The problem definition and problem drivers in the impact assessment (IA) appear to be well-supported by evidence. The IA provides a well-structured analysis of the existing situation and the likelihood for the problem to persist. The IA identifies the initiative’s general and specific objectives, which appear to be specific, achievable, relevant and time-bound, but not measurable, as recommended by the Better Regulation Toolbox ‘S.M.A.R.T.’ criteria. The IA does not define more detailed operational objectives as recommended by the BRG; instead, it provides a list of performance monitoring indicators directly linked to the specific objectives. The IA provides a sufficient range and description of the policy options. It offers an assessment of the options and presents the intervention logic in a clear and transparent manner, where the options are linked to the problem drivers and the specific objectives and their drivers. The IA analyses, in a comprehensive and balanced manner, qualitatively and, where possible, quantitatively, the main expected economic, social and fundamental rights, and environmental impacts, covering specifically effectiveness, efficiency and coherence. The IA explains how the preferred option would contribute to the SDGs; however, additional SDGs (e.g. SDG 5 on gender equality) should have been examined. The analysis of impacts on third and developing countries would have benefited from more attention, given the strong external dimension of the proposal. The IA provides a comprehensive summary of the preferred option’s (PO2) costs and benefits for the affected stakeholder groups. It is transparent about data uncertainties and assumptions. Stakeholders were widely consulted and their views were taken into account. The preferred option enjoys broad stakeholder support, with any divergent views sufficiently presented in the dedicated annex of the IA. Overall, the annex on stakeholder consultation appears to be very informative and comprehensive; however, the feedback from this consultation strategy could have been better reflected in the IA, particularly regarding the available policy options and their potential impacts. A SME test was carried out. However, it appears that no targeted SME consultation was conducted. The Commission made efforts to take the RSB’s comments into account, but some weaknesses remain (for example, as regards the description of the specific objectives in S.M.A.R.T.er terms, and a more in-depth analysis of the impacts on third and developing countries).
Source : © European Union, 2024 – EP