In the discussion paper it is proposed to increase the amount of moduls using multiple choice questions (MCQ) and to introduce autocorrectable moduls. Apart from the questions if those tools to autocorrect such moduls are available, it seems that such moduls could at best test knowledge but not the fit to practice criterion requested by the Rules (Art. 1 REE). The key of a patent attorney's work is creative work such as find a claim that protects an invention and is delimited against prior art, to find arguments for the presence or absence of novelty and inventive step, analyze complex legal scenarios etc., but not the choice between proposals. Thus, MCQ might be a tool for a preliminary test of knowledge but is not suitable to test the key requirements for the work as a patent attorney.
Another important aspect is the amount of time necesssary to provide MCQ. As Stefan Kastel has outlined in detail, it is a very time- and ressource- consuming task. Until now 20 MCQ had to be provided per year, for the format proposed in the discussion paper about 5,000 to 10,000 MCQ were necesssary. Who should do this work? Experienced EQE examiner are required and their number cannot just be increased.
Thus, the content to be tested is not adequate and the means for these tests are not available.