practice information sharing on single window interoperability. This can then form the foundation of future work that facilitates interoperability.

This builds on the agreed outcome of the 2nd Meeting of the Business to Business Connectivity Cluster: “Accelerating single window and digitised customs initiatives to remove red tape and speed up cross-border trade in goods”.


RECOMMENDATION 3: Build the digital literacy and skills of Commonwealth policymakers to deploy paperless trade, particularly focusing on supporting MSMEs and marginalised groups

As the Covid-19 pandemic accelerates the shift to a more digitised world, the increased use of ICT systems to enable businesses and traders to submit and process documents and payments electronically, or to automate more processes and procedures, increases the demand for digital skills training and development.

It is essential that policymakers across the Commonwealth are digitally literate and equipped
with adequate knowledge and skillsets to deploy paperless trade. This includes understanding the digital shifts taking place, what impact these shifts are having on business needs, and understanding how to utilise new digital tools.

A particular focus should be placed on government’s ability to support MSMEs and marginalised groups in an increasingly digitised world, considering their more acute challenges in accessing appropriate support and digital capacity development opportunities.

Partnerships with international organisations and initiatives such as Decent Jobs for Youth can be established to lead consultations with policymakers with responsibilities for these issues (skills, development, youth, women) from across the Commonwealth to discuss and share experiences and learnings relevant to capacity building for paperless trade.

The consultations should also involve leading members of the business community from across the Commonwealth, organised by private sector organisations such as the International Chamber of Commerce and COMESA Business Council, to ensure market-relevant skills are reflected and emphasised in the consultations.

The Commonwealth Secretariat can play a convening and coordinating role in this process, with the ultimate goal of building the skills of policymakers to deploy paperless trade.

This builds on the agreed outcome of the 2nd Meeting of the Business to Business Connectivity Cluster: “Improving digital skills, particularly for women-owned businesses, through Commonwealth mechanisms”.


RECOMMENDATION 4: Provide Commonwealth support to international mechanisms to facilitate equitable access to vaccines for developing, least developed and small island states

Safe and effective Covid-19 vaccines have been developed in record time, however the vast majority of doses have been administered in upper and middle-income developed countries.

This pandemic will not be over anywhere until it is over everywhere. Developing, least-developed and small island states must enjoy equitable access to Covid-19 vaccines to protect the gains achieved in developed countries, ensure that the world’s poorest and most vulnerable people have equal access to protection against the virus, and to guard against the emergence of new variants of concern.

The Commonwealth can support international mechanisms to facilitate and improve vaccine access and distribution across Commonwealth member states, especially LDCs and SIDS.

As of October 2021, 62% of Commonwealth’s 2.6 billion people remain unvaccinated while just 18.5% of the Commonwealth population are fully vaccinated, concentrated in high-income economies.

The global economy stands to lose up to USD 9.2 trillion if governments fail to ensure developed economy access to Covid-19 vaccines, according to a study commissioned by the International Chamber of Commerce (ICC) Research Foundation.


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