Guidebook tions with the public, stakeholders and experts. Subsequently, Green and White papers might be adopted. The purpose of these papers is to launch a debate with the public, stakeholders, the Parliament and the Council in order to facilitate a political consensus. Moreover, the Commission carries out an impact assessment to analyse the direct and indirect implications of a proposed measure that again can build up on reports and assessments of experts.338 Particularly efficient in this sense, may be joint opinions submitted by groups of NHRIs or through NHRIs networks. The Parliament, the Council or a million citizen can invite the Commission to submit a legislative proposal. Thus, the tool to submit a petition to the European Parliament could also be considered by NHRIs. They can – as every natural or legal person in the EU – submit a petition to the European Parliament. For example, it can have the form of a complaint, a request or an observation concerning problems related to the application of EU law or an appeal to the European Parliament to adopt a position on a specific matter.339 3.5.2. Engaging in the national transposition and implementation process of EU instruments EU law requires the Member States to transpose the Directives in their national laws but also to introduce regulations and other measures that ensure that the provisions are complied with in domestic law.340 Moreover, apart from the legal transposition process also the practical implementation of the provisions enshrined in the Directives should be assessed. Given their role and powers NHRIs could not only make sure that EU Directives are correctly transposed and implemented by the Member State but also monitor that the procedural safeguards set up in the relevant legislation are applied effectively in practice (see Chapters 3.3, 4 and 5). WAYS TO PROMOTE CHANGE 3.5.3. Engaging in the infringement procedure The Commission identifies possible infringements of EU law against a Member State either on the basis of its own investigations or following complaints or petitions from citizens, members of the public, businesses, NGOs or other organisations. NHRIs can – as any natural or legal person – file such a complaint with the European Commission.342 This might be a useful tool if a country faces challenges in the field of rule of law and cannot rely on the national procedures to strengthen human rights. For the concrete Procedure:343 »» Anyone can file a complaint with the Commission free of charge. »» A complaint cannot be filed anonymously. »» Complainants do not have to demonstrate a formal interest in brining proceedings. The NHRI does not have to prove that they are principally and directly concerned by the infringement complained about. »» Once a complaint has been submitted to the Commission the a pplicant (i.e. NHRI) NHRI will lose control over the case. The Commission decides whether or not further actions should be taken on the complaint. Thus, it is essential to prepare complaints that are solidly documented, highlighting patterns of conduct rather than mere anecdotal evidence based on a small handful of individual cases. Slovenia The Ombudsperson has been involved in the 2014 amendment of the criminal Procedure Act, transposing the EU Directives concerning the right to information and right to translation and interpretation. Further, the Ombudsperson under the NPM mandate, cooperated with the Ministry of Interior when adapting the forms related to arrest and police detention to ensure proper implementation.341 80 81