Opinion of the European Monetary Institute following a consultation from the Council of the European Union under Article 109f(6) of the Treaty establishing the European Community (“the Treaty”) and Article 5.3 of the Statute of the EMI; on a Proposal for a Council Regulation on Community action in the field of statistics (COM(94)78 final) (CON/94/10)
Date: 1995-02-15
Institutions: European Monetary Institute
Subjects: EU policy, EU statistics, financial statistics, interinstitutional cooperation (EU), statistical method

European Monetary Institute

OPINION OF THE EUROPEAN MONETARY INSTITUTE

following  a  consultation  from  the  Council  of  the  European  Union  under  Article  109f(6)  of  the  Treaty

establishing the European Community (“the Treaty”) and Article 5.3 of the Statute of the EMI;

on a Proposal for a Council Regulation on Community action in the field of statistics (COM(94)78 final).

CON/94/10

1

The  present  consultation  was  initiated  on  16th  December  1994  by  the  Council  of  the  European

Union which, for this purpose, transmitted document “COM(94) 78 final” containing the proposed

Council Regulation to the EMI.

2

The principal objective of the Draft Regulation is to define and organise Community action in the

field  of  statistics,  which  is  designed  to  produce  Community  statistics  systematically  for  the

formulation,  application,  monitoring  and  assessment  of  Community  policies  and  to  provide  these

statistics  regularly  to  the  Community  institutions,  governments,  social  and  economic  operators,

academic circles and the general public (users).

3

The EMI  welcomes  the  Draft  Regulation  for  a  number  of  reasons.  As  stated  in  the  preamble  to

the Draft Regulation, full account is taken of the independence and the responsibilities of the EMI

in the field of statistics at EU level and of the need for careful arrangements to continue the close

co-operation  between  the  Commission  and  the  EMI  with  a  view  to  promoting  the  coherence  of

statistics  at  EU  level.  These  requirements  are  fulfiled  in  a  very  balanced  manner  through  the

following provisions of the Draft Regulation:

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-

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Article 1.4  notes  that  the  EMI  and  the  National  Central  Banks  do  not  participate  in

Community  action  in  the  field  of  statistical  for  the  purposes  of  the  Regulation.  This  is  an

important  clarification  of  the  general  definition,  in  Articles  1.2  and  2.1,  of  the  authorities

responsible for producing Community statistics.

The Regulation provides the basis for Community statistical programmes. Article 3.2 clearly

states that the EMI shall be consulted on the proposals for these programmes and for their

updates and that the Commission shall take the requirements of the EMI into consideration

as far as possible.

Article 8 provides that the Commission and the EMI will co-operate closely to guarantee the

coherence  necessary  to  produce  statistics  which  meet  their  respective  information

- 2 -

requirements  and  that  the  Committee  on  Monetary,  Financial  and  Balance  of  Payments

Statistics shall take part, within the limits of its competence, in this process of co-operation.

It  should  be  emphasised  that  the  EMI’s  obligation  to  cooperate  with  the  Commission  in  the

statistical field is primarily based on Article 5.1 of the Statute of the ECB, which can be deemed to

apply  to  the  EMI  as  forerunner  of  the  ECB.  Article  8  of  the  draft  Regulation  is  in  that  respect

consistent  with  the  Treaty,  but  contains  in  addition  the  basis  for  the  Commission  obligation  to

co-operate  with  the  EMI.  At  this  stage,  this  is  deemed  sufficient  for  the  EMI’s  statistical  tasks

under the Treaty.

Co-operation between the Commission and the EMI under  Article  8  of  the  Draft  Regulation  will

take  due  account  of  the  principles  contained  in  Article 9.  These  are  impartiality,  reliability,

pertinence, cost-effectiveness, statistical confidentiality and transparency. These principles are the

basis of a sound statistical system, and the EMI is in agreement with them.

4

The  principle  of  confidentiality  is  defined  in  two  articles,  namely  Article  9.2  and  Article  13,  in  a

manner  that  it  is  not  fully  consistent.  The  EMI  understands  that  the  definition  of  Article  9.2  is

purported  to  delimit  the  application  of  the  whole  Chapter  VI  on  “Statistical  Confidentiality”,  and

therefore of Article 13. Should that not be  the  a  correct  understanding,  it  might  be  convenient  to

unify the concept in one sole definition.

5

6

7

At this stage, no additional provisions are particularly needed to assist the EMI in the performance

of its statistical tasks.

Finally,  the  preamble  confirms  that  the  opinion  of  the  EMI  has  been  sought  for  the  purposes  of

the Draft Regulation.

Accordingly,  the  EMI  considers  the  Draft  Regulation  to  be  suitable  for  its  purposes.  The  Draft

Regulation  provides  the  basis  for  the  production  of  Community  statistics,  for  many  of  which  the

EMI will have a great interest.

15th February 1995