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The Dutch Advisory Board on Administrative Burden (Actal). EBIC Conference February 19th 2007, Brussels drs. Peter Bont Secretary General Actal. Definition and context.
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The Dutch Advisory Board on Administrative Burden (Actal) EBIC Conference February 19th 2007, Brussels drs. Peter Bont Secretary General Actal
Definition and context • Administrative Burdens (AB) = costs for business sector when complying to information obligations imposed by government regulation • AB approach is part of regulatory reform program
Definition Administrative Burdens (AB)For example: • Reporting requirements • Direct ICT costs for meeting these reporting requirements • NOT: Cost of a bank vault
The Dutch AB approach • Necessary and effective infrastructure set up • Zero base measurements • Reduction target • Political commitment • Ex ante quantification • Actal: independent and objective judgement
The Actal Organisation • Independent watchdog, assessor and facilitator. • Small organisation: 3 Board members, 12 staff. • Established in 2000 : focus on AB for businesses. • Installed until 1st of June 2009.
Assignment • Bring about a cultural shift among legislators and policy advisors Through: • Formal advice (proposed and existing legislation) • Increasing insight of consequences of laws and regulation on AB • Backing the governments objective to cut back the AB by 25%
Zero measurement Insight in Administratieve Burdens: • reporting requirements • Insight in current supervisory costs ESSENTIAL TOOL FOR MEASURING INCREASE/ DECREASE OF ADMINISTRATIVE BURDENS
Pay off AB approach • Economic pay off : + 1.5% GDP / + 1.7% labor productivity • Regulatory quality: - Increasing AB awareness in other domains, e.g. intragovernmental AB • Increasing awareness of other compliance costs for businesses
Results of the Dutch approach • 25% net reduction within reach • Structural ex ante evaluation of effects of regulation • AB restrained • Cultural shift on it’s way
The Standard Cost Model LAW Information obligations Administrative actions Time Tariff Target group Frequency P Costs administrative actions Q Yearly amount administrative actions Administrative burdens = P x Q
EU and international legislation BASEL II • AB FOR DUTCH BANKING SECTOR € 28 MLN/YEAR • AB FOR INDIVIDUAL INSTITUTIONS: • Small banks + € 19.000 • Midsize banks + € 57.000 • Large banks + € 500.000 • Very large banks + € 7 mln • Small investment companies + € 2.500 • Large investment companies + € 33.330
EU and international legislation MIFID • BANKS & INVESTMENT COMPANIES • Costs of reporting requirements • ICT Costs • AB for a multilateral trading facility (MTF) • Supervisory Costs
EU and international legislationWhat we can do on national level? ONCE EU LEGISLATION IS FINAL: • Directives are solid concrete • There is no room for promoting new ideas • There is no room for better alternatives • MORE FOCUS ON AB IN EU IS NEEDED! • NO GOLDPLATING OF EU LEGISLATION
EU Action Programme • 25% reduction in 2012 • 13 priority areas • fast track action But this is the 1st step. • measurement and reduction total Aqcuis • permanent control over AB • perceived burdens
Lessons learned in NL • Infrastructure necessary • SCM pivotal in reducing AB • Commitment on political level indispensable • A quantitative target increases sense of urgency • AB come from different sources • AB only a part of the effects of regulation
Contact information Actal P.O. Box 16228 2500 BE The Hague The Netherlands tel: +31-(0)70-3108666 fax: +31-(0)70-3108679 e-mail: info@actal.nl Internet: www.actal.nl