Commission working document - Reducing Administrative Burdens in the European Union - Annex to the 3rd Strategic Review on Better Regulation {COM(2009) 15 final} {COM(2009) 17 final}
Date: 2009-01-28
Institutions: European Commission
Subjects: activity report, administrative formalities, application of EU law, impact study, operation of the Institutions, simplification of formalities

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COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 28.1.2009 
COM(2009) 16 final 

COMMISSION WORKING DOCUMENT 

Reducing Administrative Burdens in the European Union  

Annex to the 3rd Strategic Review on Better Regulation 

{COM(2009) 15 final} 
{COM(2009) 17 final} 

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COMMISSION WORKING DOCUMENT 

Reducing Administrative Burdens in the European Union  

Annex to the 3rd Strategic Review on Better Regulation 

1. 

INTRODUCTION 

Suppressing  unnecessary  administrative  burdens  is  more  important  than  ever  in  difficult 
economic  times,  when  EU  businesses  have  fewer  resources  and  need  to  invest  to  remain 
competitive1. 

In  January  2007,  the  Commission  adopted  a  more  systematic  approach  by  presenting  an 
ambitious Action Programme aimed at reducing administrative burdens on businesses in the 
EU  by  25%  in  20122.  The  Action  Programme  was  endorsed  by  the  European  Council  in 
March  20073,  when  it  specifically  agreed  “that  administrative  burdens  arising  from  EU 
legislation”  (i.e.  including  national  measures  implementing  or  transposing  this  legislation) 
should be reduced by 25% and invited Member States to “set national targets of comparable 
ambition”. The European Parliament also expressed strong support to the Action Programme's 
objectives4 and made budget available to support this activity. 

The aim of the Action Programme is to measure costs imposed by information obligations put 
on businesses and suppress unnecessary requirements. This should improve the efficiency of 
legislation without undermining its purpose. 

This  Working  Document  accompanies  the  Third  Strategic  Review  on  Better  Regulation5.  It 
details progress achieved in 2008 and presents the outlook for 2009 and beyond.  

2. 

MAPPING AND MEASURING ADMINISTRATIVE COSTS OF EU ORIGIN – KEY RESULTS 

A  key  part  of  the  Action  Programme  consists  of  large-scale  baseline  measurement  of 
administrative costs incurred by businesses when complying with legal obligations to provide 
information  to  public  authorities  or  third  parties  (reporting,  inspection,  statistics,  …).  This 
measurement  covers  obligations  stemming  from  EU  legislation  and  from  national  measures 

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Although legislation imposes different types of costs on businesses, small and medium sized enterprises 
consider administrative burdens “the most important individual business constraint” after lack of market 
demand. A large proportion of SMEs also “perceive an overall deterioration in terms of administrative 
regulations”. See results of the 2007 survey by the Observatory of European SMEs (there are 23 million 
SMEs in the EU, accounting for 99.7% of all enterprises): 
http://ec.europa.eu/enterprise/enterprise_policy/analysis/observatory_en.htm.  
COM(2007) 23. 
Presidency conclusions of the Brussels European Council (7/8 March 2007), p. 10: 
http://www.consilium.europa.eu/ueDocs/cms_Data/docs/pressData/en/ec/93135.pdf. 
See, for example, European Parliament Resolution T6-0493/2008 on ‘Better lawmaking 2006’ pursuant 
to Article 9 of the Protocol on the application of the principles of subsidiarity and proportionality of 21 
October 2008. 
COM(2009) 15. 

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implementing  or  transposing  it.  The  methodology  used  is  based  on  the  EU  “standard  cost 
model” (SCM6), drawing on national variants currently used in 20 Member States7. 

The  scope  and  depth  of  the  programme  are  unprecedented8.  The  EU  baseline  measurement 
will provide an estimate of the level of administrative costs and burdens imposed by 42 legal 
acts9 in 13 priority areas in a Union of 27 Member States.  

2.1. 

Overview of mapping results 

Overall,  the  screening  of  the  42  EU  acts  in  scope  of  the  programme  resulted  in  the 
identification  of  356  EU  information  provisions10.  The  consultants  hired  to  conduct  the  EU 
baseline measurement found that implementation or transposition of these EU obligations had 
led to the adoption of more than 9500 national obligations across the 27 Member States. Their 
review showed that more than 700 were going beyond what is required by EU law11.  

2.2. 

Overview of measurement results  

Measurement  results  are  based  on  available  statistics  (mainly  on  the  number  of  enterprises 
affected  by  an  information  obligation),  around  3000  individual  interviews  with  businesses, 
more  than  50  workshops  with  local  business  associations  and  national  ministries  and  data 
adjustment work by hundreds of sectoral experts12.  

The  EU  baseline  measurement  is  made  up  of  data  produced  by  field research,  by  retrieving 
data from national baseline measurements and by extrapolation. Original data collection took 
place simultaneously in 6 different Member States for each priority area, in order to determine 
how much time and money businesses spend to comply with information obligations. For 5 
other  Member  States,  approximately  40%  of  the  data  could,  on  average,  be  retrieved  from 
their national baseline measurements13. Results for the “EU measurement” countries and the 
“national  baseline  measurement”  countries  provide  an  improved  basis  for  analysis  of 
administrative  costs.  Data  for  the  remaining  16  Member  States  are  the  result  of  an 
extrapolation  based  on  models  developed  specifically  for  each  priority  area.  The  SCM 
approach  does  not  aim  at  producing  statistically  valid  results,  but  rather  expert-based 

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See Annex 10 of the Impact Assessment Guidelines:  
http://ec.europa.eu/governance/impact/docs/key_docs/sec_2005_0791_anx_en.pdf, as well as Annex 6. 
See the website of the Standard Cost Model Network: http://www.administrative-burdens.com/. 
The previous largest comparative study was conducted by the OECD in 2006. It measured information 
obligations imposed on the road freight sector for “hiring a worker” and “operating a vehicle during a 
year”  in  11  countries  (OECD,  Cutting  Red  Tape  –  Comparing  Administrative  Burdens  across 
Countries, 2007). 
The list included in COM(2007) 23 contains 41 original (i.e. legislative) acts plus 1 executive measure 
(comitology), assumed to account for over 80% of administrative burdens of EU origin. See Annex 1. 
EU legal texts include different types of provision that can lead to information obligations at national 
level: some impose an obligation on businesses (314); others open up the possibility for Member States 
to impose an obligation on businesses (42). 
See Annex 2. 
Each Member State has designated a “Single Point of Contact” who coordinates national feedback on 
the Action Programme. This network of governmental experts significantly contributed to improve the 
assessment  of  national  information  obligations.  The  “High  Level  Group  of  National  Regulatory 
Experts”  advising  the  Commission  on  better  regulation  issues  also  helped  mainly  with  overall 
(methodological) questions. 
Those  countries  are  AT,  DE,  DK,  NL  and  UK.  Due,  in  particular,  to  differences  in  the  mapping  of 
information obligations, adjustments had to be made to some data.  

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estimates that help understanding the nature of the problem and assessing reduction progress 
in relative terms. Doing otherwise would not be cost-efficient (considering the level of detail 
and the number of parameters concerned). 

The  measurement  phase  is  being  finalised.  Early  indications  show  that,  in  total,  the  42  EU 
acts impose administrative costs of approximately €115 billion to €130 billion. Among the 13 
priority  areas  covered  by  the  programme,  Taxation  and  Customs  as  well  as  Company  law 
seem to have the highest potential for reduction, as they account respectively for about 60% 
and  20%  of  total  administrative  costs.  Food  safety,  Working  environment,  Agriculture  and 
agricultural  subsidies  and  Transport  are  next  on  the  list,  each  of  them  accounting  for 
administrative costs of between €5.7 billion and €3 billion 14.  

2.3. 

Preliminary data analysis  

Key points emerging from the analysis of mapping results are, among others, that: 

•  the  proportion  of  EU  rules  transposing  international  obligations  is  significantly 
higher in the specific areas of company law and the working environment15;  the 
timing  of  reduction  plans  in  those  sectors  will  therefore  have  to  be  adjusted 
whenever  agreement  with  international  partners  is  a  precondition  for  changes  at 
EU level; 

•  a very significant proportion of administrative burdens appear to be the result of 
inefficient public and private administrative practices (between 30 and 40%). 

As for the analysis of measurement results, preliminary findings indicate that: 

•  the level of possible reduction of administrative burdens is not strictly correlated 
to the level of administrative costs : in a number of areas, companies would still 
perform some of the activities required by the information obligations even in the 
absence of a legal obligation16; 

•  in a majority of priority areas, “cooperation with audits and inspections by public 
authorities” is the most expensive activity for businesses; such cooperation often 
mobilises  highly  qualified  staff  for  a  fairly  long  time;  while  auditing  and 
inspecting are necessary to achieve public goals, administrative burdens could be 
very  significantly  reduced  notably  by  improving  the  risk  assessment  on  which 
enforcement activities are based;  

•  irritation  caused  by  EU  law  varies  widely  between  Member  States  but  also 

between legal requirements.  

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See Annex 3. As the various priority areas do not include the same number and type of EU acts, this 
comparison should be treated with caution. 
The International Financial Reporting Standards developed by the International Accounting Standards 
Board, for instance, are integrated into the EU legal framework. 
These “business as usual” costs are between 30% and 50% high in the areas of financial services and 
company law, against an overall average of 18%. 

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3. 

PREPARATION OF SECTORAL REDUCTION CONTRIBUTIONS 

The next step is to identify further reductions17 for each of the 42 EU acts. The final results of 
the  EU  baseline  measurement  exercise  will  greatly  help  in  setting  reduction  priorities  and 
designing reduction proposals.  

The  assessment  of  administrative  burdens  does  not  directly  tell  what  is  necessary  and 
unnecessary,  but  a  detailed  baseline  measurement  does  reveal  what  is  most  costly  and/or 
irritating  for  businesses.18  It  also  indicates  who  imposes  administrative  burden  and  can 
therefore  lighten  it.  Unlike  reduction  programmes  set  up  in  reaction  to  general  complaints, 
this  allows  to  quickly  determine  where  reduction  work  could  start  in  order  to  bring  the 
greatest relief.  

Having data for such a large number of information obligations and countries also provides a 
rich basis for comparative analysis. Great differences in the burden imposed by the same type 
of  obligation  across  sectors  with  similar  characteristics  might  be  the  result  of  differences  in 
technical options19. Similarly if businesses manage to comply with an information obligation 
more  quickly  in  one  country,  it  might  be  because  they  are  more  efficient  or  because 
implementation  of  EU  law  is  better  designed  in  that  country.  The  mapping  of  national 
measures provides a first but crucial indication on this.  

Identification  of  measures  to  reduce  administrative  burdens  in  the  two  largest  priority  areas 
has  been  completed  or  is  sufficiently  advanced  for  identifying  sectoral  reduction  figures: 
namely some €18 billion for taxation 20 and €8 billion for company  law. Figures for the other 
priority  areas  will  follow,  together  with  detailed  sectoral  plans21  listing  reduction  measures 
already  adopted,  pending  and  under  preparation.  Every  effort  will  be  made  to  present  these 
proposals before the end of this Commission's mandate. 

4. 

ACHIEVEMENTS IN REDUCING ADMINISTRATIVE BURDENS 

As announced in the Action Programme, the Commission did not wait for the results of the 
measurement  exercise  to  put  forward  first  concrete  proposals  to  relieve  businesses  from 
unnecessary  administrative  burdens.  Some  of  those  proposals  were  included  in  packages  of 
“fast track actions”,  while  others  were  presented autonomously.  Council  and  Parliament are 
invited to adopt all pending proposals as quickly as possible22. 

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A number of reduction measures have already been presented or adopted (see section 4). 
Number  of  minutes,  type  of  equipment  and/or  level  of  outsourcing  required  to  comply  with  certain 
types of information obligations and to perform certain tasks. 
For  instance,  traceability  systems  have  been  put  in  place  by  the  EU  for  different  sectors  at  different 
times. Some require a paper trail while others are based on bar-code technology, which is usually less 
costly.  
See section 4.2. for further details. 
COM(2007) 23 and COM(2008) 35. 
The  European  Parliament  and  the  Council  reiterated  their  commitment  to  reduce  unnecessary 
administrative  burdens  on  several  occasions  (see  in  particular  Parliament  Resolution  of  21  October 
2008  on  “Better  lawmaking  2006”  (2008/2045(INI))  and  the  conclusions  of  the  Competitiveness 
Council adopted on 2 December 2008). 

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4.1. 

Fast-track actions to reduce administrative burdens 

Fast  Track  Actions  (FTA)  are  defined  as  immediate  measures  that  are  likely  to  generate 
significant benefits or reduce irritation through technical changes to existing rules. In total, the 
21 FTA tabled in 2007 and 200823 offer estimated savings of more than €2.3 billion for EU 
businesses. 

Because of the nature of the changes required, it should be possible to adopt these measures 
fairly quickly. This is usually the case for executive measures: it took on average 5 months 
under the comitology procedure for adopting 6 out of the 7 FTA falling under this category in 
2007 and 2008.  

By contrast, 4 out of 6 legislative proposals presented in March 2007 have been adopted so far 
and only 1 out of 7 from the 2008 package. The FTA on the labelling of batteries (Directive 
2006/66/EC) tabled in 2008 proves however that political agreement can be reached under the 
co-decision procedure within 5 months (excluding parliamentary holidays). 

4.2. 

Stand-alone measures 

In addition to FTA, the Commission has already presented proposals for amending 26 acts out 
of the 42 currently covered by the Action Programme. Out of these proposals, 16 have already 
been adopted as of December 2008.  

The measures include a Community-wide management of customs procedures and a paperless 
environment, which may generate benefits for traders estimated at €2.5 billion per year. In the 
area  of  statistics,  the  reduction  proposals  concerning  intra-Community  trade  in  goods 
(Intrastat)  adopted  since  2004  or  pending  before  the  legislators  will  exempt  an  estimated 
370,000  companies  (in  particular  SMEs)  from  the  obligation  to  report,  provided  that  all 
Member  States  establish  their  reporting  thresholds  to  the  levels  allowed  by  the  European 
legislation. This represents a potential reduction of the surveyed population of enterprises of 
roughly  52%  over  six  years  (from  2004  to  2010)  or  more  than  €100  million  of  savings  per 
year until 2010 and more than €200 million of  savings per year from 2010 onwards. Progress 
has also been made in the area of company law. Several proposals have been adopted since 
2005 and several are still pending before legislators. The proposal regarding the publication 
and translation obligations of companies has alone administrative burden saving potential of 
over EUR 600 million.24 

The identification of future reduction measures is well advanced for two key priority areas. In 
the  case  of  company  law,  the  Commission  plans  to  propose  to  allow  Member  States  to 
exclude micro-enterprises from the scope of EU accounting directives. The “think small first 
principle” is being applied across the board to these directives to tailor the system to the needs 
of  SMEs25.  These  two  revisions  could  bring  total  savings  to  around  €8  billion.  The 
Commission will propose an ambitious revision of the VAT Directive to remove the barriers 
to  electronic  invoicing  and  to  modernise  the  invoicing  rules.  The  maximum  mid-term 

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See Annexes 5 and 6. 
Additional  information  on  simplification  measures  in  the  agricultural  and  fisheries  sectors  will  be 
presented by the Commission in spring 2009, in the form of a Progress Report and a Communication 
respectively. 
The burden placed on SMEs that are not involved in transborder activities should in particular remain 
proportionate. 

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reduction potential of removing the VAT obstacles to e-invoicing was estimated as up to €18 
billion if all invoices were sent electronically. 

This  last  example  shows  that  electronic  communications  are  a  key  tool  for  reducing 
administrative  burdens  for  businesses,  provided  they  are  well  adapted  to  the  needs  of 
businesses  as  well  as  of  the  authorities.  The  Commission  will  therefore  continue  to  reduce 
administrative burdens by promoting use of information and communication technologies, in 
line with its 2006-2010 e-Commission strategy26 and its i-2010 strategy27 for e-government in 
Europe.  

So far, reduction measures presented or foreseen represent savings in excess of €30 billion. 28 

5. 

CONSULTATION WITH STAKEHOLDERS 

Reducing  burdens  is  not  something  the  Union  can  do  on  its  own.  Community  legislation 
indeed is mostly implemented at Member State level. The Action Programme therefore needs 
outside expertise, so that the concrete experience of stakeholders is taken fully into account. 
Stakeholder  involvement  is  mainly  structured  around  three  pillars:  extensive  consultation 
based  on  various  communication  channels,  the  organisation  of  decentralised  events  and  the 
work  of  the  High-Level  Group  of  Independent  Stakeholders  on  Administrative  Burdens 
(HLG). 

5.1. 

Online and offline stakeholder consultation  

EU  businesses  have  the  possibility  to  voice  their  concerns  and  present  concrete  suggestions 
directly  to  the  European  Commission  through  an  online  consultation  in  22  EU  official 
languages29.  In  2008  the  Commission  received  148  submissions  on  its  dedicated  website. 
More than half of them were from private companies, including micro-entities30.  

In  total  237  reduction  ideas  were  also  sent  in  reports  and  letters.  These  off-line  suggestions 
originated, inter alia, from the British, Danish, Dutch, and Swedish public authorities as well 
as  from  many  (sectoral)  business  associations  at  national  and  EU  levels  –  Business  Europe 
and the UEAPME31 in particular. 

In  total  27  ideas  have  been  taken  forward  and  250  are  under  active  consideration32.  A 
significant  part  of  these  submissions  point  at  issues  concerning  cross  border  trade,  VAT, 
internal  market,  environment  and  food  safety.  The  Commission  hopes  to  receive  more 
suggestions, as precise and operational as possible. 

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http://ec.europa.eu/dgs/informatics/ecomm/index_en.htm. 
http://ec.europa.eu/information_society/eeurope/i2010/index_en.htm. 
The  Commission  is  currently  quantifying  further  reductions  achieved.  This  process  is  expected  to  be 
completed by end 2009. 
http://ec.europa.eu/enterprise/admin-burdens-reduction/online_consulation_en.htm.  
See  Annex 
and 
reduction/reports_en.htm . 
The European Association of Craft, Small and Medium-Sized Enterprises. 
After  due  review,  it  appeared  that  the  other  submissions  were  echoing  ideas  already  under 
consideration, too general to be processed or out of scope. The latter were sent to national authorities.  

http://ec.europa.eu/enterprise/admin-burdens-

quarterly 

reports 

on 

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5.2. 

Communication efforts  

In  2008  the  Commission  made  particular  efforts  to  raise  awareness  on  the  importance  of 
administrative  burdens.  It  did  so  through  a  series  of  public  events  co-organised  with  the 
Member States, email campaigns and other electronic means33 as well as by hosting a major 
conference  on  “Cutting  Red  Tape  for  Europe”  in  Brussels  on  20  June  which  attracted 
hundreds of business representatives and national experts34. 

5.3. 

The High Level Group of Independent Stakeholders on Administrative Burdens 

The  HLG  was  set  up  in  2007  in  response  to  a  suggestion  by  the  European  Parliament35.  It 
advises the Commission with regard to the Action Programme, in particular on measures to 
reduce administrative burdens. The Group is chaired by Dr Edmund Stoiber and is composed 
of  14  other  high  ranking  experts  with  a  variety  of  backgrounds  ranging  from  the  business 
community over representative bodies and NGOs to national and regional politics. It held 8 
meetings in 200836. It first dealt with the FTA package approved by the Commission in March 
2008;  it  delivered  key  opinions  relating  to  various  policies,  both  supporting  on-going 
reduction  initiatives  and  promoting  new  ones.  In  particular,  it  supported  ideas  on  company 
law & annual accounts, e-invoicing (VAT legislation) and public procurement, along with a 
number of on-line and off-line suggestions from stakeholders. In addition the HLG initiated 
the launch of the EU competition for the “Best Idea for Red Tape Reduction”37. In 2009, the 
HLG will drive the process forward in all remaining priority areas and continue to take a close 
look at suggestions received directly from businesses and other stakeholders. 

6. 

EXTENSION OF THE SCOPE OF THE ACTION PROGRAMME  

The Communication of January 2007 at the origin of the Action Programme38 provides that 
“the coverage of the Programme may be extended in function of the identification of further 
information obligations eligible for reduction”.  

In order to take into account stakeholders’ ideas, assess the extent of reduction efforts better 
and further increase benefits for businesses, the scope of the Action Programme is extended to 
30 acts listed in Annex 9. The Commission already tabled proposals on some of these acts.  

An example of an area to which the programme will be extended is formalities imposed on 
shipping companies transporting goods by sea within the European Union. The Commission 
will  propose  in  2009  a  European  Maritime  Transport  Space  without  Barriers  in  order  to 
minimise formalities on goods transported by sea between EU ports, notably with the support 
of new technologies. 

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http://ec.europa.eu/enterprise/admin-burdens-reduction/news_en.htm.  
Proceedings on http://ec.europa.eu/enterprise/admin-burdens-reduction/redtape_conference_en.htm.  
See European Parliament Resolution A6-0275/2007: Report on minimising administrative cost imposed 
by legislation of 10 July 2007 
See Annex 8. http://ec.europa.eu/enterprise/admin-burdens-reduction/highlevelgroup_en.htm 
http://ec.europa.eu/enterprise/admin-burdens-reduction/competition_en.htm 
award.eu. 
See COM(2007) 23. 

www.best-idea-

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7. 

NATIONAL PROGRAMMES FOR REDUCING ADMINISTRATIVE BURDENS 

7.1. 

National targets 

The  invitation  of  the  European  Council  in  March  2007  and  the  Action  Programme  have 
significantly  contributed  to  increase  momentum,  with  the  number  of  Member  States  having 
set  national  reduction  targets  rising  from  7  at  end  2006,  to  14  at  end  2007  and  21  at  end 
200839. A large majority have aligned their objective with the 25% reduction target set for the 
EU  level.  A  number  of  Member  States  which  set  a  national  target  at  an  early  stage  have 
already enacted major changes to the measures implementing or transposing EC legislation in 
their country and to their purely national legislation40. All Member States should now actively 
prepare and enact reduction measures. 

7.2. 

The need for coordinated efforts at EU and national levels 

Various  examples  show  that  coordinated  efforts  at  both  EU  and  Member  State  levels  are 
needed  to  ensure  less  burdens  for  more  outcomes.  This  implies  that  progress  with  the 
reductions  delivered  at  EU  and  Member  State  levels  needs  to  be  monitored  in  parallel. 
Member States are also invited, as part of their national programmes, to continue to identify 
what  changes  could  be  needed  at  EU  level  to  allow  them  to  cut  unnecessary  administrative 
burdens. 

The  Commission  also  developed  a  “starter  kit”41  to  help  Member  States  to  measure  and 
reduce  administrative  burdens.  Building  on  best  practice,  this  kit  will  include  ready-to-use 
documents (templates serving as guides for interviews, planning sheets, reporting templates, 
simplification roadmaps, etc.), a generic database for storing national data on administrative 
burdens  and  an  administrative  burdens  calculator.  These  IT  tools  are  designed  to  be  easily 
adapted  to  national  specificities.  The  starter  kit  will  be  available  in  early  2009,  along  with 
initial technical support. The Member States are invited to take full advantage of it in order to 
further data harmonisation and comparability. 

7.3. 

Sharing best practices 

The  Commission  will  continue  to  work  closely  with  national  authorities  responsible  for 
implementing and transposing EU legislation, in order to disseminate good practices capable 
of  reducing  quickly  administrative  burdens  including  at  sectoral  level.  The  Commission 
already  works  with  Member  States  to  facilitate  implementation  or  transposition  of  EC 
legislation, for example through transposition groups where Member States can compare and 
discuss draft approaches and choices. In 2009, the same method will be used in each priority 
area on the basis of detailed recommendations for reduction. 

8. 

NEXT STEPS 

The Commission will:  

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See Annex 10. 
See Annex 12. 
See Annex 13. 

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•  identify, on the basis notably of the EU baseline measurement, the specific reductions to be 
made  in  each  of  the  13  priority  areas  and  will make  every  effort  to  present  all  proposals 
stemming  from  the  present  Action  Programme  to  reduce  the  administrative  burdens 
imposed by EU legislation before the end of its mandate; 

•  systematically  look  for  further  reductions  in  administrative  burdens  whenever  EC 

legislation undergoes (sunset) review or revision; 

•  reinforce  the  part  of  its  impact  assessment  guidelines  concerned  with  administrative 
burdens by putting in place in early 2009 new IT tools designed to facilitate calculation of 
such burdens; 

•  step  up  efforts  to  disseminate  good  practices  capable  of  reducing  quickly  administrative 
burdens, by working more closely with national authorities responsible for transposing EU 
legislation; and 

•  provide  a  starter  kit  for  measuring  and  reducing  administrative  burdens  at  Member  State 

level in early 2009. 

Parliament and Council are invited to: 

•  adopt pending reduction proposals as quickly as possible;  

•  consider the impact of their amendments in terms of administrative burdens ; 

•  put in place procedures to speed up adoption of simplification measures as foreseen in the 

2003 Inter-Institutional Agreement on Better Lawmaking. 

Member States are invited to: 

•  where  appropriate,  submit  their  national  reduction  target  ahead  of  the  2009  Spring 

European Council; 

•  take  into  account  the  findings  and  recommendations  of  the  Action  Programme  when 

reducing burdens stemming from transposition and implementation of EU legislation; 

•  identify  which  changes  are  needed  in  EU  level  to  allow  them  to  cut  unnecessary 

administrative burden; 

•  introduce  concrete  reduction  measures  at  their  level  and  report  on  these  as  part  of  the 

annual national progress reports on the Lisbon strategy; 

•  take full advantage of the starter kit developed by the Commission for future measurement 

and reduction work, in order to further data harmonisation and comparability;  

•  conclude their national baseline measurement by the end of 2010 at the latest; 

•  set  common  principles  for  monitoring  progress  with  the  reductions  delivered  at  EU  and 

Member State levels.  

EN 

10 

   EN