Commission working document - Measuring administrative costs and reducing administrative burdens in the European Union
Date: 2006-11-14
Institutions: European Commission
Subjects: European Union, administrative formalities, application of EU law, exchange of information, operating cost, overheads, report

COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 14.11.2006 
COM(2006) 691 final 

COMMISSION WORKING DOCUMENT  

Measuring administrative costs and reducing administrative burdens 
in the European Union 

{COM(2006) 689 final} 
{COM(2006) 690 final} 

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   EN 

 
 
 
  
COMMISSION WORKING DOCUMENT  

Measuring administrative costs and reducing administrative burdens 
in the European Union 

1. 

INTRODUCTION 

The  European  Commission  has  proposed  an  ambitious  strategy  to  measure  administrative 
costs and reduce administrative burdens in the EU, which includes the adoption of a joint EU 
target  for  reducing  these  burdens  by  25%  overall  in  the  medium  term.  This  underlines  the 
Commission’s commitment to Better Regulation as part of the “Growth and Jobs” strategy.  

This working document accompanies the Strategic Review of Better Regulation in the EU and 
provides a detailed presentation of the building blocks of the EU-wide strategy for measuring 
administrative costs and reducing administrative burdens which are proposed in the Strategic 
Review.  These  building  blocks  have  been  formulated  on  the  basis  of  the  pilot  study  on 
measuring  administrative  burdens,  which  was  carried  out  in  the  summer  of  2006,  and  are 
summarised below hereunder1. This paper intends to initiate a wide ranging discussion with 
the Council, the European Parliament, the Member States and stakeholders on the best way to 
reduce administrative burdens in the EU. On the basis of this discussion, the Commission will 
present  a  proposal  for  an  EU  Action  Programme  on  administrative  burdens  reduction  in 
January 2007, in time for the spring 2007 European Council. This paper, therefore, constitutes 
the  first  element  of  the  Commission’s  response  to  the  June  2006  European  Council 
Conclusions  which  invited  the  Commission  to  make  appropriate  proposals  on  reducing 
administrative burdens by early 2007. 

1.1. 

Administrative costs and the EU business environment 

A  large  part  of  EC  legislation  has  been  introduced  to  correct  market  failures  and  ensure  a 
level  playing  field  at  Community  level.  That  assurance  can  often  only  be  secured  through 
obligations  to  provide  information  and  report  on  the  application  of  legislative  norms. 
However  some  of  the  procedures  in  place  have  become  needlessly  time-consuming, 
excessively complicated or useless.  

Unnecessary  and  disproportionate  administrative  costs  severely  hamper  economic  activity. 
They are also an important irritant to business activity and are often identified as a priority in 
consultations on simplification. The Commission is committed to reducing these unnecessary 
burdens to the maximum extent possible.  

Administrative  costs  are  important  since  businesses  across  the  EU  are  required  to  spend 
considerable  amounts  of  time  filling  in  forms  and  reporting  on  a  wide  range  of  issues.  By 
reducing unnecessary reporting requirements a company's employees can spend more time on 
core business activities which  may  reduce  production  costs  and  allow additional investment 
and innovation activities to materialise, which in turn should improve productivity and overall 
competitiveness. 

1 

"Pilot project on administrative burdens", WIFO-CEPS, October 2006. 

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There  are  presently  only  four  Member  States  which  have  measured  administrative  costs. 
However, an assessment based on an extrapolation of Dutch data suggests that administrative 
costs may amount to circa 3.5% of GDP in the EU. 

Administrative costs by Member State 

AT  BL2 CZ  DE  DK  ES FI  FR UK GR HU IE 

IT  NL PL PT  RE2  SK  SI  SE

EU-
25 

Administrative 
cost  share  in  GDP 
(in %)1 

4.6  2.8  3.3  3.7  1.9  4.6 1.5 3.7 1.5  6.8  6.8  2.4 4.6 3.7 5.0 4.6  6.8  4.6  4.1  1.5

3.5 

1 Based on Kox (2005): Intra-EU differences in regulation-caused administrative burden for companies. CPB Memorandum 136. CPB, 
The Hague. 

2 BL combines Belgium and Luxembourg; RE combines the Baltic Member States, Malta and Cyprus; EU-25 figures are GDP-weighted 
averages 

In 2004 the CPB, the Dutch Bureau for Economic Policy Analysis estimated that reducing the 
administrative burden by 25% would eventually lead to an increase in EU GDP of 1.6%.  

Recent  work  carried  out  by  the  Commission2  services,  building  up  on  CPB  estimates, 
indicates that a 25% administrative cost reduction may yield significant benefits of up to 1.5% 
- or some € 150 billion - in the level of GDP3. 

Graph: GDP effects by 2025 of a 25% reduction in administrative costs 

Table  

Reduction of administrative cost and gains in GDP by Member State 

(changes in % from GDP in baseline for 2025) 

AT  BL CZ  DE  DK  ES FI  FR UK GR HU IE 

IT  NL PL PT  RE  SK  SI  SE

EU-
25 

Changes 
levels (in %) 

in  GDP 

1,8  0,9 1,3  1,3  0,7  1,7 0,6 1,4 0,5 2,4 2,6 0,8 1,7 1,3 1,9 1,7  2,6  1,9  1,4  0,5 1,3 

Note: BL combines Belgium and Luxembourg; RE combines the Baltic Member States, Malta and Cyprus; EU-25 figures are GDP-
weighted averages 

Source: DG ENTR and CPB 2006 

1.2. 

Defining administrative costs 

Administrative  costs  mean  the  costs  incurred  by  enterprises,  the  voluntary  sector,  public 
authorities and citizens in meeting legal obligations to provide information on their activities 

2 
3 

"EPC Better Regulation Thematic Paper", European Commission. 
It is important to bear in mind that this represents a step change in the level of GDP in the year in which 
it is reported. For example, if administrative burden was cut by 25% between 2007 and 2011, GDP in 
2011  would  be  1.5%  higher  than  without  the  reduction.  This  gain  is  permanent  insofar  as  if  the 
administrative  burden  remains  at  the  lower  (75%)  level,  GDP  will  stay  higher.  However,  it  does  not 
affect the growth rate of GDP, i.e. the dynamics of GDP growth. 

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(or  production),  either  to  public  authorities  or  to  private  parties.  They  are  different  from 
compliance costs which stem from the generic requirements of the legislation, such as costs 
induced  by  the  development  of  new  products,  or  processes  that  meet  new  social  and 
environmental standards. Consequently, administrative cost reduction measures are limited to 
streamlining  information  requirements  and  do  not  affect  the  basic  design  of  the  underlying 
legislation.  This  suggests  that  simplification  measures  to  reduce  administrative  costs  are 
developed  more  easily  than  measures  aimed  at  changing  the  nature  or  the  scope  of  the 
underlying legislation. Given their nature and in light of experiences in Member States which 
have  developed  administrative  cost  reduction  programmes,  these  reduction  measures  should 
be  relatively  straightforward  to  decide  and  implement.  Such  measures  are  therefore 
fundamentally different from deregulation initiatives. 

Administrative requirements can be further broken down into information obligations (IOs). 
This  can  best  be  explained  as  follows:  a  piece  of  legislation  may  contain  requirements  for 
submitting information (i.e. submitting a certificate of conformity to a public authority, on a 
regular basis). Each specific requirement in the legislation is defined as an IO.  

An  important  distinction  must  be  made  between  information  that  would  be  collected  by 
businesses  even  in  the  absence  of  the  legislation  and  information  that  would  not  be 
collected without the legal provisions. The former are called administrative costs; the latter 
administrative burdens. The Commission's Better regulation strategy is aimed at measuring 
administrative costs and reducing administrative burdens. 

1.3. 

Distribution of administrative costs in the European Union 

Only three baseline measurements carried out by Member States allow the breakdown of costs 
into  categories  A,  B  and  C  as  identified  below.  Data  from  the  Dutch  and  Danish 
measurements4  suggest  that  a  minor  part  of  the  cost  originate  from  transposition  and 
implementation  measures,  while  substantial  costs  are  related  to  national  and  international 
obligations. The UK data are not yet fully available, but will be published shortly; however, 
the  data,  shared  with  the  Commission  to  facilitate  the  piloting,  seem  to  underline  the 
importance of national obligations. It is evident that a considerable amount of costs originate 
at  national  level,  which  calls  for  a  strong  national  commitment,  alongside  the  Commission 
efforts, to improve the business climate. 

The distribution of administrative costs in DK and NL 

Share of administrative costs by origin of legislation 

Category A: originates directly in international5 law 

Category B: international origin but implemented nationally 

Category C: national origin 

Source: Denmark and Netherlands baseline measurement 

DK 

28% 

15% 

57% 

NL 

43% 

13% 

44% 

4 

5 

Similar breakdowns are not available for the Czech Republic and have not yet been made public by the 
United Kingdom. 
Category A included both costs originating in EC legislation and in international (non-EU) legislation. 

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There  are  indeed  significant  differences  between  the  Member  States  reviewed  which  are 
likely to be caused by differences in the measurement methodology used, but may also be due 
to  sectoral  differences  in  national  economies,  different  legal  traditions  and  different 
administrative  cultures6.  Nevertheless,  this  data  is  important  since  it  identifies  where  costs 
originate and, therefore, also where simplification measures can be introduced. It is clear that 
the  common  EU  target  proposed  by  the  Commission  will  require  action  both  at  EU  and 
national level. Only a joint effort will significantly improve the business environment in the 
EU.  

The  comparison  of  administrative  costs  is  also  difficult  because  pieces  of  legislation  vary 
across  Member  States.  In  order  to  improve  comparability,  it  is  more  efficient  to  look  at 
Information  Obligations  (IOs)  rather  than  at  entire  pieces  of  legislation.  Hence,  the  IOs 
constitute the building blocks of any administrative cost reduction programme. 

In determining regulatory origin, it is essential to be able to determine precisely whether the 
measure  is  transposing  an  obligation  set  at  a  higher  level;  and  whether  the  transposing 
authority  has  added  something  to  that  'original'  obligation  (gold-plating).  This  is  important 
because  responsibilities  need  to  be  clearly  established  for  political,  but  also  for  practical 
reasons. 'Internal' measures and 'transposing' measures require different treatments: when the 
authority has 'created' or added to an obligation, it is free to reduce or suppress it; when it is 
strictly transposing an obligation, it usually needs a collective decision to proceed. 

Transposition is usually straightforward thanks to cross-references or recitals at the beginning 
of the act. Administrative costs stem primarily from four sources: international law, EC law, 
national law and sub-national (regional) law. International law always needs transposition. In 
order to give effect to an international treaty, signatories must ensure that its  provisions  are 
accorded the status of (domestic) law, i.e. transposed in their legal order. By contrast, part of 
EC  law  is  directly  applicable  ('Regulations'),  part  needs  transposition  ('Directives')7.  As  a 
result, some EC and national measures are transposing international obligations (World Trade 
Organisation,  Kyoto  protocol,  etc.),  while  some  national  and  sub-national  measures  are 
transposing EC law.  

Determining the extent of gold-plating is also fairly straightforward when  the  obligation set 
by  an  international  treaty  or  an  EC  act  is  clear,  precise  and  unconditional.  The  transposing 
authority should only be held accountable for what it adds to that obligation. Expert judgment 
may be required when these conditions are not met.  

2. 

MEASURING ADMINISTRATIVE COSTS: EXPERIENCES TO DATE 

2.1. 

National measurements and the Standard Cost Model 

It  is  important  to  recognise  the  work  already  carried  out  by  Member  States  that  have 
pioneered  measurement  and  to  draw  on  the  lessons  learned  when  devising  the  EU  Action 

6 
7 

Pilot project on administrative burdens", WIFO-CEPS, October 2006. 
The  distinction  between  Regulations  and  Directives  however  is  not  always  a  reliable  basis  for 
determining who is accountable for the level of administrative obligations. Indeed some Directives set 
clear,  precise  and  unconditional  information  obligations.  Member  States  have  de  facto  no  room  to 
decide  how  they  will  transpose.  Conversely  some  Regulations  only  set  general  obligations  or  let 
Member States set national thresholds.  

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Programme. Efforts to measure administrative costs by the Dutch Ministry of Finance resulted 
in the development, of the Standard Cost Model (SCM). The SCM was developed to provide 
a  simplified  and  consistent  method  to  measure  and  consequently  reduce  the  impact  of 
business regulations. 

The  main  strength  of  the  SCM  is  the  high  level  of  detail  it  provided  when  measuring 
administrative costs by, for example, assessing individual activities. The SCM's methodology 
makes  it  possible  to  produce  standardised  cost  data  of  the  resources  used  by  businesses  in 
order to comply with specific laws and executive orders. In practice, the SCM aims to identify 
the  Information  Obligations  contained  in  regulations  that  require  businesses  to  make 
information  available  to  public  authorities  or  third  parties.  It  is  possible  –  although  often 
difficult – to subdivide these information obligations into so-called ‘data requirements’ (DRs). 
To fulfil the required information obligations – or rather, to produce the requested information 
– affected businesses normally have to carry out additional administrative activities. The costs 
of these additional activities may arise from the internal use of employees’ time or from the 
external  consumption  of  resources  (e.g.,  fees  for  external  experts,  outsourcing  costs).  In  the 
Netherlands this methodology was used for carrying out, a full baseline measurement in 2003. 

The  use  of  the  Standard  Cost  Model  (SCM)  methodology  has  been  taken  up  by  several 
countries and has also resulted in the development of a network of members (countries) who 
either intend to use it for measuring their administrative costs or act as observers. Seventeen8 
of  the  twenty-five  EU  countries  are  currently  part  of  the  network  and  four  (The  United 
Kingdom,  the  Netherlands,  the  Czech  Republic  and  Denmark)  have  completed  a  full  scale 
measurement of their stock of legislation and have been able to identify the origins (national 
or international) of their legal information requirements. Several of them have set ambitious 
reduction targets. Austria and Germany have recently embarked on a similar process. In other 
members of the SCM network that have not yet engaged in a full baseline measurement, the 
use  of  the  methodology  has  triggered  several  initiatives  in  different  policy  areas.  It  is 
important  to  underline  that  while  the  basic  approach  is  very  similar  in  the  Member  States 
concerned, there are nevertheless significant differences in the precise application of the SCM 
between Member States which render comparisons difficult. 

2.2. 

The EU model 

On  23  March  2005,  the  European  Council  requested  “the  Commission  and  the  Council  to 
consider  a  common  methodology  for  measuring  administrative  burdens  with  the  aim  of 
reaching  an  agreement  by  the  end  of  2005”.  On  16  March  2005  the  Commission's 
Communication on Better Regulation for Growth and Jobs in the European Union included, 
as a companion Staff Working Paper, a detailed outline of a possible “EU Net Administrative 
Cost Model” based on the SCM9.  

In particular, in the Staff Working Paper the Commission assessed the merits of developing a 
common  approach  for  the  measurement  of  administrative  costs  to  redress  the  differences  in 
the way the SCM is applied. The expected benefits of such a common approach are: 

8 

9 

Austria,  Belgium,  Czech  Republic,  Denmark,  Estonia,  Finland,  France,  Germany,  Hungary,  Italy, 
Ireland, Latvia, Luxembourg, the Netherlands, Poland, Sweden and the United Kingdom. 
European Commission, Staff Working Paper, Annex to the 2005 Communication on Better Regulation 
for Growth and Jobs in the European Union, Minimizing Administrative Costs Imposed by Legislation, 
Detailed Outline of a Possible EU Net Administrative Cost Model - SEC(2005) 175, 16.3.2005. 

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•  clarify possible differences in procedures adopted at EU and Member State level; 

•  easier  cross-country  or  cross-policy  area  comparison,  benchmarking  and  the 

development of best practices; 

•  economies of scale in terms of data collection and validation. 

The outline of an EU Net Administrative Cost Model was then amended and refined through a 
pilot phase carried out from April to September 2005. The  pilot phase was aimed at testing 
ways of assessing administrative costs imposed by EC legislation, and led the Commission to 
present a revised methodology, also called the "EU SCM"10. The Commission listed a number 
of possible improvements to the EU SCM, while making clear that such optimisation was no 
precondition for its application. An operational manual for applying the model was included 
in  the  Impact  Assessment  guidelines  on  15  March  200611  and  translated  in  all  EU  official 
languages  to  facilitate  methodological  convergence.  The  EU  SCM  has  been  applied  in  a 
number of published or upcoming Impact Assessments12. 

2.3. 

A comparison between the two models 

Most of the important methodological features, proposed by the Commission, present strong 
similarities with the prototype SCM originally developed in the Netherlands13. For example, 
the  Commission  proposes  to  use  the  same  core  equation,  the  same  relevant  cost  parameters 
(e.g.  internal/external  tariffs,  cost  of  equipment  and  supplies)  and  the  same  formulas  for 
expressing the frequency of administrative activities, and the same approach in the assessment 
of the performance of a “normally efficient entity14. 

However,  the  EU  common  methodology  also  exhibits  a  number  of  specificities  which 
currently are only shared by some national SCM variants. These differences lie in the scope of 
those targeted by IOs (including citizens and the voluntary sector)15, in whether information 
provided to private parties should be included16 or whether to assess substantial one off costs, 
and  how  to  set  an  exclusion  threshold  for  IOs17.  In  order  to  facilitate  information  encoding 

10 

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13 

14 
15 

16 

17 

See  Staff  Working  Document,  Developing  an  EU  common  methodology  for  assessing  administrative 
costs  imposed  by  EU  legislation  -  Report  on  the  Pilot  Phase  (April–  September  2005),  SEC(2005) 
1329,  annexed  to  the  Communication  on  a  “EU  common  methodology  for  assessing  administrative 
costs imposed by legislation” - COM(2005) 518, 21.10.2005. 
See http://ec.europa.eu/governance/impact/docs_en.htm. 
See, for instance, Impact on postal services SEC(2006) 1292 accompanying COM(2006) 594. 
A  fully  fledged  methodological  analysis  can  be  found  in  the  Commission's  Pilot  project  on 
administrative burdens", WIFO-CEPS, October 2006. 
Operational manual, passim. 
The EU SCM aims at assessing costs imposed by legislation on enterprises, the voluntary sector, public 
authorities  and  also  citizens.  The  EU  common  methodology  is  similar  to  the  current  version  of  the 
Dutch SCM in this respect, but appears broader in scope than the measurements carried out in Denmark 
or the UK. 
The  EU  common  methodology 
towards  public 
administrations (e.g. accounting requirements), but also information obligations towards private parties, 
such as consumers (e.g. labelling). This feature is included in the Dutch and Danish measurement. 
In  keeping  with  the  principle  of  proportionate  analysis,  the  EU  methodology  attaches  particular 
importance  to  the  definition  of  the  most  suitable  thresholds  to  be  used  to  identify  information 
obligations that should be excluded from the analysis. The consultation undertaken with some member 
states highlighted that the only possible option would be to set thresholds expressed in number of hours, 
in line with the Danish SCM variant. 

information  obligations 

includes  not  only 

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and  retrieving,  the  EU  SCM  provides  typologies  of  information  obligations  and  required 
actions18.  More  importantly  perhaps,  its  report  sheet  allows  to  link  transposition  measures 
with their original act19 and accounts for gold-plating20. Finally, the EU SCM when applied 
for (ex ante) impact assessment follows a “net cost” approach, where net costs are the costs 
introduced  by  the  proposed  measure  minus  those  eliminated  by  the  measure  at  EU  and/or 
national level. This last feature conceived for ex ante analysis is not, as such, suited for the 
measurement of the costs of existing legislation. 

3. 

DEVELOPING AN EU WIDE MEASUREMENT OF ADMINISTRATIVE COSTS 

3.1. 

Identifying Information Obligation (IOs) 

A key finding of the pilot project is that the identification of specific IOs must constitute the 
basis  of  the  measurement  programme.  Even  if  the  number  of  IOs  is  known  to  vary 
considerably  across  Member  States21,  IOs  are  easier  to  compare  than  entire  pieces  of 
legislation which vary across Member States. This implies a clear classification of such IOs in 
the basic acts and in the subsequent implementation rules, both at the EU and national levels. 
This  is  critical  for  the  quantitative  measurement,  the  setting  up  of  appropriate  reduction 
targets (global baseline, by policy areas, by Member States, by national/regional authorities) 
and the assignment of responsibilities, such as who should act to reduce costs. 

The  carrying  out  of  an  EU  wide  measurement  includes  several  methodological  challenges. 
First,  the  use  of  the  methodology  requires  a  precise  mapping  of  all  the  major  IOs  legally 
required  by  the  legislative  act.  Secondly,  it  is  evident  that  for  an  EU  wide  measurement  to 
take  place  some  harmonisation  and  attribution  of  which  IOs  are  to  be  measured  will  be 
required. 

3.2.  Minimum harmonisation requirements 

As  the  Member  States  which  have  already  completed  their  baseline  measurements  adopted 
slightly  different  variants  to  the  original  Dutch  SCM,  cross-country  comparisons  of  the 
existing  data  are  difficult  to  make,  in  particular  when  trying  to  aggregate  results  and 
determine the origin of the IOs.  

For the EU planned measurement programme, a certain minimum level of harmonisation will 
be required to allow for the validation and comparison of data, to produce meaningful results 
at the EU level and for setting up of ad hoc reduction targets. 

The  results  of  the  pilot  programme  suggest  that  the  following  parameters  will  need  to  be 
harmonised: 

•  the classifications by origin of IOs; 

•  the standardised cost ratios (overheads); 

18 
19 

20 

21 

National SCM variants provide exemplary lists. 
If the act assessed is the transposition of an act adopted at another level, the report sheet provides the 
article and § of the 'original' act where each information obligations is defined. 
Percentages  written  in  the  international,  EU,  national  and  sub-national  columns  indicate  if  the 
transposition strictly follows the original obligation and, if not, how much costs transposition is adding.  
The UK mapped almost 20 000 obligations against 1 100 in Denmark and 3 000 in the Netherlands. 

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•  the type of administrative activities concerned and the populations (segmentation 

of the number of sectors-firms) affected; 

•  the definition of an “efficient business”; 

•  the entities concerned (e.g. households, businesses, administrations, etc.). 

Such methodological issues need to be agreed beforehand between the Commission and the 
Member States. Various options are on the table at this stage for each of these variables but it 
would seem appropriate to base the exercise on the definitions of the parameters provided in 
the EU SCM. However, it is proposed for the purposes of this first measurement exercise to 
limit the scope to businesses22, in line with the Growth and Job strategy since there are still a 
number of unresolved issues relating to the evaluation of costs imposed on other groups.  

3.3. 

A proposal for the scope of the measurement exercise 

Given the importance of European and national legislation for generating administrative costs 
and  the  connections  between  both,  it  is  clear  that  measurements  should  cover  both  levels. 
Moreover, given the scale of the operation, it is clear that the Commission and the Member 
States  both  need  to  contribute  to  the  programme.  In  practice  there  are  three  different 
possibilities  as  to  the  scope  of  the  EU  measurement  exercise.  The  programme  could  aim  at 
identifying IOs and measuring the administrative costs of23: 

•  EC regulations and directives (including IOs originating from international law), 

•  EC  regulations,  directives  and  the  national  implementing  measures  used  to 

transpose the directives, 

•  the costs of information requirements originating from all sources of legislation. 

In light of the data available for the countries that have measured costs, the last option would 
seem  the  most  appropriate.  For  practical  reasons,  however,  it  is  proposed  that  within  this 
programme,  only  the  measurements  of  EC  regulations  and  directives  and  their  national 
implementing  measures  would  be  carried  out  through  the  Commission  co-ordinated 
measurement  project.  Meanwhile,  Member  States  would  carry  out  measurements  of 
information  requirements  originating  in  national  legislation  only.  This  would  ensure  an 
efficient use of available resources. 

The pilot project has also demonstrated that costs are heavily dependent on a limited number 
of  information  obligations.  According  to  the  pilot  project,  there  seems  to  be  a  relevant 
concentration  of  costs  in  a  limited  number  of  policy  areas.  The  UK  data,  which  will  be 
published  shortly  by  the  UK  Government,  suggests  a  particularly  high  concentration.  This 
means that it would be sensible, at least in a first EU-wide measurement exercise, to prioritise 
and  consider  those  areas  for  measurement  that  appear,  from  current  national  measurement 

22 

23 

This  does  not  prevent  Commission  initiatives  aimed  at  reducing  administrative  burdens  for  citizens, 
public administrations and/or the voluntary sector. 
For  further  technical  details  see  European  Commission,  Staff  Working  Paper,  Annex  to  the  2005 
Communication  on  Better  Regulation  for  Growth  and  Jobs  in  the  European  Union,  Minimizing 
Administrative  Costs  Imposed  by  Legislation,  Detailed  Outline  of  a  Possible  EU  Net  Administrative 
Cost Model - SEC(2005) 175, 16.3.2005. 

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exercises  and  on  the  basis  of  other  information,  to  be  most  burdensome.  National 
measurement  exercises  and  other  information  point  at  the  following  areas  as  possible 
priorities. The list gives the relevant data from NL, DK and CZ, but also reflects the UK data, 
which were made available to the Commission for the piloting and will be published shortly 
by the UK Government (see Annex 2). 

The tables in Annexes 3 and 4 are the result of the pilot project looking at cross-country data 
and suggest priority areas for reducing administrative burdens. The  Commission will define 
its priority areas in the Action Programme to be published in January 2007. 

It is clear that the baseline measurements should be carried out in close co-operation between 
Member  States  and  the  Commission.  Hence,  it  is  proposed  that  the  Commission  map 
Information  Obligations  (IOs)  written  in  EC  legislation.  This  mapping  will  be  subsequently 
validated. 

3.4. 

Organisational issues 

The Commission would like to take the above approach forward through a partnership with 
the Member States, supported by a services contract which will be awarded through a call for 
tender to be launched in January 2007. The results deriving from other initiatives, in this field, 
carried  out  by  Commission  services  will  contribute  to  this  work.  For  example,  the 
Commission  intends  to  launch  a  number  of  studies  on  the  measurement  of  administrative 
burdens in specific sectors. For example, as regards Council Regulation (EC) No 1782/2003 a 
study on the measurement of administrative burdens for farmers resulting from the 2003 CAP 
reform will be launched in December 2006. 

The  outsourced  services  will  essentially  consist  of  setting  up  and  running  an  international 
team  of  experts  that  will  perform  the  required  work  for  the  Commission  and  the  Member 
States for a maximum period of up to three years.  

The essential tasks of the contractor could be:  

•  to  assist  the  Commission  and  the  designated  representatives  of  national 
governments in establishing baselines for a comprehensive measurement exercise, 
in  priority  areas,  of  administrative  costs  arising  from  national  and  Community 
legislation on the basis of the principles set out above (to be further defined in the 
Action Programme),  

•  to assist the Commission in developing a series of administrative burden reduction 
programmes  by  means  of  proposals  for  action  and  targets  at  national  and 
Community  levels  on  the  basis  of  best  practices  and  common  principles  (see 
Chapter 4). 

In order to assist the Commission with monitoring the contractor’s activities, control work in 
progress, define priorities and approve the contractor’s regular reports, a Task Force could be 
established and composed of representatives of the Commission services and of Members of 
the High Level Group of national regulatory experts  

The  work  will  not  cover  national  legislation  which  should  be  measured  individually  by 
Member  States  and  which  may  cover  different  priority  areas  as  appropriate  to  national 
realities. 

EN 

10 

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It is also envisaged to exchange views on a regular basis with the existing SCM network and 
to  seek  their  input  on  methodological  issues  that  may  arise.  In  addition,  research  has 
demonstrated  that  the  administrative  burdens  stemming  from  applying  legislation  can  vary 
considerably  between  Member  States.  Learning  from  successful  examples  is  one  way  of 
reducing  these  burdens  and  the  Commission  will  work  with  Member  States  to  identify  and 
disseminate good practices in this area. 

4. 

TARGETS FOR REDUCING ADMINISTRATIVE BURDENS 

In  order  to  reduce  administrative  burdens  in  the  EU,  political  commitment  is  needed  at  all 
levels.  Reaching  agreement  on  common  reduction  targets  ensures  political  momentum  and 
makes  all  actors  responsible  for  reducing  the  burdens  under  their  control.  With  targets,  it 
becomes  easier  to  monitor  the  whole  process  of  administrative  burden  reduction.  By 
examining  actions  taken  by  the  four  Member  States  which  have  already  embarked  on 
administrative  costs  measurement  and  reduction  programmes,  the  following  lessons  can  be 
drawn for the development of an EU strategy. 

4.1. 

Target setting in four Member States 

The four countries which have already started (or completed) the measurement phase and act 
on  the  basis  of  this  measurement  have  similar  approaches  in  their  target  setting  strategies: 
First, all countries have set a ‘political’ overall target before getting the results (UK) or even 
before starting the measurement phase (NL, DK, CZ). The Netherlands and Denmark have set 
a  reduction  target  of  25%  of  the  baseline  measurement  (in  a  5-year  timeframe),  while  the 
Czech Republic has set a target of 20%24. These differences are, however not considered to be 
of  huge  significance.  These  general  targets  were  set  to  anchor  the  exercise  and  the  overall 
level  of  ambition.  While  the  targets  are  necessarily  somewhat  crude  and  not  based  on  any 
specific  analysis,  they  have  functioned  remarkably  well  in  providing  a  framework  and 
generating the momentum necessary to push through the exercise. Secondly, specific sectoral 
targets  (by  ministries/departments)  were  set  in  the  Netherlands  and  are  being  set  in  the 
UKafter  completion  of  the  measurements  phase.  This  possibility  is  also  considered  by  the 
Czech  Republic.  Finally,  for  three  Member  States,  the  reduction  targets  set  are  net,  in  the 
sense  that  new  administrative  burdens  imposed  on  businesses  in  the  considered  period  of 
reduction are included in the total amount to be reduced.  

4.2. 

Lessons for developing EU targets 

As  set  out  in  the  Strategic  Review  and  illustrated  above,  only  common  targets  for  the 
Community  level  and  Member  States  can  generate  significant  results.  This  is  why  the 
Commission has proposed that a common reduction target should be set for all administrative 
burdens in the EU. The target setting should comprise three elements. 

Firstly,  the  experience  of  the  Member  States  reviewed  above  suggests  that  a  general  target 
should be set at an early stage in conjunction with the launching of a measurement exercise 
based  on  an  agreed  methodology.  The  Commission  considers  that  the  European  Council 
should set this target in spring 2007. It is proposed that it should amount to an administrative 
burden reduction of 25% in the entire EU. For those parts of the measurement to be carried 

24 

The  Czech  Republic  has  left  open  the  possibility  of  adjusting  its  target  after  completing  the 
measurement exercise. 

EN 

11 

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out by the Commission, action will be directed to burdens originating in the priority areas to 
be proposed in the Action Programme25. It is expected that the 25% target be achieved within 
5 years. For monitoring purposes, an intermediary target of 3 years could be proposed. This 
timeframe is ambitious given that a measurement exercise on this scale is unprecedented and 
will  take  a  considerable  amount  of  time  –  presently  estimated  at  least  1,5  year.  On 
completion,  the  Commission  and  the  Member  States  will  need  to  draw  up  proposals, 
accompanied  by  an  Impact  Assessment.  Finally,  the  changes  necessary  at  Community  level 
will,  to  a  large  extent,  need  to  be  decided  through  the  Interinstitutional  process.  This 
timeframe  will,  therefore,  require  strong  commitments  of  the  EU  Institutions  and  Member 
States. 

Secondly, more specific partial targets will be set, by policy areas, according to the results of 
the baseline measurements (i.e. in the fourth quarter of 2008): higher reduction targets could 
be envisaged in policy areas where the administrative burdens are particularly heavy and the 
scope for reduction is significant.  

Thirdly, in addition to the overall and the partial targets, it is proposed to start work already in 
the first half of next year on a limited number of  administrative  burden  reduction  proposals 
that  are  likely  to  generate  significant  benefits  through  minor  changes  in  the  underlying 
legislation. A quick harvest of these "low hanging fruits" would be tangible evidence of the 
commitment of the European Institutions to this agenda and would allow significant results to 
be achieved at an early stage. It is proposed that these low-hanging fruits be identified in the 
early  2007  Action  Programme  following  consultation  on  this  Commission  working  paper, 
while duly taking into account planned and ongoing policy review processes26.  

The targets should be agreed by the European Council and the European Parliament to ensure 
that  there  is  a  strong  and  broad  commitment  to  this  agenda.  Given  the  nature  of  the 
simplification proposals at the EU level, it is suggested that administrative burden reduction 
proposals  should  receive  priority  treatment  in  interinstitutional  decision  making,  preferably 
through the fast track procedure27. 

Finally, the commitment by Member States will be crucial since a considerable share of the 
costs originates directly from national and regional legislation, and they will have to decide on 
reducing these costs if the overall target is to be met. 

The evidence from the four Member States that have carried out a full baseline measurements, 
covering both costs originating at Community and Member State level, suggests that a 25% 
reduction target can be met by streamlining information requirements at both levels. This is 
further corroborated by the more partial measurement exercises carried out by larger number 
of  Member  States  in  individual  sectors  as  reviewed  in  Annex  1.  These  empirical  results 
demonstrate the existence of significant administrative burdens that can be reduced by relying 
on a number of cost reduction methods set out in Chapter 5 without affecting the objectives of 
the  underlying  legislation.  The  Commission  is,  therefore,  confident  that  a  joint  programme 
with Member States over a five year period will allow the target to be reached. It is equally 

25 

26 

27 

Other  planned  and  ongoing  review  processes,  including  the  single  farm  payment  review,  will  be 
explicitly counted towards the 25% target. 
A "health check"-review of Council Regulation (EC) No 1782/2003 is scheduled for early 2008 which 
will also include proposals to simplify the scheme and thus reduce its administrative burdens. 
Interinstitutional agreement on Better Regulation, December 2003 (OJ C 321, 31.12.3003, p. 1). 

EN 

12 

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clear  that  the  ability  to  reach  this  target  will  stand  or  fall  with  the  commitment  of  all  EU 
Institutions and the Member States. 

5. 

COMMON PRINCIPLES FOR REDUCING ADMINISTRATIVE BURDENS 

Measuring administrative costs in the EU is not a goal in itself. The aim is to reduce red tape 
for  businesses  in  Europe.  Results  of  the  pilot  project  indicate  that  costs  are  strongly 
concentrated in priority areas. It is proposed that the Commission measurement also focus on 
priority  areas  and,  where  possible,  to  identify  "low  hanging  fruits"  related  to  these  priority 
areas. Regarding the question of how to reduce these burdens, the following principles could, 
if agreed, make a significant contribution to guiding the burden reduction process: 

•  Reduce the frequency of reporting requirements to the minimum levels necessary 
to  meet  the  underlying  objectives  of  the  legislation  (e.g.  there  are  still  many 
financial regulations that require monthly reporting; a reduction in the frequency 
could possibly be envisaged); 

•  Review  whether  the  same  information  obligation  is  not  requested  several  times 
through different channels and eliminate overlaps (e.g. a number of environmental 
information  obligations  are  presently  required  by  more  than  one  piece  of 
legislation); 

is  presently  required,  using 

•  Require  electronic  and  web-based  reporting  where  paper  based  information 
gathering 
intelligent  portals  where  possible 
(experiences  in  Member  States  demonstrate  that  intelligent  portals  covering  a 
variety  of  information  requirements  can  generate  significant  savings;  in  Norway 
the  portal  "Antinn"  covers  nearly  all  information  obligations  on  businesses 
imposed by the central government28); 

•  Introduce  thresholds  for  information  requirements,  limiting  them  for  small  and 
medium sized companies wherever possible, or rely on sampling (it is well known 
that SMEs suffer particularly strongly from administrative costs – data collection 
for information purposes should take this into account); 

•  Consider substituting information requirements on all businesses in a sector by a 
risk based approach – targeting information requirements on those operators that 
carry  the  highest  risk  (the  experience  of  UK  enforcement  of  legislation  in  a 
number  of  areas  shows  that  this  can  significantly  reduce  costs  without 
compromising the legislation); 

•  Reduce  or  eliminate  information  requirements  where  these  relate  to  legislative 
requirements  that  have  been  dropped  or  modified  since  the  information 
requirement  was  adopted  (e.g.  there  are  still  information  obligations  in  road 
transport  dating  back  to  the  time  that  permits  were  required  to  carry  out 
international transport).  

28 

Electronic submission: 
Register of shareholders report: 62 percent in 2005, 36 percent in 2004.  
VAT returns: 46 percent first period 2005. 
Business tax return: Around 60 percent in 2005, around 40 percent in 2004. 

EN 

13 

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It  is  clear  that  these  measures  should  not  compromise  the  underlying  purpose  of  the 
legislation and there may well be cases where, for reasons to do with the protection of public 
health  or  the  environment  or  the  need  to  protect  the  Community's  financial  interests  and 
ensuring  sound  financial  management,  relatively  heavy  information  obligations  will  remain 
necessary.  

6. 

THE NEXT STEPS 

The Commission envisages a number of steps in its Strategic Review of Better Regulation in 
the European Union29. These include the presentation in early 2007 of, an Action Programme 
to  reduce  administrative  burdens  on  the  basis  of  consultation  results  on  this  Commission 
working document and the Strategic Review of Better Regulation to which it is attached. This 
Action  Programme  will  also  contain  proposals  for  immediately  taking  action  as  regards  the 
"low hanging fruits". 

The Action Programme will contain proposals allowing the spring 2007 European Council to 
take the following decisions: 

•  Set an overall target for reducing administrative burdens in the EU 

•  Agree  the  priority  areas  for  administrative  cost  measurement  and  burdens 

reduction; 

•  Endorse  the  methodology  for  measurement  proposed  in  the  Action  Programme, 

and, 

•  Agree the list of "low hanging fruits" for immediate action.  

29 

COM(2006) 689, 14.11.2006.  

EN 

14 

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The Commission, the other EU Institutions and the Member States would subsequently launch 
the measurement programme and take action in respect of the "low hanging fruits". The large 
measurement  programme  could  commence  in  the  spring  of  2007  and  report  in  the  fourth 
quarter of 2008. At this stage, the Commission could propose more detailed sectoral targets as 
well as simplification actions.  

These  actions  could  be  included  in  the  rolling  simplification  programme  which  already 
contains  a  number  of  important  proposals  to  reduce  administrative  burdens30,  in  a  separate 
chapter.  In  this  way,  the  simplification  programme  could  contribute  to  the  monitoring  of 
progress  on  the  implementation  of  the  administrative  burden  reduction  strategy.  Member 
States could in the meanwhile take similar actions during this period and to deliver on burden 
reductions by modifying national and/or regional legislation. Member States could report on 
their national administrative burden reduction programmes in the "Better Regulation" chapter 
of  their  progress  reports  in  the  context  of  the  "Growth  and  Jobs"  strategy.  In  this  way,  the 

30 

in 

the 

instance 

See  "First  progress  report  on  the  Simplification  Strategy  To  Improve  The  Regulatory  Environment", 
Staff  Working  Document,  October  2006.  For 
following  policy  areas: 
Environment:  review  of  the  Integrated  Pollution  Prevention  and  Control  Directive  (IPPC)  and  other 
related legislation on industrial emissions with a view to improving clarity and consistency (notably in 
terms  of  reporting)  and  streamlining  requirements;  Construction  products  Directive,  with  a  view  to 
clarifying  and reducing  the  administrative  burden,  in particular  for  SMEs,  through  more  flexibility  in 
the  formulation  and  use  of  technical  specifications,  lighter  certification  rules,  and  elimination  of  the 
implementation  obstacles  that  so  far  have  hampered  the  creation  of  a  full  internal  market  for 
construction products; 
Statistics:  lighten  statistical  reporting  by  economic  operators,  possibly  exempting  SMEs,  taking  into 
account the outcome of the ongoing pilot project on the measurement and reduction of administrative 
costs and the feasibility study to analyse the workability of a collection system limited to one flow. 

EN 

15 

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Commission  can  annually  report  on  progress  –  at  Community  and  national  level  –  in  its 
Annual Progress Report, thereby assisting the European Council in giving further direction to 
this programme.  

7. 

CONCLUSIONS 

The European Commission, in its strategic review of better regulation in the EU, is proposing 
to cut administrative burdens in the European Union by 25%. Analysis shows that this could 
make a major contribution towards strengthening the business climate in Europe and generate 
significant economic benefits – in the order of € 150 billion in absolute terms in the medium 
term.  

This paper sets out a possible road map for achieving this objective, based on a partnership 
between the EU Institutions and the Member States. A common methodology for measuring 
costs in agreed priority areas and common principles for reducing burdens are at the heart of 
this  approach.  Progress  would  be  monitored  through  agreed  partial  targets  as  well  as 
intermediary targets. 

The  benefits  of  such  an  approach  could  be  very  significant,  but  the  resources  needed  to 
undertake  these  efforts  should  not  be  underestimated.  Strong  commitments  from  all  EU 
institutions and Member States will, therefore, be essential to deliver the results.  

Comments and suggestions on the approach outlined in this document are eagerly sought. All 
interested parties are invited to contribute. On the basis of this consultation, the Commission 
will finalise its proposal for an Action Programme for measuring and reducing administrative 
burdens in the EU due to be presented in early 2007.  

Please send your comments to the following e-mail address by 1 January 2007: 

entr-admin-burdens@ec.europa.eu 

EN 

16 

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Current initiatives in Member States for measuring administrative costs in selected areas  

ANNEX 1 

(updated at September 2006) 

AT

BE

CZ

DK

DE

EE

FI

FR

HU

IE

IT

LV

NL

PL

SE

UK

P
P
P
P
P
P
P
P
P
P
P
P
P
P
P
P
P
P
P
P
P
P

Y
P
N
Y
P
P
P
N
P
P
P
P
P
P
P
P
P
P
P
P
P
N

Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y

Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y

P
P
P
P
P
P
P
P
P
P
P
P
P
P
P
P
P
P
P
P
P
P

Y
N
N
N
Y
N
N
N
N
Y
N
P
P
N
N
N
N
N
N
N
N
N

P
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N

N
N
N
N
N
N
N
N
N
P
N
N
N
N
N
N
N
N
N
P
P
N

Y
N
N
P
P
N
N
N
N
P
P
P
P
N
N
N
P
N
N
P
P
N

N
N
N
N
N
N
P
N
N
N
N
N
N
N
N
N
P
N
N
N
N
N

P
N
N
N
N
N
P
N
N
P
N
P
P
N
N
N
N
N
N
P
N
N

P
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N

Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y

Y
P
P
P
P
N
P
Y
P
P
P
P
P
P
N
N
N
N
N
Y
N
P

Y
Y
Y
N
P
N
Y
N
Y
N
N
Y
Y
N
N
N
N
N
N
N
Y
P

Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y

 Country

Area
Tax
- VAT (excl. invoicing)
- Excise duties
- Other tax
Business and economic affairs
Statistics
Justice
Annual Reporting
Financial Markets
Environment
Business permits
Social affairs
Labour Law
Safety at work
(Food) safety
Interior
Health
Family, consumer affairs
Science, Technology, Innovatio
Culture
Transport
Agriculture
Overall Baseline measurem
Source: SCM network
Y= Measured
P= Planned or being measured
N= not measured

EN 

17 

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Possible priority areas of Community legislation as indicated by national measurements 

ANNEX 2 

No  Area 

EC legislation - examples 

NL 

DK 

CZ 

1 

Annual 
Accounts/Company 
Law 

Fourth Council Directive 78/660/EEC of 25 July 1978 based on Article 54 (3) (g) of the 
Treaty on the annual accounts of certain types of companies. 

3rd Council Directive of 9 October 1978 (78/855/EEC) and 6th Council Directive of 17 
December 1982 (82/891/EEC)  

Council regulation (EC) No 1346/2000 of 29 May 2000 on insolvency proceedings  

Second Council Directive of 13 December 1976 on coordination of safeguards which, for 
the protection of the interests of members and others, are required by Member States of 
companies within the meaning of the second paragraph of Article 58 of the Treaty, in 
respect of the formation of public limited liability companies and the maintenance and 
alteration of their capital, with a view to making such safeguards equivalent (77/91/EEC) 
Directive 2001/83/EC of the European Parliament and of the Council of 6 November 2001 
on the Community code relating to medicinal products for human use  

Directive 2001/20/EC on the approximation of laws, regulations and administrative 
provisions of the Member States relating to the implementation of good clinical practice in 
the conduct of clinical trials on medicinal products for human use 

2 

Health Protection 
(including Animal 
Health and 
Zootechnics) 

27% of Cat. A and 
12.9% of B 

n.a. 

The area 'private law', 
which includes 
accounting, represents 
22.5% of Total 
administrative burdens 
in Cat. A and 12.8% in 
Cat. B in the NL.  

Health protection is 
23.41% of Cat. A, 
whereas 'health care is 
4.87%. In Cat. B, 
percentages are much 
lower (0.43% and 0) 

Approx. 4.8% of Cat. 
A and 12.9% of Cat. 
B 

12.8% of Cat. A 
and 21.8% of 
Cat. B 

3  Working 

environment/employ
ment relations 

Council Directive 89/391/EEC of 12 June 1989 on the introduction of measures to 
encourage improvements in the safety and health of workers at work 

9.63% of Cat. A and 
8.27% of Cat. B.  

Approx. 7.9% of Cat. 
A and 10.6% of Cat. 
B 

n.a. 

EN 

18 

EN 

 
  
No  Area 

EC legislation - examples 

NL 

DK 

CZ 

4 

Fiscal Law/VAT 

Sixth Council Directive 77/388/EEC of 17 May 1977 on the harmonization of the laws of the 
Member States relating to turnover taxes - Common system of value added tax: uniform 
basis of assessment 

19.02% of Cat A and 
14.27% of Cat. B 

9.7% of Cat. A and 
3.7% of Cat. B 
(includes duties) 

n.a. 

5 

Statistics 

Council Regulation (EEC) No 3330/91 and Commission Regulation (EC) No 1901/2000 
laying down certain provisions for the implementation of Council Regulation (EEC) No 
3330/91 

low percentages, but it 
was likely included in 
other areas, depending 
on the areas in which 
statistical  
have to be produced 

2.6% of Cat. A 
(includes keeping 
logbooks for 
fisheries) 

4.4% of Cat. A 
and 5.3% of 
Cat. B 

6 

Agriculture and 
Agricultural 
Subsidies 

Council Regulation (EC) No 1782/2003 of 29 September 2003 establishing common rules 
for direct support schemes under the common agricultural policy and establishing certain 
support schemes for farmers and amending Regulations (EEC) No 2019/93, (EC) No 
1452/2001, (EC) No 1453/2001, (EC) No 1454/2001, (EC) 1868/94, (EC) No 1251/1999, 
(EC) No 1254/1999, (EC) No 1673/2000, (EEC) No 2358/71 and (EC) No 2529/2001  

0.15% of Cat. A and 
1.61% of Cat. B 

13.2% of Cat. B 
(includes direct 
support to farmers, 
agricultural use of 
fertilizers, premium 
for livestock and 
commercial keeping 
of animals) 

Protection of 
plants and plant 
products is 
1.2% of Cat. A 
and 1.3% of 
Cat.B. 
Marketing of 
seeds and 
plants is 2.6% of 
Cat. B 

EN 

19 

EN 

 
  
 
  
  
 
 
No  Area 

EC legislation - examples 

NL 

DK 

CZ 

7 

Food Labelling 

Regulation (EC) No 1760/2000 of the European Parliament and of the Council of 17 July 
2000 establishing a system for the identification and registration of bovine animals and 
regarding the labelling of beef and beef products and repealing Council Regulation (EC) No 
820/97 

n.a.  

7.6% of Cat. A 

Directive 2000/13/EC of the European Parliament and of the Council of 20 March 2000 on 
the approximation of the laws of the Member States relating to the labelling, presentation 
and advertising of foodstuffs. (article 3-25) 

Labelling of food 
is inluded in 
"production and 
placing on the 
market of food 
and tobacco 
products" and in 
"requirements 
for packaging", 
which jointly 
account for 
53.9% of Cat. A 
Food and 
tobacco 
labelling 
accounts for 
25% of Cat. B.  

EN 

20 

EN 

 
  
  
  
 
No  Area 

EC legislation - examples 

NL 

DK 

CZ 

4.71% of Cat A and 
5.76% of Cat. B 

n.a 

n.a. 

8 

Transport 

EEC Council: Regulation No 11 concerning the abolition of discrimination in transport rates 
and conditions, in implementation of Article 79 (3) of the Treaty establishing the European 
Economic Community 
Council Regulation (EEC) No 3820/85 of 20 December 1985 on the harmonization of 
certain social legislation relating to road transport; Council Regulation (EEC) No 3821/85 of 
20 December 1985 on recording equipment in road transport; COUNCIL REGULATION 
(EC) No 2135/98 of 24 September 1998 amending Regulation (EEC) No 3821/85 on 
recording equipment in road transport and Directive 88/599/EEC concerning the application 
of Regulations (EEC) No 3820/84 and (EEC) No 3821/85 
Regulation No 725/2004 of 31 March 2004 on enhancing ship and port facility security 

Council Directive 94/57/EC of 22 November 1994 on common rules and standards for ship 
inspection and survey organizations and for the relevant activities of maritime 
administrations. 

Council Directive 96/26/EC of 29 April 1996 on admission to the occupation of road 
haulage operator and road passenger transport operator and mutual recognition of 
diplomas, certificates and other evidence of formal qualifications intended to facilitate for 
these operators the right to freedom of establishment in national and international transport 
operations;  
Council Directive 97/70/EC of 11 December 1997 setting up a harmonized safety regime 
for fishing vessels of 24 meters in length and over. 

Council Directive 96/35/EC of 3 June 1996 on the appointment and vocational qualification 
of safety advisers for the transport of dangerous goods by road, rail and inland waterway;  

Council Directive 80/1119/EEC of 17 November 1980 on statistical returns in respect of 
carriage of goods by inland waterways;  

Directive 2004/49/EC of the European Parliament and of the Council of 29 April 2004 on 
safety on the Community's railways and amending Council Directive 95/18/EC on the 
licensing of railway undertakings and Directive 2001/14/EC on the allocation of railway 
infrastructure capacity and the levying of charges for the use of railway infrastructure and 
safety certification (Railway Safety Directive); 

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Directive 2000/13/EC of the European Parliament and of the Council of 20 March 2000 on 
the approximation of the laws of the Member States relating to the labelling, presentation 
and advertising of foodstuffs;  

9 

Fisheries legislation 

Council Regulation (EEC) No 2847/93 of 12 October 1993 establishing a control system 
applicable to the common fisheries policy 

n.a 

Council Directive 97/70/EC of 11 December 1997 setting up a harmonized safety regime 
for fishing vessels of 24 meters in length and over. 

n.a 

n.a 

Source: Pilot project on administrative burdens 

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Priority areas at national level 

ANNEX 3 

Below are tables reporting the most burdensome areas resulting from national legislation31. 

Denmark Top-20 C-legislation 

Costs (€) 

Share of C 

Share of total 
costs 

Tax requirements for accounts 

Annual accounts  
Taxation 

Price labelling  
Self-checking in the food industry 

Holidays 
Income taxation etc. 

Supllementary pensions 
Working environment II 

Legal framework between employers and 
employees 

Invoicing of road, soil, sewer etc.  

Private limited companies 

Supplementary pensions II 

Land register 

Taxation of pensions 

Sale and purchase of real-estate 

Good practice for financial companies 

Public limited companies  
Unemployment benefits (sickness and maternity 

Land register II 

Total 

403.893.874  

257.738.456  
195.439.575  
166.712.672  
100.016.302  

61.333.135  
60.185.549  

59.695.163  
55.839.686  

42.827.736  

41.949.880  

40.991.726  

29.738.100  

27.548.139  

25.065.589  

24.447.172  

24.324.442  

21.721.877  
20.510.223  

17.210.322  

17,3% 

11,0% 
8,4% 
7,1% 
4,3% 

2,6% 
2,6% 

2,6% 
2,4% 

1,8% 

1,8% 

1,8% 

1,3% 

1,2% 

1,1% 

1,0% 

1,0% 

0,9% 
0,9% 

0,7% 

9,7% 

6,2% 
4,7% 
4,0% 
2,4% 

1,5% 
1,4% 

1,4% 
1,3% 

1,0% 

1,0% 

1,0% 

0,7% 

0,7% 

0,6% 

0,6% 

0,6% 

0,5% 
0,5% 

0,4% 

1.677.189.619  

71,8% 

40,2% 

31 

"Pilot project on administrative burdens", WIFO-CEPS, October 2006. 

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ANNEX 4 

Netherlands- Administrative costs by domain 
Fiscal law 
Employee insurances 
Health care 
Private law 
Spatial planning:Environmental licenses (general) 
Labour relations 
Working conditions 
Buildings 
Financial markets 
Transport of goods 
Social care 
Medical ethics 
Road traffic law 
Spatial planning: Environmental licenses (sectoral) 
Constitutional and administrative law 
Spatial planning & urban renewal 
Traffic: general 
Agriculture 
Water facilities/constructions 
Corporations and rent law 
Labour market and welfare 
Competition law, ex pricing law 
Seagoing 
Agriculture 
Spatial planning: Rest 
Cluster Telecom & Post 
Soil / ground 
Cat c 
Health protection 
Energy 
Waste 
Inland navigation 
Transportation of persons 
Waste/material & products 
Aviation 
Statistics 

C 
1984,12 
982,20 
870,97 
521,81 
304,21 
301,70 
295,30 
294,53 
211,70 
204,15 
186,20 
124,66 
103,44 
101,13 
99,98 
84,65 
64,07 
63,00 
56,91 
52,79 
47,70 
46,07 
38,96 
38,21 
30,29 
27,67 
24,64 
18,14 
15,64 
9,45 
9,33 
8,52 
7,85 
5,99 
3,87 
3,53 

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