Europaudvalget 2017
KOM (2017) 0114
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EUROPEAN
COMMISSION
Brussels, 6.3.2017
SWD(2017) 98 final
COMMISSION STAFF WORKING DOCUMENT
IMPACT ASSESSMENT
Accompanying the document
Proposal for a
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
on European Business Statistics
amending Regulation (EC) No 184/2005 and repealing 10 legal acts in the field of
business statistics
{COM(2017) 114 final}
{SWD(2017) 99 final}
EN
EN
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1.
1.1
1.2
1.3
1.4
2.
2.1
2.2
2.3
2.4
2.5
3.
4.
Table of Contents
INTRODUCTION
...................................................................................................................... 4
Background
............................................................................................................................. 4
Context
.................................................................................................................................... 5
Consultation of interested parties
............................................................................................ 7
Content of the Impact Assessment Report
.............................................................................. 9
PROBLEM DEFINITION
........................................................................................................ 10
Problem drivers
..................................................................................................................... 11
Problems
............................................................................................................................... 12
Link between problem drivers, problems and their consequences
........................................ 17
Scale of the problem
............................................................................................................. 17
What would happen without an intervention
........................................................................ 18
WHY SHOULD THE EU ACT: RESPECT OF SUBSIDIARITY PRINCIPLE
......................... 20
OBJECTIVES
............................................................................................................................... 21
4.1
4.2
General objectives and links to horizontal EU objectives
.................................................... 21
Specific objectives
................................................................................................................ 22
5.
POLICY OPTIONS
...................................................................................................................... 23
5.1
5.2
List of policy options
............................................................................................................ 24
Discarded options
.................................................................................................................. 26
6.
IMPACTS OF THE POLICY OPTIONS
..................................................................................... 29
Impacts
Option A:
Baseline scenario: no EU policy change
...................................................... 29
Option B:
Implement legislative actions limited to certain business statistics domains
.............. 30
Option C:
Modernisation of business statistics in a single framework (FRIBS) using a mix of
measures
....................................................................................................................................... 33
7.
COMPARISON OF OPTIONS
.................................................................................................... 41
8. MONITORING AND EVALUATION: HOW WOULD ACTUAL IMPACTS BE
MONITORED AND EVALUATED
.................................................................................................... 46
ANNEXES
............................................................................................................................................ 51
ANNEX I: PROCEDURAL INFORMATION
................................................................................. 51
ANNEX II: STAKEHOLDER CONSULTATIONS
........................................................................ 55
ANNEX III: WHO IS AFFECTED BY THE INITIATIVE AND HOW
......................................... 62
ANNEX IV: ANALYTICAL MODELS USED IN PREPARING THE IMPACT ASSESSMENT65
ANNEX V: LIST OF THE CURRENT LEGAL ACTS GOVERNING EUROPEAN BUSINESS
STATISTICS
.................................................................................................................................... 72
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ANNEX VI: LIST OF ABBREVIATIONS
...................................................................................... 74
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1.
INTRODUCTION
1.1
Background
Statistics and indicators are key elements for evidence-based decision making at both national
and European Union level. A number of important EU policy measures, like the
Macroeconomic Imbalance Procedure, the Excessive Deficit Procedure, the European
Semester and the policy initiatives of Europe 2020 strategy intensively use comparable EU
statistical information and indicators.
Additionally, the monitoring of the goals set through the Juncker Commission 10 priorities at
Member State and Union level requires harmonised and comparable European statistics that
decision makers need in order to design policy initiatives to meet the priorities and to monitor
the implementation of these initiatives.
European Statistics and the European Statistical System (ESS)
1
, with the quality guarantee of
official statistics, are the main statistical sources for robust EU policy making.
European business statistics are a crucial input for the production of National Accounts core
figures such as the GDP, and widely used for monitoring the performance and growth of
European businesses which are at the core of employment creation, innovation and
investments within the European Union economies.
High quality European business statistics are also an essential piece of information
infrastructure not only for designing, implementing and assessing national and EU policies,
but also a very important data source for economic research and (financial) markets.
The envisaged proposal for a Regulation of the European Parliament and of the Council on
European Business Statistics (hereinafter referred to as "Framework Regulation Integrating
Business Statistics (FRIBS)") is a natural follow-up of the ESS efforts to modernise the
production of business and trade statistics, a need recognised already in 2009 by the
European Commission with the launching of the programme for the Modernisation of
European Enterprise and Trade Statistics (MEETS)
2
.
The FRIBS is one of the key initiatives of the Commission's Regulatory Fitness and
Performance programme (REFIT). In that respect, it aims to increase the relevance of
business statistics by addressing existing user needs which are at present not served while at
the same time removing some data requirements which are no longer relevant.
1
The ESS is the partnership between Eurostat and the national statistical institutes (NSIs) and other national
authorities (ONAs) responsible in Member State for the development, production and dissemination of
European statistics.
2
Decision No 1297/2008/EC of the European Parliament and of the Council of 16 December 2008 on a
Programme for the Modernisation of European Enterprise and Trade Statistics (MEETS)
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Likewise, reliable and comprehensive EU statistics are required at the national level, as
national policy makers need to compare their situation with the rest of the EU, e.g. in terms
of productivity, investments, production, research, innovation or exports. Additionally, high
quality European business statistics are important for providing a sufficient knowledge base
for the EU citizens and for scientific research, which can help identify important trends and
future policy challenges, or explain why certain developments occur.
1.2
Context
The users and uses of European official business statistics are of a very eclectic nature
comprising policy makers at national and EU-level, businesses and their associations,
researchers providing advice on future policy initiatives as well as users from other statistical
domains, such as national accounts, who use business statistics as a crucial input for their
macro-economic indicators. European business statistics provide the basis for analysing and
monitoring issues such as economic developments in different sectors, productivity and
competitiveness of European businesses, their globalisation, growth and jobs, trade, the
functioning of the single market and the performance of small and medium sized enterprises.
Since many years a core set of business statistics is disseminated to users comprising short
term business statistics used for the analysis of business cycles (such as industrial production,
producer prices, turnover, employment), structural information (e.g. information on the
business population and the births, deaths and survival of enterprises, turnover, value added,
employment, gross investment, innovation), production output (mainly concerning
manufacturing), factor-input (personnel costs, research & development expenditure) and
international trade (imports and exports) and investment flows and prices.
The relevant international developments should also be closely followed. For instance
international manuals such as the Frascati manual regarding R&D statistics and the Oslo
manual concerning Innovation statistics as well as international agreements adopted by
United Nations, OECD, International Monetary Fund, and other international and
supranational organisations, are of relevance for European business statistics and should, as
far as necessary, be considered in European business statistics.
The MEETS Programme was used to undertake the first steps in modernising business and
trade statistics. Several actions were launched aiming for better integration, simplification,
and modernisation and investments were made across the ESS, with a EUR 37 million
contribution by the Commission. The outcome of this work feeds into the proposal for
FRIBS.
At the same time, the European Statistical Programme (ESP) 2013-2017
3
defines business
statistics as one of the three pillars of the European Statistical System (ESS). Each of these
3
Currently, work is under way for extending the European Statistical Programme (2013-2017) to 2018-2020
and thus aligning it to the cycle of the Multi-annual Financial Framework (MFF)
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pillars covers a set of primary statistics which is serving multiple policy needs. Business
statistics are also the crucial input for higher level accounting systems (e.g. National
Accounts) and for the development of indicators for different policy needs. The currently
developed extension of the ESP would also be recognising the importance of FRIBS and the
need to financially ensure its modernisation efforts by accordingly reflecting it in the ESP
budget. The ESP extension would also refer to E-commerce and ICT usage which would also
be better covered by FRIBS in terms of allowing for building a broad information base to
develop better statistics on the drivers for technological changes and innovation as well as e-
commerce. The ESP also envisaged enhancing (an increase also in budgetary terms
envisaged) the availability of indicators and statistical information for better measuring
economic globalisation; global value chains; and services.
In addition, the Commission's REFIT programme for making EU law simpler and reducing
regulatory costs has identified statistics as one of the priority areas for modernisation. In its
action plan, FRIBS is mentioned as a key pillar of this reform agenda.
The Commission's
Smart Regulation
4
initiative and the comprehensive Better Regulation
package from May 2015 strongly emphasise the significance of continuous evaluation and
quality control of EU policies which should foster more consistency, transparency,
effectiveness and efficiency in the European legislation.
In 2014, the European Statistical System Committee (ESSC) has launched its ESS Vision
2020 strategy to make the European Statistical System (ESS) fit for the future and build upon
the modernisation activities on European statistics, already undertaken by the Commission
since 2009. The ESS Vision 2020 is a joint strategic response of the ESS to the challenges
which official statistics are facing, such as the handling of big data, measuring globalisation
in official statistics, providing high quality statistics under tight budgets or addressing
emerging policy needs for new statistical indicators while being conscious of burden on
businesses. The ESS Vision 2020 foresees that data should be more integrated for better
analysing new phenomena (such as globalisation) and for better serving EU policies with
high impact (e.g. trade or R&D policy). In order to benefit from emerging opportunities for
burden and cost reduction the ESS should increase the collaboration within the system by
sharing methods, tools and even identifiable micro-data. The ESS should, moreover, become
more agile and be using innovative solutions by harnessing new data sources to produce
meaningful statistics.
The aforementioned initiatives provide the context within which Eurostat has embarked on
designing the Framework regulation integrating business statistics (FRIBS) together with
National Statistical Authorities (NSAs).
4
Commission Communication COM (2013) 686 "Strengthening the foundations of Smart Regulation –
improving evaluation"
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A FRIBS roadmap has been agreed and published in January 2013 by the Commission.
Following the introduction of the Better Regulation guidelines in 2015, the roadmap was
revised under the form of an inception impact assessment that was published in January 2016.
Further procedural information is available in Annex I.
1.3
Consultation of interested parties
In order to prepare this initiative many regular meetings (more than 100) with producers of
business statistics (NSIs and other national authorities- Directors Meetings, Task Forces,
domain-specific working groups), respondents (businesses and European Federations by
sector of industry - FEBI "Fédérations
Européennes par Branche d'Industrie"
meetings) and
users (public and private decision makers and in particular European Commission
Directorates General in annual hearings) have taken place since the start of the FRIBS project
in 2011. The FRIBS project has been discussed with national experts covering not only
business statistics, but also macro-economic statistics, National Accounts and Balance of
Payments statistics (eg. the Committee on Monetary, Financial and Balance of Payments
Statistics - CMFB).
Additionally to the regular and extensive consultations of the concerned parties, three rounds
of specific stakeholder consultations were organised for preparing the FRIBS Impact
Assessment. The first round covered the FRIBS infrastructural elements (such as the
Business Registers, micro-data exchange, quality issues and confidentiality). The second
round focussed on the changes to the data requirements to be introduced by FRIBS and the
third round collected stakeholders' opinions on the modernisation of Intrastat. Each round
consisted of a targeted consultation of the data compilers (NSAs) and an open public
consultation. While the open public consultations were open to all possible respondents (in
the sense of the Better Regulation toolbox), the objective has been to get feedback especially
from the data providers (businesses) and from the data users. Thus, stakeholders have been
intensively involved in the shaping of the FRIBS project and have been extensively
consulted. Annex II provides the details on the consultations carried out.
Consultation on FRIBS infrastructural elements
The consultation on the FRIBS infrastructural elements took place between July and October
2014 and aimed to collect input from the following three main categories of stakeholders:
Data users: all actors who are frequently using European business statistics as an input
in their daily work, such as other Commission services, national statistical authorities
monitoring the business sector, National Central Banks and the European Central
Bank, professional associations and researchers.
Data compilers: national statistical authorities (NSAs) which are responsible for the
collection, compilation and dissemination of statistics at national level. In the first
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place this includes National Statistical Institutes (NSIs), but also other compilers such
as National Central Banks;
Data providers: enterprises (including SMEs) responding to statistical surveys at
national/regional level;
In line with the geographical scope of the subsequent cost-benefit analysis, the data
compilers' consultation targeted stakeholders from all 28 EU Member States and the 4 EFTA
countries.
NSAs were consulted on:
The expected qualitative impacts of FRIBS;
A qualitative comparison of FRIBS and alternative policy options;
The expected quantitative impacts of FRIBS and alternative policy options for NSAs;
The expected quantitative impacts of FRIBS and alternative policy options for data
providers.
Consultation on FRIBS additional data requirements
A supplementary consultation in the second half of 2015 was launched to assess the impact of
the changes to the existing data requirements envisaged in FRIBS. Besides new additional
data requirements also the reductions in data requirements were included. This specific
consultation is part of the larger FRIBS Impact Assessment and it complements in particular
the first cost-benefit analysis of the infrastructural elements for which a stakeholder
consultation had been carried out during 2014.
The consultation on the FRIBS additional data requirements took place between August and
November 2015 and also consisted of a targeted consultation of the data compilers (NSAs)
and an open public consultation – via which the feedback of the data users and data providers
of European business statistics was sought. The consultation focused on the impact of the
additional data requirements that are foreseen in FRIBS.
Stakeholders were asked to give their opinion and to provide factual data regarding the
expected impacts of the changes. These impacts can be summarised as follows:
Qualitative impacts for data users (quality, flexibility, timelines);
One-off implementation costs and changes in yearly operating costs for data
compilers;
Changes in administrative burden and one-off implementation costs for data
providers.
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Consultation related to Intrastat
Separate targeted and open public stakeholder consultations have been carried out on Intrastat
feeding into the impact assessment as well as to the modernisation of Intrastat. The overall
aim of the modernisation project is to assess the impacts of the three options
5
proposed –
SIMSTAT, Revised Intrastat and Single Flow - in terms of their costs and benefits.
The NSAs have been addressed in a targeted consultation for collecting data for a cost-benefit
analysis. This cost-benefit analysis aims at providing input to the ESSC to take a strategic
orientation on the modernisation of Intrastat. At the same time the cost-benefit analysis is
contributing to the more encompassing cost-benefit analysis of FRIBS.
The methodology followed for the cost-benefit analysis consists of two actions: quantitative
assessment (cost analysis) and qualitative assessment (SWOT analysis).
The aim of the cost analysis was to estimate the costs (current costs, development and
adaptation costs, future costs) incurred by the NSAs caused by the implementation of
modernisation options for Intrastat.
The SWOT assessment for the Member States was carried out in autumn 2015 based on a
standard methodology.
For collecting data on the administrative burden, an extensive public consultation of the data
providers has been organised during the first quarter of 2016.
Additional information on the consultations of the relevant stakeholders and their outcomes is
provided in Annex II.
1.4
Content of the Impact Assessment Report
The main part of the Impact Assessment report starts with the definition of the problems
(Chapter 2) and continues with justifying the need for an EU action (Chapter 3). Then, the
objectives of the proposed legislation are presented (Chapter 4), followed by an outline of the
possible policy options (Chapter 5). The analysis of the impacts of the various policy options
are presented in Chapter 6 and the preferred option in Chapter 7. The monitoring and
evaluation activities that are foreseen for tracing the effects of the envisaged legislation are
explained in Chapter 8. Finally, additional relevant information is appended in the annexes.
Namely, Annex I – regarding the procedural information, Annex II – regarding the
stakeholder consultations, Annex III – regarding who is affected by the initiative, Annex IV –
5
Please see more in detail in Chapter 5- Policy Options
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regarding the analytical models used for the impact assessment and Annex V – comprising
the list of abbreviations, Annex VI - List of the current legal acts governing European
business statistics.
2.
PROBLEM DEFINITION
Generally, the users of business statistics are concerned about the risks of diminishing
relevance of European official statistics because of their availability and quality deficiencies
such as inadequate coverage of emerging user needs, insufficient timeliness and limited
comparability and coherence. Simultaneously, compilers of business statistics (NSIs and
NCBs) are concerned about the pressure to cover new information needs from the perspective
of more globalised and interlinked economies while facing increasingly restrictive budgetary
constraints.
While the "core" business statistics (listed in 1.2) used to focus mainly on manufacturing,
they have been extended to increasingly cover more services sectors over the years. For
instance, statistics on business services have been developed further. The environment in
which businesses function keeps evolving, leading to continued adaptation in the way
companies run their business. Phenomena such as digitalisation and globalisation have led to
the need to better measure the knowledge industries, research and development and
innovation. Consequently, new data production has been launched in these areas. Attempts to
measure globalisation, the functioning of the Single market and the development of global
value chains have resulted in the establishment of separate regulations governing data
collections e.g. on foreign affiliates, foreign direct investment and international trade in
services. On the one hand, these expansions of business statistics created several domain
specific uncoordinated solutions; on the other hand consistency across business statistics
domains was weakened considerably. In addition, challenges to remain responsive to new
user needs and to promote efficient and modern data production methods were not
sufficiently addressed. For instance, complex and interrelated phenomena like globalisation
increase the need for better linked business statistics, which is difficult to achieve in the
current dispersed system. Namely, the current legal basis governing European business
statistics is spread among 10 separate legislative acts (See Annex VI). This legal
fragmentation makes it very difficult to achieve a coordinated and consistent approach when
it comes to modifications introduced independently of each other to individual legal acts.
Furthermore, the need to limit administrative burden is recognised both at national and EU-
level, it is also a fact that high administrative burden leads to risks of decreasing response
rates which effect data quality.
To address these problems the European Parliament and the Council adopted in 2009 the
MEETS programme. The two most important reasons for launching this programme were the
need for cost reductions and for increasing the relevance of European business statistics. The
results of this programme have helped to pinpoint the current problems.
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The strategic challenges that European business statistics are facing have been also addressed
by the Riga Memorandum adopted by the ESS Committee in September 2014. The
Memorandum recognised that business statistics have to be reviewed on a regular basis,
making sure that they reflect the changing organisation of businesses and their
internationalisation bearing in mind the importance of comparability of statistics. The Riga
Memorandum also acknowledges that measuring of economic globalisation should be based
on consistent and harmonised primary statistics on international transactions and businesses.
A new framework is needed that is more flexible and more responsive to emerging user
needs, and at the same time facilitates the use of modern and efficient data production
methods which would allow for the reduction of administrative burden and cost-efficient data
production. A framework that modernises the business statistics system by replacing the
current dispersed structure with a more harmonised and streamlined one and integrates and
replaces ten legal acts currently in force. This new framework should also establish a true
collaborative system, allowing Member States the possibility to draw benefits and synergies
for the production of business statistics in a more efficient way in the context of continuous
reduction of resources both at national and EU-level.
European business statistics should support the main priorities of the Commission by
providing more consistent and relevant data to monitor growth, job creation, competitiveness,
research and innovation, the implementation of the digital single market as well as the
impacts of globalisation and the functioning of the internal market.
This chapter describes the problems, that currently exist in business statistics and which the
initiative is tackling, their causes and consequences. The consultations of the relevant
stakeholders allowed for defining the list of problems and possible causal relations between
problem drivers, problems and their consequences.
2.1
Problem drivers
The main problem drivers behind the shortcomings currently existing in the business statistics
set-up are:
Reduced relevance and responsiveness of European business statistics
Legal fragmentation in business statistics
2.1.1 Reduced relevance and responsiveness of European business statistics
European business statistics have built over the last 20 years a solid information system.
However, the system needs an upgrade in terms of burden reduction possibilities, improved
agility and responsiveness to new demands. The current legal setting is focussing on
manufacturing and only limited information is available on the services sector, which
represents roughly 70 % of the value added in the EU economy since years. The Single
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Market and globalisation have led to increases in cross-border activities and changed the way
businesses are organised; data to monitor these developments are insufficient at present. The
regional dimension should not be forgotten either, better understanding of business
demography on the local level would help national authorities to monitor developments and
take actions when needed. A legal frame which allows for satisfactory and timely responses
to changing user needs is fundamental for the relevance of official statistics in a market
which has increasing competition from private data providers who can provide information
quickly and without regard on burden on businesses. Emerging information needs for
measuring and analysing new phenomena (like globalisation), and the growing needs for
developing new statistical indicators increasingly stretch the ESS ability to respond
adequately to those challenges. Namely, those issues confront the statistical system's ability
to respond to the user needs with sufficient timeliness and maintaining high quality of data
while working under tight budgetary constraints. Thus, the fragmentation and inconsistency
existing across business statistics domains is hampering the responsiveness of the European
business statistics and undermining its relevance.
2.1.2 Legal fragmentation in business statistics
The current numerous legal acts which govern the production of business statistics have been
built up in a compartmentalised and uncoordinated manner. Thus, the statistical information
on European businesses is regulated and produced based on a high number of European
legislative acts which are not integrated and consistent in terms of data requirements,
concepts, definitions and methods as well as statistical processes. The current system also
lacks agility to respond appropriately to emerging and changing policy or user needs.
2.2
Problems
2.2.1 Lack of consistency
Producing statistics following the current compartmentalised approach, i.e. where each
business statistics domain is covered by a separate legal framework (that is known as the
stovepipe model)
is no longer sustainable as it is too costly and does not allow providing the
necessary agility when responding to emerging user needs. Main challenges to respond to are:
The main stakeholders are demanding more and better information on topics not
sufficiently covered by the existing business statistics. Better measurement of the
competitiveness, performance and international activities of businesses is necessary.
To fulfil these needs and to provide a comprehensive and coherent picture, data from
different sources have to be integrated.
Business statistics are also crucial input for other statistics, in first instance macro-
economic statistics (e.g. national accounts). Better business statistics will therefore
also improve the quality of macro-economic data.
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Statistical production processes are dispersed and non-integrated. More efficient and
integrated statistical processes should overall reduce the statistical burden on
respondents, notably businesses, and the costs for national statistical authorities.
• While statistical production is organised nationally, businesses do not regard national
borders as limits to their activity. On the contrary, businesses, even SMEs
increasingly engage in cross border trade and multinationals adjust their value chains
in order to remain competitive and have sufficient presence in different markets. The
Digital Single Market will further intensify those developments. Hence, the
international and global activities of businesses are currently not sufficiently
recognised by official statistics and statistical data production increasingly
necessitates cooperation also between National Statistical Authorities in different
countries for better measuring the business activities.
Modern information technology and standards are becoming increasingly important for
statistical production, in particular to ensure integrated production processes. Such integrated
production processes comprise multi-source/cross-domain data sources, integrated
management of registers, use of standards and shared tools for data exchange and
dissemination as well as a standardised quality management. These requirements are
challenging the current system of European business statistics and the current legal setup. The
present fragmented legislation is not able to respond to these requirements appropriately. This
hinders putting in place modern and integrated multi-source production and dissemination
processes.
Stovepipe-based
business statistics and legal fragmentation have resulted in a series of
deficiencies, such as:
lack of methodological consistency across business statistics domains, e.g. with
regard to statistical variables, statistical registers and confidentiality rules;
different business surveys organised at national level are not integrated and therefore
create additional burden;
administrative data sources are not used systematically;
micro-data is in general not exchanged among NSAs within the European Statistical
System;
considerable burden on businesses exists for collecting intra-EU trade (imports and
exports) statistics (Intrastat);
statistics on the services sector, including international trade in services (e.g.by mode
of supply or by enterprise characteristics), are insufficient and do not respond to user
needs;
inability to respond quickly to new and upcoming user needs
quality of the data on SMEs, globalisation or employment needs to be improved to
better serve the policy needs;
data-linking across business statistics domains is now very cumbersome or not
possible because of lack of coordination when organising surveys.
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The barriers that the domain fragmentation creates in the area of business statistics is
underlined by the fact that a number of cross-cutting variables (i.e. variables used in several
business statistics domains) have similar, but not entirely the same definitions. For instance,
turnover
is used in 6 business statistics domains (Structural Business Statistics, Foreign
Affiliate Statistics ( both inward and outward control), Short Term Statistics, Community
Innovation Statistics and ICT statistics)
6
, but across domains there are differences as to
include or not subsidies and excise duties. The definitions used also deviate from the
concepts used in business financial statements and therefore make the use of administrative
data sources more difficult.
Another example concerns the breakdowns of enterprise populations into size classes of
employment, which allow for an analysis of businesses of different sizes. The size classes of
employment used in R&D and Innovation statistics have been determined on the basis of the
number of employees whereas for other business statistics the number of persons employed
7
is used. As a result data from other business statistics such as value added from structural
business statistics for a certain size class is not consistent with related data of a similar size
class for R&D expenditure. Users who need a complete overview of all data of a certain size
class of enterprises cannot be served by the current business statistics.
2.2.2 Lack of flexibility
The scattered domain-specific regulations on European business statistics fix simultaneously
the statistical policy programming and its technical implementation. This mixture of
programming (policy) and implementation (technical requirements) in the current legal
architecture reduces the efficiency of decision-making. The business statistics legislation
currently in force often refers technical issues to the European Parliament and Council, with
the risk of diverting the attention from striking the right balance between receptiveness to
European information requirements and the underlying costs and response burden. This
results in legislative delays and rigidity. Those shortcomings could be overcome if European
business statistics legislation reflected better the principle of division of responsibilities as
envisaged in the Lisbon Treaty.
The basic idea is that the European Parliament and Council should focus on policy-relevant
strategic decisions at the level of programming (what statistics are to be produced in order to
shape the policy agenda of the EU and to assess progress), but the technical provisions (how
to produce the statistics and the indicators needed) should as far as possible be defined within
the European Statistical System according to the principles and rules set out within the EU's
6
SBS- structural business statistics; FATS- foreign affiliates statistics; STS- short-term business statistics; CIS-
community innovation survey (innovation statistics); ICT- information and communication technologies
statistics
"Persons employed" comprises both the "employees" and the "self-employed"
7
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statistical law (Regulation 223/2009). This division of decision making should lead to both an
accountable and responsive statistical programming and an efficient, integrated data
production and dissemination.
Under the existing incoherent and scattered legal bases, changes to the existing data
collections, small modifications of technicalities or additional data breakdowns or
methodological innovations are very time-consuming to introduce and their implications for
other business statistics domains difficult to assess. This also impairs an adequate matching
the of user needs.
2.2.3 Limited possibilities for applying innovative methods and sources
Modern statistical production comprises increasingly integrated business processes in order to
exploit the strongly growing capacity of information technology. Such integrated business
processes comprise e.g. multi-source/cross-domain data integration, integrated management
of registers and statistical frames, creation/maintenance of common infrastructure, common
standards and shared tools for data processing, exchange and dissemination and standardised
quality assessments. Usually, improvements in one Member State could be implemented in
others, leading to cost reduction, under the condition that processes are standardised. The
efforts on standardising the statistical business processes undertaken by Eurostat, the UNECE
(United Nations Economic Commission for Europe) and the NSIs (such as the definition of
the Generic Statistical Business Process Model - GSBPM - and the Common Statistical
Production Architecture – CSPA) aim for increased use of common standards and shared
tools for the production of statistics.
The existing business statistics legislation is not sufficiently accommodating the increased
necessity to use innovative data collection methods that could foster reductions in production
costs. Some Member States are regarding the lack of relevant provisions in European
legislation as the main barrier towards developing and applying innovative methods. The
difficulties in introducing innovative methods and alternative sources clearly illustrate the
limitations of the current business statistics legal setup.
Innovative methods for producing new indicators could either be national such as linking data
from different business statistics domains or collaborative efforts within the whole ESS such
as reducing costs and burden by exchanging micro-data. Pilot exercises regarding data
linking, in the area of innovation, ICT and the in the area of international out-sourcing have
demonstrated that data linking is an efficient technique enriching the existing data at a minor
cost and making better use of the information collected. The Enterprise Group Register
established at Eurostat based on input from the National Statistical Institutes (NSIs) provides
a valuable service and information source on the structure of enterprise groups to the national
compilers of data on foreign affiliates. Further collaborative efforts in other statistical
domains would support cost savings and burden reduction.
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2.2.4 Sub-optimal quality
8
of statistical data
Quality issues arise from the lack of coherence and comparability among data collections in
business statistics, which again is due to the historical development of business statistics in
separate
stovepipes
with different methodologies and production processes. These
deficiencies in coherence and comparability are problematic for the data users.
The legislation governing business statistics is mainly output-based, NSAs have the freedom
to adopt different approaches and methods for statistical data production influenced by the
specific national contexts and needs. Data are produced according to agreed definitions and
quality reporting is in place to ensure a sufficient level of quality of the statistics
disseminated at EU-level. However, especially in domains where "mirror" data is produced
such as imports and exports of goods and statistics on foreign controlled enterprises
inconsistencies are evident and even pronounced in some cases.
An example from the International Trade in Goods Statistics (ITGS) could be taken. For the
reference year 2012, the ITGS show Intra-EU asymmetries between (-) 38,9 % and (+) 9,7 %
at Member State level for imports. As the data is used to support policy analysis and serve as
input for national accounts, the quality of these figures are of primary concern. FRIBS
foresees the collection of one additional variable
9
which has the potential to reduce the Intra-
EU asymmetries to a great extent.
2.2.5 High burden on data providers
The existing
stovepipe
model is not favourable to providing data on cross-cutting topics. On
the contrary it creates redundancies and duplication of work. This parallel work structure has
led to inefficiencies such as unnecessary costs for NSIs and increasing burden for data
providers. The European Statistical Advisory Committee (ESAC) also points out the
necessity to reduce the burden on data providers and encourages better coordination of the
various surveys. At this stage the inconsistencies in the legal requirements for data production
mean that surveys cannot be aligned and used for producing statistics for many domains with
one data collection. High burden on data providers may also trigger lower response rates
which would hence affect negatively the quality of the aggregate data output.
For example the surveys organised for Structural Business Statistics and those organised for
the Innovation Statistics are hardly integrated in terms of concepts, definitions or data
structures to be produced. This leads to an increase of burden on the respondents and higher
costs for the NSAs (e.g. when the same enterprise receives both questionnaires).
8
In the context of the European Statistical Law (Regulation (EC) No 223/2009), the criteria defining statistical
quality are: relevance; accuracy, timeliness; punctuality; accessibility, comparability, coherence.
Exchange of the importer’s VAT number i.e. the exchange of the identification number of the partner in the
Member State of imports. The current legislation does not require the collection of such an ID number.
9
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2.3
Link between problem drivers, problems and their consequences
PROBLEM
DRIVERS
PROBLEMS
Lack of consistency
Lack of flexibility
Limited possibilities for
applying innovative
models and sources
Suboptimal quality of
statistical data
High burden on data
providers
CONSEQUENCES
Rigidity of European
business statistics
Reduced relevance
and responsiveness
Increasing
inefficiencies in the
production of business
statistics
Legal fragmentation in
business statistics
Dissatisfaction of users
Dissatisfaction of data
providers (businesses
)
2.4
Scale of the problem
Currently a number of key cross-cutting variables are used in more than one statistical
domain. These variables (such as e.g. turnover or employment) have often different meanings
according to the various business statistics domains. This strongly hampers the comparability
of the data, prevents their optimal use and can even lead to misleading policy input.
Moreover, the inconsistency also leads to inefficient data production methods as synergies
between data collections cannot be used and data collected for one domain cannot serve the
production of indicators in another domain.
The public consultation of users shows that 95% of respondents believe that inconsistencies
have a negative impact on the quality of their work whereas 81% indicate this increases
significantly the time needed for exploiting the data. Moreover, 70% of respondents indicate
having already experienced difficulties in combining data from different business statistics
domains.
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The quality and the usability of the business statistics disseminated at present would benefit
from further efforts, as foreseen by FRIBS, to remove not only inconsistencies, but also from
collaborative efforts to remove e.g. the asymmetries in the international trade in goods data
mentioned above.
Based on the results from the consultations of the relevant stakeholders, the estimated burden
on businesses of the collection of the current business statistics is around EUR 689 million.
Although the burden of collecting business statistics corresponds to just about EUR 1.4 per
person in the European Union, the subjective perception of statistical burden is higher. One of
the aims of FRIBS is to reduce the burden on businesses.
The Treaty on the Functioning of the European Union requires the co-legislators to adopt
measures for the production of statistics where necessary for the performance of the activities
of the Union. In this regard and to overcome the problem as described above, the existing
legal provisions would have to be harmonised with each other for reaching more consistency
between them. FRIBS aims at securing this consistency over time, notably by avoiding the
risk that changes will be made in just one of the statistical areas in the future. Last but not
least, the adjusted legal acts must be implemented in a harmonised way in the Member States.
When considering the above-mentioned constraints it looks impossible to produce more and
better information in using the output of the current non-integrated business statistics
domains. In any case, the importance of business statistics goes much beyond their own
statistical area and serving their own purposes. Namely, business statistics play an integral
role for the production of National Accounts key figures such as GDP. The significance of
European business statistics is also substantiated by the major number of extractions
registered in the Eurostat databases: over 20 % of the around 31 million extractions from
Eurostat's databases during the period May 2015 - April 2016 concerned business statistics.
2.5
What would happen without an intervention
If no policy action is undertaken, all the above-mentioned problems of a scattered
stovepipe
system for statistical production of European business statistics will persist. The current non-
harmonised legal frame and the sub-optimal legal decision-making process cannot be
significantly improved under the context of the currently dispersed and non-harmonised legal
acts for European business statistics.
Continuing in this way could even lead to deterioration of European business statistics in
terms of relevance, consistency, quality or costs over time. Many users would remain
dissatisfied. Additional user requirements could only be fulfilled when additional surveys are
launched or when additional non-integrated data sources are exploited. This makes the
system not only more costly, but also rather inflexible. As changes would be done in an
isolated manner in each statistical area and as these changes will add on to a non-harmonised
system, the inconsistency of the production output would increase. Moreover, the costs and
burden for producing any additional business statistics would increase over-proportionally
over time.
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Due to the present limited cooperation in data production in the European Statistical System,
the measurement of complex phenomena like globalisation would be less consistent and
informative, namely in the domains where "mirror data" is produced such as Intrastat and
FATS. European business statistics are already losing relevance and would increasingly do
so..
The loss of relevance make users look for alternative data sources covering their
informational needs outside official statistics. This has several consequences for all
stakeholders. Apart from the additional costs for users, the quality related commitments of
these alternative data sources differ from official statistics and as such may form a less secure
basis for decision-making. Private data providers may launch data collections to produce their
figures without regard to burden created on businesses. This leads to an actual increase in
burden on businesses perceived as administrative burden. Lower relevance of official
statistics could lead to further budget constraints for NSAs. Possible cost savings and
reduction of burden e.g. resulting from an increased use of administrative data, merging
questionnaires or from the exchange of micro-data cannot fully be realised with the current
system.
Table 2: risks and potential impacts to the current European business statistics system
RISK
PROBABILITY OF RISK
High. (As information needs increase,
additional requests could be
implemented inconsistently)
High. (As new information needs
emerge, official statistics cannot
adequately serve policy-makers).
IMPACT
-
misleading and incomparable
information
-
dissatisfaction of users
-
inadequate information for policy-
makers
-
decrease of means for official
statistics as it does not meet the
needs of policy-makers
Increasing
Inconsistency
Loss of relevance
Increased costs and
burden
Normal to high. (Additional information
needs will increase costs and burden
over proportionally).
Increasing inflexibility
Low to high (Long and domain-scattered
legislation process in order to address
additional information needs)
-
Lack of modernised and
collaborative way of data
production will hamper responding
to new information needs
-
dissatisfaction/burden of data
providers
-
users get their evidence base too
late
-
users may look for other sources
outside official statistics
-
policy might be misguided
Furthermore, some of the existing legal frameworks, such as the framework governing the
production of ICT statistics is subject to a sunset clause which will expire in 2018.
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3.
WHY SHOULD THE EU ACT: RESPECT OF SUBSIDIARITY PRINCIPLE
Article 338 of the Treaty on the Functioning of the European Union provides the legal basis
for the EU legislators to adopt measures for the production of statistics where necessary for
the performance of the activities
10
of the Union. Reliable and comparable statistics are needed
to underpin the planning and the monitoring of the implementation of Union policies.
The Commission (Eurostat) cannot work alone to provide the necessary statistics. The
European Statistical System (ESS) is the partnership between the Union statistical authority,
which is the Commission (Eurostat), and the national statistical institutes (NSIs) and other
national authorities responsible in each Member State for the development, production and
dissemination of European statistics. The ESS is established by Regulation (EC) No
223/2009 on European Statistics. The Member States ensure the actual compilation of
statistical information at the national level. For the compilation of statistics at European level,
a harmonised methodology and the definition of a common output to be delivered by Member
States are indispensable in order to guarantee the required high quality statistics necessary to
support the Union policies and robust decision-making. As the difference in methodology is
not only caused by the diversity of statistical domains, but also by heterogeneous
methodology in Member States, attaining harmonised methodology can be fully achieved
only by way of EU action. The proposed Regulation will guarantee the required data quality
e.g. in terms of coherence and comparability of the business statistics relevant for the
activities of the Union.
Only the Commission (Eurostat) is in a position to propose the necessary measures for
harmonisation of statistical information across Member States and produce harmonised
business statistics at the European level on the basis of the data compilation carried out by
Member States. Consequently, the European Union may adopt measures in accordance with
the principle of subsidiarity as set out in Article 5 of the Treaty on European Union (TEU).
Thus, the proposed EU action is fully justified.
Although this reasoning is also valid for all other domains where statistical information is
needed for EU policy-making and monitoring, specific phenomena of business statistics are
transnational or increasingly global. These cannot be adequately addressed by actions on the
Member States level alone. Better monitoring of globalisation, based on a better knowledge
of multinational enterprises and their activities, can only be done at European level. Also the
structured and regular exchange of micro-data between Member States, which is needed to
alleviate the burden on businesses, can only be established at the EU level.
Businesses undertake production, sales, research and development where it is the most
advantageous and not necessarily within certain national borders. This has to be taken into
10
There is a whole range of EU policy areas whose development and monitoring of implementation relies on
data covered by the business statistics domain: e.g.- employment, competitiveness, innovation, trade,
industry, regional, economic and monetary policy.
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account by statisticians. A correct statistical picture of the European economy can no longer
be given by simply adding up national figures. This underpins the need for a uniform and
coordinated EU action.
4.
OBJECTIVES
Effective tackling of the issues defined under Chapter 2 would necessitate a more robust and
streamlined legislative framework for European business statistics that should ensure
comparability and coherence of data in the future.
Three types of objectives are distinguished: general, specific and operational (or "measures").
Firstly, the general objectives indicate why a policy action is needed and are defined by
taking into account the different aspects of the problem. Within this general framework,
specific and operational objectives are then identified, illustrating respectively what should be
done to reach these general objectives, and how this should be done in practice.
With a view of achieving the identified objectives and ultimately solving the problem, a
number of different policy options are set out and analysed in the following chapters.
4.1
General objectives and links to horizontal EU objectives
In order to define the general objectives of the policy initiative, a broader view of the general
long term EU policies is taken within which the initiative should be placed. More
specifically, the monitoring of the goals set through the
Juncker Commission 10 priorities
requires harmonised and comparable European statistics to design policy initiatives to meet
the priorities and to monitor the implementation of these initiatives.
Furthermore, the
EU 2020 Strategy
envisages a Europe that would
"be turned into a smart,
sustainable and inclusive economy delivering high levels of employment, productivity and
social cohesion".
Monitoring the objectives set by the strategy requires an information
capacity that can deliver high quality, reliable and integrated European business statistics.
Moreover,
ESS Vision 2020
strategy invigorates the modernisation activities on European
statistics, already started in 2009 with the MEETS programme. The ESS Vision 2020
recognises the need to address emerging policy requirements for new statistical indicators and
calls for the more integrated and deeper analysis of new phenomena (such as globalisation)
and for better serving EU policies with high economic or social impact (e.g. trade or R&D
policy).
The Commission’s initiative on
Smart Regulation
underlines that the evaluation of EU
policies would lead to an increasing need for more relevant data (Commission
Communication COM (2013) 686 "Strengthening the foundations of Smart Regulation –
improving evaluation").
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The FRIBS is one of the key initiatives of the Commission's Regulatory Fitness and
Performance programme (REFIT). In that respect, it aims to increase the relevance of
business statistics, streamline and simplify, facilitate the use of modern and efficient data
production methods which would allow for the reduction of burden and costs in the long run.
The
European Statistical Programme (ESP) 2013-2017
defines business statistics as one of
the three pillars of the European Statistical System. The ESP underlined that business
statistics need to support the decision-making process and help European citizens and
businesses understand the impact of EU policies, focused on European businesses with an
increasing need for detailed and harmonised statistics. Addressing globalisation, the ESP also
envisaged among its objectives to enhance the indicators and statistical information available
for better measuring economic globalisation and global value chains. This should be done by
better analysing the global value chains through foreign trade and business statistics, in also
linking the statistical micro-data.
The FRIBS objectives set out below are fully in line and coherent with the objectives of the
ESP relating to European Business Statistics. In particular, the ESP emphasises the need for
more efficiency and effectiveness of statistical production processes; the provision of high-
quality statistics; the requirements to reduce the administrative and reporting burden.
The
European Statistical System Committee's Riga Memorandum
recognises the
strategic challenges that the business statistics is confronted with and the need for business
statistics to be reviewed regularly so that comparability and relevance of data is guaranteed.
The Riga Memorandum confirms that measuring of economic globalisation should be
anchored on consistent and aligned primary statistics on international transactions and
businesses.
Given this context, the general objective can be formulated as follows:
streamline and rationalise the European business statistics in order to better respond to
the changing user needs; simplify the respective European legislation; modernise and
increase the efficiency of the production and dissemination of high quality European
business statistics to make it fit for the future, while at the same time adhering to
impartiality, reliability, objectivity, scientific independence, cost-effectiveness and
statistical confidentiality.
11
4.2
Specific objectives
From the general objective defined above, five specific objectives can be derived:
11
Improve consistency;
As provided for by Art 338 TFEU
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Enhance flexibility;
Facilitate the use of innovative methods and sources;
Ensure quality of data production;
Reduce unnecessary burden on data providers.
The specific objectives listed above can be further translated into a number of operational
objectives. The operational objectives would be defined on the basis of the policy options that
will be set out in Chapter 5 of this report.
GENERAL OBJECTIVES
SPECIFIC OBJECTIVES
OPERATIONAL
OBJECTIVES
1. Streamline and
rationalise the European
business statistics;
2. Simplify the respective
European legislation;
3. Modernise and increase
the efficiency of the
production and
dissemination of high
quality European business
statistics
1. Improve consistency;
2. Enhance flexibility;
3. Facilitate the use of
innovative methods and
sources;
4. Ensure quality of data
production;
5. Reduce unnecessary
burden on data providers.
See Chapter 8
5.
POLICY OPTIONS
In order to solve the problem described in Chapter 2 Eurostat has considered several policy
options to achieve the objectives set out in Chapter 4.
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5.1
List of policy options
As a result of the consultations of stakeholders that took place in the context of the impact assessment
and the extensive discussions with Member States, the following list of policy options, on which the
detailed qualitative and quantitative assessment will focus, has been defined:
Option A - Baseline scenario – no EU policy change;
Option B - Implement legislative actions limited to certain business statistics domains,
including alternative options for the modernisation of Intrastat.
Option C - Modernisation of business statistics in a single framework (FRIBS) using a
mix of measures, including alternative options for the modernisation of Intrastat.
Baseline scenario – no EU policy change (Option A)
5.1.1
No action is taken and therefore the current legal framework of business statistics divided
into 10 heterogeneous legislative acts with the shortcomings described previously would
continue to exist.
This option A refers to the baseline scenario without any EU policy change and does not
require any particular measure or action.
5.1.2 Implement legislative actions limited to certain business statistics domains,
including alternative options for the modernisation of Intrastat. (Option B)
This option would implement the inclusion of additional data requirements, the identified
simplifications of the data requirements and certain modernisation of the statistical
production facilitating reduction of burden on data providers and minimisation of costs for
data compilers through separate amendments to the 10 legislative acts currently existing in
the area of business statistics. This option requires the use of different legal instruments to
modify existing legislation on certain business statistics domains. Depending on the scope of
the changes and the procedures foreseen in each individual legal act, an ordinary legislative
procedure or/and the adoption by the Commission of delegated or/and implementing acts
would be necessary.
For the collection of statistics on intra-EU trade (Intrastat), this option B includes four
possible sub-options -
SIMSTAT, Revised Intrastat, Single Flow
and a combination between
SIMSTAT and Revised Intrastat (explained below in 5.1.3)).
5.1.3 Modernisation of business statistics in a single framework (FRIBS) using a mix
of measures, including alternative options for the modernisation of Intrastat (Option C)
The structure of the framework integrating business statistics (FRIBS) project is designed in a
modular way, with the different components being discussed at different levels and adopted
by different means:
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-
On the one hand, all infrastructural elements would be part of a framework Parliament
and Council Regulation. This would cover the business registers (including the EuroGroups
Register), the basic data topics and their periodicity, the data sources, the exchange of micro-
data for Intrastat, data transmission, data quality, data confidentiality, etc. This framework
legal text would repeal the existing regulations for the various business statistics domains
which will then be integrated into FRIBS.
-
On the other hand, non-essential elements can be supplemented or amended by
delegated acts (e.g. detailed topics for all business statistics and for business registers as well
as subjects and characteristics of the dynamic statistics- ICT, CIS, GVC
12
), while the
technical provisions (e.g. detailed data requirements in terms of for instance, breakdowns,
statistical populations etc. , data quality reports and the technical provisions for the exchange
of data and micro-data) will be part of implementing acts. The procedure for the adoption of
these provisions will be included in the framework Parliament and Council Regulation..
Similarly to Option B, for the collection of Intrastat statistics four sub-options to lower the
burden on data providers are considered (SIMSTAT,
Revised Intrastat, Single Flow
and a
combination between
SIMSTAT and Revised Intrastat).
Thus, for Intrastat, option C (like option B) is sub-divided into the following four sub-
options:
Option C1: SIMSTAT –exchange of micro-data
Under the SIMSTAT sub-option, Member States remain responsible for compilation and
transmission of statistics on both intra-EU exports and imports. The novelty of the SIMSTAT
approach in comparison to current Intrastat is the creation of an additional data source. Each
Member State collects data on intra-EU exports and makes it available to other Member
States via a hub. Each transaction reported in one Member State may thus serve as a data
source for two Member States: for compiling the intra-EU exports of the exporting Member
State, and for compiling and/or verifying the intra-EU imports of the partner Member State.
To enhance the reusability of exports data, it is foreseen that it will need to have a quality
requirement on the collected trade (97 % like currently) and also information on the
importing company (VAT number of partner operator) and country of origin of goods. For
import statistics quality requirements will be for the statistical output rather than for the input
(collection), making it possible to use either national data collection on imports or exchanged
exports data or a combination of both.
Option C2: Revised Intrastat
12
GVC – Global Value Chains statistics
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Revised Intrastat means continuation of the current Intrastat system in a simplified form, but
adjusting the coverage requirements. In this option Member States will need to compile and
transmit to Eurostat statistics on both intra-EU exports and imports like they do currently.
Less data will be collected from both companies' flows or for either of the two flows,
depending on the final parameters of this option. The quality requirements will be defined
either through the amount of collected data or through the statistical output. This option
foresees neither mandatory exchange of micro-data nor collection of new data from
exporters.
Option C3: Single flow
Single flow differs from the other two options in the sense that Member States will need to
compile and transmit to Eurostat statistics only on intra-EU exports. The corresponding
imports statistics are created by mirroring. Consequently, this option foresees no data
collection on intra-EU imports. A quality requirement based on the amount of collected data
is maintained for the exports flow (97 %). This option foresees neither mandatory exchange
of micro-data nor collection of new data from exporters.
Option C4: Combination of SIMSTAT and Revised Intrastat
At the beginning of the so-called REDESIGN of Intrastat project these three different
approaches for Intrastat have been considered separately in order to assess their impacts. The
results from the extensive consultation exercise on Intrastat (and more specifically the
analysis of costs and benefits for NSIs) revealed that Single Flow is not a viable option for
MSs due to serious quality problems. On the basis of these assessments the preferred option
for Intrastat is going to be the combination of sub-options C1- SIMSTAT and C2- Revised
Intrastat, as decided by the ESSC in May 2016, in order to maximise the benefits while
mitigating the risks and costs. The ESSC decision was to combine elements from the
SIMSTAT option (mandatory exchange of micro-data) and from the Revised Intrastat option
(more flexibility in the choice of data sources used).
5.2
Discarded options
Taking into account the broad list of existing preliminary policy options, and against the
background of the results from the stakeholder consultations, an initial analysis was firstly
carried out regarding the overall practicability of all options. The goal was to identify any
options that are considered unsuitable, so as to discard them from the detailed assessment.
This analysis has led to the conclusion that the three options set out below are not suitable for
further assessment and were discarded. Additionally, it should be clarified that a
horizontal
recast
of the ten existing legislative acts governing European Business Statistics (as an
alternative to a
framework regulation)
has not been suggested as an option during the
stakeholders' consultation. The reason for that was the guidance provided by the
Interinstitutional agreement ((2002/C 77/01)) setting up the rules for the use of recasts and
stipulating that:
"A
new legal act shall not constitute a recast act if, …, it makes substantive amendments to
all the provisions of the earlier act, which it replaces and repeals."
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The undertaken initiative to modernise and streamline European Business statistics
necessitates substantive amendments to the provisions of the legislative acts currently in
force. That is why a framework regulation has been suggested instead of a recast.
5.2.1 Better enforcement and implementation of existing legislation (the Statistical
Unit Regulation- "Council Regulation 696/93") (Option B in the IAA)
In line with the Impact Assessment Guidelines, an option on the better enforcement and
implementation of existing legislation, possibly with improved guidelines should always be
considered. Current compliance by Member States, with existing legislation in the field of
business statistics, is generally very good. This however is less the case for application of the
Statistical Unit Regulation (Council Regulation 696/93) in the different business statistics
domains for which implementation problems can be observed in many Member States.
Currently, most of the Member States assume that legal units are identical to enterprises and
thus take a juridical/administrative view instead of an economic view. This is not in line with
the organisational development of the economy. Many enterprises consist of more than one
legal unit. Moreover, several Member States have indeed implemented the Statistical Unit
Regulation, but not in a uniform way. Inconsistencies resulting from different applications of
the Statistical Unit Regulation have a considerable impact. The enterprises stored in the
national business registers are not harmonised across countries and the resulting business
statistics could be distorted. As mainly large entities are concerned, changes to the business
statistics due to the harmonised implementation of the Statistical Unit Regulation are
expected to be significant.
This option therefore focusses mainly on improving the application of the Statistical Unit
Regulation (Regulation No 696/93).
However, given the serious impacts of the non-compliance or non-uniform compliance with
the Statistical Unit Regulation and the urgent need to tackle this issue, a decision was taken at
the end of 2014 to immediately address the issue and support further Member States' efforts
in better complying with the existing Statistical Unit Regulation through national action plans
supported by EU grants and by clarifying existing definitions through developing operational
rules. These action plans have already been put in place and are supposed to lead to full
compliance with the Statistical Unit Regulation and to quality improvements of European
business statistics. Therefore, for the time being no further non-legislative measures could be
implemented to improve the business statistics. All in all, due to the measures already taken
to improve the application of the Statistical Unit Regulation, this option has become obsolete.
5.2.2 Integration of business statistics in a single framework (FRIBS) using a mix of
measures and including one option (SIMSTAT) for the modernisation of Intrastat
(Option D in the IAA)
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This option would implement the simplification (burden and cost reduction) and
modernisation as well as respond to additional user needs. In addition, it would allow for the
alignment and harmonisation of the collection, compilation, transmission and dissemination
of business statistics, with a much more integrated and cross-cutting output for users.
This option also envisages that clearer and better implementable definitions of the statistical
units will be included in FRIBS. Regarding the modernisation of intra-EU trade in goods
statistics this option only encompasses SIMSTAT.
Thus, this option is characterised by two major shortcomings. Firstly, (as also explained
under 5.2.1) due to the serious impacts of the non-compliance with the Statistical Unit
Regulation and the urgent need to address the problem, measures have already been taken to
address the non-compliance and support further Member States' efforts in better complying
with the existing Statistical Unit Regulation. Therefore this option has become obsolete in
terms of its objective to include in FRIBS better implementable definitions of the statistical
units. Secondly, limiting the modernisation of Intrastat only to the SIMSTAT sub-option is
too restrictive. The NSA consultations have demonstrated that different alternatives for the
modernisation of Intrastat should be considered, (SIMSTAT, Revised Intrastat, Single Flow,
or a combination of them). Consequently, it is better to allow for an analysis covering all
three sub-options for the modernisation of Intrastat. Against this background, this option has
been discarded.
5.2.3 Implementation of a non-legislative strategy for the rationalisation of the
statistical production of business statistics and the reduction of the burden on
businesses
This option would focus on the better management of the production of business statistics
from the procedural point of view, looking for synergies in the collection and compilation
processes, enhancing the access and exploitation of existing administrative sources and
promoting the use of modern tools. This option would require the use of agreements between
Eurostat and the NSA or any other kind of bilateral or multilateral instruments outside of
legislation.
However, given the various pieces of legislation underpinning the European system of
business statistics, not many corrective actions could be undertaken without revising one or
more elements of the legal texts. For instance, definitions are mainly fixed by legislation,
which means that reducing the existing inconsistencies in definitions of certain variables
would imply reviewing legislation. This would be contradictory with the non-legislative
nature of the policy option under consideration and this is why this option has been discarded.
Additionally, the exchange of micro-data for intra-EU trade in goods statistics (Intrastat),
which has a considerable potential for burden reduction on EU businesses, could not be
undertaken unless a legal framework is put in place. Furthermore, the budgetary provisions
for the statistical production of the NSAs are determined on the basis of legislative acts,
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hence any initiatives which have cost impacts would be difficult to implement without a legal
frame.
6.
IMPACTS OF THE POLICY OPTIONS
Each of the shortlisted policy options presented in Chapter 5 has been assessed on impact of
the actions on specific stakeholders (data users, data providers – businesses -, and data
compilers). These assessments use on the one hand detailed qualitative information collected
from the stakeholders and on the other hand quantitative information collected from data
providers and data compilers. Given the fact that all expected benefits e.g. from the improved
availability of data could not be monetised, an overall 'net
benefit'
in monetary terms cannot
be obtained for each of the policy options.
Impacts
Option A:
Baseline scenario: no EU policy change
The baseline scenario foresees a continuation of the current system in terms of legislation, as
well as the structure and practices of the collection, compilation, transmission and
dissemination of statistical information on Member States' economic activity of businesses.
No action is undertaken to improve the degree of consistency of business statistics across the
EU and their quality, nor are attempts made to alleviate administrative burden on data
providers. The problems encountered in the current situation continue to persist, as the
current
stovepipe
approach is not adapted anymore to the changes in the business
environment and changing user needs. Flexibility to more adequately and timely respond to
these needs is not improved and it is not possible to use new methods or procedure to fulfil
these new user needs.
Based on the results of the stakeholders' consultations, the total cost of the production of the
business statistics by the NSAs is estimated to be EUR 290 million annually and the total
burden by data providers at EUR 689 million.
Effectiveness of fulfilling the objectives of this policy initiative and impact on
stakeholders
This option does not fulfil any of the objectives set for this policy initiative. The problems
identified under chapter 2 e.g. the lack of responsiveness of business statistics would remain
unresolved.
Efficiency
The combination of domain-specific Regulations and non-integrated production processes
contributes to inefficiencies of the business statistics system. The current system maintains
overlaps and redundancies in data compilation. The non-integrated system limits the potential
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for NSI or Eurostat to reduce such overlaps. The current system cannot really eliminate
inefficiencies. As there will not be any change to the statistical system, no additional costs
(for redevelopment and adaptation of the statistical system) for NSI are expected in the short
term on top of the current running costs for maintaining the system. However, possibilities to
address current inefficiencies would be limited.
Changes to the sources used for compiling the statistics will be limited as access to
administrative sources will remain at its current level and the use of alternative sources such
as big data and new procedures such as data linking will not be possible. The burden on the
data providers will remain unchanged. The relevance of statistical information will become
increasingly obsolete.
Coherence
The baseline scenario is not coherent with the European Statistics Programme 2013-2017
(and its ongoing extension) since the ESP already envisaged a number of modernisations and
extensions of data collection in business statistics which would not be able to be put in place
without a policy change - under this Option A.
Option B:
Implement legislative actions limited to certain business statistics domains
The second policy alternative Option B foresees the amendment of some or all of the current
legal acts in force. Hence, current data requirements could be simplified with the aim of
reducing the cost of the NSIs and the burden on data providers. Also additional new data
requirements can be added for better satisfying the user needs. All this would be organised
through updates of the separate legislative acts currently in use for business statistics.
Consequently, the production processes at Member State level may continue to be organised
by different statistical domains.
However, the streamlining and harmonisation across all business statistics would hardly be
achieved. Separate legal texts and separate statistical production processes would provide
neither the necessary consistency across statistical domains nor allow for an integration of the
collection, compilation, transmission and dissemination of business statistics. In addition, this
option would not permit the users to use the statistical output in an integrated way.
Effectiveness of fulfilling the objectives of this policy initiative and impact on
stakeholders
This option may fulfil most of the pre-identified objectives. In fact, a series of distinct
legislative changes enables streamlining and rationalising the production of business
statistics, somewhat reducing unnecessary burden on data providers. These changes could
also incorporate the provision of EU-wide common infrastructure tools (e.g. business
registers) to increase overall quality, accuracy and comparability of business statistics..
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The legislative changes foreseen under this option significantly impact all categories of
stakeholders. This option opens up some possibilities for data compilers to use and combine
new/innovative methods for data compilation. It also allows for improving the production
processes and statistical output quality to a certain extent. The maintenance of the various
domain-specific Regulations in fact hampers the possibilities to introduce and fully apply
innovative methods, and as such, also has an impact on the efficiency of the underlying
statistical processes. The maintenance of fragmented production processes and data
collections at the level of Member States counterweights the increased consistency which
eventually could be achieved through this option. If Eurostat continues to request data from
Member States using the traditional fragmented
stovepipes,
NSIs will continue to have
insufficient resources for modernising their systems.
This option does not reduce the fragmentation of the business statistics system and it will not
fully serve the user looking for consistent business statistics. The existing domain-specific
Regulations require Eurostat to apply similar or identical concepts, methods and standards
across domains for ensuring the quality of the output across the various domains and for
increasing its comparability. There is a certain degree of hampering of desired results in view
of the fact that coordination of implementation between statistical domains and with other
operational objectives is not optimised (which e.g. impacts on opportunities for re-use and
linking of data). This is not only a temporary effect but rather a continuous shortcoming. For
instance, the removal of inconsistencies in the definitions of variables would create additional
possibilities for improved re-use of data. In a non-integrated approach these inconsistencies
are not necessarily solved in a sustainable way (e.g. there is a risk they will diverge again
after future adaptations of the separate legal acts), so that the re-use of data in the long run is
not sufficiently ensured. Unnecessary overlaps and redundancies in the data collections
would remain. The continuing legal fragmentation would therefore still hamper Eurostat’s
possibilities to ensure the quality of produced data in terms of comparability and coherence.
Due to the need to amend domain specific regulations, also this option has considerable limits
in responsiveness to changing user needs arising from societal changes.
In addition, any European level future changes to the contents of the data compilation and
data output to better satisfy users’ needs will be required to be legally incorporated across the
10 domain-specific legislative acts, through separate legal procedures. This multiplies the
efforts and resources needed for preparing and managing these legal processes. For this
reason, considerable limits in responsiveness to business and societal needs at the EU level
continue to be in place. This policy option therefore does not improve the responsiveness of
business statistics to user needs. The national production processes would only be integrated
across statistical domains as far the data requirements are kept consistent over possible
changes to individual legal acts. All in all, this option might achieve some degree of
harmonisation across the 10 different business acts, however this would be a cumbersome
and partial solution only.
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Efficiency
Assuming that all of the existing legal acts would be amended, current user needs could be
addressed in a satisfactory manner. Given that new data requirements would be added,
investment costs to adapt the current systems and increases in the initial operational costs
would be incurred.. Bringing non-harmonised solutions, this option B would reduce the
existing inconsistencies (present under the baseline scenario), but only to a limited extent.
The additional implementation costs for NSAs will be partly offset by simplifications to the
data requirements and from the modernisation of Intrastat. The additional costs, incurred by
NSAs, for implementing this policy option are estimated to represent an annual increase on
average per Member State by:
6.8 % (or EUR 700 000) of the annual operating costs for sub-option B1 (SIMSTAT);
6.7 % (or EUR 691 000) of the annual operating costs for sub-option B2 (Revised
Intrastat);
4.3 % (or EUR 436 000) of the annual operating costs for sub-option B3 (Single
Flow);
Between 6.7 % (or EUR 691 000) and 6.8 % (or EUR 700 000) of the annual
operating costs for sub-option B4 (combination of SIMSTAT and Revised Intrastat)
The estimated one-off investment costs per Member State are:
EUR 1.9 million for sub-option B1 (SIMSTAT);
EUR 1.25 million for sub-option B2 (Revised Intrastat);
EUR 1.16 million for sub-option B3 (Single Flow);
Between EUR 1.25 million and EUR 1.9 million for sub-option B4 (combination of
SIMSTAT and Revised Intrastat)
Applying a cost model (See Annex IV) for calculating the net present value of the total EU-
28 costs (NSIs' one-off investment costs + NSIs' annual implementation costs) over a 10-year
implementation period, the following results have been obtained:
sub-option B1: net cost increase of EUR (+) 103 million,
sub-option B2: net cost increase of EUR (+) 83 million;
sub-option B3: net cost increase of EUR (+) 29 million;
sub-option B4: between minimum net cost increase of EUR (+) 83 million and maximum net
cost increase of EUR (+) 103 million.
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The new data requirements foreseen would increase the burden on the respondents (data
providers). In order to off-set this increase in burden, simplifications would be introduced in
the existing requirements of several business statistics regulations. Especially the
simplifications or collaborative ways of data production foreseen in statistics on intra-EU
trade (Intrastat) would enable the Member States to materialise the untapped potential for
burden reduction on data providers. The extent of the burden reductions will depend on the
way the final combination of sub-options chosen for the modernisation of Intrastat is
implemented by each Member State following the subsidiarity principle. However, under
each of those sub-options, the burden reduction would be more than off-setting the burden
increases associated with the new data requirements. The burden reductions that may be
introduced are the same for Option C, as further elaborated below.
Coherence
This Option B which foresees the implementation of legislative actions limited to certain
business statistics domains is in line with the ESP 2013-2017 (and its extension). Namely, the
measures planned in the ESP 2013-2017, regarding business statistics, could indeed be
introduced by targeted legislative actions in the respective specific business statistics
domains.
Option C:
Modernisation of business statistics in a single framework (FRIBS) using a mix of
measures
The third policy alternative proposes replacing the 10 existing statistical EU legislative acts
for business statistics by a common coherent framework, by repealing the existing domain-
specific Regulations, simplifying and replacing these with a single legislative package. This
package covers a common statistical infrastructure (i.e. the business registers, the
EuroGroups Register, the basic data topics, the data sources, the exchange of micro-data for
Intrastat, data transmission, data quality, data confidentiality, etc.) which will then create the
possibility to integrate the production processes at national and international level. The
introduction of measures that remove the
stovepipes
in the production processes of NSIs in
combination with coherent business statistics legislation, will lead to the most comprehensive
harmonisation of European business statistics. Similarly to Option B, for the collection of
statistics on intra-EU trade (Intrastat), this option C also includes the three alternative sub-
options for the modernisation of Intrastat.
This option would implement the simplification and modernisation and create a system which
facilitates increased cooperation in statistical production to respond to cross-cutting statistical
needs, the reduction of burden for data providers and the minimisation of cost impacts for
data compilers. In addition it would allow for better inherent consistency, the integration and
harmonisation of the collection, compilation, transmission and dissemination of business
statistics, with a much more harmonised and cross-cutting output for users.
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Effectiveness of fulfilling the objectives of this policy initiative and impact on
stakeholders
This is the only option that enables to fulfil all objectives identified for the policy initiative.
The integration of EU legislation on business statistics and measures to enable the better
integration of national production processes contribute to a higher responsiveness of the
business statistics to changing data needs due to economic and societal changes. When new
(cross-domain) issues arise, Eurostat can effectively use the overarching framework
legislation instead of changing various domain-specific legislations. At the same time, the
production processes for business statistics get more agile for accommodating new cross-
domain issues, which will become increasingly important. As the framework Regulation
establishes a European Network of Business Registers the central role of the European
business registers in business statistics is enhanced making it easier to produce additional
statistics by means of data linking. All this responds well to the needs of users and
policymakers asking for more flexibility of the business statistics system. In addition, this
option allows for the creation of a system which is more forward looking, with best potential
for modernisation and collaborative approaches to statistical production and more openness
for accommodating new and innovative production methods for statistics.
A reduction of fragmentation in data production processes in Member States creates
incentives to use and combine alternative data sources and methods across various domains.
The framework legislation will thus contribute to an increasing use of administrative sources
and registers as input for business statistics. Such a focus not only reduces the cost of data
production but also the response burden of data providers. Many Member States already
allow their NSIs to access these sources, and a strengthened EU support could provide further
leverage to NSIs to convince their governments to expand the use of these sources.
Additional methodological work could be done to assess the quality of administrative or big
data sources, to harmonise the concepts used with those used for the production of business
statistics and then overall to decrease the production costs.
Option C provides in addition more benefits for users in terms of data quality, transparency,
comparability and additional statistics (e.g. through linking). In addition, the effectiveness to
ensure the quality of data production and output is maximised. The framework legislation
inherently helps Eurostat in increasing the consistency of statistical output across different
domains for instance by using the same definition for the same concept. Integrating business
statistics in a harmonised data structure also makes the existing links between these statistics
more apparent and NSIs will then adapt their production processes to take these links into
account and profit from the harmonisation. This framework also facilitates to deal effectively
with possible newly arising quality concerns that could come from innovative methods, like
the use of new or big data sources. At the same time, the reduction of fragmentation of the
production processes in Member States will lead to better data quality as more harmonised
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standards are used. For new cross-domain data production the quality can be better ensured
through the effective integration of EU legislation. 85% of respondents in the first public
consultation of data users have indicated that a single harmonised regulation and quality
requirements would further increase their already overall high level of confidence of quality
in European business statistics. Although improvements in quality of statistical data are
highly appreciated by users, they also bring about breaks in time series resulting in problems
to use the data in the short term. However, over time these problems will gradually disappear.
In addition, some existing data requirements were cut to make room for new data
requirements. For users who need these data for their analyses this could pose problems.
However, the main stakeholders were consulted on the proposed data requirement
simplifications and understood the need to balance the cost and burden as much as possible.
This policy option foresees the introduction of new data requirements. The additional data
requirements to be introduced by FRIBS are proposed on the basis of extensive consultation
of the main stakeholders and based on the outcome of pilot studies carried out to ascertain the
feasibility of the data collection assessing the benefits and the costs. The usefulness of the
additional data requirements has been confirmed by the outcome of a second public
consultation of data users.
Nearly 85% of respondents to the first public consultation of data users indicated that a
single harmonised regulation and quality requirements (option C) would further increase
their confidence in European business statistics, and that especially those elements that
aim to increase consistency across all business statistics domains and/or across countries
are very welcomed. 75% of the respondents chose Option C as their preferred policy
option. Concerns regarding some elements of this option that were raised by few data
users include less consistency with previous data sets (breaks in time-series) and a
general decrease in quality of the currently existing statistics in view of the extension in
data requirements. The majority of users however see the extension in data requirements
as a positive evolution.
For the different sub-options the impacts on the stakeholders are included in the paragraphs
below. The qualitative assessment relies on the SWOT (Strengths/Weaknesses
Opportunities/Threats) tool and is based on consultation of the National Statistical
Authorities for identifying positive and negative impacts which are expected to follow from
the Member States' implementation of the sub-options.
Sub-option C1:
SIMSTAT
Using the SIMSTAT sub-option for Intrastat has a substantial positive impact on the quality
of the data concerned as the comparability of statistical data across Member States will be
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enhanced as the exchange of micro-data allows for identifying asymmetries at the micro-data
level. In addition, it encourages the harmonisation of production methods across Member
States. SIMSTAT implementation will increase the flexibility in the data collection and the
relevance of the data thanks to the use of multiple data sources. The availability of the
identification number of the importer improves the re-usability of the data. The results of a
SIMSTAT pilot study indicate that smaller economies would gain information when using
exchanged instead of nationally collected data. Data providers are sensitive to data
confidentiality so the security of micro-data exchange between National (Statistical and
Other) Authorities must be ensured to address their concerns.
Sub-option C2:
Revised Intrastat
Under the Revised Intrastat sub-option Member States would continue compiling their own
statistics independently. This option implies flexibility in both collection and compilation
methods: if an exports-driven approach is chosen (Member States choose to maintain the
coverage rate for intra-EU exports), the impact is expected to have similarities to SIMSTAT
because there is dependency on other NSAs. However, as this option does not foresee micro-
data exchange the impacts are assessed to be less pronounced than in SIMSTAT. As the share
of the estimations increases, quality of data is lower. The current level of trust of data
providers over data security will not be affected.
Sub-option C3:
Single Flow
The Single Flow sub-option is considered to cause significant quality problems. As only one
flow is collected and import statistics are derived from export statistics, it will no longer be
possible to check the quality of the import data. Comparability over time will be seriously
hampered as there will be significant breaks in series of import data. This could have a
serious impact on trade balance and other relevant macro-economic statistics. The reliability
and accuracy of imports data will be negatively affected because Member States are not able
to control the data sources of the partner countries. It will not be possible to compile statistics
on characteristics of businesses engaged in import activities anymore (Trade by enterprise
characteristics (TEC)) as imports could not be allocated anymore to individual companies.
Negative effects on timeliness of data availability are expected since data on intra-EU
imports will exclusively depend on other countries. The current flexibility of the system of
collection and compilation will be reduced because all Member States have to collect the
same data elements and to apply the same methodology for estimation of imports, without the
possibility to explore different data sources. NSAs will be fully dependent on NSAs of
partner Member States for the compilation of statistics on intra-EU imports.
Sub-option C4:
combination of SIMSTAT and Revised Intrastat
This sub-option would combine elements from both SIMSTAT and from Revised Intrastat.
From SIMSTAT, the mandatory exchange of micro-data feature would be taken. While from
Revised Intrastat, the key feature taken would be more flexibility in the choice of data
sources used, meaning that less data will be collected from companies' imports and exports
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flows or for either of the two flows. The impact of this combined sub-option should be a
reduction of the response burden in Intrastat of at least 25 % which would hence lead to a
reduction of at least 13.5% of the overall burden of business statistics (for FRIBS as a whole)
with a potential for an even larger reduction of burden. Sub-option C4 would provide a sound
level of quality in response to stakeholders’ (i.e. users and respondents) needs. It would also
allow for flexibility in data sources and compilation methods used by Member States and
would prepare international trade statistics for the challenges brought by globalisation.
Efficiency
The efficiency gains to be made by including all existing business statistical legislation in an
overarching framework legislation replacing the currently existing domain-specific
Regulations will be substantial. The lengthy procedures currently associated with changing
any element in business statistics legislations are inefficient. Streamlining and overall
reducing these procedures under one framework legislation will lead to considerable
efficiency gains for NSIs and also Eurostat and to fulfilling emerging user needs in a timelier
manner. It creates the possibilities to develop more integrated data production processes and
to use more innovative and alternative data sources, efficiency gains can also be expected on
the response burden on businesses acting as respondents.
Efficiency gains for the business statistics system are possible due to the combination of legal
integration and the better integration and modernisation of national production processes.
This policy option explicitly opens the possibility for NSIs to modernise their systems and to
reduce costs. The integration of data production processes in a more coherent manner is
supported by the integration of legal instruments at the EU level. NSIs can use innovative and
more cost-efficient methods of data production across the better integrated domains. This will
further contribute to an expected reduction of costs for NSIs in the long run and to the
reduction of burden on businesses, but it is not possible at this stage to quantify these
reductions.
Despite these efficiency gains for the business statistics system for data production and
dissemination, NSAs point out that there are cost increases in the short-term due to the
necessary investments needed. This is mainly due to changes from heterogeneous processes
to more integrated ones using more harmonised standards and methods. The costs for changes
towards harmonisation and consistency are to be carried by NSAs, who will have to revise
and modernise their statistical processes to accommodate the more consistent requirements.
In addition, the new data requirements introduced by the framework Regulation and its
implementing/delegated acts to fulfil longstanding user needs will also increase the costs for
the data compilers.
In general terms, all Member States will face one-off implementation costs for adapting their
national statistical systems to the new data requirements in the short run. The implementation
of the modernisation and rationalisation possibilities offered by FRIBS will also entail initial
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investments before benefits, increased productivity and improved cost efficiency can be
reached.
The countries most affected by the changes are those that either do not yet collect the
additional data requested by FRIBS for national policy purposes or that have not yet
participated in (pilot) actions for preparing the new data requirements financed by the
Commission by means of grants. In the short term those countries – representing a minority
of the Member States - would indeed face increases in the costs of compiling business
statistics.
The FRIBS Regulation is an output-oriented Regulation, meaning that it does not prescribe
the Member States which sources (input) need to be used for compiling business statistics,
but it enforces the correct implementation of agreed definitions and data requirements for
ensuring the comparability of the statistical output. Thus, Member States are free to choose
the most cost and burden efficient data sources and production methods to provide the data
requested. Due to the efficiency gains from other provisions of FRIBS which do not result in
quick cost reductions, but will take more time, these initial cost increases are expected to be
compensated in the medium and long run.
A number of provisions are foreseen to alleviate the possible initial cost and burden impacts
of FRIBS. For example, the current simplifications exempting smaller countries from
delivering all the requested data will be extended to the domains of PRODCOM, business
services and global value chain statistics. Additionally, financing is foreseen (within the
limits of budget availability) for actions to develop new data collections or to develop
modernised data production processes. Furthermore, the provisions for improved access to
administrative sources, a new data source for compiling the intra-EU trade in goods statistics
at the national level (exchanged micro-data) and consistent definitions allowing for integrated
surveys are examples of the rationalisation and modernisation potential offered by FRIBS.
This is creating cost reduction possibilities after the initial investment phase.
The calculations for the long term development of costs (see below) were done on the basis
of estimates at the European Statistical System level. Due to the lack of factual evidence on
how the FRIBS implementation will be done in each Member State, it is impossible to
estimate whether the countries with the highest increase in initial costs will be fully
compensated by efficiency gains induced by FRIBS in the long term.
The additional implementation costs for NSAs will be partly offset by simplifications to the
data requirements and from modernisation of Intrastat. The additional costs, incurred by
NSIs, for implementing this policy option (similarly to Option B) are estimated to represent
an annual increase on average per Member State by:
6.8 % (or EUR 700 000) of the annual operating costs for sub-option C1 (SIMSTAT);
6.7 % (or EUR 691 000) of the annual operating costs for sub-option C2 (Revised
Intrastat);
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4.3 % (or EUR 436 000) of the annual operating costs for sub-option C3 (Single
Flow);
Between 6.7 % (or EUR 691 000) and 6.8 % (or EUR 700 000) of the annual
operating costs for sub-option C4 (combination of SIMSTAT and Revised Intrastat).
The estimated one-off investment costs per Member State are:
EUR 1.9 million for sub-option C1 (SIMSTAT);
EUR 1.25 million for sub-option C2 (Revised Intrastat);
EUR 1.16 million for sub-option C3 (Single Flow);
Between EUR 1.25 million and EUR 1.9 million for sub-option C4 (combination of
SIMSTAT and Revised Intrastat)
The results derived from the targeted NSAs' consultation on the additional data requirements
show that the changes in annual operating costs do however vary significantly across
Member States. For instance, the reported changes in annual operating costs, as forecasted by
NSIs during the targeted consultation on the changes to the data requirements, due to the
introduction of the new data requirements and deletion of obsolete data requirements range
from -1 % to +20 % across Member States. After the initial investment costs and the
increases in annual operating costs, considerable efficiency gains should however be reached
by NSAs using more integrated processes. These efficiency gains are expected to
significantly compensate for the initial investment and annual operating costs incurred in
NSAs. A model for estimating the impacts on costs is presented in the box below. The
Commission has already contributed around EUR 13 million in the form of grants in order to
fund the additional costs that NSIs face in order to prepare and adapt their production systems
to the changes introduced by the framework Regulation and will continue to make available
financial resources in order to facilitate the implementation of the framework Regulation. It
should moreover be noted that part of the increased costs for data compilers is related to
actions reducing the burden on data providers.
To summarise, the Option C impacts both the annual operating costs of the production of
business statistics and results in initial investments costs (one-off implementation costs) for
the NSA. The simplifications and modernisation possibilities included in the Option will
allow for a gradual reduction of the running cost and the initial investment costs will be partly
borne by the Commission (grants to be given within the constraints of the Commission
budget).
Applying a cost model (See Annex IV) for calculating the net present value of the total EU-
28 costs (NSIs' one-off investment costs + NSIs' annual implementation costs) over a 10-year
implementation period, the following results have been obtained:
sub-option C1: net cost increase of EUR (+) 9 million,
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sub-option C2: net cost savings of EUR (-) 10 million;
sub-option C3: net cost savings of EUR (-) 62 million;
sub-option C4: between maximum net cost savings of EUR (–) 10 million and maximum net
cost increase of EUR (+) 9 million.
The new data requirements introduced to fulfil longstanding user needs will increase the
burden on data providers in the same way as for option B. The introduction of the new data
requirements would amount to a burden increase of about EUR 24 million. This increase will
be compensated by the simplifications and rationalisations foreseen in the different domains
and by the modernisation of Intrastat.
Based on information collected from the respondents of the surveys regarding the
administrative burden, the burden reduction which could be realised would depend on the
approach chosen for the intra-EU trade data. Notwithstanding that the final approach chosen
for the intra-EU trade will try and maximise the burden reduction while guaranteeing the
quality and especially the timely availability of the statistics on intra-EU trade, the total
potential burden reduction for FRIBS (for the EU on total) is estimated to be:
26.8 % (or EUR 184 million ) for sub-option C1 (SIMSTAT);
12.1 % (or EUR 83 million) for sub-option C2 (Revised Intrastat);
33.6 % (or 231 million) for sub-option C3 (Single Flow);
13.5 % (or EUR 93 million), at least, for sub-option C4 (combination of SIMSTAT
and Revised Intrastat)
Some of the additional data requirements covered by the FRIBS Regulation would increase
the burden on SMEs especially with regards to the extension of business statistics to cover
more services than were previously not covered. This is, however, to respond to a long-
standing specific user need to enable the monitoring of European and national policy actions
with regards to SMEs for which sufficient information is currently lacking. The data
compilers are moreover encouraged to use as much as possible existing administrative data
(e.g. from tax authorities) to respond to this data request and to minimise the use of surveys
and therefore limit the burden on SMEs.
The simplifications foreseen by FRIBS in the area of intra-EU trade statistics, on the other
hand, could reduce the burden for SMEs. However, for intra-EU trade statistics the
determining factor whether to be obliged to report or not is not the size of the company but
the trade volume. Though usually one can expect to have some sort of correlation between
the two, small businesses can have large trade volumes while large companies have very little
or no trade at all. The intra-EU trade statistics system however benefits from the availability
of VAT data on intra-EU sales and purchases which allows exempting the smallest traders
from intra-EU trade statistics reporting.
The ESSC agreed on 18 May 2016 on the principle of burden neutrality on exporters. This
could mean in practice that additional burden which exporters would face due to reporting of
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the new data elements needed for exchanging the micro-data could be compensated by
lowering the overall minimum collection rate (threshold) of exports. Based on estimations,
the burden neutrality could be ensured by lowering the collection rate from 97% to 95% of
the total exports. In this case the exporters who would be exempted from reporting would be
the smallest ones of which the majority can be expected to be SMEs. In addition, any
reduction of the imports data collection would mostly be in favour for the SMEs so the
overall impact on the SMEs should be very positive. However, the system will be all-
encompassing; there might always be individual SMEs who may not benefit from burden
reductions and may even face more burden.
Nevertheless, any possible burden increases on SMEs would be kept limited also because
many countries will use administrative data for fulfilling new data requirements, in some
cases combined with model-based estimation methods. In addition, some of the new data
requirements (e.g. regarding Global Value Chains) are specifically directed to large
enterprises (there is a threshold in terms of employment) and thus the SMEs are protected
from excessive burden. Additionally, for the new data requirements for which surveys have
to be organised, the practice to cover only a sample of small enterprises will also be applied
(whereas large enterprises are covered exhaustively). What is more, the replies from the
targeted consultation of the data compilers on the additional data requirements introduced by
FRIBS indicated that the data compilers would make particular efforts to minimise the
burden on SMEs for those new data requirements that are more burdensome on respondents.
Coherence
Option C is fully coherent with the ESP 2013-2017 and its extension to 2020. Modernisation
of business statistics in a single framework (FRIBS) would fully and consistently address the
measures and novelties envisaged for European business statistics by the ESP and its
extension.
7.
COMPARISON OF OPTIONS
In this chapter the proposed three policy options are compared. This will be done using the
thorough impact analysis as outlined in the previous chapter. The following table gives a
summary overview of the impacts of the different policy options on the different
stakeholders.
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Table 4: Comparison of policy options
Option A: No policy change -
baseline scenario
Net effects for data users
Qualitative assessment of
impacts on data users
-
Users remain not fully satisfied.
(the more new emerging user
needs, the less responsive and
accommodating the current
system)
No impact
Current annual burden (total
EU): EUR 689 million
Continuous high burden on
data providers
Option B: Implementation of legislative actions limited to certain business
statistics domains
+
A non-integrated approach could bring about similar advantages as an integrated
approach; action that touch upon different domains are however expected to lead
to less advantages (in terms of consistency, harmonisation etc.) in view of the
risks of non-optimisation of the coordination of implementation.
Option C: Modernisation of business statistics in a single framework (FRIBS)
++
The harmonised European business statistics package fit for the future and agile
enough to react to policy needs.
Net effects for data providers
Expected impact in the annual
administrative burden
+
Significant burden reductions (total EU) compared to option A
++
Substantial burden reductions (total EU) compared to option A
26.8 %
( or EUR 184 million ) for sub-option C1 (SIMSTAT);
12.1 %
( or EUR 83 million ) for sub-option C2 (Revised Intrastat);
33.6 %
( or EUR 231 million ) for sub-option C3 (Single Flow);
13.5 %
(or EUR 93 million), at least, for sub-option C4 (combination of
SIMSTAT and Revised Intrastat)
What is more, the integrated Business statistics should lead to an additional
reduction of burden over time as fewer questionnaires will be used. More
administrative and innovative data sources will be used, definitions of variables
will be more aligned, (which is not likely to occur under the non-integrated
option-B).
-
Changes in classifications and definitions require initial efforts from the
businesses to adjust their responses to the new requirements.
26.8 %
( or EUR 184 million ) for sub-option B1 (SIMSTAT);
12.1 %
( or EUR 83 million ) for sub-option B2 (Revised Intrastat);
33.6 %
( or EUR 231 million ) for sub-option B3 (Single Flow);
13.5 %
(or EUR 93 million), at least, for sub-option B4 (combination of
SIMSTAT and Revised Intrastat)
Qualitative assessment of other
impacts on data providers
Net effects for data compilers
Expected impact on the Annual
operating cost
0
--
separate legislative changes bring new risks of different time schedules as well as
divergent concepts and definitions.
No impact
Current annual operating cost:
Around EUR 10,5 million per
Member State on average,
ranging from EUR 1,3 million
to EUR 70,6 million per
Member State; EUR 290
million for the EU on total
6.8 % (or EUR 700 000 per MS) of the annual operating costs for sub-option B1
(SIMSTAT);
6.7 % (or EUR 691 000 per MS) of the annual operating costs for sub-option B2
(Revised Intrastat);
4.3 % (or EUR 436 000 per MS) of the annual operating costs for sub-option B3
(Single Flow);
Between 6.7 % (or EUR 691 000) and 6.8 % (or EUR 700 000) of the annual
operating costs for sub-option B4 (combination of SIMSTAT and Revised
Intrastat)
At present, but the figure is potentially higher in the long run for this option since
the (temporary) non-integrated business statistics are less efficient and will lead
to a need of additional resources to cope with the data requirements.
Between EUR 1.16 million and EUR 1.9 million on average per Member State
(or between EUR 32 million and EUR 52 million for the EU on total)
-
Exchange of micro-data might add challenges such as complexity of data
compilation and dependency on other countries.
6.8 % (or EUR 700 000 per MS) of the annual operating costs for sub-option B1
(SIMSTAT);
6.7 % (or EUR 691 000 per MS) of the annual operating costs for sub-option B2
(Revised Intrastat);
4.3 % (or EUR 436 000 per MS) of the annual operating costs for sub-option B3
(Single Flow);
Between 6.7 % (or EUR 691 000) and 6.8 % (or EUR 700 000) of the annual
operating costs for sub-option C4 (combination of SIMSTAT and Revised
Intrastat)
This increase should however be counterbalanced by regular efficiency gains of
the data compilers to be expected through the continuous modernisation of
national production processes.
Between EUR 1.16 million and 1.9 million on average per Member State (or
between EUR 32 million and EUR 52 million for the EU on total)
+
Exchange of micro-data might add challenges such as complexity of data
compilation and dependency on other countries. These are however largely
compensated by benefits coming from actions such as enhancement of the role of
business registers (incl. unique ID), reduction of inconsistencies in definitions of
variables etc.
+ slightly positive impact
++ positive impact
Expected one-off implementation
cost
Qualitative assessment of other
impacts on data compilers
EUR 0
none
-- negative impact
- slightly negative impact
0 neutral impact
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Option A is keeping the status quo. This option does not look acceptable as the need for
modernising European Business statistics was already recognised in 2008, mainly as the
current business statistics serve the policy and other user needs only partially. Since then
investments have been made to accelerate the modernisation of the system. These investments
would be lost if the current system of European Business Statistics is maintained. Policy users
would be increasingly dissatisfied with the data disseminated now and turn to other data
sources. Over time, this would deteriorate the quality of European or national policy
decisions. What is more, this option is not coherent with the ESP 2013-2017 and its extension
(under preparation) because the modernisation and modifications which the ESP envisages
would not be possible without undertaking legislative measures in the area of business
statistics. That is why keeping the status quo, would even negatively affect coherence with
other legal initiatives (see comparison table below).
Option B tackles the modernisation of the current system of European Business Statistics to a
certain extent. This is in particular true for the upgrading of the data production and data
output for policy and other users which will get more relevant. It is also true for the
modernisation of the Intrastat system which should lower the burden on data provider.
However this option leaves a series of current deficiencies unsolved. These are:
Keeping 10 separate legislative acts for Business statistics means that more efforts are
needed to reduce inconsistencies and to preserve the coherence of data and indicators
produced for policy users in the future. In view of the risks of non-optimisation of the
coordination of implementation of the different legal acts, indicators produced on the
basis of such a dispersed system would not be relevant enough and misguide policy
users.
Secondly keeping 10 separate legislative acts also creates a high work load for the
management and updates of these pieces of legislation; this affects NSAs, but also
data providers (enterprises) who might need to answer to fast changing or sometimes
inconsistent questionnaires.
In addition, the improvement actions proposed in this option do not really create more
agility and responsiveness to changing policy and other user needs. Heavy procedures
and long-lasting discussions do prevent more agility of the system and therefore
hamper the relevance of the output for users.
In terms of coherence Option B is an improvement to the baseline scenario, since the
measures planned in the ESP 2013-2017 and its extension could indeed be introduced by
targeted legislative actions in the corresponding specific business statistics domains.
Option C as outlined above is the most advanced and most forward-looking one as it
modernises the European business statistics system. This option covers a long-term
investment in European business statistics in making them fit for the future. All European
business statistics will be put into one single legal framework FRIBS. This has – compared to
the previous options – a series of clear advantages. These are:
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The assembling of 10 separate legislative acts including the Business Register
Regulation into one single legal framework will implicitly guarantee much higher
consistency of business statistics (e.g. in terms of timing of changes and harmonisation
of definitions etc.). This allows for the drawing of higher benefits from the ESS
system as a whole and maximises the value added of the EU at the same time. The
frontiers between the various statistical domains will diminish or even completely
disappear. This alignment will make it possible to serve the policy needs much better
as more streamlined indicators and combinations of indicators can be disseminated. As
an example, - contrary to the current situation - there will only be one single figure for
the variable "number of active enterprises" for a certain industry which will be used all
across the system.
The streamlining of all business statistics in FRIBS and the underlying FRIBS legal
architecture will increase the agility of the system. New policy needs can be
accommodated with rather short delays and be embedded in a functioning and well-
designed system. This assures a level of agility which is not really possible under the
two previous options.
In contrast with Option B the costs for adaptations of the statistics disseminated and of
the underlying legal framework are minimised under this preferred Option C as all
necessary revisions are introduced more easily in one go. The framework Regulation
contains only the essential statistical elements. Non-essential elements can be
supplemented or amended by delegated acts, while the technical provisions will be
part of implementing acts. This brings much more agility and responsiveness to the
system.
Most importantly Option C has – by far - the highest potential for reducing the burden
on enterprises. Better harmonisation of business statistics will also streamline the data
collection and production methods used by NSAs or also by Eurostat. For instance the
"employment" figures will be asked from enterprises only once and then be reused for
many different indicators made available to policy users. In many Member States the
number and coverage of questions to which enterprises need to respond should
considerably decrease over time. FRIBS encourages that more harmonised methods
and processes are used by NSAs with the effect of a further decrease of burden on
enterprises. Thus, the increased coordination and use of multipurpose methods
(administrative data sources, combining of survey questionnaires, use of "big data"
data sources etc.) will create better opportunities for the reduction of data production
costs. FRIBS also allows for enhanced use of micro-data exchange in various domains
in the future and better and more aligned output facilitating e.g. new indicator
production.
Regarding coherence, Option C is fully in line with the ESP 2013-2017 and its extension and
is therefore clearly superior to Option A. Only the integrated approach of Option C (FRIBS)
could completely and coherently implement the actions and modernisations envisaged for
business statistics by the ESP and its extension.
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The table below summarises the scoring of each of the policy options regarding:
- the extent to which different options would achieve the objectives (effectiveness);
- the relation between costs and benefits;
- the coherence with the overarching objectives of EU policies.
Effectiveness
Streamline
and improve
consistency
Improve
flexibility and
responsiveness to
user needs
-
+
++
Facilitate the use of
innovative methods
and sources, make the
system fit for the
future
0
+
++
Ensure
quality of
data
production
0
0
++
Reduce
unnecessary
burden
on
data
providers
0
+
++
Efficiency
(Costs/ben
efits)
Coherence
Policy
Options
Option A
Baseline
Option B
Option C
-
+
++
0
+
++
-
+
++
-- negative impact
- slightly negative impact
0 neutral impact
+ slightly positive impact
++ positive impact
To conclude, all these advantages clearly favour Option C. It responds best to the objectives
of the REFIT programme by simplifying and streamlining the heterogeneous and inconsistent
legal texts currently governing business statistics into one coherent legal framework. It is
based on extensive user consultations and has the highest potential for reducing regulatory
burden. This option makes the European business statistics system fit for the future in meeting
much better the policy user needs compared to the rather inflexible system of today, while
being also best placed to introduce the innovations envisaged for business statistics in the ESP
and its extension. This option provides more possibilities for burden reduction as explained
above. Option C is the only option which takes fully advantage of the EU in maximising its
value added; this option creates the platform for a more collaborative and agile system
allowing for further modernisation in the future. The increased cost for data compilers in the
beginning of the implementation would be counterbalanced by potential benefits and
efficiency gains that would be realised once the FRIBS measures start to take effect (see cost
model in Annex IV). What is more, these increase costs would be completely offset by the
advantages for data users and the decrease in the burden for the data providers which Option
C would allow for. Moreover, the results of the first consultation of the NSAs clearly showed
that Option C - FRIBS was their preferred option. Namely, around 55 % of the NSIs indicated
FRIBS as their preferred option, while only around 10 % preferred Option B - the non-
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integrated approach of separate revisions of the individual acts and only 7 % of the
respondents preferred Option A - keeping the status quo (no policy change )
13
.
8.
MONITORING AND EVALUATION: HOW WOULD ACTUAL IMPACTS BE
MONITORED AND EVALUATED
The European Commission REFIT agenda makes evaluation of all new legislative measures a
priority for the Commission. The proposed FRIBS legislation will also be subject to a
complete evaluation in order to assess, amongst other things, how effective and efficient it has
been in terms of achieving the objectives presented in this report and to decide on whether
new measures or amendments are needed.
It is not expected that the implementation of the FRIBS framework Regulation and its
accompanying delegated and implementing acts would be potentially more difficult in certain
Member States.
In general the existing monitoring and evaluation tools, in place and valid for the statistical
production and dissemination of European statistics, will be used. These should enable a
profound analysis of the effectiveness and efficiency of the new statistical initiative and of the
quality of the data produced. These tools are:
The European Statistical Programmes (currently based on Regulation (EU) 99/2013)
foresee systematically mid-term and final evaluations. Business statistics are part of
this reporting mechanism
14
.
The Eurostat Management Plan foresees the follow up of key performance indicators,
which also apply to business statistics
15
.
User satisfaction surveys are carried out on an annual basis
16
.
FRIBS also requires the production of standard quality reports, regularly produced by
Member States and Eurostat, as part of the Statistical Quality Assurance Framework.
13
Another 25 % of the respondents to the consultation did not have a clear preference
See
http://ec.europa.eu/eurostat/web/quality/general-evaluation-results
The five key performance indicators are the following ones: Number of data extractions made by external
users from Eurostat reference databases (EuroBase and Comext) via the Eurostat website, Percentage of
users that rate as "Very good" or "Good" the overall quality of European statistics, Percentage of users that
rate as "Very good" or "Good" the timeliness of European statistics for their purposes, Percentage of users
that rate as "Very good" or "Good" the comparability of European statistics among regions and countries,
Residual error rate (RER)
See
http://ec.europa.eu/eurostat/web/quality/general-evaluation-results
14
15
16
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Eurostat and the NSAs will further improve the standard metadata and quality reporting
system for business statistics. This will allow a more sophisticated monitoring and evaluation
of the statistical processes used in Member states and of the output disseminated. For
example, more detailed information will be available on the use of administrative data sources
(leading to burden saving) by Member States or on the use of shared services or IT tools
(leading to cost savings). The results and the effect of the FRIBS legislative initiative would
regularly be monitored via the annual compliance and quality reports.
Measuring the progress towards achieving the objectives of the initiative the following list of
monitoring indicators has been defined. Those indicators are juxtaposed against a list of
operational objectives which have been derived from the specific objectives (presented in
Chapter 4). The indicators would be measured against the benchmark targets indicated in the
last column of the table below.
Table 5. Monitoring and evaluation indicators
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SPECIFIC OBJECTIVES
OPERATIONAL
OBJECTIVES
Enhance the role of European
business registers in creating a
more inter-connected European
Network of Business Registers
KEY PERFORMANCE
INDICATORS
KPI1
percentage of
consistency of data
between EuroGroups
Register and the
national business
registers
TARGETS
17
90 % within 10 years
of implementation of
FRIBS
Source: quality reports of
business registers
Improve consistency;
Implement a unique identifier for
the units recorded in the European
Network of Business Registers
KPI2
percentage of units
that have a unique
identifier
95 % within 10
years of
implementation of
FRIBS
Source: quality reports of
business registers
Eliminate or reduce the existing
inconsistencies in certain
definitions of variables across
statistical domains and facilitate
the consolidation of surveys in
different business statistical
domains
KPI3
reduction in number
of surveys in business
statistics
Source: national metadata and
quality reports
KPI4
percentage of changes
to data requirements
that need to be
introduced by EP and
Council Regulation in
total changes to data
requirements
Less than 10% over
a 10 year period (all
units) (we should
take into account
how likely it is to
have FRIBS2 within
10 year of
implementation of
FRIBS1)
A draft reply to new
data needs received in
year t is discussed with
the experts of the
Business Statistics
Directors'
Group/relevant working
group in t+1
Enhance flexibility;
Improve the legal architecture to
gain more flexibility
Introduce new data requirements
KPI5
Inventory of new data
needs and when they
have been answered
KPI6
Increase of the use of innovative
data sources for the production of
business statistics
Number of innovative
data sources used
Source: national metadata and
quality reports
KPI7
Number of Member
States using
exchanged micro-data
on intra-EU exports of
goods for the
compilation of
imports of goods
Facilitate the use of
innovative methods and
sources;
Introduce micro-data exchange
processes in the field of intra-EU
trade in goods statistics
Source: national metadata and
quality reports
17
For KPIs 3, 6, 7, 12, 13: no exact benchmarks can be specified as FRIBS does not impose any obligation to the
Member States but only enables use of new sources and simplifications regarding those indicators.
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KPI8
Percentage of users
that rate as "Very
good" or "Good" the
overall quality of the
European business
statistics provided by
Eurostat
60% within 10 years
of implementation of
FRIBS
Define a harmonised data quality
framework across business
statistical domains
KPI9
Percentage of users
that rate as "Very
good" or "Good" the
timeliness of
European business
statistics for their
purposes
60% within 10 years
of implementation of
FRIBS
KPI10
Ensure quality of data
production;
Percentage of users
that rates as "Very
good" or "Good" the
comparability of
European business
statistics among
countries
60% within 10 years
of implementation of
FRIBS
Source: Annual user
satisfaction survey
(USS) carried out by
Eurostat
KPI11
Number of data
extractions (in
millions) made by
external users from
Eurostat public data
bases of business
statistics via the
Eurostat website
Decrease as
compared to
previous year does
not exceed 5%/
Source: Monitoring reports in
Eurostat electronic
dissemination
Facilitate further the exchange of
micro-data for statistical purposes
(within NSI and between NSIs)
Optimise use of EGR (Euro
Groups Register)
Promote and facilitate the access
to and use of administrative data
for statistical purposes
Please see above KPI7
Please see above KPI1
KPI12
Number of
administrative sources
used replacing survey
data
Source: national metadata and
quality reports
Reduce unnecessary burden
on data providers
Introduce changes that alleviate
burden generated by the business
statistics legal frame e.g.by
removing coverage rate in
Prodcom and increased output
orientation in ITGS
Use new and innovative data
sources
KPI13
Number of measures
implemented by NSAs
to reduce burden on
data providers
Source: national metadata and
quality reports
Please see above KPI6
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(*) FRIBS does not impose a redesign of the national production systems to reduce the burden on data providers
but makes it possible for the Member States to reduce their number of surveys, to use innovative or additional
administrative sources or to reduce the burden on the data providers.
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ANNEXES
ANNEX I: PROCEDURAL INFORMATION
Basic information:
Title of the initiative: Framework Regulation Integrating Business Statistics (FRIBS)
Lead DG: Eurostat
Agenda Planning Number: 2012/ESTAT/011
In its Communication on EU Regulatory Fitness of December 2012 the Commission
committed to strengthen its various smart regulation tools (impact assessment, evaluation,
stakeholder consultation) and launched the REFIT programme. Through REFIT, the
Commission services have mapped the entire EU legislative stock looking to identify burdens,
gaps and inefficient or ineffective measures including possibilities for simplification or repeal.
Thus, the Framework regulation integrating business statistics (FRIBS) falls under the scope
of the REFIT initiative. Under this context, Eurostat started the preparation of this impact
assessment in 2013 with a view to comparing the impacts of different possible options for
integrating and rationalising business statistics. As this was prior to the adoption of the Better
Regulation guidelines in 2015, no specific full evaluation of the current situation was done to
support this initiative. However, the regular evaluation mechanism in place at Eurostat (e.g.
quality reports, rolling reviews, evaluation of the European statistical programme,
management plans) as well as an ex-post analysis of the current situation (through discussions
with NSIs, interviews with main users, public consultation collecting feedback from general
users and thorough desk research) provided a broad basis for the Impact Assessment.
A FRIBS roadmap has been agreed and published in January 2013. A revised roadmap has
been prepared and published in January 2015 in order to reflect the latest state of play of the
FRIBS preparation. Following the introduction of the Better Regulation guidelines in 2015,
the roadmap has once again been revised under the form of an inception impact assessment
that was published in January 2016.
Consultation of Impact Assessment Steering Group (IASG)
An inter-service steering group was set up in 2013 involving the following DGs: Secretariat-
General (SG), Competition (COMP), Economic and Financial Affairs (ECFIN), Employment,
Social Affairs and Inclusion (EMPL), Internal Market, Industry, Entrepreneurship and SMEs
(GROW), Communications Networks, Content & Technology (CNECT), Trade (TRADE),
Taxation and Customs Union (TAXUD), Research and Innovation (RTD) and Legal Service
(SJ). The inter-service steering group met 5 times (the meetings took place respectively in
October 2013, May 2014, the June 2015, and twice in April 2016). Following the results of
the latest meeting of the IASG, a revised version of the Impact Assessment Report was
prepared and sent to the Regulatory Scrutiny Board.
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Consultation of Regulatory Scrutiny Board (RSB)
The RSB examined the Impact Assessment Report on 8 June 2016. The RSB gave a positive
opinion and provided recommendations for further improvements. The report was further
adjusted in order to integrate the Board's recommendations.
Board recommendations
1. The range of options initially
presented and analysed was not
complete because the consultation
process on the possible sub-options
concerning the modernisation of
the intra-EU trade statistics
continued after the initial
submission of the impact
assessment report to the RSB's
scrutiny. Therefore, the report
should be extended with the
combination of options on intra-EU
trade statistics, as proposed by the
European Statistical System
Committee (ESSC).
2. The analysis regarding the
possible budgetary implications in
individual Member States should
be strengthened and it should be
defined if some of them would face
more
difficulties
with
implementation than others and
whether any alleviating measures
were planned for those Member
States.
What has been done?
Eurostat updated the list of the
proposed policy options, reflecting the
ESSC conclusions concerning the
modernisation of the intra-EU trade.
Where?
5.1.3, Chapter 6, Chapter 7,
Annex II (section 2.3) and
Annex IV
Further clarifications as to the countries
most affected by the changes were
given.
A number of examples were provided
pertaining to foreseen simplifications
for smaller countries and to the
rationalisation
and
modernisation
potential offered by FRIBS creating
future cost reduction possibilities. It
was also explained that financing was
foreseen (within the limits of budget
availability) for actions to develop new
data collections.
Eurostat clarified the administrative
burden impacts on data providers.
Some of the additional data
requirements responding to long-
standing specific user need to enable
the monitoring of policy actions with
regards to SMEs would indeed increase
the burden on SMEs. A number of
examples have been provided to
vindicate that in many Business
Statistics domains special measures are
in place to guarantee that SMEs were
protected from excessive burden and
data compilers would make particular
efforts to minimise the burden on
SMEs for those new data requirements.
Chapter 6 under efficiency of
Option C
3.
The
analysis
of
the
administrative burden impacts on
data
providers
should
be
strengthened and it should in
particular be more nuanced
towards the SMEs, while indicating
any measures to be taken for
protecting SMEs from increased
burdens.
Chapter 6 under efficiency of
Option C
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Further recommendations for
improvements by the Board:
The problem definition should be
clearer. The presentation should
follow the logic outlined in the BR
Toolbox. All elements should be
supported with qualitative and/or
quantitative evidence.
The general objectives should be
treaty-based goals which the policy
aims to contribute to. The general
objectives included in the report
are broadly identical to the specific
objectives.
The description of the options
should be improved. Not all
options of the inception impact
assessment report need to be
quoted. It should be explained in
the report why the option of a
recast of the existing regulations
was not included in the report.
All retained options should be
assess against three basic criteria,
i.e. effectiveness, efficiency and
coherence. The report lacks the
assessment of the latter.
The comparison of options should
include narrative on coherence.
What has been done?
Where?
Chapter 2 of the impact assessment
report has been redrafted to explain
better the existing problems and their
consequences.
Qualitative
and
quantitative evidence has been added.
Throughout Chapter 2.
The general objective and the specific
objectives have been redrafted in line
with the recommendation.
Section 4.1 and Section 4.2
The list of policy options has been
redrafted and the mapping of the
options (compared to ones from the
inception report) was deleted. The
discarded options paragraph was
redrafted to explain why the recast
option was not considered.
Sections 5.1 and 5.2
The criterion of coherence
assessed for all retained options.
was
Chapter 6
For each of the options the effect on
coherence was added under the
comparison.
Targets for key performance indicators
for each of the operational objectives
were included in the report.
Chapter 7
The report should specify when the
objectives of the initiative are
considered as having been met or
not.
The report should explain if any of
the conducted public consultation
were open public consultations and
should not be limited only to the
queries on costs but also on other
elements consulted upon.
Overview table at the end of
Chapter 8.
It has been clarified that all public
consultations were open and that other
issues than costs were consulted upon.
Section 1.3 and Annex II
Evidence used
In reference to the evidence that constitutes the basis for the Impact assessment, it is first
pertinent to mention the evaluation tools currently in place that already allow for good
analysis of the effectiveness and the efficiency of new statistical initiatives and the quality of
the data produced. These tools include: the European Statistical programmes (currently
regulation 99/2013), which foresee systematic mid-term and final evaluation of the
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programme, of which business statistics represent an integral part
18
; the follow-up of a series
of performance indicators, as planned by the Eurostat management, which also applies to
business statistics
19
; and the Users satisfaction surveys carried out on a regular basis
20
.In
addition, the ongoing assessment of the quality of the statistics undertaken by Eurostat,
presented in the form of Quality reports
21
,represent a source of extensive and reliable
evidence for the preparation of the impact assessment and at the same time a tool for
monitoring and evaluating the impacts of the new legislative proposal.
Systematic Rolling Reviews, in accordance with the binding standards approved by the
Commission, were also carried out. They formed part of the Quality Assurance Framework
developed by Eurostat in 2007
22
.
Further evidence for this impact assessment was collected from the consultations of the
relevant stakeholders –Directorate Generals of the European Commission, National Statistics
Institutes (NSIs) and National Central Banks (where relevant), and businesses and their
associations and the public (i.e. academics/researches, interest groups, media and non-
governmental organisation, and individuals) –conducted as part of the preparation of this
impact assessment. The combination of the information provided from the data users –from
within (DGs and EU agencies) and outside of the EU administration (e.g. external micro-data
users); from data providers (businesses); and from the data compilers (National Statistics
Institutes) and extensiveness of the consultations ensures the robustness and the relevance of
the information collected. An additional aspect that contributes to the robustness and
comprehensiveness of the evidence gathered thorough the stakeholders' consultation is the use
of several modes of data collections (i.e. the use online questionnaires addressed to the open
public, the data users and data providers, the targeted consultation of data compilers, in
combination with in-depth discussions to data users and data producers), which broadened the
scope of the exercise, and allowed to undergo a more detailed analysis of the problems at
hand, and a thorough assessment of the possible solutions from the perspectives of the
different stakeholders.
External expertise used
The inter-service group (ISG) created in the context of this impact assessment, in which the
above-mentioned DGs were represented, constituted –besides its already established function
of steering the IA process and contributing to the collective preparation of the IA report, and
18
19
See
http://ec.europa.eu/eurostat/web/quality/general-evaluation-results
The five key performance indicators are the following: Number of data extractions made by external users
from Eurostat reference databases (EuroBase and Comext) via the Eurostat website, Percentage of users that
rate as "Very good" or "Good" the overall quality of European statistics, Percentage of users that rate as
"Very good" or "Good" the timeliness of European statistics for their purposes, Percentage of users that rate
as "Very good" or "Good" the comparability of European statistics among regions and countries, Residual
error rate (RER)
20
See
http://ec.europa.eu/eurostat/web/quality/general-evaluation-results
21
See:
http://ec.europa.eu/eurostat/web/quality/quality-reporting
22
More detail can be found under
http://ec.europa.eu/eurostat/web/quality/evaluation
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in relation to the fact that the DGs are main data users of the business statistics provided by
Eurostat–, a most relevant source of external expertise for the preparation the Impact
assessment of new legislation.
Besides the expertise and the advice sought from the inter-service steering group of the DGs,
also the assistance of two external contractors has been used. Namely, the contractors assisted
in executing the stakeholders' consultations, summarising the main results and analysing the
evidence gathered.
The expertise of the NSIs has also been profoundly relied upon. Namely, there have been
extensive discussions and exchange of views as part of regular domain-specific working
groups, task-forces, directors groups and also informally through various bilateral
consultations.
ANNEX II: STAKEHOLDER CONSULTATIONS
1. Introduction
Besides the regular and extensive consultations of the concerned parties (more than 100
meetings in total with Member states, EFTA countries and others) during the development of
the FRIBS proposal (including the problem definition and the need for a EU rather than a
national solution (subsidiarity)), three rounds of specific stakeholder consultations were
organised for the preparation of the FRIBS Impact Assessment. The first round covered the
FRIBS infrastructural elements (such as the Business Registers, micro-data exchange, quality
issues and confidentiality). The second round focussed on the changes to the data
requirements to be introduced by FRIBS and the third round collected stakeholders' opinions
on the modernisation of Intrastat. Each round consisted of a targeted consultation of the data
compilers (NSAs)
23
and an open public consultation also aiming at collecting feedback from
the data providers (businesses)
24
and data users
25
. . The consultations meet the minimum
standards of the European Commission for the consultation of interested parties. This Annex
will first give an overview of the different consultations undertaken. In addition, the outcomes
of the respective consultations are summarised.
1. 1. The first round of consultations on the FRIBS infrastructural elements
26
23
National statistical authorities (NSAs) of the 28 EU Member States and 4 EFTA countries responsible for the
collection, compilation and dissemination of statistics at the national level; this includes the National
Statistical Institutes (NSIs), but also other compilers such as National Central Banks.
Businesses (including SMEs) responding to statistical surveys at national/regional level.
All actors who are frequently using European business statistics, such as other Commission services, national
policy makers, NSAs, National Central Banks and the European Central Bank, professional associations,
businesses and researchers.
The infrastructural elements include the Business Registers, micro-data exchange, quality issues and
confidentiality
24
25
26
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The consultation on the FRIBS infrastructural elements took place in 2014 In the targeted
consultation of the NSAs, the data compilers were in particular consulted on the expected
qualitative impacts of FRIBS, the qualitative comparison of FRIBS and alternative policy
options, the expected quantitative impacts of FRIBS and alternative policy options and the
expected quantitative impacts of FRIBS and alternative policy options for data providers.
29 of the 32 NSAs which were invited to participate in the targeted consultation of data
compilers provided their contribution. 27 EU Member States and 2 EFTA countries finally
responded.
In total, 54 respondents answered to the public consultation of data users and providers on the
expected qualitative impacts of FRIBS and the qualitative comparison of FRIBS and
alternative policy options. Professional associations were responding most, followed by
academic and research institutes and by business themselves. Most respondents were users of
European business statistics, only a few were providers of statistical data (i.e. enterprises).
The remaining responses came from organisations linked to national and/or European
institutions.
1.2. The second round of consultations on the FRIBS additional data requirements
During the Business Statistics Directors Group (BSDG) meeting in 12/2014, Member States
asked for an additional consultation on the impacts of the additional data requirements in
FRIBS. Therefore, this second consultation was organised in 2015 assessing the impact of the
data requirements as changed by FRIBS (both for increases and reductions). This second
round of consultations complements the first cost-benefit analysis of the infrastructural
elements as described under section 1.
This second consultation phase also aimed at receiving input data compilers, data providers
and data users. The data users were asked to describe the qualitative impacts of the proposed
changes (quality, flexibility, timeliness),
The data compilers were asked to assess the one-off implementation costs and changes in
yearly operating costs as well as the estimated changes in administrative burden for data
providers caused by the changes in the data requirements of FRIBS.
All 28 NSIs from EU Member States and 1 NSI from EFTA countries answered to this
consultation. In addition 17 replies came from NCBs (9 of those were joint replies from the
NCB and the NSI).
For this round of public consultation separate questionnaires were addressed to data providers
and data users respectively. The data users were asked to describe the qualitative impacts of
the proposed changes (quality, flexibility, timeliness) and the data providers to assess the
impact on administrative burden ( qualitative assessment) caused by the changes in the
proposed data requirements of FRIBS.
52 data users answered; many replies came from National Accounts departments and business
associations. In addition EU institutions, research institutes, public authorities' individual
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businesses and central banks replied. In spite of many extensive efforts from Eurostat, only a
limited number of replies from data provides were received.
1.3. The third round of stakeholder consultations related to Intrastat
Separate targeted and open public stakeholder consultations have been carried out on Intrastat
feeding into the impact assessment as well as to the modernisation of Intrastat. The overall
aim of the modernisation project is to assess the impacts of the three options proposed –
SIMSTAT, Revised Intrastat and Single Flow - in terms of their costs and benefits.
The NSAs have been addressed in a targeted consultation for collecting data for a cost-benefit
analysis. This cost-benefit analysis aims at providing input to the ESSC to take a strategic
orientation on the modernisation of Intrastat. At the same time the cost-benefit analysis is
contributing to the more encompassing cost-benefit analysis of FRIBS.
The methodology followed for the cost-benefit analysis consists of two actions: quantitative
assessment (cost analysis) and qualitative assessment (SWOT analysis).
The aim of the cost analysis was to estimate the costs (current costs, development and
adaptation costs, future costs) incurred by the NSAs caused by the implementation of
modernisation options for Intrastat. 24 Member States provided data for all three types of
costs. Eurostat finally estimated the complete EU costs for the NSAs.
The SWOT assessment for the Member States was carried out in autumn 2015 based on a
standard methodology. 26 Member States provided their SWOT assessments, with some
updates in 2016.
For collecting data on the administrative burden, an extensive open public consultation of the
data providers has been organised during the first quarter of 2016. More than 20.000 replies
have been collected.
2. Outcome of the consultations
The three rounds of consultations have been summarised in this section by category of
stakeholder in order to provide a comprehensive picture, given that the consultations have
been complementary.
2.1.
Data users
In the first round, 48 users responded to the consultation, in particular reporting the following
issues:
1. Combining data from different business statistical domains: many problems with
inconsistencies between statistical domains exist.
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2. Consistency of statistical data across Member States: many respondents believe that
inconsistencies exist and that those have a negative impact on both the quality of their
work and the time required for exploiting the data. Around 80% of respondents
consider that an increased coherence and consistency of data would significantly
improve both, the quality of their work and the time needed for exploiting the data.
3. Additional data needs: The majority of users judge the extension of the FRIBS data
requirements positive.
4. Confidence of users in the European business statistics system: nearly 80% of the
respondents are very/rather confident in the quality of the current European business
statistics;
5. Nearly 85% of the respondents have indicated that a single harmonised regulation
would further increase their confidence in European business statistics.
The second consultation focused on the FRIBS additional data requirements (i.e. new data
requirements as well as deletion of some existing requirements). 52 data users responded to the
consultation, covering EU institutions and research institutes (28%), National Accounts
departments (25%), business associations (23%) and other public authorities, individual
businesses or central banks (22%).
Around 50% of the data users emphasised that the FRIBS additional data requirements are
crucial or highly important for them. Crucial new requirements are in particular indicators on
globalisation and global value chains of enterprises in Structural Business Statistics and in FATS
statistics; and the improved coverage of the services sector, especially the introduction of a
monthly production index for services in Short-Term Statistics and the level of detail of
Structural Business Statistics available for National Accounts.
2.2. The data compilers (NSAs)
The results presented here summarize the information collected on costs using the three
targeted consultations of the data compilers. The NSAs that provided details regarding the
current costs, caused by European business statistics, report
total yearly costs of about EUR
290 million.
This total translates into an average amount of EUR 10.5 million per Member
State (
27
).
The total yearly costs caused by European business statistics can – as
an average
- be
distributed as follows over the different statistical domains and the Business Registers (BR)
28
.
27
Median value: EUR 4.9 million
The business register is considered at the same level as the statistical domains.
28
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Importance of statistical domains in current annual costs of NSAs related to
business statistics
15,3%
8,0%
4,6%
3,9%
3,6%
3,1%
1,7%
0,6%
0,5%
ITGS
STS
SBS
BR
Prodcom
ITSS
R&D/CIS
FDI
ISS
OFATS
IFATS
26,4%
13,4%
32,3%
On average, the current annual costs are EUR 0.57 per EU inhabitant. An increase in yearly
operating costs of NSAs between 4.3 % (EUR 436 000) and 6.8 % (EUR 700 000) (depending
on the different Intrastat sub-options consulted and analysed) is expected due to FRIBS
implementation as a whole, encompassing the infrastructural changes and the upgrade in the
FRIBS data requirements.
FRIBS would also cause one-off investment costs, on average per Member State between
EUR 1.16 million and EUR 1.9 million (or between EUR 32 million and EUR 52 million for
the EU on total) depending on the different Intrastat sub-options consulted and analysed.
These increases (operational cost increase and one-off implementation cost) represent
additional costs between EUR 0.08 and 0.14 per EU inhabitant. Cost increases are caused by
all statistical domains, except International Trade in Goods Statistics (ITGS). The new data
requirements for STS and SBS statistics cause most of the additional costs. For the ITGS, a
reduction of costs through a modernised Intrastat system can be expected (between EUR 8
million and EUR 18 million depending on the different Intrastat sub-options consulted and
analysed).
During the preparatory phase of the FRIBS, the Commission (Eurostat) provided a total of
EUR 37 million, mostly to NSIs, through the MEETS programme on the modernisation of
enterprise and trade statistics in addition to other pilot studies financed and carried out to test
the feasibility of new data requirements. Eurostat aims to provide financing ( within the
Commission budgetary constraints) to offset some of the investments costs needed for the
further modernisation of the data production processes and systems as well as for capacity
building and piloting of data production related to new data requirements. It can also be
expected that once the initial investments have been made the yearly operating costs for the
NSA would gradually decrease when multi-source and multi-purpose data collections and
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access to alternative data sources – administrative or collaboratively generated by the ESS
(i.e. EGR and micro-data exchange) – will be increasingly used in many Member States.
Regarding the preferred policy option, the results of the first targeted consultation of the
NSAs show that around 55 % of the NSIs indicated FRIBS as their preferred option, around
10 % preferred Option B - the non-integrated approach of separate revisions of the individual
acts and 7 % of the respondents preferred Option A - keeping the status quo (no policy
change). Same ranking of the policy options was indicated by the data users during the open
public consultation. The results however depict even greater support for FRIBS - Option C
with 74 % of the respondents supporting it, followed by Option B (non-integrated revision of
separate legislative acts) with 13 % and finally Option A – no policy change was supported by
4 % of the respondents.
2.3.
Data providers (businesses)
In spite of considerable efforts from Eurostat to advertise and encourage the participation of
data users in the open public consultation, only a limited number of replies by data providers
were received on qualitative impacts in the first two rounds of the public consultations.
Consequently, the responses could not be considered representative and not analysed further.
Namely, during the first open public consultation only 6 partial responses (from 1 micro-
enterprise, 1 small enterprise, 1 large company and 3 professional associations, all originating
from different EU countries) were recorded. During the second consultation round (on the
additional data requirements) only 5 replies were received. These came from: two individual
businesses; a federation of businesses; a chamber of commerce, and a national statistical
office.
From the targeted consultations on FRIBS infrastructural elements and changed data
requirements (other than intra-EU trade statistics), information on the current burden and on
changes in the burden for data providers (businesses) were estimated by the NSAs. For most
statistical domains, between 26 and 28 NSAs provided estimates regarding the costs for
businesses obliged to fill in business statistics surveys. Information on the administrative
burden caused by the intra-EU trade statistics and the effects of its modernisation was
collected by a public consultation of data providers (businesses). When the inputs from the
consultation on businesses regarding the burden of the collection of Intrastat data is also taken
into account the total administrative burden of business statistics is estimated to be around
EUR 689 million.
Three statistical domains cause around 89% of this total burden:
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Importance of statistical domains in current annual burden on businesses
related to business statistics
12,83%
8,39%
4,03%
7,43%
67,32%
2,16%
1,59%
0,49%
0,47%
0,38%
2,34%
ITGS
STS
SBS
ITSS
Prodcom
FDI
R&D/CIS
IFATS
ISS
OFATS
67 % of the burden on businesses is caused by statistics on International Trade in Goods.
Structural Business Statistics and Short Term Statistics are ranking second and third. The
potential reduction of the total burden on businesses will depend on the level of national
implementation of the simplifications and modernisation possibilities provided by FRIBS and
is estimated to be:
26.8 % (or EUR 184 million) for sub-option C1 (SIMSTAT);
12.1 % (or EUR 83 million) for sub-option C2 (Revised Intrastat);
33.6 % (or EUR 231 million) for sub-option C3 (Single Flow);
13.5 % (or EUR 93 million), at least, for sub-option C4 (combination of SIMSTAT and
Revised Intrastat).
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ANNEX III: WHO IS AFFECTED BY THE INITIATIVE AND HOW
The production and use of European business statistics involves 3 main categories of
stakeholders:
Data users: this includes institutional users –national administrations, other
international organisations, or professional staff working within the Commission
services or DGs and other EU institutions, and other external users, such as mass
media and academics.
Data compilers: this category comprises the authorities responsible for the
collection and compilation of business statistics. It mainly includes the NSIs and
Eurostat.
Data providers: this category includes businesses which respond to surveys
The preferred policy option has a significant impact on each of the stakeholder categories.
1. Data users
of European business statistics
Currently the possibilities for users to analyse data across domains of business statistics are
hampered by differences in concepts, definitions and classifications. Data users will benefit of
an increased coherence of the business statistics. The use of common concepts and
definitions, classifications and breakdowns, will improve the quality perceived by the users of
statistics.
The preferred policy option allows for greater flexibility in the statistical work programme by
providing for improved mechanisms to accommodate emerging information needs. Under the
preferred policy option, the system will increase flexibility as well as harmonise business
statistics; this has the double advantage of covering new information needs by producing new
data and by combining them with those already collected.
The producers of macro-economic accounts will benefit from the increased consistency as
well as from the improved quality of the business statistics which are used as critical inputs
for the calculation of main economic indicators such as the GDP.
To benefit of greater flexibility, users have to closely work with statistical authorities to
achieve proportionality in the satisfaction of information needs and production efforts. This
implies ensuring an effective mechanism for the identification of negative priorities. At the
European Commission level, the institutional users (mainly (DGs) will continue working
closely with Eurostat on defining their needs and will develop the mechanisms for budget
delegations. This is normally formalised through Memorandum of Understanding between
each user DG and Eurostat and the annual formal "hearing" with each DG that supports the
definition of the annual and multi-annual statistical programmes.
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2. Data compilers, the National Statistical Authorities
The production of European business statistics is mostly done at national level by NSIs and
NCBs, which are public institutions and therefore with public budgets. Additional
requirements of information lead to the need for higher budgets, unless measures to
significantly increase efficiency are taken.
The cost of accommodating new information needs includes new methodological work, new
data collection, new processing or dissemination methods. The bulk of costs go to data
collection. The increased information requirements foreseen in the preferred option
necessitate an assessment at the national level on the most cost-efficient way of data
production, but an initial investment - irrespective of the choice on the production method-
can be expected. As a consequence, the preferred option also foresees provisions which allow
for the modernisation of production (e.g. using more administrative data, better technology or
sharing methodological solutions among NSIs) and by data sharing ( as foreseen by the EGR
and the modernisation of Intrastat) and collaborative approaches to data compilation.
National production processes would benefit from a network of integrated business registers,
from the improved access to administrative and other data sources as well as from the
possibility to use micro-data collected by other national statistical authorities. More integrated
processes should also lead to increased cooperation between the national statistical authorities
concerned and facilitate long term overall cost savings for them.
Carrying out new surveys or increasing the frequency of data collections has a significant
impact on cost. Unless constraints on the rising cost are put in place, policy options increasing
the flexibility may highly impact the budgetary needs of NSIs.
It has to be mentioned that the most expensive surveys are those carried out with large
samples or with high frequency (e.g. STS). Policy options that consider mechanisms for (1)
evaluating the relevance of additional information requirements and (2) simplifying the work
programmes by excluding the data collections which are not deemed relevant anymore
(negative priorities) would provide safeguards for increases in cost.
NSIs would however benefit of a simpler, integrated legislation that would allow for reducing
the legal work to update the statistical regulations, that would consider the whole system of
business statistics when planning and designing each data collection and that would promote
the modernisation of processes (e.g. by facilitating access to administrative data and other
sources) and increase the methodological coherence across surveys.
In practice, the joint work of Eurostat and the NSIs to integrate business statistics will
continue with the elaboration of the necessary implementing measures. The role of the BSDG
will thus be reinforced as the main technical forum of discussion on business statistics,
advising the ESSC and the Commission. The balance of costs and benefits, in financial terms,
is difficult to assess since it depends on the actual implementation of changes in existing data
collections. In some Member States such collections existed or have already been
implemented. Progress in the harmonised and comparable measurement of production costs in
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NSIs would not only improve the management at the national level, but also provide a sound
basis for monitoring and evaluating the impact of any modernisation process – be it or not
related to legal obligations.
3. Data providers, the businesses
While some of the new information needs proposed by the preferred policy option could be
accommodated using administrative sources or data sharing, there will be impacts also on data
providers. The increased coverage of the services sector and the increased frequency of some
of the short-term statistics to be produced may create more burden on the respondents.
However, this potential increase is expected to be more than offset by the possibility to re-use
data collected by other NSAs for intra-EU trade in goods statistics and by modernising the
trade in goods statistics. The SIMSTAT exchange of micro-data has the potential to reduce
the overall burden created by business statistics by about 10 %. In addition, a reduction of the
coverage rates (of imports and exports) for intra-EU trade in goods statistics , foreseen in the
Revised Intrastat sub-option would also relieve some businesses from the burden to provide
data for intra-EU trade in goods statistics.
Impact on SMEs:
The additional data requirements might result in additional burden for SMEs especially as
regards the extended information on the services sector. In the qualitative consultation
responses provided by the data compilers the NSAs have assured that the utmost care is taken
to ensure that the burden on the SMEs is as limited as possible by e.g. the use of
administrative data or advanced statistical methods. The modernisation of Intrastat as
mentioned above would also reduce the burden of SMEs.
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ANNEX IV: ANALYTICAL MODELS USED IN PREPARING THE IMPACT
ASSESSMENT
The impact assessment has been based on a cost-benefit analyses of: on one hand the
REDESIGN of Intrastat (i.e. the options for modernising the collection of Intrastat statistics)
and on the other hand, all the envisaged modifications in all other statistical domains which
FRIBS is covering. Those two cost-benefit analyses have been combined with the goal to
evaluate and compare in detail the ability of the policy options to achieve the objectives,
identified for solving the current problems. This cost-benefit analysis has utilised as much as
possible the use of quantitative data, having in mind a principle of proportionality. For the
assessment of some of the impacts quantitative data could however not be collected and for
these elements qualitative elements have been collected. In summary, the following
assessments are made for each of the shortlisted policy options:
• qualitative assessment of their impacts;
• quantitative assessment of: expected costs for NSAs; expected costs for data providers
(administrative burden);
The analysis thus implies that the outcome of the comparison of quantified costs (in Euros)
and benefits is confronted with the qualitative assessment of other advantages and
disadvantages.
Common to all approaches presented is the fact that in an impact assessment, impacts are
typically to be expressed as an expected effect in comparison to what would happen under the
no policy change option. As a consequence, the cost-benefit analysis will provide estimations
of the additional costs and additional benefits compared to the baseline scenario. Indeed, the
main objective of the impact assessment is to enable comparison between the options, which
implies that expressing the correct relations between values and options (relative
relationships) are of higher importance than determining the total cost/benefit of each option.
An effort has however been made to quantify the baseline scenario. There was a lack of
existing harmonised and comprehensible data. A targeted data collection was necessary.
The cost-benefit analysis brings together the comparative results of the different approaches,
so as to allow an integrated comparison over all types of impacts of the different policy
options. Namely:
- qualitative assessment of the impacts of each policy option;
- assessment of the costs for NSIs;
- assessment of the costs for data providers
Qualitative assessment of the impacts of each policy option
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One of the cornerstones of a detailed comparative assessment of the policy options is a
qualitative assessment of the way in which the options address the different objectives (i.e. the
effectiveness of the policy options). In this way, it is possible to take account of impacts that
cannot be quantified in Euros, such as the benefits.
For the qualitative assessment, a set of expected impacts relating to the identified objectives,
are defined, and subsequently reviewed per policy option, in order to identify the most
advantageous option. By linking the impacts directly to these objectives, the degree to which
the options will reach the objectives will become apparent in a very straightforward way.
Information on the impacts was collected via an open and a more targeted consultation.
The appropriate objectives for a suchlike analysis in this case are the operational objectives,
as this level of detail allows a well-founded analysis and by consequence a true comparison of
options.
Assessment of the costs for NSAs
A second part of the cost-benefit analysis consists of the assessment of the costs for NSAs for
implementing the different policy options. This assessment is for the largest part based on
information that was specifically collected from the individual NSAs during the consultation
rounds (first one on FRIBS infrastructural elements and second one on introduction of new
data requirements and on a separate track the consultation on the costs of different sub-
options for modernising Intrastat). NSAs were asked to provide a baseline and to assess the
cost of the changes brought about by the envisaged changes. NSAs have provided their
estimations of costs (current and future) per statistical domain and an estimate for the one-off
implementation costs of the changes which would also be incurred.
Assessment of the costs for data providers (administrative burden)
The third part of the cost-benefit analysis relates to the assessment of the costs for data
providers (i.e. administrative burden) linked to the implementation of the different policy
options. In order to give a complete overview of the impact on the administrative burden, the
assessment is not limited to the costs directly linked to the completion of statistical surveys,
but will consider the administrative burden of data provider (businesses) in a broad sense,
including also qualitative elements , as well as non-staff costs (e.g. investments in IT-
systems).
Regarding all the business statistics domains, except for the Intrastat part of International
Trade in Goods (ITGS), the individual contributions of NSAs from the targeted consultations
represent the main sources for the assessment of the costs for data providers
29
. Regarding
29
Through the consultation of stakeholders, it was also attempted to obtain direct inputs from data providers, but
this has not resulted in usable information.
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Intrastat, the assessment of the costs for data providers is based on public consultations of the
data providers themselves.
The Standard Cost Model (SCM) methodology was applied to the figures obtained through
these consultations: by combining the total time spent on filling out surveys on a yearly basis
and (cost) level of the employee completing the survey, the (current and future) administrative
burden could be derived.
Overview of the costs of data production under different policy options:
In Chapter 6, the final results of a model based scenario were presented for the cost of data
production under the different policy options. The cost model and its assumptions for Options
B and C respectively are presented in the following two boxes:
Option B: Modelling implementation costs against the benefits in data collection and production
Even though there are severe limitations to estimating the long term impacts on costs of data collection and
production, this box contains a modelling example to compare the increase in one-off costs of implementation of
a new data production design and in operational costs due to the new data requirements foreseen at this stage
against the long term benefits of more efficient data collection and production. Another limitation of the model is
that the implementation speed of the initiative might significantly vary across Member States. This hence would
also imply heterogeneous rates of the potential implementation cost reductions and productivity gains over time
triggered by the underlying modernisations undertaken by Member States.
The information regarding the increase in one-off costs and initial operational costs has been estimated based on
the information collected from the data compilers. The potential decrease of cost in data collection and
production facilitated by legislative actions under this Option B over a ten year period is estimated based on a
conservative model assuming an annual (diminishing) decrease of costs of 1% over a period of 10 years. It is
assumed that the annual decrease of costs diminishes with 0.05 % per year (eg. 1 % in year N and 0.55 % in year
N+9). In addition, a decrease in costs over time due to annual (diminishing) productivity gains of 2 % (based on
Eurostat calculations) is forecasted. It is assumed annual productivity gains would be diminishing with 0.1 % per
year (eg. 2 % in yean N and 1.1 % in year N + 9). As it is difficult to assess when exactly the cost reductions
will occur, a linear model has been applied. Costs related to non yearly surveys have been annualised. All
amounts are presented in present values, with a discount rate of 4 %.
Combining this assumption, and the input received from NSAs results, for the EU on total, in: estimated one-off
costs plus increased annual operational costs (over the 10 years) of: EUR 230 million for sub-option B1, EUR
209 million for sub-option B2, EUR 144 million of sub-option B3, and between EUR 209 million and EUR 230
million of sub-option B4 while leading to a (EU on total) decrease of EUR -120 million for all sub-options in the
data collection and production during the 10 years of implementation. This results in a net increase (for the EU
on total and over the 10 years): of EUR +103 million for sub-option B1; EUR +83 million for sub-option B2, of
EUR +29 million of sub-option B3, and between EUR 83 million and EUR 103 million of sub-option B4 in
present value terms.
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1729728_0068.png
Option C: Modelling implementation costs against the benefits in data collection and production
Even though there are severe limitations to estimating the longer term impacts on costs of data collection and
production, this box contains a modelling example to compare the increase in one-off costs of implementation of
a new data production design and in initial operational costs due to the new data requirements foreseen at this
stage against the longer-term benefits of more efficient data collection and production. Another limitation of the
model is that in reality the implementation speed of the initiative might significantly vary across Member States.
This hence would also imply heterogeneous rates of the potential implementation cost reductions and
productivity gains over time triggered by the underlying modernisations undertaken by Member States.
The information regarding the increase in one-off costs and initial operational costs has been estimated based on
the information collected from the data compilers. The potential decrease of cost in data collection and
production facilitated by legislative actions under this Option C over a ten year period is estimated based on a
conservative model assuming an annual (diminishing) decrease of costs of 2 % over a period of 10 years. It is
assumed that the annual decrease of costs diminishes with 0.1 % per year (eg. 2 % in year N and 1.1 % in year
N+9). In addition, a decrease in costs over time due to annual (diminishing) productivity gains of 2 % (based on
Eurostat calculations) is forecasted. It is assumed annual productivity gains would be diminishing with 0.1 % per
year ( eg. 2 % in yean N and 1.1 % in year N + 9). As it is difficult to assess when exactly the cost reductions
will occur, a linear model has been applied. Costs related to non yearly surveys have been annualised. All
amounts are presented in present values, with a discount rate of 4%.
Combining this assumption, and the input received from NSAs results in, for the EU on total, estimated one-off
costs plus increased annual operational costs (over the 10 years) of: EUR 224 million for sub-option C1, EUR
203 million for sub-option C2, EUR 140 million of sub-option C3, and between EUR 203 million and EUR 224
million of sub-option C4 while leading to a decrease of EUR -235 million for all sub-options in the data
collection and production during the 10 years of implementation. This results in a present value (for the EU on
total and over the 10 years) of: net increase of: EUR +9 million for sub-option C1, net savings of EUR -10
million for sub-option C2, net savings of EUR -62 million of sub-option C3, and between EUR + 9 million and
EUR – 10 million for sub-option C4.
It is important to note that the model is based on data collected from the data compilers and
on assumptions summarised in the following table, together with the results aggregated for all
the data collections.
The yearly details of the various sub-options
30
are presented in the following table.
30
Sub-option B4 and sub-option C4 are not explicitly inserted in the table since, as indicated in the boxes above,
their values are the ranges between the values of sub-options B1 and B2; and C1 and C2 respectively.
68
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1729728_0069.png
Source of
data/Assumpti
ons
Subopti
on B1
targeted
consultations
of data
compilers
SIMSTA
T
normal
decrease in
cost due to
productivity
gains = 2% in
first year
(reduced with
0.1% for every
consecutive
year);
additional
decrease due
to changes to
existing legal
acts = 1% in
first year
(reduced with
0.05% for
every
consecutive
year)
Change
in costs
as
compare
d to the
baseline
EU-total
annual
cost
increase
including
one-off
investme
nt
EU-total
cost
decrease
year
1
year
2
year
3
year
4
year
5
year
6
year
7
year
8
year
9
year1
0
Total
Net
prese
nt
value
72.9
2
19.1
6
18.6
4
18.1
7
17.7
3
17.3
3
16.9
7
16.6
4
16.3
4
16.07
229.9
5
-
2.90
-
5.52
-
7.88
-
10.0
0
-
11.9
2
-
13.6
3
-
15.1
7
-
16.5
5
-
17.7
8
-
18.86
-
120.2
1
102.7
1
Subopti
on B2
targeted
consultations
of data
compilers
EU-total
annual
cost
increase
including
one-off
investme
nt
EU-total
cost
decrease
54.4
3
18.8
8
18.3
7
17.9
0
17.4
7
17.0
8
16.7
2
16.3
9
16.1
0
15.83
209.1
5
revised
Intrastat
normal
decrease in
cost due to
productivity
gains = 2% in
first year
(reduced with
0.1% for every
consecutive
year);
additional
decrease due
to changes to
existing legal
acts = 1% in
first year
(reduced with
0.05% for
every
consecutive
year)
targeted
consultations
of data
-
2.90
-
5.52
-
7.88
-
10.0
0
-
11.9
2
-
13.6
3
-
15.1
7
-
16.5
5
-
17.7
8
-
18.86
-
120.2
1
83.08
Subopti
on B3
EU-total
annual
cost
44.9
5
12.1
1
11.7
9
11.4
9
11.2
1
10.9
6
10.7
3
10.5
2
10.3
3
10.16
144.2
5
69
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1729728_0070.png
compilers
single
flow
normal
decrease in
cost due to
productivity
gains = 2% in
first year
(reduced with
0.1% for every
consecutive
year);
additional
decrease due
to changes to
existing legal
acts = 1% in
first year
(reduced with
0.05% for
every
consecutive
year)
targeted
consultations
of data
compilers
increase
including
one-off
investme
nt
EU-total
cost
decrease
-
2.90
-
5.52
-
7.88
-
10.0
0
-
11.9
2
-
13.6
3
-
15.1
7
-
16.5
5
-
17.7
8
-
18.86
-
120.2
1
29.69
Subopti
on C1
EU-total
annual
cost
increase
including
one-off
invetme
nt
EU-total
cost
decrease
72.9
2
18.9
7
18.2
9
17.6
7
17.1
0
16.5
9
16.1
2
15.7
0
15.3
3
14.99
223.6
8
SIMSTA
T
normal
decrease in
cost due to
productivity
gains = 2% in
first year
(reduced with
0.1% for every
consecutive
year);
additional
decrease due
to changes to
existing legal
acts = 2% in
first year
(reduced with
0.1% for every
consecutive
year)
targeted
consultations
of data
compilers
-
5.80
-
10.9
8
-
15.6
0
-
19.7
3
-
23.4
0
-
26.6
7
-
29.5
8
-
32.1
5
-
34.4
3
-
36.43
-
234.7
6
9.26
Subopti
on C2
EU-total
annual
cost
increase
including
one-off
investme
nt
54.4
3
18.6
9
18.0
2
17.4
1
16.8
5
16.3
4
15.8
9
15.4
7
15.1
0
14.77
202.9
7
70
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1729728_0071.png
revised
Intrastat
normal
decrease in
cost due to
productivity
gains = 2% in
first year
(reduced with
0.1% for every
consecutive
year);
additional
decrease due
to changes to
existing legal
acts = 2% in
first year
(reduced with
0.1% for every
consecutive
year)
targeted
consultations
of data
compilers
cost
decrease
-
5.80
-
10.9
8
-
15.6
0
-
19.7
3
-
23.4
0
-
26.6
7
-
29.5
8
-
32.1
5
-
34.4
3
-
36.43
-
234.7
6
-10.29
Subopti
on C3
EU-total
annual
cost
increase
including
one-off
investme
nt
EU-total
cost
decrease
44.9
5
12.0
0
11.5
6
11.1
7
10.8
1
10.4
9
10.2
0
9.93
9.69
9.48
140.2
8
single
flow
normal
decrease in
cost due to
productivity
gains = 2% in
first year
(reduced with
0.1% for every
consecutive
year);
additional
decrease due
to changes to
existing legal
acts = 2% in
first year
(reduced with
0.1% for every
consecutive
year)
-
5.80
-
10.9
8
-
15.6
0
-
19.7
3
-
23.4
0
-
26.6
7
-
29.5
8
-
32.1
5
-
34.4
3
-
36.43
-
234.7
6
-62.00
71
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ANNEX V: LIST OF THE CURRENT LEGAL ACTS GOVERNING EUROPEAN
BUSINESS STATISTICS
1)
Business Registers domain:
REGULATION (EC) No 177/2008 OF THE EUROPEAN PARLIAMENT AND OF THE
COUNCIL of 20 February 2008 establishing a common framework for business registers for
statistical purposes and repealing Council Regulation (EEC) No 2186/93;
2)
Structural Business Statistics (SBS) domain:
REGULATION (EC) No 295/2008 OF THE EUROPEAN PARLIAMENT AND OF THE
COUNCIL of 11 March 2008 concerning structural business statistics;
3)
Short-Term Business Statistics (STS) domain:
COUNCIL REGULATION (EC) No 1165/98 of 19 May 1998 concerning short-term
statistics;
4)
Statistics on the production of manufactured goods (PRODCOM) domain:
COUNCIL REGULATION (EEC) No 3924/91 of 19 December 1991on the establishment of
a Community survey of industrial production;
5)
Foreign Affiliates Statistics (FATS) domain:
REGULATION (EC) No 716/2007 OF THE EUROPEAN PARLIAMENT AND OF THE
COUNCIL of 20 June 2007 on Community statistics on the structure and activity of foreign
affiliates;
6)
Statistics on trade with non-member countries (Extrastat) domain:
REGULATION (EC) No 471/2009 OF THE EUROPEAN PARLIAMENT AND OF THE
COUNCIL of 6 May 2009 on Community statistics relating to external trade with non-
member countries and repealing Council Regulation (EC) No 1172/95;
7)
Statistics on trade between EU Member States (Intrastat) domain:
REGULATION (EC) No 638/2004 OF THE EUROPEAN PARLIAMENT AND OF THE
COUNCIL of 31 March 2004 on Community statistics relating to the trading of goods
between Member States and repealing Council Regulation (EEC) No 3330/91;
8)
Research and Development Statistics and Innovation Statistics (R&D and CIS)
domain:
72
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DECISION No 1608/2003/EC OF THE EUROPEAN PARLIAMENT AND OF THE
COUNCIL of 22 July 2003 concerning the production and development of Community
statistics on science and technology;
9)
International Trade in Services Statistics (ITSS) and Foreign Direct Investment
Statistics (FDI) domain:
REGULATION (EC) No 184/2005 OF THE EUROPEAN PARLIAMENT AND OF THE
COUNCIL of 12 January 2005 on Community statistics concerning balance of payments,
international trade in services and foreign direct investment;
10)
Information and Communication technologies statistics (ICT) domain:
REGULATION (EC) No 808/2004 OF THE EUROPEAN PARLIAMENT AND OF THE
COUNCIL of 21 April 2004 concerning Community statistics on the information society.
73
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ANNEX VI: LIST OF ABBREVIATIONS
BSDG - Business Statistics Directors Group
CIS - Community Innovation Survey (innovation statistics)
EGRs – EuroGroups Register
ESS - European Statistical System
ESSC - European Statistical System Committee
Extrastat – Statistics on trade with non-member countries
FATS - Foreign Affiliates Statistics
FRIBS - Framework Regulation Integrating Business Statistics
GVC – Global Value Chains statistics
ICT- Information and Communication technologies statistics
Intrastat – Statistics on trade between EU Member States
ISS – Information Society Statistics
ITGS - International Trade in Goods Statistics
ITSS - International Trade in Services Statistics
MEETS - Modernisation of European Enterprise and Trade Statistics
NCB – National Central Bank
NSA – National Statistical Authority
NSI – National Statistical Institute
PRODCOM - "Production
Communautaire"
or statistics on the production of manufactured
goods
SBS- Structural Business Statistics
STS- Short-term Business Statistics
74