Impact Assessment
Note: This is not updated to take into account the new Working Methods.
An impact assessment is required for Commission initiatives that are likely to have significant economic, environmental or social impacts.
Work for major initiatives can begin once political validation by the First Vice President, Vice President, Commissioner and in close collaboration with the President.
The political validation requirements are below:
The IA development is led by the lead DG. The IA is prepared by an inter-service group (ISG) which will steer the IA process and collectively prepare the IA report.
Under an earlier version of Better Regulation, the ISG was known as the Impact Assessment Steering Group (IASG) (link).
The Secretariat-General will lead ISG when the item is in (1) the Commission’s Work Programme, or (2) an important initiative, or (3) a sensitive initiative. Otherwise, the lead DG steers with the help of their DGs Impact Assessment unit.
Along with the lead DG, all other relevant DGs will be involved. The relevant policy unit within the Secretariat-General and Legal Service will be present. Additional expertise from other DGs needs to be drawn in, such as an economic analysis (e.g. ECFIN), scientific research and analytical models (e.g. JRC), social impacts (e.g. EMPL), SMEs, competitiveness (e.g. GROW), environment (e.g. ENV), fundamental rights (JUST), innovation (RTD), digital/ICT (CNECT) etc.
Some ISG can be large containing over 40 officials. The benefit of the ISG is that it provides you with a lot of opportunities to provide additional input. This is dependent on you having already provided a substantive submission during the public consultation.
If you choose not to participate in the input to impact assessment or provide little to no supporting evidence to support your case, the chances of you being listened to during the adoption phase are limited.
The quandary is that the impact assessment model is rightly evidence heavy. Data, studies and information are the currency of influence. Many find ‘evidence-based policymaking’ hard to accept in practice.
Sometimes, the lead DG is unacquainted with the rigour required in preparing an IA. The exercise is set up to avoid confirmation bias or writing up the conclusions at the start before any evidence is presented. There have been cases where DGs have found it difficult to prepare an impact assessment. In those cases, the work is repatriated to the SG to complete.
Preparing a good quality Impact Assessment is not a slight ordeal. Yet, a good quality impact assessment helps strengthen the policy and later on, the political case, for the final proposal.
The process lasts around 12 months and follows these steps.
