Impact assessments on a crest of a wave

Following the lead of the Regulatory Impact Unit (RIU) in Britain's Cabinet Office, impact assessments are in fashion in governments across Europe at the moment, with the European Commission replacing its earlier interest in ex ante evaluation with impact assessment. But does impact assessment actually deliver the goods or is it a paper-pushing game that bureaucrats play in order to get their regulations through the hoops of Parliament? This note argues that impact assessment is not as easy as it looks, if the early history in the Commission is observed.

The 2002 Communication of the European Commission on Impact Assessment committed the Commission to undertake impact assessment of all major policy proposals in order to “improve the quality and coherence of the policy development process.” It was also seen as contributing to regulatory reform.

By 2003, a unified system of integrated impact assessment had been introduced which replaced several separate, more specialised forms of assessment that were in use in different parts of the Commission. The new system consisted of ‘preliminary’ assessment of all proposals in the Commission’s work programme and ‘extended’ assessments of major proposals. In the first year of use, a total of 20 Extended Impact Assessments (Ex IA) were completed with a further 46 intended for 2004. However, during the course of 2004, the Commission decided to drop the ‘Extended’ label on the grounds that all policy proposals were deserving of integrated impact assessment.