Proportionality test before adoption of new regulation of professions

Briefing 12-05-2017

In general, the IA appears to set out logical reasoning linking the problem, its underlying drivers, the objectives and the policy options to tackle the problem. It seems to be based on sound research and analysis, while nevertheless recognising that there are still data gaps to be filled. With regard to the analysis of impacts, a more targeted analysis of the likely impacts on SMEs might have been desirable. Also, the IA does not seem to identify operational objectives for its preferred policy option and corresponding monitoring indicators. More generally, a proof-reading of the final text, and different choices as to its organisation and presentation, would almost certainly have considerably improved the IA's clarity and readability and its effectiveness in supporting the policy choices made in the proposal.