Administrative burden in Impact Assessments

for Commission proposalsNovember 2012 – February 2013

Dr. Marianne KlingbeilDeputy Secretary GeneralEuropean Commission7 March 2013

Directive on Marine Equipment

The IAB opinion asked in its second opinion that the report should "provide some quantitative illustration […] of regulatory burden reductions for the main policy options".

Revision of the Tobacco Product Directive

The IAB asked in its first and second opinion

that the IA "should also assess in greater detail

the administrative costs for national

authorities."

EU Guidelines for the application of State aid rules in relation to rapid

deployment of broadband networks

The IAB asked for move evidence:"The available evidence from the case studies should be more explicitly used to give an indication of the likely costs and benefits for the different parties involved, including the costs for national administrations".

Alternative Investment Fund Management Directive

Level 2 Measures

The IAB asked for a better assessment of administrative burden:"First, it should try to quantify [impacts] as much as possible. This is particularly important for impacts on costs and administrative burden."

Revision of the Regulation 1346/2000 in insolvency proceedings

The IAB asked for further quantification:

"[The report] should also strive to estimate all expected

economic impacts, in particular, administrative

burden".

Regulation on occurrence reporting in civil aviation

The IAB asked for a better description of costs:

"The report should also provide a breakdown of the

administrative burden costs for each of the major

stakeholders affected, within the main text".

Action Plan against tax fraud and evasion and on recommendations

on good governance

The IAB asked for further clarifications of impacts and

conclusions:

"The report should better explain the impacts on

administrative burden and better justify certain

conclusions […]".

Voluntary agreement concluded under the Ecodesign Directive 2009/125/EU to

improve the energy efficiency of imaging equipment

IAB recommendation:

"[The report] should then assess the potential impacts on

consumers and on retail prices, and substantiate the

administrative costs to industry and national authorities,

and especially the administrative burden associated with

the yearly reporting and evaluation arrangements".

Reinforcing the protection of the Euro against counterfeiting by means

of criminal law

IAB recommendation:

"The report should clearly distinguish between compliance

costs and administrative costs, and specify which of the two

apply where, and how they are analysed. Administrative

costs should be further analysed, including an indication of

their expected magnitudes across the Member States,

given the different legal systems".

Legislative proposals to eliminate remaining administrative and technical

barriersin the field of interoperability and safety on the EU railway market

IAB recommendation:

"It should correctly apply relevant cost concepts, for example

by clearly distinguishing between administrative costs for

different economic actors, and the costs of public

administration, including the administration costs of ERA".

Statistics

• 22 IA reports were published from November 2012 to February 2013

• 10 of these have been identified as being especially interesting from the point of view of administrative burden

Challenges November 2012 – February 2013

• clearer assessment of administrative

costs/burden, more detailed quantification

• specific indication of administrative costs for

national/public authorities

• clearer distinction between administrative

burden/costs and compliance costs