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Based on a 2018 (REFIT) evaluation, the IA defines the main problems, the objectives and the policy options to address them with a clear intervention logic. It is based on solid internal and external expertise and various consultations to compensate for a considerable (and acknowledged) lack of data. While it is transparent about methods, uncertainties and limitations, additional quantification and/or substantiation would have been useful in some areas, namely when it comes to potential impacts on ...

The ex-ante analysis of this initiative, aimed at addressing impacts on the single market caused by a potential future crisis, implies major uncertainties and limitations, openly acknowledged by the IA (notably owing to a lack of data). Notwithstanding this important caveat, the IA develops a clear intervention logic, linking the problems with objectives to achieve through three policy options, without, however, fully complying with the Better Regulation Guidelines. It assesses the broad scope of ...

The IA is based on solid expertise, with ample information in 13 annexes, some of which form an integral part of the analysis (namely Annexes 5 and 12 for the problem definition and Annex 8 for the assessment of the options' impacts). The qualitative and quantitative assessment of the options is concise, balanced and logical. The IA is transparent regarding methods, assumptions and uncertainties in the analysis, which it addresses through a sensitivity analysis to ensure a robust evidence base. The ...

The IA is based on solid internal and external sources, in particular several ESMA review reports, and stakeholder consultations. However, the definitions of both the problems and the objectives lack consistency and coherence, as the lines between problems, their drivers and consequences are blurred and objectives seem to overlap (and shift). This weakens the IA's intervention logic. The policy options presented to tackle the problems are assessed against two baseline scenarios, which is unusual. ...

The IA supports the proposal for the review of the AIFMD in an overall effective and transparent manner. It is based on solid internal and external expertise, including an array of technical recommendations from the relevant EU and international bodies in charge of monitoring and supervising investment funds. While the intervention logic of the mostly qualitative IA is clear, some aspects could have been substantiated in a more precise way. The highly technical analysis would have been more accessible ...

The IA follows a clear intervention logic, with objectives and options deriving from the problems to tackle. It is transparent about limitations and uses estimates with the appropriate caution. The range of options is predetermined by the outstanding Basel III standards, which the IA prefers to implement with adjustments reflecting specificities of the EU banking sector and potential consequences of the Covid-19 crisis. The qualitative assessment is complemented by selective pertinent quantification ...

The IA is based on extensive internal and external research and modelling and covers a lot of ground relating to a variety of potential impacts, both in the main text and the annexes. It is also transparent with regard to the limitations and uncertainties of the analysis. While not all aspects could be assessed in depth, in the interest of proportionality, the IA considers the relevant impacts of the retained options, with a focus on the industrial sectors that were selected for coverage; it addresses ...

European green bond standard

Briefing 21-10-2021

The IA assesses elements to be added to the 2019 TEG report on a European Green Bond Standard (EU-GBS). The range of options is therefore limited to these additional aspects and does not cover the entire set of rules for green bonds. The IA is based on reliable internal and external research, international data and several stakeholder consultations. While the definition of the objectives could have been more specific, the problem analysis and the assessment of options are overall logical and thorough ...

The IA underpinning the proposal to tackle foreign subsidies is based on solid internal and external research, which compensates an admitted lack of data. It is transparent about methods, underlying assumptions and certain limitations. The intervention logic of the IA is clear, even if the complex set-up of the policy options and their assessment could have been more structured and coherent. The IA does not present operational objectives and few, yet pertinent, monitoring provisions. While the mostly ...

EU partnership on metrology

Briefing 09-06-2021

The IA underpinning the proposal on the EU partnership on metrology is based on solid sources. The relatively narrow range of options is pre-determined by the Horizon Europe provisions, and the mostly qualitative and comparative assessment gravitates early on towards the preferred option. While subsidiarity, competitiveness and coherence with the overarching political priorities are consistently addressed, the consideration of benefits and costs of the options could have been more complete and precise ...