2.2 Specific criminal offences (Articles 3 – 7 of the Directive) a) Illegal access to information systems Referring to illegal access to an information system, Article 3 of the Directive is covered by the national legislation of AT, CY, CZ, EL, ES, IE, FI, FR, LT, LU, NL, PL, PT, SE and SK. For all remaining Member States, i.e. BE, BG, DE, EE, HR, HU, IT, LV, MT, RO, SI and the UK, the respective national description of the criminal offence does not differ between gaining access to the whole or to only a part of the information system, even though this is explicitly provided for in the Directive. Also, DE`s transposition does not cover mere access to computer hardware, and additional requirements are provided for by AT and LU regarding a special intention (intent to gain knowledge, inflict disadvantage or fraudulent intent) and by LV regarding the cause of substantial harm. In the case of BE, BG, FR, HR, LU, MT, PT, RO, SI and the UK, the scope of the national provisions is broader than the Directive, as these provisions do not require circumventing any security measure to establish criminal liability. The remaining Member States either refer literally to the offence being committed by infringing a security measure (CY, EL and SK), or they use similar terminology to describe the aspect (AT, CZ, DE, EE, ES, FI, HU, IT; LT, LV, NL, PL and SE). b) Illegal system interference Article 4 of the Directive refers to illegal system interference. The Directive lists 8 possible acts (inputting computer data, transmitting, damaging, deleting, deteriorating, altering or suppressing such data, rendering it inaccessible) and 2 possible results of the respective act (seriously hindering or interrupting the functioning of an information system). BE, CY, CZ, EL, IE, FR, HR, LU, MT, PT, SE and the UK (except for Gibraltar) have introduced corresponding legislative measures. BG refers only to inputting a virus, while for the rest of the Member States (AT, DE, EE, ES, HU, IT, LV, NL, PL, RO, SI, SK and the UK), 1 or up to 4 of the possible acts are not specifically mentioned. In this context, it can be observed that most issues arose with the terms ‘deteriorating’ (lacking in 8 cases) and ‘rendering inaccessible’ (lacking in 9 cases). c) Illegal data interference Article 5 of the Directive covers illegal data interference and lists the following 6 possible acts: deleting, damaging, deteriorating, altering, suppressing data or rendering it inaccessible. CY, EL, IE and MT have literally transposed the provision; BE, CZ, LT, PT and SE used more generic terms to cover all the possible acts. All other Member States` transposition measures do not cover each of the possibilities but rather refer to only 5 alternatives (FI and SK) or less (AT, BG, DE, EE, FR, HR, HU, IT, LU, NL, PL, RO, SI and the UK). Most issues arose with ‘damaging’ (missing 8 times), ‘deteriorating’ (13 times), ‘suppressing data’ (11 times) and ‘rendering data inaccessible’ (13 times). In addition to the Directive`s wording, FI requires the 'intention to cause harm or financial loss' for criminal liability while LT and LV require the 'act to incur major damage or substantial harm'. d) Illegal interception Article 6 refers to illegal interception and targets the non-public transmission of computer data and electromagnetic emissions from an information system carrying such data. CY, CZ, DE, ES, IE, FI, HR, LV, MT, RO, SE, SK and the UK (Gibraltar) have introduced legislation which fully covers Article 6. The general scope of the Directive referring to the interception of computer data is limited to messages (AT and BG), the observation of a person (EE) or correspondence (FR and HU). Furthermore, the following Member States` transposition measures do not cover the interception of electromagnetic emissions: BE, BG, EE, FR, HU, 7