Scrutiny of recent Inception Impact Assessments

February 10th 2020

The Impact Assessment Institute conducts regular analysis on Inception Impact Assessments (IIAs) adopted by the European Commission. 

In the period December 2019-January 2020, four Inception Impact Assessments were published on the European Commission’s website (https://ec.europa.eu/info/law/better-regulation/initiatives). Two relate to financial services, one to gender equality, one to non-financial company reporting.

Our scrutiny of these, evaluating the text according to Better Regulation principles, has identified good practice alongside a number of concerns in the assessment of evidence (see table below). These concerns relate mainly to the assessments of expected impacts, which may prejudge the upcoming full Impact Assessments or lack balance in their analysis.

Stakeholders are invited to provide their own insights into these IIAs and to reach out to the Institute’s Analytics division to discuss further scrutiny of evidence on these or other dossiers.

Key: Xx = no issues identified; Yy = issues identified; Zz = significant issues identified

Context and problem definition

Objective(s) and policy options

 

 

Assessment of expected impacts

 

Background data and sources

 

Timeline (respect of Better Regulation rules)

Generally balanced and comprehensive

Appears to cover full range of measures and clearly presented

 

Impacts on traditional financial markets not addressed

Apparently comprehensive and well-referenced

Timing of proposal in 2020 not specified

Full description but includes premature references to solutions

Level of detail not commensurate with the context/problem definition

 

Predictions too concrete for early stage assessment, no consideration of potential negative impacts

Apparently comprehensive and well-referenced

Timing of proposal in 2020 not specified

Concept and extent of "pay transparency" not fully explained

Objectives not specified, options not clearly explained

 

 

Economic impacts not substantiated, social impacts not sufficiently examined

Apparently comprehensive and well-referenced

 

Aligned

General balanced and comprehensive

 

Appear to cover full range of measures and clearly presented

 

 

Intentions presented as likely impacts

 

Apparently comprehensive and well-referenced

 

Aligned

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