European Commission impact assessment guidelines
European Commission guidelines (48 pages, PDF) on the preparation of impact assessments for policy proposals.
These guidelines define, in effect, a logic model with two main layers:
- the "problem" to be solved is a way of describing the relevant policy objective or desired outcome; and
- the "objectives" are operational activities and targets that contribute towards that outcome.
They suggest that impacts can best be identified through a causal model.
The guidelines emphasise proportionality and subsidiarity as criteria to choose between options. The criteria of effectiveness (achieving the objectives), efficiency (minimising costs) and consistency (minimising distributional effects and economic/social/environmental trade-offs) are to be used to screen the options to be subjected to assessment.
The annexes (51 pages, PDF) are not fully targeted on the impact assessment concepts defined in the guidance. For example:
- Annex 2 appears to be asking officials to identify political objectives under the guise of "problems calling for a solution", which is only defined by reference to a non-existent perfect world: for example imperfect information is described as a potential problem, despite the fact that there is no such thing, even in theory, as a working world with perfect information, and despite the warning in the guidance that "problems should not be defined as a lack of something". The separation between civil service and political responsibilities may be unnecessary muddled as a result.
- Annex 9 does not provide an useful analysis of competition issues, although the DG Competition guidance published subsequently may largely fill the gap.
- Annexes 12 and 13 appear to encourage officials to use cost-benefit analysis and variants in order to choose between options, and ignores the proportionality and subsidiarity principles highlighted in the guidance.
A single file (99 pages, PDF) containing the guidance and annexes is also available, as are (now) German and French (116 pages, PDF) versions. Further links can be found on the European Commission's impact assessment website. DG Competition's competition screening guidance was published a few weeks after the guidelines.
Filed under Guidance, Impact assessment.
