Externally contracted studies

The following remarks, disclaimers and caveats apply to the final reports below:

• The EU baseline measurement assesses the level of administrative burdens as of 1st January 2005. The EU legal acts taken in consideration for the baseline measurement are therefore those in force on that date. The 2007 and 2009 lists defining the scope of the Action Programme (COM(2007)23 / COM(2009)16) are referring to pre-2005 EU legal acts for which reduction measures had to be found and post-2005 EU legal acts reducing administrative burdens. These lists could therefore not be used as such for the baseline measurement. A correspondence table [10 KB] was therefore prepared to clearly indicate what is part of the baseline measurement and what is part of the reduction measures. The findings of the consultants were used accordingly to compute the figures presented in the Communication of October 2009 (COM(2009)544).
• The EU baseline measurement and the assessment of subsequent changes in terms of administrative burdens are based on the EU "Standard Cost Model" as defined in Annex 10 of the "Impact Assessment Guidelines". The purpose of the SCM methodology is to produce an order of magnitude of the burdens in different regulatory areas. Considering the level of detail and the number of parameters concerned, it would not have been cost-efficient to aim at statistically valid results.
• The assessment of the 42 legal acts initially in scope of the Action Programme (COM(2007)23) is based on field research in some Member States, on results from national baseline measurements and on econometric modelling.
  • Original data collection (interviews/workshops, expert assessments) took place in 2007-8. Field research covered on average 6 Member States for each priority area. The selection of Member States varied across priority areas.
  • The consultants also retrieved data from national baseline measurements completed at the time (Austria, Denmark, Germany, the Netherlands and the United Kingdom). National data from these baseline countries were produced between 2005 and 2008. Differences in time and currencies (euro, UK pound, Danish krone) were assumed to have a marginal effect on the level of administrative burden and therefore on the comparability of these data (when the latter correspond to the same regulatory perimeter – see below). The main factors affecting the level of administrative burdens were indeed overall relatively stable (inflation rate, hourly wages, exchange rate between these currencies and the euro, and the total number of businesses in the EU). Whenever it was not possible to retrieve (comparable) data from these national baseline measurements, figures are based on extrapolation (see below).
  • The level of administrative burdens in the remaining Member States was extrapolated on the basis of these original and retrieved data (econometric modelling). Factors likely to affect the level of administrative burdens in a country vary across priority areas. Specific extrapolation models were therefore developed for each priority area.
• The assessment of the 30 EU legal acts put in the scope of the Action Programme in January 2009 (COM(2009)16) was done on the basis of a lighter approach, building on the results and lessons from the mapping and assessment of the first 42 legal acts. This approach is described in the introduction of the CEPS reports. The same approach is used for the assessment of the burden reduction potential from reduction measures concerning all 72 acts.
• The impact of reduction measures is assessed in terms of their maximum reduction potential in the EU as a whole. In other words, it is assumed that possibilities offered to Member States and businesses are used to the full, and that Member States refrain from gold plating. Concretely this means for instance for Member States to stick to the collection of data required by EU legislation and for businesses to take full advantage of new possibilities and incentives (e.g. resorting to electronic invoicing rather than paper invoicing).
• Member States were involved in the work done by the consortium led by Deloitte (mapping, assessment and reduction recommendations concerning the 42 acts initially in scope). They were informed throughout and got the opportunity to provide detailed feedback. However, as already mentioned, authorship responsibility lies with the external contractor. Some of the reports refer to the consortium team in a Member State by simply citing the name of that country. This should not be understood as a direct input or validation from public authorities of the said country. The Member States were not directly involved in subsequent work based on the lighter approach as this approach does not in particular rely on field research in specific countries and systematic retrieval from all national baseline measurements.
• The Commission believes that the EU aggregate figures are of sufficient quality to give an indication of the level of EU administrative burdens and monitor EU wide changes. Some of the reports break data on administrative burdens down to the Member State level. Such breakdowns should be seen as very preliminary estimates for illustrative purpose only. These estimates will need to be revised on the basis of the results of new and updated national baseline measurements. Ways to improve the extrapolation method might also be considered.
• The scope of the EU baseline measurement is limited to EU provisions imposing explicitly the provision of information. It should however be noted that there are some EU legal acts setting an objective for the Member States, without making reference to the provision of information, but which may lead the latter to introduce national information obligations on businesses to monitor progress towards the EU objective. These national information obligations could be considered as stemming from EU implicit information obligations. This notion has been examined as part of the work done by the Consortium on VAT [4 MB] . The UK also made a review of discrepancies [221 KB] between EU mapping and its national mapping resulting from implicit IOs. The latter shows that the EU baseline measurement and the national baseline measurements have a different perimeter.
• The Standard Cost Model may be applied in different but equally valid ways. These differences often explain variation between EU baseline measurement and national baseline measurements. Factors leading to variation, which need to be taken into consideration for any interpretation of the data, are inter alia

* difference in perimeters (the ambition of the EU baseline measurement is to focus on the most burdensome information obligations, where the aim of some national baseline measurements was to measure all information obligations; some national exercises only covered the burdens imposed in the country by EU directives while excluding EU regulations; some national measurements cover charities in addition to businesses and/or consider that labelling obligations to inform consumers are not an information obligation)

* the use of different tariffs (the hourly wages used in the EU baseline measurement are taken from the harmonized ISCO tariff covering all 27 Member States; this tariff differs from tariffs used in national measurements),

* difference in assumptions (Since the SCM is by definition a method for estimating burdens, different assumptions underlying these estimates naturally give rise to different results. This is for instance the case in what should be considered as "business as usual costs".