Special Report No 10 // 2016#Further improvements needed to ensure effective implementation of the excessive deficit procedure #(pursuant to Article 287(4), second subparagraph, TFEU)
Date: 2016-02-25
Institutions: European Court of Auditors
Subjects: EU Member State, budget deficit, budget policy, budgetary discipline (EU), national budget

EN 

2016 

NO 10

Special Report  Further improvements 

needed to ensure effective 
implementation of the 
excessive deficit procedure

EUROPEAN
COURT
OF AUDITORS

 
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Luxembourg: Publications Office of the European Union, 2016

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EN 

2016 

NO 10

Special Report

Further improvements 
needed to ensure effective 
implementation of the 
excessive deficit procedure

(pursuant to Article 287(4), second subparagraph, TFEU)

Audit team

02

The ECA’s special reports set out the results of its performance and compliance audits of specific budgetary areas or 
management topics. The ECA selects and designs these audit tasks to be of maximum impact by considering the risks 
to performance or compliance, the level of income or spending involved, forthcoming developments and political and 
public interest.

This performance audit was produced by Audit Chamber IV — headed by ECA Member Milan Martin Cvikl — which 
specialises in auditing revenue, research and internal policies, financial and economic governance and European Union’s 
institutions and bodies. The audit was led by ECA Member Milan Martin Cvikl, supported by the Head of his private office, 
Kathrine Henderson and Andreja Rovan, Attaché; Zacharias Kolias, Director; Albano Martins Dias da Silva, Head of Task; 
Giuseppe Diana, Marko Mrkalj, Maria Isabel Quintela, Marion Schiefele, Duarte Semedo Leite and Stefano Sturaro, audi‑
tors; Thomas Everett and Marek Riha, language support.

From left to right: G. Diana, M. Schiefele, A. Rovan, A. Martins Dias da Silva, Z. Kolias, 
M. M. Cvikl, S. Sturaro, M. I. Quintela, K. Henderson, T. Everett.

Contents

03

Paragraph

Abbreviations and acronyms

Glossary

I – IX 

Executive summary

01 – 25 

Introduction

01 – 04 

Background on economic and fiscal governance policy in the EU

05 – 25 

The excessive deficit procedure: maintaining the soundness of public finances

07 – 17 

The EDP process: ensuring data quality, assessing the situation, initiating an EDP

18 – 24 

Corrective action: reporting by Member States, monitoring and surveillance by the Commission

25 

Outcome of the EDP

26 – 31  Audit scope, objectives and approach

26 – 29 

Audit scope and objectives

30 – 31 

Approach

32 – 127  Observations

32 – 84 

EDP process: improvements needed to strengthen the basis of the EDP and enhance the 
objectivity of assessments

32 – 62 

An appropriate framework for decisions, but greater clarity needed

63 – 84 

Data quality assessments and economic analyses lack transparency; analyses carried out according to the 
rules, but focused more on government deficit than on debt

 
 
Contents 

04

85 – 112 

EDP corrective and surveillance actions: reporting by Member States, monitoring and 
surveillance by the Commission

85 – 87  Member States’ reporting on corrective action could be improved

88 – 112  Monitoring and surveillance by the Commission is subject to increasingly complex rules, lacks 
transparency and provides a limited assessment of the effect of structural reforms

113 – 127  Outcome of the EDP

113 – 127  EDP reforms have introduced tools for enhancingbudgetary discipline, but the EDP has not proved fully 

effective as a corrective mechanism

128 – 149  Conclusions and recommendations

130 – 139  Eurostat

130 – 131  Examination of data

132 

Assessment of control systems

133 – 135  Dialogue visits and direct verification

136 

137 

Action points

Guidance

138 – 139  Outcome

140 – 149  DG Economic and Financial Affairs

140 – 141  Transparency

142 – 143  Debt criterion

144 – 145  Structural reforms

146 – 147  Reporting

148 – 149  Sanctions

Contents 

05

Annex I  —  Legislation on the excessive deficit procedure

Annex II  — 

 Some examples of missing information in documents from the six Member States 
examined

Annex III  — 

 Some examples of classification weaknesses in documents from the six Member 
States examined

Annex IV  — 

 Some examples of action points with a potential impact on the deficit and debt 
data

Annex V  —  Annual nominal GDP growth rate

Annex VI  — 

 Compliance with the nominal and structural targets set in EDP recommendations 
and EDP deadline extensions

Annex VII  —  Differences between Commission and Council recommendations

Annex VIII  — 

Implementation of planned structural reforms

Reply of the Commission

 
 
 
 
 
 
 
 
 
Abbreviations and 
acronyms

06

ACR: Autonomous Commission recommendation

AMECO: Macroeconomic database of the European Commission

DG Economic and Financial Affairs: Directorate‑General for Economic and Financial Affairs

DG Migration and Home Affairs: Directorate General for Migration and Home Affairs

ECB: European Central Bank

ECOFIN: Economic and Financial Council

edp: Excessive deficit procedure

EEF: European economic forecast

EFC: Economic and Financial Committee

EMU: Economic and monetary union

EPP: Economic partnership programme

ESA: European System of Accounts

Eurostat: Statistical Office of the European Union

GDP: Gross Domestic Product

GFS: Government finance statistics

MTO: Medium‑term budgetary objective

SCP: Stability or convergence programme

SDV: Standard dialogue visit

SGP: Stability and Growth Pact

TFEU: Treaty on the Functioning of the European Union

UDV: Upstream dialogue visit

Glossary

07

Actual data: Historical (not planned/forecast) data.

Bottom‑up fiscal effort: A quantification of the fiscal impact of corrective measures, expressed as the aggregated 
impact of individual measures. See Top‑down fiscal effort.

Budget balance: The balance between total public expenditure and revenue in a specific year, with a positive 
balance indicating a surplus and a negative balance indicating a deficit. For the monitoring of Member State 
budgetary positions, the EU uses general government aggregates. See also Structural (budget) balance, Primary 
(budget) balance.

Code of Conduct: Policy document with guidelines for the implementation of the Stability and Growth Pact and 
the format and content of stability and convergence programmes.

Convergence programmes: Medium‑term budgetary and monetary strategies presented by Member States that 
have not yet adopted the euro. They are updated annually in accordance with the provisions of the Stability and 
Growth Pact. See also Stability programmes.

Cyclical component of budget balance: That part of the change in the budget balance which follows 
automatically from cyclical elements in the economy, due to the reaction of public revenue and expenditure to 
changes in the output gap. See Structural (budget) balance.

Data quality: Data quality means compliance with accounting rules, completeness, reliability, timeliness and 
consistency (Article 8(1) of Council Regulation (EC) No 479/2009). 

Dialogue visit: Carried out by Eurostat in a Member State to review the actual data reported and review all relevant 
aspects of EDP data. Member States are visited at least every two years. DG Economic and Financial Affairs and the 
ECB act as observers.

From 2011 to 2013 Eurostat carried out both ‘standard’ and ‘upstream’ dialogue visits – the latter to assess the 
management and control of upstream public finance/systems data flows. These verifications are now included in 
standard dialogue visits.

Economic and Financial Committee (EFC): Formerly the Monetary Committee, the EFC is a Committee of the 
Council of the European Union set up by Article 134 of TFEU. Its main task is to prepare and discuss ECOFIN Council 
decisions with regard to economic and financial matters.

EDP inventory of sources and methods: Description of the procedures (methods) and basic statistics (sources) 
used by a Member State to produce estimates for EDP notifications. Includes ‘bridge tables’ showing the 
correspondence between public accounting items and the ESA headings, and a list of general government units 
classified by sub‑sector and industry.

Glossary 

08

EDP notifications and related questionnaires: 
EDP notifications
Twice a year, Member States send their general government deficit and debt figures in the form of notifications 
comprising four groups of tables with information, for all levels of government, on the government deficit/surplus 
and debt levels, the adjustments made to the public accounts working balance to obtain the deficit/surplus, the 
factors contributing to the level of debt, and other compulsory data.

Related questionnaires
A set of tables containing standard information on revisions, adjustments, financial transactions and the application 
of Eurostat decisions.

ESA (ESA 95 and ESA 2010): The European system of national and regional accounts is the EU’s internationally 
compatible accounting framework for the systematic and detailed description of the economies of the EU 
Member States and regions. For most of the audited period the relevant system was ESA 95, which was upgraded 
in September 2014 to ESA 2010, reflecting developments in measuring modern economies, advances in 
methodological research and the needs of users.

While the ESA is broadly consistent with the definitions, accounting rules and classifications applied by the 
comparable UN system, it also has some specific features which are more in line with EU practices.

European Semester: The annual cycle of economic policy coordination, which takes place over the first six months 
of the year. The European Commission undertakes a detailed analysis of Member States’ programmes of economic 
and structural policies, and the European Council and the Council of Ministers provide policy advice before Member 
States finalise their draft budgets.

Financial/non‑financial corporations: 
Financial corporations sector (ESA 95, paragraph 2.32)
Includes all corporations and quasi‑corporations which are principally engaged in financial intermediation (financial 
intermediaries) and/or in auxiliary financial activities (financial auxiliaries).

Non‑financial corporations sector (ESA 95, paragraph 2.21)
Consists of institutional units whose distributive and financial transactions are distinct from those of their owners, 
and which are market producers whose principal activity is the production of goods and non‑financial services.

Fiscal consolidation: An improvement in the budget balance through measures of discretionary fiscal policy, 
specified either by the amount of the improvement or the period over which the improvement is sustained.

General government: ESA 95 defines the ‘general government’ sector as ‘All institutional units which are other 
non‑market producers whose output is intended for individual and collective consumption, and mainly financed by 
compulsory payments made by units belonging to other sectors, and/or all institutional units principally engaged in 
the redistribution of national income and wealth’.

Glossary 

09

It is composed of four sub‑sectors:

 ο central government ‑ all administrative departments of the state and other central agencies whose 

responsibilities cover the whole economic territory of a country, except for the administration of social security 
funds;

 ο state government ‑ institutional units that exercise some government functions below central government and 

above local government level, except for the administration of social security funds;

 ο local government ‑ all types of public administration whose responsibility covers only a local part of the 

economic territory, except for local agencies of social security funds;

 ο social security funds ‑ central, state or local institutional units whose main activity is to provide social benefits. 

Government debt: The total gross debt at nominal value outstanding at the end of the year and consolidated 
between and within the sectors of general government as defined in ESA 95. It comprises currency and deposits, 
securities other than shares excluding financial derivatives, and loans (Maastricht debt).

Government deficit: The level of net borrowing as defined in ESA 95/ESA 2010, with certain adjustments.

Government finance statistics: Data on the economic activities of general government, including government 
revenue, expenditure, deficit, transactions in assets and in liabilities, other economic flows and balance sheets. 
European GFS are produced in accordance with the ESA, with additional interpretation and guidance from Eurostat.

Medium‑term budgetary objective (MTO): According to the reformed Stability and Growth Pact, stability 
programmes and convergence programmes present a medium‑term objective for the budgetary position. The MTO 
is country‑specific to take into account the diversity of economic and budgetary positions and developments and 
of fiscal risks to the sustainability of public finances, and is defined in structural terms. See also Structural (budget) 
balance.

Methodological visit: An exceptional monitoring and verification visit carried out by Eurostat to a Member State 
where significant risks or problems with regard to data quality have been clearly identified.

One‑off and temporary measures: Government transactions having a transitory budgetary effect that does not 
lead to a sustained change in the budgetary position. See also Structural (budget) balance.

Output gap: The difference between actual output and estimated potential output at given point in time. See also 
Cyclical component of budget balance.

Potential GDP: The level of real GDP in a given year that is consistent with a stable rate of inflation. If actual output 
rises above its potential level, constraints on capacity will start to bite and inflationary pressure will build; if output 
falls below the potential level, resources are lying idle and inflationary pressure will abate. See also Output gap.

Glossary 

10

Primary (budget) balance: The budget balance net of interest payments on general government debt.

Primary/upstream data: Data collected by a national statistical institute (e.g. from administrative records, surveys, 
census) for the purpose of compiling aggregates (such as EDP transactions). The public accounts of government 
departments, agencies, etc. are an example of primary data.

Public accounts: Government financial statements (from departments, agencies and any public corporations 
classified as part of general government). They record state revenue and expenditure and are the main source for 
compiling EDP data. 

Public debt: See Government debt.

Snowball effect: The self‑reinforcing effect of public debt accumulation or decumulation arising from a positive or 
negative differential between the interest rate paid on public debt and the growth rate of the national economy.

Stability and Growth Pact (SGP): Approved in 1997 and reformed in 2005 and 2011, the SGP clarifies the provisions 
of the Maastricht Treaty regarding the surveillance of Member State budgetary policies and the monitoring 
of budget deficits during the third phase of economic and monetary union. The SGP consists of two Council 
regulations setting out legally binding provisions to be followed by the European institutions and the Member 
States, and two resolutions of the European Council in Amsterdam (June 1997). 

Stability programmes: Medium‑term budgetary strategies presented by Member States that have adopted the 
euro. They are updated annually in accordance with the provisions of the Stability and Growth Pact. See also 
Convergence programmes.

Stock‑flow adjustment: The stock‑flow adjustment (also known as the debt‑deficit adjustment) ensures 
consistency between net borrowing (flow) and the variation in the stock of gross debt. It includes the accumulation 
of financial assets, changes in the value of debt denominated in foreign currency, and remaining statistical 
adjustments.

Structural (budget) balance: The actual budget balance net of the cyclical component and one‑off and other 
temporary measures. The structural balance gives a measure of the underlying trend in the budget balance. 

Top‑down fiscal effort: A quantification of the fiscal impact of government policy, obtained by looking at the 
overall change in the structural balance. It may differ from the bottom‑up quantification of effort due to the 
incomplete coverage of the latter, second‑order economic effects or inconsistency in the ‘no policy change’ 
assumption.

Working balance: Public accounts revenue minus expenditure.

Executive summary

11

I
The Treaty on the Functioning of the European Union establishes it as a basic rule of budgetary policy that Mem‑
ber States must avoid excessive government deficits. Accordingly, where the reference values for deficit and debt 
are exceeded a corrective mechanism may be initiated against the Member State concerned. This mechanism, the 
excessive deficit procedure, is a key element of the EU’s economic governance framework.

II
The Commission’s role in implementing the excessive deficit procedure is to check the quality of the data notified 
by each Member State, to assess whether the reference thresholds have been breached, or risk being breached, and 
on this basis to address opinions and recommendations to the Council to act accordingly. The Council then decides, 
according to the Treaty provisions, whether or not to adopt the Commission recommendations.

III
Member States placed under an excessive deficit procedure are given recommendations to remedy the situation, 
including a deadline by which to correct the situation, a path for correction and an annual fiscal effort to be deliv‑
ered. The Commission monitors the Member State’s implementation of corrective measures and reports its findings 
to the Council. The Council, on the basis of Commission proposals, takes further action as appropriate (lifting the 
procedure, extending the deadline, setting new targets or imposing sanctions).

IV
The Court examined the Commission’s implementation of the excessive deficit procedure between 2008 and 2015, 
focusing on six Member States. We considered the Commission’s quality assessment of Member States’ EDP data, 
the quality of its own forecast data and models and whether its assessments were in tune with the Council’s deci‑
sions to launch a procedure. Lastly, we examined how the Commission monitored the corrective action taken by 
Member States under an excessive deficit procedure.

V
We found that, although detailed procedures and guidelines exist for most areas of the Commission’s data collec‑
tion and analysis and its assessment of compliance with the rules on budgetary discipline, there are problems with 
its implementation of these tasks. This is because the Commission did not make full use of its powers to enforce the 
provision of comprehensive data and compliance with recommendations for corrective action, and because of the 
failure at times to give adequate feedback on Member States’ reports, the insufficient resources devoted to analys‑
ing and reporting on key data, and poor record‑keeping.

Executive summary 

12

VI
A related issue is that of transparency, where, despite improvements in recent years, too much information is still 
generally unavailable regarding the Commission’s data assumptions and parameters and its understanding of key 
concepts. In addition, even where the Commission has set clear internal rules it may decide to depart from the 
established procedure, which raises questions about the overall reliability of its assessments.

VII
In the area of monitoring structural reforms, an aspect of corrective action which the Commission recently high‑
lighted as crucial to overcoming an excessive deficit situation, there are signs that the Commission does not go far 
enough, as it essentially focuses on legislative aspects rather than the actual implementation of reforms. The exces‑
sive deficit procedure continues to over‑emphasise the criterion of deficit rather than debt.

VIII
In conclusion, we find very positive signs in the Commission’s efforts over the years to adapt and rationalise the 
excessive deficit procedure in response to developments in the EU. The legislative basis is sound and is generally 
supported by clear internal rules and guidelines. What has been lacking is consistency and transparency in the 
application of those rules; the Commission does not adequately record its underlying assumptions or share its sur‑
veillance findings for the greater benefit of all Member States. In recent statements, the Commission has acknowl‑
edged these shortcomings and indicated that it is prepared to make the necessary improvements.

IX
Our overall conclusions are explained in detail at the end of the report, and a number of specific recommendations 
are addressed to the Commission. Those recommendations are summarised below.

Our recommendations

(a)  In the area of data collection and analysis, which is Eurostat’s field of competence, the Commission should:

(i)  enhance its quality assessment procedures and better document its work;

(ii)  assess Member States’ own control systems;

(iii)  take steps to improve the effectiveness of its on‑the‑spot verifications;

(iv)  make full use of the powers available to ensure that Member States implement follow‑up action points;

(v)  maximise transparency by making public all advice and guidance to Member States;

(vi)  better document its internal procedures and criteria for setting reservations or making amendments to 

data.

Executive summary 

13

(b)  In assessing the situation in Member States leading to recommendations in connection with the EDP (this is the 

role of DG Economic and Financial Affairs), the Commission should:

(i) 

improve transparency by applying clear definitions, disclosing all calculation and assessment data and 
promoting the involvement of national fiscal councils to confirm the national data used in the Commission’s 
analyses;

(ii)  focus closely on the reduction of government debt, especially in heavily‑indebted Member States;

(iii)  strengthen its monitoring of the implementation of agreed structural reforms, including making full use of 

its powers to ensure Member States meet their commitments;

(iv)  more strictly enforce the rules on Member States’ reporting;

(v)  exploit the option, where appropriate, of recommending that the Council take tougher action and impose 

sanctions.

Introduction

14

1  An excessive deficit situation 
means that either the general 
government deficit or the 
general government debt or 
both exceed the respective 
reference values.

Background on economic and fiscal governance policy 
in the EU

01 
The Treaty on European Union, also known as the Maastricht Treaty, which en‑
tered into force on 1 November 1993, established the principles of economic and 
monetary union (EMU) and led ultimately to the euro as a common currency in 19 
out of 28 Member States. The proper functioning of EMU required the introduc‑
tion of a mechanism to safeguard the soundness of public finances and to reduce 
the risk of spillover from Member States pursuing unsuitable fiscal policies. This 
mechanism comprises two arms, one preventive and the other corrective. The 
preventive arm aims to ensure sound budgetary policies in the medium‑term and 
avoid excessive deficit situations1. The corrective arm addresses excessive deficit 
situations and is known as the excessive deficit procedure (EDP). Member States 
that breach the ceiling on budgetary deficit or debt (respectively 3 % and 60 % of 
GDP) may be subject to an EDP.

02 
The primary legal basis for the EDP is Article 126 of the Treaty on the Function‑
ing of the European Union (TFEU) and Protocol No 12 annexed to that Treaty. 
These specify the different steps in the procedure and the reference thresholds. 
They are complemented by secondary legislation in the form of the Stability and 
Growth Pact (SGP), which was introduced in 1997 and provides operational clarifi‑
cations on the circumstances in which an EDP should be launched.

03 
The EDP has undergone several reforms (in 2005, 2011 and 2013) aimed at 
improving its implementation by strengthening reporting requirements and 
sanctions and introducing the flexibility to adapt the procedure to a changing 
economic environment. Figure 1 provides an overview of the evolution of eco‑
nomic and fiscal governance policy in the EU, with measures related to the EDP 
highlighted in bold. Annex I contains a chronological list of EU legal instruments 
that are most relevant to the EDP.

Introduction 

15

1 Evolution of economic and fiscal governance policy in the EU
e
r
u
g
i
F

Treaty of Maastricht
Establishes economic and monetary union
Member States must coordinate their economic policies and submit to multilateral surveillance
in this regard (Article 121 TFEU)
Member States undertake to observe ﬁnancial and budgetary discipline and may be placed
under the EDP if in an excessive deﬁcit situation (Article 126 TFEU)

1992

1997

2005

2011

2012

2013

Stability and Growth Pact (SGP)
Member States must submit stability or convergence programmes (SCPs) disclosing their
medium-term budgetary plans
Member States must pursue a nominal medium-term objective (MTO) for their budgetary position
Deﬁnition of temporary and exceptional excess deﬁcit compared with a reference value
Rules to speed up the EDP
Sanctions (for euro-area Member States only) in the form of a non-interest bearing deposit

Reform of SGP
MTO is redefined in structural terms (cyclically adjusted balance net of one-off and temporary 
measures) and made country-specific
Deviations from the MTO or adjustment path are allowed in the event of major structural reforms
Structural eﬀort
New deﬁnition of ‘severe economic downturn’
Non-exhaustive list of ‘other relevant factors’, including pension reforms
Extension of deadlines for the correction of excessive deﬁcits

‘Six-pack’
European semester for economic policy coordination 
More detailed requirements on the content of SCPs; new expenditure benchmark: expenditure to
grow less than potential GDP
Requirements for budgetary frameworks in the Member States
Macroeconomic imbalance procedure and sanctions
Operationalisation of the debt criterion (average annual reduction of 1/20th of the excess over
60 % for three years); three-year transitional period from the end of the EDP for the 
23 Member States under an EDP as of November 2011
Structural eﬀort to be adjusted annually
Reports on action taken
Sanctions in the form of ﬁnes, to be approved by the Council

Treaty on Stability, Coordination and Governance (Fiscal Compact)
‘Golden rule’ of a structural deficit rule not exceeding the MTO, with a national automatic correction
mechanism in the event of deviation. To be enshrined in national constitutions, national fiscal councils
to monitor compliance.

‘Two-pack’ (euro-area Member States only)
Assessment of draft budgetary plans by national fiscal councils 
Enhanced surveillance of Member States experiencing or likely to experience serious financial stability 
difficulties; macroeeconomic adjustment programmes; post-programme surveillance
Road map for structural reforms: economic partnership programmes
Closer monitoring of Member States under an EDP: regular reporting (in-year budgetary 
execution report)
Early-warning mechanism against risk of non-correction of the excessive deﬁcit by the EDP 
deadline: autonomous Commission recommendations
Swifter sanctions

Note: Measures related to the EDP are highlighted in bold.

Source: ECA.

 
Introduction 

16

04 
Most recently, on 21 October 2015 the Commission adopted a communication2 on 
steps towards completing economic and monetary union to implement the ‘Five 
Presidents‘ Report’3. The communication and its accompanying proposals are 
intended to take forward the process of deepening the EMU and boost competi‑
tiveness. The package of measures includes improved tools for economic govern‑
ance, including the creation of national competitiveness boards and an advisory 
European Fiscal Board. The Commission has indicated that the steps proposed 
are both ambitious and pragmatic and will need concerted action from all actors 
involved.

2  COM(2015) 600 final of 

21 October 2015 ‘On steps 
towards completing Economic 
and Monetary Union’.

3 

‘Completing Europe’s 
Economic and Monetary 
Union’, Report by Jean‑Claude 
Juncker, in close cooperation 
with Donald Tusk, Jeroen 
Dijsselbloem, Mario Draghi 
and Martin Schulz, 
22 June 2015.

The excessive deficit procedure: maintaining the 
soundness of public finances

05 
The main parties to an EDP are the Member State, the Commission (DG Economic 
and Financial Affairs and Eurostat) and the Council.

(i)  The Member State is required (a) to report statistical data to Eurostat twice 
a year (before 1 April and 1 October), (b) to correct the excessive deficit 
situation by the deadline given by the Council, (c) to deliver the fiscal effort 
required in the respective EDP recommendation, and (d) to report on action 
taken.

(ii)  Eurostat is responsible for assessing the quality both of actual data reported 

by Member States and of the underlying government sector accounts.

(iii)  DG Economic and Financial Affairs is responsible for assessing the Member 
State’s compliance with the debt and deficit thresholds and monitoring its 
action to correct the excessive deficit situation.

(iv)  The Council, on the Commission’s proposal, decides to launch, to step up or 

to abrogate the EDP.

06 
Figure 2 shows how these parties cooperate and interact at the various stages of 
the EDP.

Introduction 

17

2 The EDP at a glance
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19

4  Previously ESA 95, now ESA 

2010.

5 

6 

7 

8 

Except in Belgium, where this 
role is taken by the central 
bank.

‘Actual data’ is the term used 
for historical data. In the EDP 
notification for a given year N, 
actual data are to be 
submitted for the years N‑1, 
N‑2, N‑3 and N‑4.

The planned data for a given 
year N correspond to the 
forecast for that year.

Flows are recorded on an 
accrual basis; that is, when 
economic value is created, 
transformed or extinguished, 
or when claims and 
obligations arise, are 
transformed or are cancelled 
(see ESA 95, paragraph 1.57).

Introduction 

The EDP process: ensuring data quality, assessing the 
situation, initiating an EDP

07 
This section covers the successive stages of the process leading to a decision.

Ensuring the quality of the data used to calculate the level of 
deficit and debt

08 
Member States are required to compile EDP data in accordance with the Euro‑
pean System of Accounts (ESA4) and the Manual on Government Deficit and Debt 
(MGDD), as well as Eurostat’s decisions and guidance notes. These data, reported 
in standardised ‘notification’ tables and related questionnaires, are sent to Euro‑
stat together with other government finance statistics (GFS) data and an inven‑
tory of sources and methods.

09 
Each Member State decides how the EDP data are to be compiled. The national 
statistical institute (NSI) takes the lead role5 and is responsible for compiling 
actual data6, while planned data7 are compiled by the ministry of finance. How‑
ever, the ministry of finance and other government departments and the central 
bank usually also provide primary data and, in some cases, are jointly responsible 
for the compilation process. The NSI supplements its estimates from other data 
sources (financial statements of public units, business surveys, etc.).

10 
Eurostat examines and assesses the quality both of the actual data reported 
by Member States and of the underlying general government sector accounts. 
Quality data presupposes compliance with the accounting rules (ESA and MGDD), 
completeness, reliability, timeliness and consistency. The assessment focuses on 
areas specified in the EDP inventories, such as the delimitation of the general 
government sector population (including exhaustiveness checks that all public 
units are covered), the classification of specific government transactions, liabili‑
ties and the accrual recording of transactions8.

Introduction 

11 
Eurostat also makes ‘dialogue visits’ to Member States to verify and assess the 
EDP data and reporting processes, including whether they comply with the ac‑
counting rules. Where significant risks and problems in the quality of data are 
identified, Eurostat may carry out ‘methodological visits’ (so far only one such 
visit has been made, to Greece)9.

12 
Following its quality assessment, Eurostat forwards the data to DG Economic and 
Financial Affairs for economic analysis. However, where there is evidence that 
the data reported by a Member State do not comply with the accounting rules, 
Eurostat may express a reservation as to the quality of the actual data10 or make 
amendments11. It may also initiate an investigation into manipulation of statistics. 
In such cases fines of up to 0.2 % of GDP can be imposed12.

Assessing the situation

13 
DG Economic and Financial Affairs analyses the actual Member State data provid‑
ed by Eurostat, and its own European economic forecasts produced in the con‑
text of the European Semester13, to monitor the evolution of deficit and debt and 
to assess Member States’ plans for convergence towards the reference thresh‑
olds. The data are analysed according to a framework of rules and guidance. DG 
Economic and Financial Affairs maintains regular contact with the Member States 
throughout this process to obtain information on local developments.

14 
The objective of the analysis is to:

(i)  assess whether a Member State has breached the deficit and/or debt criteria, 
taking account of any particular circumstances (severe economic downturn, 
recent trends and forecasts for indicators, adjustment for potential output, 
etc.);

(ii)  if a breach of either the deficit or the debt criteria is identified in a Member 

State, prepare a report under Article 126(3), which considers in detail a series 
of aggravating and mitigating factors, and assesses the case for launching an 
EDP; the report is sent to the Economic and Financial Committee (EFC)14 for 
an opinion; and

(iii)  if an excessive deficit situation is recognised, inform the Member State and 

the Council and recommend that the latter launch an EDP with deadlines for 
the Member State to take corrective action.

20

9  Methodological visits are 
designed to monitor the 
processes and verify the 
accounts underlying the 
reported data and to draw 
conclusions as to the quality of 
the latter. Eurostat carries out 
methodological visits in 
exceptional cases, where 
significant risks or problems 
with respect to the quality of 
the data are clearly identified.

10  By expressing a reservation, 

Eurostat indicates that it does 
not consider the data 
concerned to be of sufficient 
quality; it announces this 
publicly through the press 
release associated with the 
notification.

11  Eurostat may unilaterally 

amend a Member State’s data 
where it is able to estimate the 
impact of the reservation with 
sufficient accuracy.

12  See Article 8 of Regulation (EU) 
No 1173/2011 of the European 
Parliament and of the Council 
of 16 November 2011 on the 
effective enforcement of 
budgetary surveillance in the 
euro area (OJ L 306, 23.11.2011, 
p. 1), and the Commission 
Delegated Decision 2012/678/
EU on investigations and fines 
related to the manipulation of 
statistics (OJ L 306, 6.11.2012,  
21).

13  DG Economic and Financial 
Affairs produces economic 
forecasts on behalf of the 
Commission. They serve as 
a basis for various economic 
surveillance procedures, for 
example in the context of the 
European Semester, and are 
published three times a year 
(spring, autumn and winter).

14  The Economic and Financial 

Committee is a working group 
set up to promote policy 
coordination among the 
Member States, notably by 
supporting the work of the 
ECOFIN Council. It is 
composed of senior officials 
from national administrations 
and central banks, the ECB and 
the Commission. Further 
information on its 
organisation and objectives 
can be found in Article 134 of 
the TFEU and at http://europa.
eu/efc/index_en.htm.

21

Introduction 

Initiating an EDP

15 
It is the Council which decides whether to place a Member State under an EDP. 
The Member State is then informed accordingly and the decision is published. 
The Council sets a deadline for addressing the situation (in principle one year 
from the detection of the excessive deficit, although several multiannual EDPs 
were launched in 2009 due to the financial and economic crisis). Table 1 summa‑
rises all the Council’s EDP decisions to 17 November 2015.

16 
In the case of multiannual EDPs, the Council also sets annual fiscal targets. 
Through its recommendations, moreover, it usually calls for the development 
and implementation of national structural measures, such as public expenditure 
reform.

17 
At this point, euro‑area Member States that have already been sanctioned for 
non‑compliance with the recommendations based on Article 121(4) TFEU on the 
preventive arm of the Pact, or whose breach of the deficit and debt ratios is espe‑
cially serious, may also face a fine in the form of a redeemable non‑interest‑bear‑
ing deposit of 0.2 % of GDP.

Introduction 

22

1
e
l
b
a
T

Excessive deficit procedures launched so far

Closed

Ongoing

Council decision  
initiating an EDP

Council decision  
abrogating the EDP

Council decision  
on initiating an EDP

Current deadline for 
correction

Belgium

Bulgaria

Czech Republic

Denmark

Germany

Ireland

Greece

Spain

France

Croatia

Italy

Cyprus

Latvia

Hungary

Lithuania

Luxembourg

Malta

Netherlands

Austria

Poland

Portugal

Romania

Slovenia

Slovakia

Finland

United Kingdom

2.12.2009
2015

13.7.2010

5.7.2004
2.12.2009

13.7.2010

21.1.2003
2.12.2009

-

5.7.2004

-

3.6.2003

-

28.7.2005
2.12.2009

5.7.2004

7.7.2009

5.7.2004

7.7.2009

2010

5.7.2004
2009
7.7.2009
21.6.2013

2.6.2004
2.12.2009

2.12.2009

5.7.2004
7.7.2009

5.11.2002
20.9.2005

7.7.2009

-

5.7.2004
2.12.2009

13.7.2010

2004
24.1.2006

20.6.2014
20151

22.6.2012

3.6.2008
20.6.2014

20.6.2014

5.6.2007
22.6.2012

-

5.6.2007

-

30.1.2007

-

3.6.2008
21.6.2013

11.7.2006

21.6.2013

21.6.2013

21.6.2013

20101

5.6.2007
20091
4.12.2012
19.6.2015

7.6.2005
20.6.2014

20.6.2014

8.7.2008
19.6.2015

11.5.2004
3.6.2008

21.6.2013

-

3.6.2008
20.6.2014

12.7.2011

20041
9.10.2007

-

-

-

-

-

27.4.2009

27.4.2009

27.4.2009

27.4.2009

21.1.2014

-

13.7.2010

-

-

-

-

-

-

-

-

2.12.2009

-

2.12.2009

-

-

-

-

-

-

-

2015

2016

2016

2017

2016

-

2016

-

-

-

-

-

-

-

-

2015

-

2015

-

-

8.7.2008

Financial year 2016/17

1 The Commission issued an Article 126(3) report which did not give rise to a Council decision.
Source: DG Economic and Financial Affairs website (as at 17.11.2015).

 
23

15  Member States must report 

within the deadlines set by the 
Council under Article 3(4) of 
Council Regulation (EU) No 
1177/2011 of 8 November 2011 
amending Regulation (EC) No 
1467/97 on speeding up and 
clarifying the implementation 
of the excessive deficit 
procedure (OJ L 306, 
23.11.2011, p. 33) for 
compliance with the 
recommendations (from three 
to six months depending on 
the seriousness of the 
situation).

16  Under the SGP, stability and 

convergence programmes are 
submitted once a year, the 
former by euro‑area Member 
States and the latter by 
Member States outside the 
euro. They set out the Member 
State’s budgetary plan for the 
next three or four years.

17  A document which presents 
the country’s policies and 
measures to sustain growth 
and jobs and reach the Europe 
2020 targets. It is presented in 
parallel with each annual 
stability/convergence 
programme.

Introduction 

Corrective action: reporting by Member States, monitoring 
and surveillance by the Commission

18 
This section describes how corrective measures are reported to and monitored 
by the Commission.

Reporting by Member States

19 
Member States are responsible for developing and implementing correc‑
tive measures to restore fiscal stability in accordance with the Council’s 
recommendations.

20 
They are required to keep DG Economic and Financial Affairs informed about the 
measures planned and/or adopted and developments in their fiscal and econom‑
ic situation15. They must submit a report on action taken and disclose EDP‑rel‑
evant information in their stability or convergence programmes16 and national 
reform programmes17 prepared in the context of the European Semester. Before 
the ‘Six‑pack’ (2011), Member States were not legally obliged to submit a report 
on action taken. The ‘Two‑pack’ then introduced additional reporting require‑
ments for euro‑area Member States (see Figure 1 and Figure 7) to enhance the 
Commission’s monitoring and surveillance.

Monitoring and surveillance by the Commission

21 
DG Economic and Financial Affairs is responsible for examining whether a Mem‑
ber State has complied with the Council’s recommendations, for monitoring the 
implementation of EDP corrective measures and for proposing further action.

Introduction 

24

22 
DG Economic and Financial Affairs carries out assessments of the action taken by 
each Member State under an EDP:

(i)  as early as three or six months from the launch of the procedure on the basis 
of the Member State’s report on the action taken in response to the Council 
recommendations;

(ii)  regular monitoring coinciding with each forecast, in the light also of informa‑

tion disclosed by the Member State in its stability/convergence programme 
and, for euro‑area countries, its draft budgetary plan; and

(iii)  at the expiry of the deadline, unless the procedure is abrogated.

23 
More specifically, DG Economic and Financial Affairs assesses whether the Mem‑
ber State has announced or taken measures that seem adequate to ensure suf‑
ficient progress towards correction of the excessive deficit within the time limits 
set by the Council.

18  Article 9 of Council Regulation 
(EC) No 1467/97 of 7 July 1997 
on speeding up and clarifying 
the implementation of the 
excessive deficit procedure (OJ 
L 209, 2.8.1997, p. 6). While 
a procedure is in abeyance, 
the Council and Commission 
regularly monitor the Member 
State’s compliance with the 
recommendations. 
Depending on the conclusions 
of monitoring, the procedure 
can be either abrogated or 
reactivated.

19  Member States that have 

delivered a fiscal effort in line 
with the recommendations 
are assessed as having taken 
effective action.

20  Article 3(5) of Regulation (EC) 

1467/97.

21  As set out in Article 126 and 

Article 139 TFEU and Article 10 
of Regulation (EC) No 1467/97, 
as amended.

24 
Depending on the assessment made, DG Economic and Financial Affairs will pro‑
pose different actions to the Council:

(i)  where the Commission considers that the Member State has complied with 

the recommendations and that the EDP requirements are likely to be fulfilled, 
the procedure will be ‘held in abeyance18;

(ii)  where there has been effective action19 but ‘unexpected adverse events with 
major unfavourable consequences for government finances have occurred’20, 
a revised recommendation may be proposed. The revised recommendation 
may extend the deadline for correction of the deficit, usually by one year, or 
may set out new nominal and structural targets linked to a new underlying 
macroeconomic scenario, without extending the deadline;

(iii)  where there has been no effective action and the Member State is in the euro 
area, the EDP may be ‘stepped up’. The Council will issue a notice inviting the 
Member State to take specific measures and to submit reports by set dead‑
lines, and if the Member State fails to comply with this notice the Council can 
impose sanctions21. Where applicable, the Council may decide to suspend 
payments under the Cohesion Fund and, with effect from the 2014‑2020 pro‑
gramming period, the European Structural Investment Funds.

25

Introduction 

Outcome of EDP

25 
The expected outcome of the EDP decision and corrective action is that the 
Member State will restore budgetary discipline, and hence the sustainability of its 
public finances, by correcting the excessive deficit within a reasonable deadline. 
The EDP decision is also intended to foster the implementation of structural 
reforms in the Member State, which is conducive to public finance stability in the 
medium/long term.

Audit scope, objectives and 
approach

26

22 

In Malta two separate 
procedures were launched 
during the period.

23  The sample was taken from 
a shortlist of Member States 
which excluded countries that 
(i) are currently addressed by 
other Court audit tasks in the 
financial and economic 
governance area (Hungary, 
Ireland, Latvia, Portugal, 
Romania and Greece), (ii) have 
never been placed under an 
EDP (Estonia, Sweden and 
Luxembourg), (iii) benefit from 
special or unique conditions in 
relation to the EDP (United 
Kingdom), or (iv) only recently 
joined the European Union 
(Croatia). 
In selecting among the 
remaining Member States, the 
aim was to obtain 
a representative sample of 
large and small countries, both 
within and outside the euro 
area, and, as far as possible, of 
procedures launched after 
2008 that have since been, or 
could have been, closed.

Audit scope and objectives

26 
The Court assessed whether the Commission is managing the implementation of 
the EDP appropriately. For this purpose we looked at the procedure as applied 
to Cyprus, the Czech Republic, France, Germany, Italy and Malta22 between April 
2009 and May 201523. In relation to the quality of data, we looked at the period 
2008 ‑ 2014 and, where necessary, back to 2005.

27 
However, although we analysed some of the details underlying the definition of 
the EDP threshold values, we did not assess the appropriateness of these values, 
nor did we assess the quality of the measures taken by Member States to imple‑
ment the procedure.

28 
More specifically, we examined:

(i) 

the Commission’s assessment of the quality of Member States’ statistical data 
(Eurostat) and its interpretation of those data (DG Economic and Financial Af‑
fairs) leading ultimately to recommendations that the Council initiate or take 
further action in relation to an EDP;

(ii)  the Commission’s monitoring and surveillance tasks; and

(iii)  the outcome of the procedure.

29 
The main audit criteria were derived from:

(i)  regulatory requirements (e.g. Council regulations, decisions, directives and 

conclusions); and

(ii)  the Commission’s internal rules and procedures (e.g. instructions and 

guidelines).

Audit scope, objectives and approach 

27

Approach

30 
We reviewed the documentation relating to the separate EDPs. We also inter‑
viewed Eurostat and DG Economic and Financial Affairs staff and representatives 
of the institutions involved in implementing the procedure in each of the Mem‑
ber States selected for the audit. Table 2 lists the entities visited in each Member 
State.

31 
Finally, we discussed EDP issues with representatives of several organisations 
whose views were relevant to the audit (including representatives of the IMF and 
of the United Kingdom Office for Budget Responsibility), and for more technically 
complex aspects we made use of specialised internal and external expertise.

2 Visits to Member State authorities and other entities
e
l
b
a
T

Supreme 
Audit 
Institution

National 
Statistical 
Institute

Ministry of 
Finance

Fiscal Council

Central Bank

Czech Republic

Germany

France

Italy

Cyprus

Malta

Source: ECA.

√

√

√

√

√

√

√

√

√

√

√

√

√

√

√

√

√

√

√

√

√

√

Others

Economic Adviser to the Presidency of the Council of 
Ministers

DG Economic and Financial Affairs resident 
representative

 
Observations

28

EDP process: improvements needed to strengthen the 
basis of the EDP and enhance the objectivity of 
assessments

An appropriate framework for decisions, but greater clarity 
needed

32 
This section examines the Commission’s procedure for analysing the data and 
assessing compliance prior to recommending a decision.

The Commission examines extensively the quality of the statistical 
data…

33 
Eurostat is responsible for assessing the quality of the statistical data used in the 
EDP process. Its role in this task has developed significantly since 1993, specifical‑
ly through the introduction of new tools and new discretionary powers (Figure 3 
shows how the main legal framework has evolved since the Maastricht Treaty).

Observations 

29

EDP statistics

3 Evolution of the main legal framework governing Eurostat’s quality assessment of 
e
r
u
g
i
F

Deﬁnition of the data (planned deﬁcit and actual deﬁcit and debt) to be provided by 
Member States, as well as periodicity and deadlines. 
(Regulation (EC) No 3605/93) 

1993

1997

2005

2009

2011

2014

Source: ECA.

Deﬁnition of Eurostat’s role and responsabilities (to analyse statistical data, provide 
advice and support to Member States, promote cooperation and develop statistical
methods).
(Commission Decision of 21 April 1997)

Member States are required to send new information (planned debt and additional 
information, including an inventory) within new EDP reporting deadlines, to make 
EDP data public, to report major revisions and to consult Eurostat on diﬃcult issues. 
Eurostat is required  to regularly assess the quality of data and to report within
three weeks, to carry out dialogue visits and, where necessary, methodological 
visits. Eurostat is given the possibility of expressing reservations as to the quality
of actual data or making amendments.
Regulation (EC) No 2103/2005 amending Regulation (EC) No 3605/93)

Eurostat is granted access to NSIs and all the data sources in a Member State, and 
empowered to decide on matters of interpretation. An indicative list of cases that 
may trigger a methodological visit.
(Regulation (EC) No 479/2009, as amended; Regulation (EC) No 223/2009)

Possibility of imposing ﬁnes where statistics have been manipulated.
(Council Regulation (EU) No 1173/2011; Commission Delegated Decision of 29 June 2012)

Implementation of ESA 2010 in the compilation of EDP data with eﬀect from 
September 2014.
(Commission Regulation of 7 March 2014 amending Regulation (EC) No 479/2009)

 
Observations 

30

34 
Eurostat has itself made significant further efforts to develop its approach and 
improve the quality assessment process. Between 2008 and 2014 it introduced 
many new measures. Most importantly, in 2011, having reviewed its EDP data 
quality assessment structures and processes, Eurostat made resourcing and pro‑
cedural changes. For example, upstream visits were initiated to assess the quality 
of the systems generating primary data. See Figure 4 for further details.

4 Assessment of data quality by Eurostat (main improvements since 2011)
e
r
u
g
i
F

Procedures

Resources

Control

0  dedicated Directorate for 

Government ﬁnance statistics
0  assignment of around 50 staﬀ 
to EDP work (three times as 
  many as a few years before)
0  establishment of a team of desk 
oﬃcers, each responsible for
a maximum of two Member 
States

0  establishment of a team of 
  methodologists who also take 

part in missions

0 

0 

0 

introduction of standardised 
procedures and agendas in EDP 
dialogue visits 
internal establishment of 
annual country risk assessments
introduction of standardised 
procedures for the provision of 
guidance (bilateral and on 
complex issues)

0 

0 

implementation of extensive 
analysis of EDP notiﬁcations and 
the related questionnaires, 
allowing a more detailed 
analysis of deﬁcit and debt
introduction of ‘upstream’ 
dialogue visits 

0  more powers granted to access 
all the EDP data underlying 
the compilation process

0  power to recommend ﬁnancial 
sanctions for deliberate 
  misreporting or serious 

negligence in the reporting 
of EDP statistics

Source: ECA, based on Eurostat information.

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Observations 

31

… on the basis of comprehensive and widely disseminated 
internal rules and guidance…

35 
Commission recommendations to launch an EDP are predicated on the results of 
specific analyses by DG Economic and Financial Affairs. These analyses are based 
in turn on a set of internal rules, instructions and guidelines that explain how 
they are to be performed and describe the most relevant underlying concepts.

24  DG Economic and Financial 

Affairs Occasional Papers 151, 
May 2013.

25  Specifications on the 

implementation of the 
Stability and Growth Pact and 
Guidelines on the format and 
content of Stability and 
Convergence Programmes, 
3 September 2012.

36 
Most of these internal rules, instructions and guidelines can be found in a ‘Vade‑
mecum on the Stability and Growth Pact’ (available to the public24) and ‘Specifi‑
cations on the implementation of the Stability and Growth Pact’ (also known as 
the ‘Code of Conduct’25). They address all the most relevant issues.

37 
Moreover, given the underlying importance of the rules, instructions and guide‑
lines to the Commission’s proposals on the launch of an EDP, DG Economic and 
Financial Affairs regularly prepares analytical and operational notes for the EFC in 
order to explain to Member States its approach to interpreting and implementing 
the SGP.

… applying a widely‑used methodology to produce forecasts…

38 
The Commission’s regular European economic forecasts (spring, autumn and 
winter) are another important part of its analyses leading to a decision whether 
or not to propose launching an EDP. The generation of forecasts combines ele‑
ments at country level – prepared by DG Economic and Financial Affairs’s country 
desks – with centralised elements produced by the horizontal unit (see Box 1). 
Overall, about 150 staff from different units within DG Economic and Financial 
Affairs are involved in the process.

Observations 

32

1
x
o
B

Generating European economic forecasts

Two months before the expected publication date, DG Economic and Financial Affairs prepares a position pa‑
per setting out general assumptions. Forecasting is then based on an iterative process with cross‑verification 
to ensure consistency between the country‑level and central forecasts.

The country desks each prepare country‑specific macroeconomic and fiscal forecasts. To do this they use 
a spreadsheet tool based on a centrally‑managed template, as well as additional tools that reflect coun‑
try‑specific characteristics such as data availability and economic structure.

The horizontal unit adds follow‑up calculations based on the projections by the country desks (e.g. the output 
gap and cyclically‑adjusted fiscal figures) and performs quality checks, which include:

 ο ensuring that a common set of external assumptions is used;

 ο checking numerical and economic consistency between country desk forecasts;

 ο checking the consistency of the country desks’ trade flow projections.

39 
The Commission’s forecasting procedure is complex. However, it is structured in 
a similar way to that of other international organisations (e.g. IMF, OECD, ECB), as 
a mix of top‑down and bottom‑up elements. This set‑up allows country fore‑
casts to be tailored to the country‑specific characteristics without losing central 
oversight. Furthermore, in terms of overall forecast accuracy, the Commission’s 
economic forecasts do not deviate significantly from those produced by peer 
organisations26.

40 
Compared with those of its peers, the Commission’s country forecasts are more 
heavily reliant on expert judgement and less on econometric approaches. This 
poses difficulties when it comes to evaluating and assessing their validity.

26  A number of studies have 
been carried out in this 
respect. Among the most 
recent are those referred to on 
p. 27 of OECD Economics 
Department Working Paper 
No 1107 (2014), which is 
available at http://www.
keepeek.com/
Digital‑Asset‑Management/
oecd/economics/oecd‑forecas
ts‑during‑and‑after‑the‑financ
ial‑crisis_5jz73l1qw1s1‑en, and 
in the Commission’s Economic 
Paper 476 of December 2012, 
at http://ec.europa.eu/
economy_finance/
publications/economic_
paper/2012/ecp476_en.htm 
(this is a comparative analysis 
of the accuracy of European 
Commission, IMF and OECD 
economic forecasts).

 
Observations 

33

… that still lack transparency

41 
Some Member State authorities interviewed believe that the forecasting process 
lacks transparency, in particular with regard to the detailed country‑specific 
assumptions made for fiscal indicators. If differences arise between the Commis‑
sion’s projections and those made nationally, the Member States find it impos‑
sible to evaluate them because the Commission does not sufficiently disclose the 
details of its assumptions in its talks with national authorities.

27  Article 4(2) of Council Directive 

2011/85/EU of 
8 November 2011 on 
requirements for budgetary 
frameworks of the Member 
States (OJ L 306, 23.11.2011,  
p. 41).

28  See the Commission’s reply to 
recommendation 2 in Special 
Report No 18/2015 ‘Financial 
assistance provided to 
countries in difficulties’  
(http://eca.europa.eu).

42 
This is consistent with our experience when reviewing the forecasts. Discrepan‑
cies between the Commission’s forecasts and those produced by the Member 
States can be explained by different underlying assumptions. However, iden‑
tifying the assumptions that are responsible for such discrepancies is not an 
easy task given the multiplicity of spreadsheets and expert opinion. In addition, 
there is no standard summary (e.g. in the form of a reconciliation table) clearly 
outlining the differences between the Commission’s and Member States’ esti‑
mates for the fiscal indicators that are used as the basis for the Commission’s 
recommendations.

43 
The above should be seen in the light of the rules, which state that ‘the Commis‑
sion shall make public the methodologies, assumptions and relevant parameters 
that underpin its macroeconomic and budgetary forecasts’27. Nevertheless, the 
Member State authorities also noted that the Commission’s disclosure of informa‑
tion has significantly improved over the years.

44 
Changes in economic knowledge and the structure of the economy call for 
continuous improvements to the forecasting process. In recent years, the Com‑
mission has taken a number of steps to enhance its forecasting. For instance, the 
main forecasting template has been overhauled, the level of detail for some eco‑
nomic sectors has been increased, and an elaborate new tool for detecting ad‑
ditional data inconsistencies has been introduced. Furthermore, the Commission 
is developing a pilot forecast model, initially for the euro area as a whole, and 
country‑specific modules, with the eventual aim of using the model to deliver 
quality checks that complement its judgement‑based forecasts28.

Observations 

34

45 
Further improvement is necessary. The Commission publishes the relevant 
external forecast assumptions and other technical assumptions, but implicit 
country‑specific assumptions are not described and were very hard to infer 
from the spreadsheets. Furthermore, DG Economic and Financial Affairs consid‑
ers the spreadsheets to be internal documents – not to be shared outside the 
Commission.

Shortcomings in the process of examining statistical data still 
need to be addressed, …

46 
Eurostat’s examination of statistical data includes verifications carried out either 
in‑house (data quality assessments) or on‑the‑spot (dialogue visits). These are 
complemented by guidance provided either bilaterally (at the request of a Mem‑
ber State), or, as a Eurostat initiative, on particularly complex issues.

Data quality assessment

47 
Eurostat carries out an extensive analysis of the statistical data received from 
Member States and their answers to requests for clarification in the three weeks 
following each of the two annual EDP notifications (see paragraph 10). Outside 
this period, Eurostat also carries out in‑house verification of methodological and 
other data‑related issues, complemented by dialogue visits to Member States.

48 
There is still room to document the in‑house verification process more compre‑
hensively. At present it can be difficult to see how individual quality assessments 
were carried out and, therefore, to understand the reasons for the assessment. 
It can also be more difficult to demonstrate that assessments are carried out in 
a consistent way. Box 2 gives some examples of weak documentation.

Observations 

35

2
x
o
B

Some examples of weak documentation by Eurostat

In the six Member States visited, there were cases where the authorities were asked if they applied the neces‑
sary criteria but were not required to substantiate their replies. Examples included the recording of privatisa‑
tions and dividends.

One Member State sent data on interest and financial statements, but the assessment made by Eurostat was 
not well documented.

Without further substantiation, one Member State simply confirmed as briefly as possible that interest was 
calculated on an accrual basis.

There is no evidence of any systematic or detailed Eurostat analysis of the information in bridge tables29. Euro‑
stat has never provided feedback to Member States on the quality of bridge tables.

29  Bridge tables show the correspondence between the items in the public accounts and the ESA classifications.

49 
In addition, the data provided by the Member States are not always complete. 
This applies to both mandatory and voluntary data, as the latter are also of‑
ten used in Eurostat assessments. Annex II gives some examples of missing 
information.
50 
Most of the quality assessment process is governed by internal written proce‑
dures and guidance setting out how data should be analysed. However, it could 
be made more explicit how the existing rules and guidelines (ESA and MGDD) are 
to be applied in one key area: the classification (delimitation) of public institu‑
tional units within the general government sector (i.e. which entities/bodies are 
to be included in the calculation of government debt and deficit). This could 
improve the coverage and consistency of the assessment (see Annex III).

 
Observations 

51 
We examined the classification of a number of public institutional units in the six 
Member States in the sample. We found that in some cases the ESA 95 rules for 
the classification of units30 should have been analysed in greater depth. We also 
found that the six Member States applied different time spans for analysing and 
classifying public units (see Box 3 for some examples).

36

30  According to the accounting 

rules, to establish the 
population of the general 
government sector each 
institutional unit must be 
analysed in terms of its main 
function, nature and control 
arrangements. If the main 
function of a unit is to 
distribute wealth, it should be 
included in general 
government. Units engaged in 
financial intermediation 
should be classified in the 
financial corporations sector. 
Units not subject to general 
government control should be 
classified outside general 
government. In terms of their 
nature, units under general 
government control should be 
classified within the general 
government sector if they 
qualify as non‑market after 
the application of the 50 % 
criterion which states that 
a unit is ‘market’ if the ratio 
between sales and costs of 
production is above 50 % and 
‘non‑market’ if it is below 
50 %. Sales cover the sales of 
goods and services, excluding 
taxes on products but 
including all subsidies on 
products (all payments linked 
to the volume or value of 
output), but payments to 
cover an overall deficit are 
excluded.

3
x
o
B

Some examples of classification weaknesses in documents from the six Member 
States examined

 ο cases not fully compliant with ESA 95 but accepted by Eurostat, such as exhaustiveness, different ap‑

proaches ‑ in classifying units;

 ο the main weaknesses found in the classification of public institutional units;

 ο weaknesses in relation to the procedures and timing for analysing and (re)classifying units within/outside 

the general government sector.

For more details see Annex III.

 
37

Observations 

Dialogue visits

52 
Eurostat has used two types of visits to Member States to verify the data used in 
the EDP process. The first type is the standard dialogue visit (SDV), which is used 
to review data, examine methodological issues and assess the NSI’s compliance 
with the accounting rules. SDVs are made to each Member State at least once 
every two years. Secondly, from 2011 to 2013 Eurostat also undertook ‘upstream’ 
dialogue visits (UDVs) as a means of assessing the management and control of 
upstream public finance/systems data flows from the various providers of EDP 
statistical data to the NSI, which uses them to compile deficit and debt statistics. 
The objective of these visits was to identify, assess and monitor significant risks 
or problems with a view to taking corrective action. UDVs were incorporated into 
SDVs as of 2014. Table 3 shows the dates of dialogue visits during the audited 
period.

3 Dialogue visits carried out in the period 2008‑2014
e
l
b
a
T

2008

2009

2010

2011

August 
(SDV)

May 
(SDV)

March 
(SDV)

Czech Republic

Germany

France

Italy

Cyprus

Malta

June 
(SDV)

December (SDV)

January 
(SDV)

Source: ECA, based on Eurostat information.

May 
(SDV)

May 
(SDV)

June 
(SDV)

November (SDV)

December (SDV)

July 
(SDV)

2012

2013

2014

May 
(UDV) November 
(SDV)

November (SDV)

November (UDV)

September (SDV)

May 
(SDV)

June 
(UDV) 
October (UDV)

February 
(SDV)

November (SDV)

February 
(SDV)

June 
(SDV)

September (SDV)

May 
(SDV)

 
Observations 

38

53 
Eurostat uses a risk analysis model to identify the risks associated with the col‑
lection and compilation of EDP statistics in a Member State. The risk assessment 
is carried out once per year and per Member State. It is a well‑structured and 
comprehensive model that covers all the aspects of the compilation process (see 
Figure 5). The risk analysis was mainly used to rank the Member States to be vis‑
ited for a UDV. However, it could have been better documented. For example, we 
did not always find written explanations for changes from one year to the next in 
the likelihood and/or the impact of the risks assessed. There was also no evidence 
that high‑risk topics were selected for the visits.

5 Risk analysis model
e
r
u
g
i
F

Risks related with the
institutional environment

legal and institutional environment of the NSI and 
other statistical authorities
access to data
resources
professionalism
independence and impartiality
EDP inventory
transparency and responsiveness

Inherent risks

methodological soundness
ESA95/MGDD related issues
revisions

EDP control environment

concerning NSI/other reporting authority
concerning upstream entities supplying data for EDP

Source: ECA, based on Eurostat information.

 
39

31  Statistical capacity issues 

(institutional arrangements 
and data sources, status of 
inventory); follow‑up of 
previous dialogue visits; 
follow‑up of the latest 
reporting – analysis of EDP 
tables and the related 
questionnaires; 
methodological issues and 
recording of specific 
government transactions 
(delimitation of general 
government, application of 
50 % rule in national accounts, 
implementation of accrual 
principle, and recording of 
specific government 
transactions) other issues 
(planned future operations, 
transmission of GFS data, etc.).

Observations 

54 
From 2006 to 2014, the average duration of SDVs and UDVs in the six Member 
States selected was 1.7 and 3.5 days respectively. The number of topics to be cov‑
ered varied from three to ten for SDVs and from four to seven for UDVs. As a rule, 
the agenda of a dialogue visit includes five standard points31 and a number of 
specially selected issues. In exceptional cases, where the country is visited more 
frequently or the purpose is to discuss a limited number of issues, the agenda 
might include fewer items. Given that the team consists of three to four staff, it 
is unlikely that the time on site is sufficient to cover all the ground in sufficient 
depth and so data quality issues may not be adequately examined.

55 
Eurostat’s assessment of EDP data quality is reliant on Member States’ statistical 
systems. Consequently, it must have assurance, not only that EDP data are com‑
pliant with the ESA standards but also that, notwithstanding their different sta‑
tistical systems, Member States apply a consistent approach to data compilation. 
During the period examined, Eurostat visits covered the institutional arrange‑
ments in place in Member States, namely the existence of formal agreements 
binding the national authorities under an EDP. Although recommended, this is 
not a legal obligation. In the course of its UDVs, Eurostat also reviewed the qual‑
ity of EDP systems, mainly in relation to upstream data. Eurostat does not have 
formal written rules in this regard, and we did not find any evidence that desk of‑
ficers assess Member States’ own supervisory and control systems. Without much 
documentation on the supervisory and control systems in place for data compila‑
tion, it is not possible to implement a systems‑based approach for examining the 
quality of the data received.

56 
For the Member States examined, reports were published between nine and 52 
weeks after the corresponding visits (see Figure 6). On‑the‑spot verifications may 
trigger ‘action points’ that the Member State should implement so as to address 
weaknesses found in the course of the verifications. Action points are non‑man‑
datory and often take a long time to resolve. In the six Member States, approxi‑
mately one third of action points had not been resolved within the deadline set 
by Eurostat. However, we found no cases in the sample where failure to respond 
to the action points within the deadline was taken into account in the quality 
assessment of the data submitted, even though they sometimes cover important 
issues which could have an impact on the data.

Observations 

40

6 Time taken to publish visit reports (in weeks)
e
r
u
g
i
F

50

40

30

20

10

0

60

Cyprus
Czech Republic
France
Germany
Italy
Malta

2014

2013

2012

2011

2010

2009

2008

Source: ECA, based on Eurostat information.

 
41

Observations 

Guidance

57 
To ensure a harmonised approach, Eurostat provides methodological guidance to 
Member States on how specific issues of general government should be record‑
ed. Guidance may be triggered in one of two ways:

(a)  Member States may ask Eurostat for advice on complex issues.

(b)  During its quality assessment work Eurostat may come across methodologi‑
cal issues requiring interpretation. If these issues concern multiple Member 
States it sets up a taskforce or organises expert consultation of the Commit‑
tee on Monetary, Financial and Balance of Payments Statistics.

58 
Eurostat provides bilateral guidance at service level if so requested by a Member 
State. On particularly complex issues, it also sometimes takes the initiative to pro‑
vide guidance. Although binding, however, bilateral guidance is not always re‑
ported to the EFC and not always made public due to the Member States’ desire 
for confidentiality. Guidance provided to three of the six Member States (in the 
form of ex‑ante/ex‑post advice) was neither reported to the EFC nor published 
on the Eurostat website. In 2014 and 2015, Eurostat received 36 formal requests 
for ex‑ante/ex‑post advice, of which only 23 were made public. The publication 
of such guidance could help with the sharing of practices among Member States 
and improve comparability and transparency.

… and key aspects of the assessment process need further 
clarification.

59 
Some key aspects of the assessment process are unclear, for example the identifi‑
cation of one‑off and temporary measures and the quantification of their esti‑
mated impact. These measures may make the difference when deciding whether 
or not to place a Member State under an EDP, or whether to extend the deadline 
for correcting an excessive deficit situation (see also paragraph 80).

Observations 

42

60 
The definition of such measures is vague and therefore open to interpretation. 
They are defined as ‘measures having a transitory budgetary effect that does 
not lead to a sustained change in the inter‑temporal budgetary position’32, or 
‘non‑recurrent measures whose impact on the general government balance is 
concentrated in one or a very limited number of years’33, but there is no detailed 
methodology for identifying them. The indicative list in Box 4 is taken from the 
‘Public finances in EMU 2006’ report and gives some examples of measures con‑
sidered to be one‑off and temporary.

32  Code of Conduct.

33 

‘Public finances in EMU 2006’, 
Part II, section 4.2. The report 
was issued as European 
Economy No 3/2006.

4
x
o
B

Public Finances in EMU 2006 (extract)

Deficit‑reducing measures

Tax amnesties implying a one‑off tax payment. The typical case is that of a government offering an am‑
nesty in order to repatriate capital from abroad. The amnesty may be subject to a one‑off tax payment, which 
can potentially be large.

Sales of non‑financial assets (real estate, publicly owned licenses and concessions). The most famous exam‑
ple is the sale of UMTS licences in 2000 (and in some countries in subsequent years).

Temporary legislative changes in the timing of outlays or revenues with a positive impact on the gen‑
eral government balance. This includes changes in tax rates that are clearly announced as temporary and 
temporary changes in the timing of expenditure and collection of revenues.

Exceptional revenues linked to the transfer of pension obligations. These revenues correspond to the 
payment by a given company to the government, in exchange for the transfer of the responsibility for the 
future payment of pensions of its employees. The magnitude of the one‑off payment depends on the value of 
the pension commitments assumed by government and is potentially important.

Changes in revenues or expenditure consecutive to Court or other authorities rulings. Such measures 
include for instance reimbursements of subsidies to general government decided by the Commission.

Securitisation operations with a positive impact on the general government balance.

Exceptional revenues from State owned companies.

Deficit‑increasing measures

Short‑term emergency costs associated with major natural catastrophes or other exceptional events 
(e.g. military actions, others). Experience shows that the exceptionality of these costs depends considerably 
on the size of the country.

Changes in revenues or expenditure consecutive to Court rulings or consecutive to Commission 
decisions.

 
Observations 

43

61 
Another key aspect requiring clarification is the issue of ‘unexpected adverse 
economic events with major unfavourable consequences for government fi‑
nances’ (see paragraph 24). Although a definition of ‘major unfavourable con‑
sequences for government finances’ exists for internal purposes, the concept of 
‘unexpected adverse economic events’ has never been defined34.

34  According to the internal 

version of the DG Economic 
and Financial Affairs 
Vademecum on the SGP.

62 
While it is not possible to exhaustively define the set of individual country cir‑
cumstances to which the concept may apply, given particularly that such events 
are by nature unanticipated, criteria are needed with a view to providing some 
guidance. Faced with the lack of a definition and guidance, when looking at 
France in 2013 the Commission classified unexpectedly low economic growth as 
an ‘unexpected adverse event’, but it is difficult to see how this can be justified.

Data quality assessments and economic analyses lack 
transparency; analyses carried out according to the rules, but 
focused more on government deficit than on debt

63 
This section considers the transparency, objectivity and practicability of the Com‑
mission’s reservations and recommendations.

The criteria for Eurostat’s reservations and amendments to data 
are not sufficiently transparent and objective

64 
Eurostat may express reservations or make amendments if it judges that data 
quality is compromised. During the period 2008‑2014, Eurostat set twelve res‑
ervations and amended data in ten cases, none of which concerned any of the 
Member States examined by us. Considering the large number of action points, 
Eurostat sets reservations rather infrequently.

Observations 

44

65 
Eurostat has not explicitly laid down criteria for setting reservations or amend‑
ing Member States’ data, and the procedure is based on professional judgement. 
In some cases where Eurostat identified methodological problems, the reasons 
for not expressing a reservation were not well documented, including the po‑
tential impact on the deficit and debt data. Box 5 describes some of the cases 
concerned.

5
x
o
B

Some examples of cases with a potential impact on the deficit and debt data that 
were not well documented

Czech Republic

 ο application of the market/non‑market test was infrequent and a large number of public units (corpora‑

tions) were not tested.

France

 ο amount received by a government unit for assuming the costs of decommissioning nuclear facilities 

(1.6 billion (0.1 % of GDP) for 2004).

 ο incompleteness of the local government sector.

Germany

 ο non‑market units are not classified in the general government sector from the first year of their non‑mar‑

ket status.

 ο unavailability of detailed data for the analysis of capital injections, financial derivatives and distributions.

Malta

 ο classification of Malita and City Gate project.

Italy

 ο recording of gross fixed capital formation is not made on an accrual basis for large investment amounts.

For more details see Annex IV.

 
45

35  Article 126(2).

36  For a full list see Article 2(3) of 
Regulation (EC) No 1467/97.

Observations 

DG Economic and Financial Affairs analyses are carried out as 
required by the rules…

66 
When an EDP is launched, DG Economic and Financial Affairs produces analyses, 
which are used as the basis for subsequent EDP decisions, and issues recommen‑
dations. Where a procedure is ongoing, it does this following its regular assess‑
ments of effective action (see paragraph 22). The results of these analyses are 
presented, for new procedures, in the report required by Article 126(3) TFEU or, 
for ongoing procedures, in an internal Commission working document.

67 
An EDP will be triggered, in line with the provisions of the TFEU35, by the Com‑
mission’s examination of Member State compliance with budgetary discipline on 
the basis of the deficit and debt criteria. To this end, DG Economic and Financial 
Affairs monitors the development of the budgetary situation and of the stock 
of government debt in each Member State on the basis of actual data, the plans 
outlined in the Member State’s stability or convergence programme, and the 
Commission’s forecasts. A breach of the thresholds laid down in Protocol No 12 to 
the TFEU does not automatically trigger an EDP, since other relevant factors need 
to be taken into account. These consist of an open‑ended list of economic indica‑
tors grouped under the headings of medium‑term economic, budgetary and 
government debt positions36, as well as any other factors considered relevant and 
put forward by the Member State. The Article 126(3) reports reviewed covered all 
the topics mentioned above.

… however, the EDP has so far focused more on government 
deficit than on debt.

68 
The debt criterion only became operational in 2012, is still being phased in and 
will not apply to all Member States until at least 2020. EDPs initiated before 
November 2011 are to be abrogated on the basis of the deficit criterion only, and 
this will be followed by a three‑year transitional arrangement for debt. Box 6 
shows how the debt criterion has evolved since the Maastricht Treaty.

Observations 

46

6
x
o
B

Evolution of the debt criterion

Protocol No 12 to the Treaty on European Union, signed in Maastricht in 1992, set a threshold level, for the 
public deficit, of 3 % of GDP and, for debt, of 60 % of GDP or a ratio that is ‘sufficiently diminishing and ap‑
proaching the reference value at a satisfactory pace’.

Assuming a 5 % annual nominal GDP growth rate, a deficit of 3 % of GDP will eventually stabilise the 
debt‑to‑GDP ratio at 60 %. If the ratio is above 60 %, a 3 % deficit will induce an annual reduction in the debt 
ratio of one twentieth of the differential with respect to the reference value of 60 %. In other words, focusing 
on the deficit was deemed sufficient to ensure the steady reduction of debt, and for many years it was felt un‑
necessary to define more precisely the pace of convergence with the reference value.

Since the 2008 crisis, the 5 % assumption for annual nominal GDP growth has clearly been unrealistic (see 
Annex V). Hence a deficit of 3 % of GDP no longer automatically implies convergence towards a debt‑to‑GDP 
ratio of 60 % (for example, at an annual nominal growth rate of 3 % and a 3 % deficit, the debt‑to‑GDP ratio 
will stabilise at 100 %). For this reason the debt criterion was adjusted.

A more precise definition emerged in Article 1(2)(b) of Council Regulation (EU) No 1177/2011 of 8 November 
2011: ‘the [debt‑to‑GDP ratio] shall be considered sufficiently diminishing and approaching the reference 
value at a satisfactory pace […] if the differential with respect to the reference value has decreased over the 
previous three years at an average rate of one twentieth per year as a benchmark […]’.

However, the 23 Member States already under an EDP in November 2011 are subject to a transitional rule for 
a period of three years after abrogation of the respective EDP. As a result, the new debt criterion will not apply 
universally to all Member States before at least 2020 (see also Table 1).

69 
The rule since 2011 has been that the government debt‑to‑GDP ratio complies 
with the debt criterion if it does not exceed the reference value (60 % of GDP), or 
if the differential with respect to the reference value decreases over three years 
at an average rate of one twentieth per year, on a backward, forward‑looking or 
cyclically adjusted basis.

70 
The acceptable pace of reduction in the debt‑to‑GDP ratio is approximately that 
which would apply, regardless of the initial level of debt, given a public deficit of 
3 % of GDP and annual nominal growth of 5 %. As nominal growth has consist‑
ently been below 5 % since 2008, to meet the debt benchmark the public deficit 
must be brought below 3 % of GDP – and when higher levels of initial debt are 
factored in the deficit target will be more demanding still. This makes the conver‑
gence requirements particularly challenging for heavily‑indebted Member States.

 
Observations 

47

71 
In Table 4 we use the Commission data and projection37 for the debt‑to‑GDP 
ratio from 2013 to 2020 to calculate the annual ratio resulting from compliance 
with the debt benchmark for five countries in our sample38. Only Germany and 
Malta, where debt hovers around 70 % of GDP, are shown as meeting the debt 
criterion over the period under consideration. Cyprus, which was placed under 
a programme of financial assistance in April 2013, is forecast to be compliant 
with the debt benchmark in 2018. France, which was placed under an EDP in 
April 2009 and is expected to exit the procedure by the end of 2017, should be 
compliant with the debt criterion at the end of a three‑year transitional period 
starting at the abrogation of the EDP (i.e.in 2020). However, with a debt‑to‑GDP 
ratio of 96.5 % in 2015, France is not expected to fulfil the debt criterion by 2020. 
As with France, for all years in the period the Commission also projects that Italy’s 
debt‑to‑GDP ratio will exceed the maximum acceptable for compliance with the 
benchmark. Assuming the scenario projected by the Commission, therefore, Italy, 
which had a debt‑to‑GDP ratio of 133.0 % in 2015, will be unable to comply with 
the debt benchmark by the forecast horizon of 2020 – and is thus prima facie in 
breach of the debt criterion.

37  Data for Germany, Italy, France 
and Malta taken from the 
Commission’s Fiscal 
Sustainability Report 2015, 
baseline scenario. The 
Commission does not include 
data for Cyprus as it is 
a country under a financial 
assistance programme. So 
data for Cyprus taken from the 
IMF Article IV Report on 
Cyprus (IMF Country Report 
No 14/313 – October 2014).

38  With the exception of the 
Czech Republic, where the 
debt‑to‑GDP ratio is below the 
60 % threshold.

4 Evolution of debt under Commission baseline scenario versus debt benchmark (all 
e
l
b
a
T

figures %)

GERMANY

FRANCE

ITALY

CYPRUS

MALTA

debt-to-GDP (EC)

debt-to-GDP (benchmark)

debt-to-GDP (EC)

debt-to-GDP (benchmark)

debt-to-GDP (EC)

debt-to-GDP (benchmark)

debt-to-GDP (EC)

debt-to-GDP (benchmark)

debt-to-GDP (EC)

debt-to-GDP (benchmark)

2013

77.4

2014

74.9

2015

71.4

92.3

95.6

96.5

128.8

132.3

133.0

111.5

117.4

126.0

69.6

68.3

65.9

2016

68.5

73.1

97.1

91.5

132.2

124.5

122.5

112.9

63.2

67.1

2017

65.6

70.4

97.4

92.9

130.0

125.5

116.4

116.1

61.0

65.2

2018

63.0

67.6

97.8

93.4

128.2

124.7

111.1

115.5

59.2

63.0

2019

60.6

65.1

97.8

93.8

126.0

123.3

106.5

111.0

58.1

61.0

2020

58.2

62.7

97.4

94.0

123.5

121.4

102.6

106.2

57.4

59.4

Source: ECA simulation based on EC data – the cells highlighted in yellow indicate that for that year the Member State is forecast to comply with 
the debt benchmark.

 
Observations 

48

Analyses by the Commission are difficult to follow…

72 
The number of relevant factors (see paragraph 14(ii) that the Commission can 
take into account in its analysis is potentially unlimited. Since, moreover, there 
is no methodological framework in place to weigh the impact of those factors 
in the assessment, all conclusions are left to the Commission’s economic judge‑
ment. Although certain cases may require a more qualitative approach based on 
expert knowledge, it is difficult to understand how the Commission’s capacity for 
economic judgement applies to other factors.

39  Czech Republic (7.10.2009), 
Italy (7.10.2009), Cyprus 
(12.5.2010), Malta (13.5.2009).

40  Germany (7.10.2009), France 
(18.2.2009), Malta (18.2.2009).

41  The baseline scenario was 
based on the 2013 spring 
forecast underlying the 2013 
EDP recommendations.

73 
In four of the nine Article 126(3) reports examined, the Commission concluded 
that the relevant factors present or seem to present a ‘mixed picture’39, and 
in three other reports it concluded that the relevant factors seem to present 
a favourable, or relatively favourable, situation40. However, the reasoning behind 
these conclusions is unclear, as is the impact of this analysis on the final deci‑
sion whether or not to place a Member State under an EDP or extend the EDP 
deadline.

… without access to all the data used it is not possible to replicate 
the underlying calculations, …

74 
Information on the data used by the Commission in its calculations was often 
not easily accessible. This finding was corroborated by the representatives of the 
national authorities of some of the Member States visited.

75 
In the case of revised recommendations, for example, the information in the 
Commission’s relevant staff working document was not sufficient to replicate the 
calculation of the fiscal effort and other variables that are essential for the assess‑
ment of Member States’ compliance with the original recommendations. In this 
regard, the working document underlying the Commission’s recommendation to 
extend the EDP deadline for France in February 2015 did not contain data in sup‑
port of the baseline scenario41 or any detail of additional discretionary revenue 
measures, although these data are essential to replicate the assessment of effec‑
tive action which led to the extension.

Observations 

49

… and decisions are not always based on sufficiently objective 
arguments.

76 
We reviewed the Commission analyses underlying the Council’s EDP decisions 
and recommendations in respect of the Member States in the sample. The legal 
framework governing the issue of EDP decisions and recommendations provides 
room for a relatively high degree of flexibility of interpretation and application. 
This is true for the assessment of the Italian budgetary situation in the Article 
126(3) report of 27.2.2015, which concluded that the debt criterion should be 
considered satisfied. Box 7 summarises our analysis of the case.

7
x
o
B

Compliance with the debt criterion – Italy

Italy was placed under an EDP in November 2009. The procedure was lifted in May 2013. Since then, Italy has 
been required to comply with the three‑year transitional rule for the debt criterion. In February 2015 the Com‑
mission carried out an assessment and concluded that the Member State was prima facie in breach of the debt 
criterion.

However, after taking account of the relevant factors, and in spite of the fact that the debt‑to‑GDP ratio was 
still increasing, the Commission assessed Italy to be compliant with the debt criterion. The decision cited three 
main relevant factors:

(i)  The currently unfavourable economic situation, characterised by very low inflation, which make compli‑

ance with the debt rule particularly demanding.

Our analysis: the debt adjustment benchmark already takes into account the influence of the economic cycle 
on the pace of debt reduction. Rules for doing so are set out in a note addressed to the Economic and Finan‑
cial Committee alternates entitled ‘Operationalising the debt criterion in the Excessive Deficit Procedure’. This 
document makes it clear that the adjustment of debt for the cycle also factors in the evolution of prices, which 
is captured by the GDP price deflator.

(ii)  Adherence to the medium‑term budgetary objective (MTO) or the path of adjustment towards it. Accord‑
ing to DG Economic and Financial Affairs, strict compliance or convergence with the MTO implies, under 
normal macroeconomic circumstances, compliance with the debt criterion in the medium term and debt 
sustainability.

Our analysis: based on the 2015 winter EEF, Italy complied with the MTO in 2014 (in the sense that, its econo‑
my being in recession, it was not required to make any adjustment towards the MTO – the structural balance 
actually deteriorated by 0.2 %) and was forecast to comply in 2015. However, although the 2015 winter EEF 
also covers 2016, the assessment only takes account of 2014 and 2015. According to the Commission’s fore ‑
cast Italy will not be in line with the path of adjustment to the MTO in 2016 (forecast structural effort ‑0.2 % 
instead of the +0.5 % required). Hence, Italy was not forecast to meet the condition of ‘strictly respecting the 
required adjustment towards the MTO’.

 
Observations 

50

7
x
o
B

(iii)  Structural reforms: in a January 2015 communication42, the Commission clarified that the relevant factors 
to be taken into account when deciding not to launch an EDP include major structural reforms having 
direct long‑term positive budgetary effects and planned in sufficient detail by the Member State. In DG 
Economic and Financial Affairs’s view, Italy had made progress with the implementation of an extensive 
reform agenda with measures ‘expected to have a positive impact on growth and therefore on the sus‑
tainability of public finance’.

Our analysis: the communication does not quantify the terms ‘major positive impact on growth’ and 
‘long‑term positive budgetary impact’. Italy itself did quantify the expected impact of reforms on growth, 
but not the long‑term budgetary impact. In addition, the Commission did not share some of the assumptions 
underlying Italy’s estimate of a positive impact on growth, merely stating that ‘these results have not been en‑
dorsed by any national independent institution and seem to over‑estimate the impact of the reforms’. Finally, 
there is no methodological framework in place that explains how the budgetary cost of reforms should be 
estimated and factored into the assessment of compliance with the debt criterion.

42  COM(2015) 12 final of 13 January 2015 ‘Making the best use of the flexibility within the existing rules of the Stability and Growth Pact’.

77 
We focused on Italy because, of the Member States in the sample, it was the only 
one where an EDP was not launched even though the country failed to meet the 
debt benchmark; the decision was shaped by considerations drawn from the 
analysis of other relevant factors. Of the five other Member States, the Czech 
Republic’s debt‑to‑GDP ratio is below the threshold, and Germany is currently 
meeting the debt benchmark. Malta was under an EDP from 2013, when it missed 
the debt requirement, until 2015, when it too became compliant for both deficit 
and debt. The rules regarding surveillance are different for Cyprus, since it was 
placed under a financial assistance programme in 2013. Finally, in the case of 
France, which has been under an EDP since 2009, according to Regulation EC No 
1467/97 the debt criterion will only apply when the Member State exits the EDP, 
i.e. not before 2018.

 
Observations 

51

78 
In the case of Italy, the Commission took advantage of the option of invoking rel‑
evant factors in order to avoid applying the EDP to a Member State which would 
be highly unlikely to comply with the debt benchmark. In other words, rather 
than addressing the root causes that made compliance with the benchmark very 
demanding (because, for example, it does not take account of the initial level 
of debt), the Commission put off the problem by emphasising relevant fac‑
tors which made strict compliance with the benchmark a matter of secondary 
importance.

79 
For three of the six Member States in the sample the EDP deadline was extended 
and revised recommendations were issued (see Table 5).

5 Revised recommendations
e
l
b
a
T

Original recommendations

Revised recommendations

Date

Deadline

Average annual 
fiscal effort

Commission 
assessment 
date

Date of 
recommendation

Extension

Deadline

November 2009

November 2009

1 year

2013

France

April 
2009

2012

At least 1 % of GDP 
starting in 2010

May 2013

June 2013

2 years

2015

February 2015

March 2015

2 years

2017 at the 
latest

Average annual 
fiscal effort

Above 1 % of GDP over 
the period 2010-2013

1.3 % of GDP in 2013, 
0.8 % of GDP in 2014, 
0.8 % of GDP in 2015

0.5 % of GDP in 2015, 
0.8 % of GDP in 2016, 
0.9 % of GDP in 2017

Cyprus

July 2010

2012

At least 1.5 % of 
GDP over the period 
2011-2012

May 2013

May 2013

4 years

2016

Not specified

Malta

July 2009

2010

Not specified

February 2010

February 2010

1 year

2011

0.75 % of GDP in 2011

Source: ECA.

 
Observations 

52

80 
We consider that the analysis underlying the March 2015 extension of the French 
EDP, based on 2015 winter forecast, was not fully transparent. In particular, the 
revised recommendation was based on a bottom‑up assessment which stated 
that, ‘overall the available evidence does not allow concluding that the recom‑
mended effort has not been delivered in 2013 – 2014’43. This despite the fact that 
the calculation of structural effort included the effects of a discretionary revenue 
measure44 which, being temporary (financial impact from 2014 to 2016), should 
not have been taken into account. The measure in question was worth 0.1 % of 
GDP. Without it the structural effort would have fallen short of the 1.1 % needed 
to justify extension of the EDP deadline.

43  SWD(2015) 19 final of 

27 February 2015, p. 18.

44 

Increase from 5 % to 10.7 % in 
the rate of the exceptional 
contribution on corporate 
income tax (‘Contribution 
exceptionnelle sur l’impôt sur les 
societés’). The measure was 
introduced on 29 December 
2013 and is due to expire on 
30 December 2016.

81 
Moreover, the Commission regarded France as compliant in retrospect and 
invoked compliance to justify extending the deadline so as to bring the deficit 
below the threshold at a more relaxed pace. However, this assessment was based 
only on 2013 and 2014 data. The forecasts available for 2015, which showed that 
France was going to miss its targets, were not taken into account in the Commis‑
sion’s assessment (see Annex VI).

82 
According to the Vademecum on the SGP, the assessment of effective action 
should be brought forward if there is a risk that the outturn data at the expiry 
of the deadline will show that the headline deficit target has been missed. The 
purpose of this recommendation is to prevent any conflict between Article 10(3) 
of Regulation EC No 1467/97, which requires the EDP to be stepped up immedi‑
ately if, according to the outturn data, the headline target is missed, and Article 
3(5) of the same regulation, which allows for an extension of the deadline on the 
basis that effective action was taken (i.e. the Member State achieved the required 
fiscal effort as assessed using top‑down and/or bottom‑up indicators). However, 
according to the information available at the time of the assessment France 
was not on course to meet any nominal or structural indicators by the end‑2015 
deadline. Rather than extending the deadline, therefore, the Commission should 
have either issued an early warning (through an autonomous recommendation) 
or stepped up the procedure.

Observations 

53

83 
The Commission made use of the high degree of flexibility and discretion afford‑
ed by the SGP rules in its assessments of Italy and France.

Moreover, there were unexplained differences between the EDP 
decisions and recommendations adopted by the Council and those 
proposed by the Commission

84 
We compared EDP decisions and recommendations in the version finally adopted 
by the Council with those proposed by the Commission, and found a number 
of differences for which the available records did not give underlying reasons. 
For example, in the case of Cyprus (06/07/2010) the Commission recommended 
1.75 % of GDP over the period 2010‑2012. This was changed in the Council’s rec‑
ommendation to 1.5 % of GDP over the period 2011‑2012. For the most relevant 
discrepancies see Annex VII.

Observations 

54

EDP corrective and surveillance actions: reporting by 
Member States, monitoring and surveillance by the 
Commission

45  France and Malta.

Member States’ reporting on corrective action could be 
improved

Member States’ reporting on EDP corrective action does not 
provide a sufficiently wide and solid basis for the Commission to 
implement its monitoring and surveillance tasks

85 
The ‘Six‑pack’ and the ‘Two‑pack’ introduced new reporting requirements with 
the aim of enhancing surveillance of the EDP (see Figure 7). However, there is 
no statutory arrangement for ensuring that Member States comply with these 
reporting requirements. As a consequence, the Commission does not take any 
action against Member States which fail to provide the required information. 
Furthermore, our analysis showed that the Commission did not bring this issue 
to the attention of the European Parliament and the Council in its November 
2014 review of economic governance and the application of the ‘Six‑Pack’ and 
‘Two‑Pack’. The Member States in our sample that are subject to the new re‑
porting requirements45 have not always complied with them (see Figure 8 for 
examples).

7 New reporting requirements introduced by the ‘Six‑Pack’ and the ‘Two‑Pack’
e
r
u
g
i
F

‘Six-pack’
(November 2011)

Report on action taken
(in response to Council recommendation/notice)

‘Two-pack’
(May 2013)

Economic partnership programme
In-year budgetary execution report
Report on measures adopted (in response to ACRs)

Source: ECA.

 
Observations 

55

8 Examples of Member States’ non‑compliance with reporting obligations
e
r
u
g
i
F

In october 2013, France was required to submit three EDP documents:

Document to be sent by France in 2013

Finding

(i)   In-year budgetary execution report

France did not send this document to the 
Commission. 

(ii)  Report on action taken

(iii) Economic partnership programme

France submitted an extract from its 2014 draft
budget, which was meant to replace the report 
on action taken and the economic partnership 
programme. However, the extract is not consistent
with the required format and content for an 
economic partnership programme; nor does it 
disclose sufficient information on corrective 
measures for the latter years of the period, as is 
required for the report on action taken.

In october 2014, France and Malta were required to send the following reports:

Document to be submitted in 2014

Finding

France: two in-year budgetary execution
reports

France did not submit the documents.

France: report on measures adopted

Malta: two in-year budgetary execution
reports

Source: ECA.

The Commission required France only to report on
measures adopted in its forthcoming stability 
programme (for 2014) and not, as stipulated by 
Regulation (EU) No 473/2013, in a report on 
measures adopted. The Member State did provide 
some information in its 2014 stability programme, 
but this was not as detailed as required by the 
Regulation.

Malta sent both documents, but the reports did 
not provide the required data on the in-year 
budgetary impact of discretionary measures for 
the year 2014.

 
Observations 

56

86 
With the exception of Cyprus (after it agreed to a financial assistance programme 
in 2013), corrective measures were not sufficiently detailed and/or their fiscal 
impact was not sufficiently clearly identified or explained (see Box 8) for the 
Commission to exercise effective supervision.

87 
Moreover, the deadlines set for the production of European economic forecasts 
are not aligned with national budgetary deadlines. This results in frequent dis‑
crepancies between the Commission forecasts and national budget forecasts, 
and consequently between budgetary targets and the required EDP adjustment 
paths.

8
x
o
B

Examples of insufficient detail on corrective measures

 ο The Czech national reform programme (2012) contained a list of measures, both planned and implement‑
ed, as well as implemented measures with an expected financial impact in 2013 and 2014. However, the 
programme did not include any estimate of the fiscal impact of these measures.

 ο The Czech convergence programme (2012) included a table specifying the fiscal impact of measures envis‑
aged for 2013‑2015. However, the data in the text could not be reconciled with the information in the table. 
Moreover, in one case there were no details on the corrective measures proposed.

 ο The Maltese report on action taken (2013) specified corrective measures for 2013 but was vague about 

2014. Instead of giving details, the report merely referred to the forthcoming budget. Therefore the Com‑
mission’s assessment46 did not incorporate the planned measures (they were not included until the winter 
forecast), which weakened the basis for effective monitoring and surveillance.

 ο The French stability programmes for 2010 to 2014 did not describe the corrective measures for every year 
in the requisite detail47. As a consequence, the Commission did not have a sufficient basis for effective 
supervision or decision‑making.

46  Published on 5 November 2013 and based on the autumn forecast.

47  Each successive stability programme covers three years. France systematically gave full details for the first year, but not for the second or the third.

 
Observations 

57

Monitoring and surveillance by the Commission is subject to 
increasingly complex rules, lacks transparency and provides 
a limited assessment of the effect of structural reforms

88 
This section describes the rules and procedure for assessing effective action, 
examines the quality of the Commission’s assessments and considers the impact 
of recent changes.

89 
The rules for assessing effective action have evolved as a result of:

(i) 

the SGP reforms in 2005 and 2011, which complemented the initial deficit 
benchmark (3 % ‑ SGP 1997) with a top‑down approach based on the struc‑
tural balance; and

(ii)  additional interpretative guidance, endorsed by the Council in 2014, includ‑

ing a bottom‑up assessment methodology.

90 
Compliance with the EDP recommendations is checked by assessing whether, on 
the basis of the actual data and Commission forecasts, the Member State meets 
the annual deficit targets. If the Member State fails to do so, an assessment of ef‑
fective action is carried out using the top‑down and bottom‑up approaches (see 
Box 9).

Observations 

58

9
x
o
B

Assessment of effective action

Top‑down approach

If the annual deficit targets are not reached, the top‑down approach is used to assess whether the Member 
State achieved the improvement in the structural balance (‘recommended fiscal effort’ R) required in the EDP 
recommendations.

This is done by comparing R with the observed or forecast change in the structural balance (‘observed fiscal 
effort’ ΔS) and with the change in the structural balance adjusted for the impact of (a) revisions in potential 
output growth, (b) revisions in the composition of the economic growth or other windfalls/shortfalls on rev‑
enues, and (c) other unexpected events (‘adjusted fiscal effort’ ΔS*).

If both ΔS and ΔS* are equal to or greater than R, the Member State is considered to have taken effective 
action and the EDP is held in abeyance. In all other cases, the assessment needs to be confirmed by a careful 
analysis, which is carried out using the top‑down and bottom‑up approaches.

Bottom‑up approach

The bottom‑up approach aims at assessing the fiscal effort by providing a direct estimate of the budgetary 
impact of new fiscal measures implemented by the Member State since the EDP recommendation was issued, 
or since compliance with the EDP recommendation was last assessed.

The fiscal effort is calculated as the sum of (a) the estimated budgetary impact of additional discretionary rev‑
enue measures and (b) the change in nominal expenditure compared to a baseline scenario which the Com‑
mission projected earlier on the assumption of no policy change.

 
Observations 

59

The rules for assessing effective action have become increasingly 
complex

91 
Introduction of the top‑down and bottom‑up approaches has made the rules for 
assessing effective action more complex.

92 
Top‑down approach: the structural effort depends on an estimate of the output 
gap, which is understood as the difference between actual and potential output. 
Potential output is defined as the maximum level of output that can be obtained 
without generating inflationary pressure. It is an unobservable variable and esti‑
mating it is fraught with uncertainty (see Box 10).

0
1
x
o
B

Potential output

Since the 2005 reform, potential output has played a crucial role in the EDP. This theoretical concept is unob‑
servable, even in retrospect, and has to be estimated.

There are various methods of estimating potential output. Despite the view of experts that ‘there is significant 
uncertainty around any estimate of the output gap’ and the fact that ‘it would be unwise to base an assess‑
ment of economic prospects on any single approach alone’48, the ECOFIN Council did adopt such a single 
approach: the production function methodology.

This methodology uses a pre‑defined functional form for the production function and estimates potential 
output by combining, after removing their cyclical component, the capital stock, the labour force and the to‑
tal productivity of factors. The same production function applies to all Member States: a Cobb‑Douglas func‑
tion with an output elasticity of labour equal to 0.65 and an output elasticity of capital equal to 0.35. These 
values were obtained using ‘the mean wage share for the EU15 over the period 1960‑2003 […] as the estimate 
for the output elasticity of labour, which gives a value of 0.63 […] and, by definition, 0.37 for the output elas‑
ticity of capital.’ However, ‘since these values are close to the conventional mean values of 0.65 and 0.35, the 
latter are imposed for all countries.’49

Revisions of potential output estimates are triggered by the adjustment of past data and the use of new data 
on output and expected output, but also by other technical issues and underlying hypotheses – such as ex‑
pected changes in inflation.

48  UK Office for Budget Responsibility (the UK’s fiscal council), Briefing paper No 2 ‘Estimating the output gap’, April 2011.

49 

‘The production function methodology for calculating potential output growth and output gaps’, Economic Papers 535, November 2014.

 
Observations 

60

93 
This is why potential output estimates are subject to frequent and possibly signif‑
icant revisions which may also affect past estimates. Actual output figures (both 
historical and forecast) may also be substantially revised. The result of all this is 
that the output gap is often revised and may fluctuate enormously – in some 
cases the magnitude of revision is greater than the previous estimate of the out‑
put gap itself. Figure 9 illustrates this volatility. For example, the 2013 output gap 
in Cyprus was initially estimated in the 2011 forecast at ‑1.32 %; it fell to ‑6.16 % in 
the spring 2013 forecast and rose to ‑4.1 % in the spring 2014 forecast.

9 Examples of volatility of the output gap in Commission’s forecasts
e
r
u
g
i
F

2.00 %

1.00 %

2009
A

2010
S

2010
A

2011
S

2011
A

2012
S

2012
A

2013
W

2013
S

2013
A

2014
W

2014
S

Germany 2011
Italy 2012
Cyprus 2013

0.00 %

- 1.00 %

- 2.00 %

- 3.00 %

- 4.00 %

- 5.00 %

- 6.00 %

- 7.00 %

Note: A=autumn, S=spring, W=winter

Source: Commission’s annual macroeconomic database (AMECO).

 
Observations 

61

94 
The bottom‑up approach is also somewhat complex, owing mainly to the dif‑
ficulty in defining the impact of revenue measures and to the ‘no policy change’ 
benchmark against which government actions will be assessed. The Commis‑
sion’s scrutiny/certification of the estimated budgetary impact of fiscal measures 
inevitably depends on information and figures provided by the national authori‑
ties. It is impossible for the Commission to adequately assess the accuracy of 
these figures with the resources it makes available for the task.

The Commission’s analyses of the impact of fiscal measures lack 
transparency…

95 
The increased complexity of the rules for assessing effective action has widened 
the Commission’s scope for interpretation and discretion. As a result its analyses 
have become less transparent.

96 
With regard to the top‑down approach, it is not possible to recalculate the struc‑
tural effort without access to certain key data which were not shared in full with 
the Member States until the 2015 spring forecast and have still not been made 
public (see paragraphs 74 and 75).

97 
The Commission used the bottom‑up approach for France in May 2013. This 
methodology enabled the Commission to judge that France had taken effec‑
tive action and to extend its EDP deadline. However, the methodology was not 
endorsed by the Council until June 2014. In addition, the impact assessment 
of revenue measures is a projection, not an ex‑post assessment, and therefore 
may be overly optimistic compared with the actual outcomes. Moreover, the 
impact of expenditure measures is assessed against a baseline identified by the 
Commission under the ‘no policy change’ assumption and is a matter for expert 
judgement.

Observations 

62

98 
The Commission has been making efforts to enhance transparency. In part since 
the 2014 spring forecast, and in full since the 2015 spring forecast, it has shared 
with Member States the information they need to replicate its effective action 
calculation. However, as most of this detailed information is not made public, an 
interested third party would not be able to replicate the assessment.

99 
In common with the EDP reporting documents submitted by national authorities 
(see paragraph 86), the Commission assessments reviewed by us contained no 
detailed (measure‑by‑measure) or quantified ex‑post assessment of the correc‑
tive measures implemented by Member States.

… and its conclusions are not always sufficiently clear or 
well‑founded

100 
Since the entry into force of the ‘Six‑pack’, Member States placed under an EDP or 
granted an extension have been required to produce a report, within the follow‑
ing six months, on the corrective action taken (see Figure 7 in paragraph 85). This 
concerned two Member States in the sample (Malta and France in October 2013). 
In both cases, we found that the conclusions of the Commission’s assessment 
were based on incomplete data. In particular:

(i) 

the Commission pointed out that Malta (EDP deadline end of 2014) failed to 
meet the EDP requirements for 2014 in both nominal and structural terms, 
and that neither the report on action taken nor the draft budgetary plan 
provided sufficient detail about the discretionary measures underpinning the 
budgetary targets;

(ii)  the Commission’s top‑down assessment showed that, in France (extended 
EDP deadline end of 2015), the structural effort was insufficient for both 
2013 and 2014, but the adjusted structural effort was on target. In accordance 
with the rules, a bottom‑up analysis was also carried out to confirm whether 
the Member State had taken effective action. However, the second analy‑
sis showed that for both years the structural effort fell short of the Council 
recommendations (i.e. the budgetary impact of new discretionary measures 
was insufficient). As for 2015, the last year of the EDP period, the Commission 
warned that ‘a significant set of measures on top of those already specified 
will be needed to ensure that the target for 2015 is reached’. As a matter of 
fact, France missed that target.

Notwithstanding these comments on both Malta and France, the Commission’s 
conclusion for both reports on action taken was that the Member State ‘has taken 
effective action and no further steps in the procedure are needed at present’.

63

50  As can be seen from Annex VI, 
France is the only Member 
State in the sample to which 
this weakness in the ongoing 
assessment applies.

Observations 

101 
The Commission argued that the assessment of the report on action taken is 
retrospective. However, this is not in line with the rules set out in the Vademe‑
cum on the SGP (paragraph 232 ‘…the Commission examines [the Member State’s 
report on action taken] to see whether the Member State has complied with the 
Article 126(7) recommendations. This is done by assessing whether the Member 
State is forecast to meet all the nominal targets, according to the Commission 
forecasts’), and it also means that setting unambitious targets for the first year 
of an EDP (when the report falls due) could turn the assessment of the report on 
action taken into a mere formality that provides no added value. In this respect 
we note, for example, that the Council recommendations issued in June 2013 
required France that year to achieve a headline deficit equal to the forecast made 
for 2013 in the EEF underlying the EDP recommendations, and required only 
those discretionary measures which the Member State had already approved 
in its most recent budget at that time. Lastly, the requisite structural effort was 
simply derived from the headline budget target.

102 
The assessment of effective action should allow the procedure to be stepped 
up if the Member State is missing, or is forecast to miss, all the targets (headline 
deficit, structural effort, adjusted structural effort and bottom‑up targets). How‑
ever, we found that this was not the case with the ongoing assessments (‘regular 
monitoring’) that were made of France50 on the occasion of the 2014 spring and 
autumn forecasts: although France was missing all its targets, the procedure was 
not stepped up (see Annex VI).

103 
Our analysis of the assessment that the Commission carries out at the expiry of 
the deadline for revised recommendations (Malta in 2010 and France in 2009, 
2013 and 2015) is given in paragraphs 79 et seq.

Observations 

64

104 
On the issue of debt, we found in general that, even after the application of the 
debt criterion, the analysis of the dynamics of the debt ratio is inconclusive for 
Member States under an EDP that was already in place in November 2011. The 
analysis broadly describes historical and forecast trends in the debt‑to‑GDP 
ratio, and warns that Member States’ projections might underestimate the debt 
growth rate and that measures planned in their stability programmes could be 
insufficient to bring the debt‑to‑GDP ratio down. However, the conclusions do 
not even question whether or not the debt criterion was breached. The Commis‑
sion pointed out that any such conclusion would only become relevant after the 
abrogation of the EDP. In this respect we also note that, according to the internal 
version of the Vademecum on SGP, EDPs that were open in November 2011 are to 
be abrogated on the basis of the deficit criterion only.

Nevertheless, the introduction of annual fiscal targets in EDP 
recommendations from 2011 onwards provides a clear benchmark 
for the ongoing assessment of effective action in multiannual 
EDPs

105 
In principle, an EDP should be closed by the end of the year following that in 
which it was opened. The targets set by EDP recommendations therefore have an 
annual horizon.

106 
However, in 2009 several EDPs were launched with a multiannual deadline. 
A general government deficit target was set for the period as a whole, with, to 
this end, a fiscal effort averaged over the period (see Annex VI, yellow cells). 
The drawback was that this allowed Member States to postpone most corrective 
action until the last year of the period. At that point, the sheer magnitude of the 
corrections needed made them unrealistic and forced the Council to extend the 
deadline.

107 
To remedy this weakness, since 2011 EDP recommendations have included annual 
fiscal targets for these multiannual EDPs in both nominal and structural terms, 
thus restoring the annual benchmark for assessing corrective action as was the 
case before 2009.

Observations 

65

Structural reforms are now also taken into account in the overall 
assessment of EDP action taken…

51  COM(2015) 12 final.

108 
Excessive public deficits may be rooted – at least in part – in structural weak‑
nesses. Structural reforms address those weaknesses and remove obstacles to 
the fundamental drivers of growth by, for example, liberalising labour, product 
and service markets, which in turn encourages job creation and investment and 
improves productivity. Thus structural reforms may improve competitiveness, 
boost growth and, in the medium and long term, contribute to a lasting correc‑
tion of the deficit.

109 
Since May 2013 the Commission has also taken structural reforms into account in 
the overall assessment of EDP action. It does this by assessing economic partner‑
ship programmes (EPPs). Since the entry into force of the ‘Two‑pack’, euro‑area 
Member States under an EDP have been required, together with their reports on 
action taken, to submit EPPs, which are a sort of road map of planned structural 
reforms. Moreover, since February 2015 the Commission has regarded structural 
reforms planned in sufficient detail as a relevant factor for not launching an EDP 
or for granting a multiannual deadline51.

… although the analyses carried out in this regard are still limited 
and do not take sufficient account of the importance of structural 
reforms in the context of the EDP.

110 
EPP assessments are a one‑off exercise, and the Commission does not systemati‑
cally follow up the weaknesses identified. For example, in its opinion on the EPP 
submitted by Malta in October 2013 the Council concluded that all reforms were 
a work in progress and that implementation remained subject to risks. In addi‑
tion, some country‑specific recommendations had not yet been fully addressed. 
It therefore invited Malta to provide additional information on the implementa‑
tion of the planned reforms in the upcoming national reform programme and 
stability programme, while considering additional measures to ensure long‑term 
public finance sustainability. However, although Malta failed to address all the 
aspects of the Council’s Opinion in respect of a number of reforms, the Commis‑
sion did not mention the missing details in its assessment of the relevant national 
reform programme.

Observations 

66

111 
With the exception of Member States under a financial assistance programme 
(e.g. Cyprus), follow‑up of the implementation of structural reforms by Member 
States under an EDP is done only in the context of the European Semester (moni‑
toring of the implementation of country‑specific recommendations) and is no 
stricter than that carried out in respect of other Member States.

112 
Moreover, the monitoring of country‑specific recommendations does not always 
extend to the actual implementation of reforms or to assessing their effective‑
ness. It mainly focuses on the steps taken to put the proposed measures into law 
(see Box 11). We consider that weak monitoring could compromise the impact of 
the Commission’s recent decision to take greater account of the implementation 
of structural reforms.

1
1
x
o
B

The Commission’s assessment of structural reforms implemented by Italy

By way of illustration of the Commission’s approach to the assessment of structural reforms, reference is made 
to three reforms regarded as priorities by both Italy and the Commission:

 ο Spending review: in their 2013 and 2014 national reform programmes the Italian authorities highlighted 
the appointment of a commissioner to oversee the spending review. However, the commissioner ap‑
pointed in October 2013 resigned in October 2014 (two years before the end of his mandate) after putting 
forward a spending review plan. The Commission in its assessment (COM (2015)113 final) only noted that 
‘in the context of the spending review a choice for more political ownership has been made but only some 
instruments are fully operational’. It did not assess Italy’s progress (or lack of it) in implementing the com‑
missioner’s proposals. A new spending review commissioner was appointed only five months later.

 ο Tackling corruption: DG Economic and Financial Affairs’s assessment of the anti‑corruption authority 
failed to detect any weaknesses undermining its effectiveness. These weaknesses only came to light in 
June 2014 after a report by DG Migration and Home Affairs had identified several issues (February 2014) 
and a major corruption scandal broke in Italy (EXPO 2015 in Milan in April 2014). Two other major corrup‑
tion cases emerged later the same year (the Mose project in Venice in June, Mafia Capitale in Rome in 
December).

 ο Tackling tax evasion: in its assessment the Commission did not examine the figures disclosed by 

Italy as the outcome of measures implemented under this heading in the stability and national reform 
programmes.

 
Observations 

67

Outcome of the EDP

EDP reforms have introduced tools for enhancing budgetary 
discipline, but the EDP has not proved fully effective as 
a corrective mechanism

113 
This section summarises what has been done to further improve budgetary dis‑
cipline and examines the effectiveness of the EDP as a corrective and structural 
reform mechanism.

52  The structural balance is the 
budget balance net of the 
cyclical component and 
one‑off and other temporary 
measures.

53  Data are provided for the 
period under scrutiny, i.e. 
2008‑2015. However, data for 
the structural balance have 
only been available in AMECO 
since 2010.

Successive EDP reforms have introduced tools for enhancing 
budgetary discipline in the Member States…

114 
Recent reforms to the EU fiscal framework (the ‘Six‑pack’ in 2011 and ‘Two‑pack’ 
in 2013 – see Figure 1) were made with the aim of achieving and maintaining the 
soundness of public finances. In the context of the EDP, the reforms introduced 
complementary rules, an early‑warning mechanism and a range of new monitor‑
ing and surveillance tools; they also strengthened sanctions and eased the condi‑
tions for imposing them.

… however, the EDP has not proved fully effective as a corrective 
mechanism.

115 
The budget balance and debt‑to‑GDP ratio are the two Treaty indicators used 
to assess the budgetary position of a Member State (see paragraph 1). The 2005 
reform of the SGP supplemented these by introducing the structural balance52 
as one of the targets that Member States under the EDP must achieve in order to 
correct an excessive deficit situation.

116 
Of the 23 Member States under an EDP in November 2011, 15 had exited the pro‑
cedure as of the end of 2015 (see Table 1). All of the Member States we examined 
improved both their budget balance and their structural balance during the 
audited period (see Figure 1053). The Czech Republic, Germany, Italy and Malta 
managed to exit the procedure. Cyprus agreed to a programme of financial assis‑
tance, and France remains under the EDP after three extensions to the deadline. 
France is the only Member State in our sample with a deficit that still exceeded 
the 3 % threshold in 2015.

Observations 

68

0
1
e
r
u
g
i
F

General government budget balance (2008‑2015) and structural balance (2010‑2015)

General government net lending (+)/net borrowing (-) as % of GDP

2008

2009

2010

2011

2012

2013

2014

2015

2

0

- 2

- 4

- 6

- 8

- 10

2

1

0

- 1

- 2

- 3

- 4

- 5

- 6

Germany 

France 

Italy 

Cyprus 

Malta

Czech Republic

General government structural balance as % of potential GDP

2010

2011

2012

2013

2014

2015

Germany 

France 

Italy 

Cyprus 

Malta

Czech Republic

Source: ECA, based on AMECO (last update 5 May 2015).

 
Observations 

69

117 
The debt‑to‑GDP ratio of all the Member States in the sample was higher in 2015 
than in 2008 (see Figure 11). In mitigation, it must be recognised that the EDPs 
we examined were introduced in the midst of a severe financial crisis which 
contributed to a rapid increase in the debt level through a variety of channels, 
for example capital injections to banks and low or negative nominal growth. On 
average, the debt‑to‑GDP ratio in the EU increased by more than 24 % of GDP 
between 2008 and 2012, and all countries were affected.

1 Debt–to‑GDP ratio (%) 2008‑2015
1
e
r
u
g
i
F

140

120

100

80

60

40

20

2008

2009

2010

2011

2012

2013

2014

2015

Germany 

France 

Italy 

Cyprus 

Malta

Czech Republic

Source: ECA, based on AMECO (last update 5 May 2015).

 
70

54  The primary balance is the 

budget balance net of interest 
payments on general 
government debt. The 
primary balance indicates the 
(positive or negative) amount 
of new debt created by the 
government and can thus be 
considered an indicator of 
fiscal discipline.

55  The snowball effect is the 
effect on public debt 
accumulation arising from the 
differential between the 
interest paid on public debt 
and the nominal GDP growth 
rate. If the interest rate is 
higher than the nominal rate 
of GDP growth, the snowball 
effect will induce an increase 
in the debt‑to‑GDP ratio. In 
principle, to stabilise the 
debt‑to‑GDP ratio the 
government has to achieve 
a primary balance that offsets 
the snowball effect.

56  The stock‑flow adjustment 
groups all changes in public 
debt that cannot be explained 
by the deficit. It includes 
changes (accumulation and 
sales) in financial assets, 
changes in the value of debt 
denominated in foreign 
currency and sundry statistical 
adjustments.

Observations 

118 
In Germany, Malta and the Czech Republic (where it remains under the thresh‑
old), the increase over the 2008‑2015 period was moderate (4.4 percentage 
points in Malta, 6.4 percentage points in Germany and 12.8 percentage points 
in the Czech Republic) and the ratio is now on a downward path. Cyprus has had 
to cope with an unprecedented banking crisis and experienced an increase of 
61.4 percentage points in its debt‑to‑GDP ratio from 2008 to 2015, with the sharp ‑
est rise coming between 2008 and 2013 (from 45.3 % to 102.2 %). However, since 
2013, when it was placed under a programme of financial assistance, the debt 
dynamics have eased, and the ratio stabilised in 2014 (107.5 %) and 2015 (106.7 %). 
Finally, both, France and Italy experienced a continuous increase of around 
30 percentage points in their debt‑to‑GDP ratio over the 2008‑2015 period.

119 
The drivers behind debt dynamics are the primary balance54, the snowball ef‑
fect55 and the stock‑flow adjustment56. The evolution of the debt‑to‑GDP ratio 
can therefore be broken down by the respective impact of those three drivers. 
Figure 12 shows that breakdown, and Box 12 provides a deeper analysis of the 
breakdown and of the debt dynamics for the Member States in the sample.

120 
The analysis in Box 12 suggests that the EDP framework is potentially effective at 
keeping debt at bay. However, a high initial level of debt (as in Italy) may hamper 
the effectiveness of the procedure in keeping the debt‑to‑GDP ratio under con‑
trol, as may the reluctance of a Member State (e.g. France) to implement the EDP 
recommendations and ensure fiscal discipline.

121 
Italian debt continued to increase, in spite of efforts towards fiscal discipline (as 
illustrated by a positive annual primary balance of +1.1 % on average over the 
period), owing to a significant snowball effect resulting from a combination of 
a large initial stock of debt, low or negative nominal GDP growth and episodes 
of high interest rates. France’s debt‑to‑GDP ratio increased despite a moderate 
initial level due to a lack of budgetary discipline, as illustrated by insufficient 
improvement in the budgetary indicators (see Figure 10) and by a significant 
negative primary balance (‑2.7 % on average over the period).

Observations 

71

2 Decomposition of the growth of public debt percentage points 2008‑2015
1
e
r
u
g
i
F

70

60

50

40

30

20

10

0

-10

61.4

16.6

26.4

6.9

30.8

0.8

28.3

8.3

19.2

18.4

6.4

12.5

2.6

- 8.8

8.3

4.6

12.8

12.5

- 4.3

4.4

0.3 5.8
-1.7

France

Germany

Cyprus

Czech Republic

Malta

31.7

- 7.8

Italy

Primary balance

Snowball effect

Stock-flow adjustment

Debt-to-GDP variation

Source: ECA, based on AMECO (last update 5 May 2015).

 
Observations 

72

2
1
x
o
B

Analysis of the evolution of public debt from 2008 to 2015

At the outset of the 2008 financial crisis, Italy’s public debt was 102.3 % of GDP. From 2009 to 2015, Italy had to 
cope with a difficult economic situation, which was reflected in a strong negative output gap (‑3.3 % on aver‑
age) and a yearly average nominal growth rate of 0.0 %. Although Italy improved its structural balance from 
2009 (see Figure 10), the debt‑to‑GDP ratio rose by 30.8 percentage points. The debt dynamics were mainly 
driven by a strong snowball effect, since the primary surplus broadly offset the stock‑flow adjustment (see 
Figure 12). The snowball effect can be explained by the high stock of debt, the weakness of nominal growth 
and the impact of the sovereign debt crisis on interest rates.

France’s debt‑to‑GDP ratio was 68.1 % in 2008. During the 2009‑2015 period France faced a less severe eco‑
nomic turndown than Italy, with annual nominal growth of +1.3 % and an average output gap of ‑1.6 %. 
Despite a lower initial level of debt and better cyclical conditions, France experienced a comparable increase 
in the debt‑to‑GDP ratio (28.3 percentage points) during the period. The increase was mainly due (around 2/3) 
to a lack of budgetary discipline: during the period France ran an annual primary deficit of 2.7 %. The final 1/3 
of the increase can be explained by the snowball effect.

In Germany the debt‑to‑GDP ratio stood at 65.1 % in 2008. Over the 2009‑2015 period Germany benefited 
from a higher nominal annual growth rate (2.4 %) than France and Italy and a less negative output gap (‑1.1 % 
on average) and experienced a rise of 6.4 percentage points in its debt‑to‑GDP ratio. This can be explained 
by better cyclical conditions combined with a protracted period of fiscal consolidation. However, the primary 
surplus only partially offset the stock‑flow adjustments that were the main driver of the increase in debt ‑ the 
snowball effect also playing a limited role.

In 2008 Cyprus had a debt‑to‑GDP ratio of 45.3 %. Over the period Cyprus faced a deep crisis, with negative 
average nominal growth (‑1.0 %) and an output gap of ‑2.1 %. The increase of 61.4 percentage points (from 
45.3 % in 2008 to 106.7 % in 2015) in its debt‑to‑GDP ratio can be explained by the negative impact of all the 
drivers: primary balance (‑18.4 percentage points), snowball effect (‑26.4 percentage points) and stock‑flow 
adjustment (‑16.6 percentage points).

The Czech Republic’s debt‑to‑GDP ratio increased from 28.7 % to 41.5 % between 2008 and 2015, and thus re ‑
mained below the threshold. In an economic environment characterised by average nominal growth of 1.5 % 
and an output gap of ‑1.5 %, the increase in debt (+12.8 percentage points) can mostly be explained by the 
primary deficit (‑12.5 percentage points), with the stock‑flow adjustment offsetting the snowball effect.

In 2008, Malta had a debt‑to‑GDP ratio of 62.7 %. Over the 2009‑2015 period the country experienced average 
nominal growth of 4.6 % and an average nominal deficit of ‑2.8 %. As a result its debt‑to‑GDP ratio essentially 
remained stable, with an increase of 4.4 percentage points that can mostly be explained by the stock‑flow 
adjustment.

 
Observations 

73

122 
The EDP provides for the possibility of sanctions against euro‑area Member 
States for poor budgetary discipline. This can be done by stepping up the proce‑
dure whenever the Commission assessment shows that a Member State has failed 
to take effective action to correct its excessive deficit in time. Sanctions could 
also mean the imposition of a fine of up to 0.5 % of GDP.

123 
However, since its inception, the EDP has been stepped up only once, for Bel‑
gium, and no sanctions have been applied so far. In our view this entails the risk 
that Member States will believe that it is unlikely that sanctions will be imposed. 
Such a perception would undermine the effectiveness and credibility of the EDP. 
Indeed, although the imposition of sanctions is not the real aim, a system de‑
void of sanctions is one that relies on nothing more than moral suasion, in which 
case, unless the Commission can win the Member States’ cooperation, the EDP is 
bound to be ineffective.

The procedure has also had limited impact on ensuring 
implementation of the recommended structural reforms

124 
Structural reforms are neither binding nor enforceable; therefore Member States 
are likely to make them subject to their governments’ political agenda. The Com‑
mission is unable to influence or boost their implementation. As a result, most of 
the Member States in the sample only made partial or limited progress towards 
their reform objectives (see Annex VIII). The outcome of EDP monitoring of the 
implementation of structural reforms often simply consisted in repeating the 
Council’s country‑specific recommendations from year to year.

125 
Of the countries in our sample, only Cyprus made substantial progress in imple‑
menting structural reforms once it agreed to a financial assistance programme 
(April 2013). The latest available assessment shows that Cyprus has implemented 
the majority of the agreed measures in full, albeit with some delay. The pro‑
gramme placed Cyprus under closer and more comprehensive monitoring and 
stricter enforcement rules.

74

57  Press release at http://europa.

eu/rapid/
press‑release_IP‑15‑5874_
en.htm.

58  COM(2015) 600 final.

Observations 

Positive signs ‑ and a challenge ‑ for the future

126 
When presenting its proposals to implement the ‘Five Presidents’ Report’ (see 
paragraph 4), the Commission acknowledged that the framework of European 
economic governance ‘has deepened and widened in scope over the past years, 
but has also gained in complexity’57, and that a first review of the strengthened 
framework had ‘identified some areas for improvement, notably concerning 
transparency, complexity and predictability of policy making, which are relevant 
to the effectiveness of the tools’58. The Commission then expressed a commit‑
ment to pursuing ‘the full and transparent application of the available instruments 
and tools’, and to improving clarity and reducing complexity, with the ultimate 
aim of improving the effectiveness of the existing rules.

127 
We consider the proposals a positive development and encourage the Commis‑
sion to abide resolutely by its commitments.

Conclusions and 
recommendations

75

128 
The Commission has taken significant steps towards rationalising and simplifying 
its use of the excessive deficit procedure as a tool for better economic govern‑
ance throughout the EU, in a context of increasing complexity. Most recently, 
it has stated a commitment to change in areas where we identified problems 
during the audited period: the need for a comprehensive outlook and for greater 
clarity and transparency to maximise the effectiveness of extensive rules and 
guidelines. The rules are in place, and implementation of the EDP is on the right 
track but will benefit greatly from the Commission’s commitment to further 
improvements.

129 
More detailed conclusions on the areas of implementation covered by the audit 
are set out below, together with specific recommendations.

Eurostat

Examination of data

130 
The Commission (Eurostat) has improved its quality assessment processes since 
2011 at the level of both resources and procedures. Standardising and increasing 
the number of requests for information has allowed EDP data to be more exten‑
sively analysed.

131 
The Court found that the process of examining statistical data is not sufficiently 
well‑documented for the analysis underlying quality assessments to be easily 
understood. In addition, it is based on data that are not always complete. It could 
also be made more explicit how the existing rules and guidelines are to be ap‑
plied (see paragraphs 47 to 51).

Conclusions and recommendations 

76

Recommendation 1

The Commission (Eurostat) should better document and enhance the transparen‑
cy of its work in relation to in‑house verifications. This would give management 
and other desk officers a clearer overview of the content of analyses.

The Commission (Eurostat) should establish internal written procedures guiding 
the work of analysis in the quality assessment and better assess and document 
its in‑house verification of data in areas such as the delimitation of the general 
government sector and specific government transactions.

Assessment of control systems

132 
The Commission (Eurostat) does not adequately assess Member States’ control 
systems in order to ensure that, despite Member States’ having different statisti‑
cal systems, they apply a consistent approach to the compilation of data. Owing 
to the general absence of documentation on the supervisory and control systems 
in place for data compilation, it is not possible to implement a systems‑based ap‑
proach for examining the quality of the data received (see paragraph 55).

Recommendation 2

The Commission (Eurostat) should enhance its quality assessments by includ‑
ing an examination of the supervisory and control systems in place in Member 
States, and clearly document its analyses. Written procedures should be drafted 
and implemented to ensure consistency.

Dialogue visits and direct verification

133 
Between 2011 and 2013, the Commission (Eurostat) supplemented its ‘stand ‑
ard’ dialogue visits (SDVs) by introducing ‘upstream’ visits (UDVs) to analyse the 
management and control of upstream data. UDVs proved to be very useful to the 
quality assessment tasks of identifying, assessing and monitoring risks and prob‑
lems. In 2014, UDVs were merged with SDVs, with the resulting visits each lasting 
two days. Given the large number of items on visit agendas, the duration of visits 
is not sufficient for important data quality issues to be adequately examined (see 
paragraphs 52 and 54).

Conclusions and recommendations 

77

134 
Eurostat performs limited direct verifications during its on‑the‑spot visits. 
A well‑structured risk analysis has been introduced, but this is not used to pre‑
select high‑risk issues for visits. The elements of the risk analysis used to deter‑
mine which Member States should receive a dialogue visit, and the topics to be 
discussed during such visits, could be better documented (see paragraph 53).

135 
Eurostat’s dialogue visit reports are published anything from nine to 52 weeks 
after the corresponding visits. Delays in publication mean that Member States 
are unable to share good practices and may prevent other stakeholders/users 
from recognising at the appropriate time that certain problems exist in a Member 
State (see paragraph 56).

Recommendation 3

The Commission (Eurostat) should adapt the duration of its dialogue visits to 
Member States, or carry out more visits, to ensure more complete coverage.

The Commission (Eurostat) should enhance its direct verifications as part of 
on‑the‑spot visits.

The Commission (Eurostat) should further reduce the time taken to publish its 
visit reports.

Action points

136 
Action points are often not resolved within the recommended deadline. This en‑
tails a risk that problems relating to important issues will not be adequately taken 
into account in Eurostat’s quality assessments (see paragraph 56).

Recommendation 4

The Commission (Eurostat) should make full use of its powers to enforce ac‑
tion in the areas of completeness, methodological responsibility and delivery of 
documents.

Conclusions and recommendations 

78

Guidance

137 
When so requested for reasons of confidentiality, Eurostat does not report to the 
EFC or make public all the ex‑ante/ex‑post advice which it provides to Member 
States on a bilateral basis. This practice compromises transparency and compara‑
bility (see paragraphs 57 and 58).

Recommendation 5

To enhance transparency, the Commission (Eurostat) should report to the EFC 
and make public all advice which it provides on methodological issues. Where 
confidentiality concerns prevent publication of a document in full, at least a sum‑
mary should be provided.

Outcome

138 
The reasons for Eurostat reservations and amendments to data could be made 
more transparent (see paragraph 65).

139 
Eurostat has not explicitly laid down written internal procedures for setting reser‑
vations as to data quality or making amendments (see paragraph 65).

Recommendation 6

The Commission (Eurostat) should better document its internal procedures and 
criteria for setting reservations or making amendments to data in order to dem‑
onstrate that all methodological problems with a potential/actual impact on net 
lending/net borrowing are addressed in a consistent way.

Conclusions and recommendations 

79

DG Economic and Financial Affairs

Transparency

140 
In general, the analyses underlying the Commission’s proposals for EDP decisions 
and recommendations lack transparency and, in certain key aspects, are based 
on vague definitions. Moreover, subsequent reforms of the EDP have increased 
the complexity of the analytical process. All this makes it difficult in some cases 
to establish a clear link between the analysis made and the conclusions drawn 
(see paragraphs 59 to 62, 72 to 83, 91 to 97 and 100 to 104).

141 
There is therefore a need to balance the increased complexity and wider scope 
for economic judgement by enhancing transparency and thus facilitating public 
scrutiny. In recent years, the Commission has made commendable efforts to im‑
prove transparency. However, these efforts are not yet sufficient and need to be 
pursued further (see paragraph 98).

Recommendation 7

The Commission (DG Economic and Financial Affairs) should further enhance the 
transparency and clarity of the EDP in the following areas:

 ο Assessment process: the Commission should be more transparent about the 
key aspects of its analyses. It could achieve this by, for example, devising 
a methodology to identify and quantify the impact of one‑off and temporary 
measures, by providing sufficiently detailed explanations of its assessments 
and conclusions in country‑specific documents ‑ regarding, notably, the con‑
cept of ‘unexpected adverse economic events’ when assessing effective ac‑
tion ‑ and by establishing a methodological framework to weigh the impact 
of the relevant factors that it takes into account in its assessments.

 ο Accessibility of data: the Commission should make public all the detailed 
information needed to perform the calculations on which its analyses are 
based, thus enabling any interested third parties to replicate the assessments.

 ο

 ο

Bottom‑up assessment: national fiscal councils should be involved in the 
assessment process by inviting them to provide independent scrutiny of the 
reliability of the figures and information provided by ministries of finance 
and used by the Commission in its analyses.

Robustness of analysis: the Commission should consistently make use of all 
the relevant information made available in its forecasts, abide by the relevant 
methodologies and disseminate them as widely and promptly as possible.

Conclusions and recommendations 

80

Debt criterion

142 
The EDP has so far focused more on government deficit than on debt. The debt 
criterion only became operational in 2012, is still being phased in and will not ap‑
ply to all Member States until at least 2020. The assessment of the debt dynamics 
of Member States under an EDP initiated before November 2011 is inconclusive: 
these EDPs are to be abrogated on the basis of the deficit criterion only, and this 
will be followed by a three‑year transitional arrangement for debt (see para‑
graphs 68 to 69 and paragraph 104).

143 
Flexibility add‑ons to the EDP have meant that, in unfavourable economic times, 
compliance may be recognised even if the debt‑to‑GDP ratio increases. This may 
undermine the credibility of the process and put at risk the sustainability of pub‑
lic debt, especially during protracted periods of recession (when debt can rise 
even if the debt criterion is met). Ultimately, whether or not the debt criterion is 
met, the key thing is to repay or sustainably re‑finance the actual amount of debt 
(see paragraphs 76 to 78).

Recommendation 8

The Commission should focus closely on debt developments, especially in heavi‑
ly‑indebted Member States, to prevent debt building to unsustainable levels.

Where the 60 % debt threshold is exceeded and the concerned Member State is 
placed under the EDP, the Commission should ensure that the required adjust‑
ments provide for a realistic and credible convergence path towards compliance 
with the debt rule, in particular by taking into account the initial level of debt.

In its EDP recommendations for Member States exceeding the debt threshold, 
the Commission should, when setting the annual deficit targets, also specify the 
annual debt‑to‑GDP levels that are consistent with those targets.

Conclusions and recommendations 

81

Structural reforms

144 
Excessive public deficits may be at least partly due to structural weaknesses. Tar‑
geted structural reforms can therefore help to bring about lasting deficit correc‑
tions. Since May 2013, structural reforms have been gaining importance as a fac‑
tor for the Commission’s EDP assessments. However, they are still not enforceable 
and the Commission is no more diligent in monitoring their implementation than 
it is for Member States not under an EDP (see paragraphs 108 to 111).

145 
Moreover, the monitoring of country‑specific recommendations does not always 
extend to the actual implementation and effectiveness of reforms. This could 
compromise the impact of the Commission’s recent decision to take greater ac‑
count of the implementation of structural reforms (see paragraph 112).

Recommendation 9

In conjunction with the Macro‑Imbalances Procedure, the Commission (DG 
Economic and Financial Affairs) should make full use of the European Semester 
in monitoring the implementation of structural reforms for Member States under 
an EDP, in particular where fiscal structural reforms are included in an economic 
partnership programme. Besides focusing on legislative aspects, it should seek to 
assess the effectiveness of the implemented reforms.

The Commission should make full use of its powers to ensure that Member States 
under an EDP meet their commitments with regard to structural reforms.

Conclusions and recommendations 

82

Reporting

146 
The ‘Six‑pack’ and ‘Two‑pack’ introduced new reporting requirements for Mem‑
ber States with the aim of enhancing the Commission’s surveillance of the EDP. 
However, these requirements are non‑enforceable, in that there is no legislative 
provision to ensure that Member States comply in this regard, or for sanctions 
against those that do not. Thus the effectiveness of the Commission’s surveil‑
lance is dependent on the active cooperation of the Member States. We found 
one case where the Member State had not sent reporting documents as required. 
However, the Commission has not made this public in its corresponding assess‑
ments (see paragraphs 85 to 86).

147 
Even when it receives full documentation, the Commission does not always as‑
sess or follow up the information supplied, which raises concern that it is failing 
to make best use of the Member States’ reports or that Member States are being 
burdened with a needless bureaucratic requirement (see paragraphs 99 and 110).

Recommendation 10

The Commission (DG Economic and Financial Affairs) should always make clear 
in its assessments whether the Member States have fulfilled their reporting 
requirements.

The Commission should make use of the possibility to launch infringement pro‑
cedures when Member States do not comply with their reporting obligations.

Sanctions

148 
Successive EDP reforms have strengthened sanctions against Member States 
that do not comply with recommendations, and have eased the conditions for 
imposing them. Since the EDP’s inception, no sanctions have been applied (see 
paragraphs 114 and 122).

Conclusions and recommendations 

83

149 
While sanctions are also useful as a deterrent, not applying them when Member 
States fail to fulfil their commitment to budgetary discipline brings the risk that 
they will be perceived as a tool unlikely to be used. This would undermine their 
credibility and effectiveness, and hence that of the EDP as a whole.

Recommendation 11

In line with existing legislation, the Commission (DG Economic and Financial 
Affairs) should recommend that the Council step up the procedure and apply 
sanctions when there is evidence that a Member State has not complied with EDP 
recommendations and therefore has failed to fulfil its commitment to budgetary 
discipline under the Treaty.

This Report was adopted by Chamber IV, headed by Mr Milan Martin CVIKL, Member 
of the Court of Auditors, in Luxembourg at its meeting of 25 February 2016.

For the Court of Auditors

Vítor Manuel da SILVA CALDEIRA
President

 
 
 
Annexes

84

I Legislation on the excessive deficit procedure
x
e
n
n
A

—  Council Regulation (EC) No 3605/93 of 22 November 1993 on the application of the Protocol on the exces‑

sive deficit procedure annexed to the Treaty establishing the European Community, amended by:

√ 

√ 

√ 

Council Regulation (EC) No 475/2000 of 28 February 2000. Updated the conceptual framework underlying the 
EDP to ESA 95.

Commission Regulation (EC) No 351/2002 of 25 February 2002. Clarified the references to ESA 95 in the context 
of the EDP by replacing the codes ‘B.9’ and ‘D.41’ with ‘EDP B.9’ and ‘EDP D.41’ respectively.

Council Regulation (EC) No 2103/2005 of 12 December 2005, on the quality of statistical data in the context 
of the EDP.

—  Council Regulation (EC) No 479/2009 of 25 May 2009 on the application of the Protocol on the excessive 

deficit procedure annexed to the Treaty establishing the European Community (replaced amended Regula‑
tion No 3605/93). Amended by:

√ 

Council Regulation (EU) No 679/2010 of 26 July 2010 amending Regulation (EC) No 479/2009 as regards the 
quality of statistical data in the context of the excessive deficit procedure.

—  Council Regulation (EC) No 1467/97 of 7 July 1997 on speeding up and clarifying the implementation of 

the excessive deficit procedure, as amended by the Council.

—  Regulation (EC) No 1056/2005 of 27 June 2005 and Regulation (EU) No 1177/2011 of 8 November 2011 – 

the corrective arm of the Stability and Growth Pact.

— 

From the ‘Six‑pack’:

√ 

√ 

Regulation (EU) No 1177/2011 of the European Parliament and of the Council of 8 November 2011 amend‑
ing Regulation (EC) No 1467/97 on speeding up and clarifying the implementation of the excessive deficit 
procedure;

Regulation (EU) No 1173/2011 of the European Parliament and of the Council of 16 November 2011 on the 
effective enforcement of budgetary surveillance in the euro area.

— 

From the ‘Two‑pack’:

√ 

Regulation (EU) No 473/2013 of the European Parliament and of the Council of 21 May 2013 on common provi‑
sions for monitoring and assessing draft budgetary plans and ensuring the correction of excessive deficit of 
the Member States in the euro area.

— 

Intergovernmental Treaty on Stability, Coordination and Governance in the Economic and Monetary Union 
(Fiscal Compact) – 2 March 2012.

 
Annexes 

85

examined

I Some examples of missing information in documents from the six Member States 
I
x
e
n
n
A

Missing information in the 2012, 2013 and 2014 April notifications

For year N-1:

— 

In one Member State:

(i) 

(ii) 

 some detailed data for the social security funds sub-sector and for local government (including the working balance) was missing for entities 
that are not part of local government and for other adjustments to local government data;

 no data was provided on the contribution to the debt level by long-term loans (increase and reduction) for all levels of general government 
(April 2012 only) or on the breakdown of shares and other equity for state and local government.

— 

In another Member State, data were not provided for some sub-sectors (for the working balance, financial transactions included in the working 
balance and ‘other adjustments’ on state government, local government and social security funds). For all levels of general government, most of the 
non-mandatory details requested were missing. 

Missing data on trade credits and advances (AF.71 L) in table 4

In one Member State no data was provided until 2009, and in another there was none before 2011.

Missing data in EDP questionnaires

Five of the six Member States returned EDP questionnaires with incomplete mandatory fields. Examples of incomplete information:

(i) 

four Member States sent incomplete data on capital injections, or none at all, for all years, and one Member State for year N-1;

(ii) 

three Member States sent an incomplete table 4 (Breakdown of other accounts receivable/payable reported in EDP tables);

(iii)  although completeness has improved, two Member States sent incomplete tables 5 (Taxes and social contributions: other accounts receivable/

payable of general government), 8 (Central government claims, debt cancellation) and 9 (Guarantees). 

Other information

During 2008-2014, one Member State did not send the bridge tables1 and the inventory as requested, and three Member States submitted after the dead-
line. The EDP inventories were due by December 2013, but two Member States sent them after the deadline – one in April and the other in November 2014.

1  Bridge tables show the correspondence between the items in the public accounts and the ESA classifications.

Source: ECA, based on Eurostat information.

 
Annexes 

86

States examined

I Some examples of classification weaknesses in documents from the six Member 
I
I
x
e
n
n
A

Main cases not fully compliant with ESA 95 but accepted by Eurostat

 ο

 ο

 ο

in three Member States, the statistical register of public units did not provide exhaustive coverage, mainly at local government level;

one Member State took a prudent approach, that is, automatically allocated to the general government sector – as ancillary units – all public units 
where sales to general government represented more than 80 % of total revenue, and applied the 50 % criterion to the remaining public units. The 
prudent approach is an automatic criterion that does not take into consideration the activity of the unit (type of services provided) or other condi-
tions, such as tendering and market. The accounting rules do not specify what is to be done in these cases. Moreover, some units were classified on 
a group basis (e.g. hospitals) instead of being classified individually according to their market/non-market nature;

one Member State took a prudent approach, but only with units below a certain size; for these units the 50 % criterion was applied so as to exclude 
‘other revenue’ from sales and include all types of taxes in the cost of production. This was done because the Member State was unable to identify 
the subsidies to deduct from sales. However, although all taxes were included on the costs side, according to the accounting rules only ‘other taxes on 
production’ should have been included.

Main weaknesses in the classification of public institutional units

 ο

 ο

one Member State classified the supervisory unit for financial markets, which is an institutional unit, within the general government sector. Accord-
ing to ESA 95, units of this kind should be classified outside general government (namely, as financial auxiliaries within the financial corporations 
sector). Other Member States correctly classified these institutional units outside general government;

in one Member State we examined public units that were non-market and had been reclassified in October 2014 following the ESA 2010 benchmark 
revision. The Member State had reclassified a total of 158 public units in the general government sector, 20 because of the new ESA 2010 rules and 
the remaining 138 as part of a normal benchmark revision. The second group would have been reclassified within the general sector if they had 
previously been analysed correctly.

Other weaknesses

 ο

In relation to the procedures and timing for analysing and (re)classifying units within/outside the general government sector, we found different 
approaches in the six Member States:

(i) 

two Member States analyse and (re)classify units every five years under successive benchmark revisions, but monitors new units every year. 
However, in 2011 one had an action point recommending that the 50 % criterion should not exceed a period of 3-4 years, while the other had an 
action point recommending the market/non-market testing of all public units on an annual basis;

(ii) 

three Member States analyse units every year and reclassify them if their nature (market/non-market) is different for three successive years;

(iii)  one Member State analyses units twice a year, or when funding conditions change, and reclassifies them when the nature of the units changes. 

Source: ECA, based on Eurostat information and documents from the six Member States examined.

 
Annexes 

87

V Some examples of action points with a potential impact on the deficit and debt data
I
x
e
n
n
A

Application of the market/non‑market test was infrequent and a large number of public units (corporations) were 
not tested

Czech Republic

During its visit in 2009, Eurostat found that units with ‘commercial’ legal status (e.g. joint-stock companies, limited companies) had 
not been tested so far and set an action point accordingly. During the 2012 SDV, Eurostat set an action point because the govern-
ment control test for large companies that are less than 50 % government-owned was not applied and therefore these units were 
not analysed. Despite the potential impact no reservation was expressed.

Reclassification of non‑market units to the general government sector from the first year of their non‑market 
status

In its February 2014 visit, Eurostat detected the problem and set a deadline for compliance of May 2014. The matter was considered 
closed in July 2014. Clarifications sent in October 2014 showed that the NSI had only applied the action point to units classified after 
February 2014. Despite the potential impact (not known) no reservation was expressed.

Germany

Unavailability of detailed data for the analysis of capital injections, financial derivatives and distributions

Eurostat first raised the problem of unavailable data following its visit in 2007. The 2009 visit found that the situation had improved 
for central government swaps and for dividends. Eurostat detected certain problems but did not set an action point, and the 
matter of dividends was not discussed in detail. Action points were set in 2011 and 2013. In 2011 Eurostat noted that detailed data 
were unavailable for a proper analysis of capital injections and distributions, and that no local government data were available for 
swaps, but no action point was set. The 2013 UDV did result in action points, but the problem remains. Despite the potential impact 
(not known) no reservation was expressed.

Decommissioning of nuclear facilities ‑ Marcoule (1.6 billion (0.1 % of GDP) for 2004)

This action point was first discussed at the time of the 2006 visit but, owing to disagreement with the NSI about the correct classifi-
cation, Eurostat postponed the decision. The case concerned the recording of a lump-sum payment received by a government unit 
against the assumption of decommissioning costs, with all other obligations to be discharged by the operator. In 2005 Eurostat had 
given advice on this transaction, proposing that it be classified as pre-payments for the purchase of services, but the NSI disagreed 
and instead recorded a capital transfer, which improved the net lending/net borrowing figures. In 2008 the issue was discussed 
again but no further action was taken. Despite the known impact no reservation was expressed.

France

Sector delimitation

Following its visit in 2012, Eurostat set an action point in connection with the fact that the general government sector was incom-
plete because it did not include public corporations belonging to/controlled by local government. As of the end of 2014 the NSI had 
still not provided an exhaustive list. Despite the potential impact (not known) no reservation was expressed.

 
Annexes 

88

V

I
x
e
n
n
A

Italy

Accrual recording of gross fixed capital formation

In its 2012 UDVs Eurostat set an action point in connection with the fact that large investment amounts were recorded on a cash 
rather than an accrual basis. The NSI was given until 2014 to calculate the correct amounts. In 2013 an action point was set request-
ing a progress report. The NSI corrected the amounts in the October 2014 EDP notification. Despite the potential impact (not 
known) no reservation was expressed.

Malita and City Gate project

Malta

Eurostat had detected a problem in its analysis of the revisions in the EDP notification of October 2011. In 2012 it set an action point 
as a follow-up to discussions: the NSI was urged in short order to send Eurostat a description of the statistically relevant aspects of 
the Malita and City Gate project, together with its view of the statistical recording of operations. This point was analysed by Euro-
stat under bilateral guidance; it was agreed in August 2012 and implemented in October the same year. The impact on the deficit 
was 0.4 % of GDP. No reservation had been expressed in April 2012.

Source: ECA, based on Eurostat reports on visits to the six Member States examined.

 
Annexes 

89

V Annual nominal GDP growth rate
x
e
n
n
A

1
8
9
1

2
8
9
1

3
8
9
1

4
8
9
1

5
8
9
1

6
8
9
1

7
8
9
1

8
8
9
1

9
8
9
1

0
9
9
1

1
9
9
1

2
9
9
1

3
9
9
1

4
9
9
1

5
9
9
1

6
9
9
1

7
9
9
1

8
9
9
1

9
9
9
1

0
0
0
2

1
0
0
2

2
0
0
2

3
0
0
2

4
0
0
2

5
0
0
2

6
0
0
2

7
0
0
2

8
0
0
2

9
0
0
2

0
1
0
2

1
1
0
2

2
1
0
2

3
1
0
2

4
1
0
2

5
1
0
2

6
1
0
2

%
3
≥
y
>
%
5

%
5
≥
y

%
3
<
y

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F

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S

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annexes 

90

V Annual nominal GDP growth rate
x
e
n
n
A

4
9
9
1

5
9
9
1

6
9
9
1

7
9
9
1

8
9
9
1

9
9
9
1

0
0
0
2

1
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0
2

2
0
0
2

3
0
0
2

4
0
0
2

5
0
0
2

6
0
0
2

7
0
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2

8
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9
0
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2

0
1
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2

1
1
0
2

2
1
0
2

3
1
0
2

4
1
0
2

5
1
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2

6
1
0
2

%
3
≥
y
>
%
5

%
3
<
y

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5
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e
t
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G
B

O
R

R
H

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annexes 

91

I

V
x
e
n
n
A

Compliance with the nominal and structural targets set in EDP recommendations 
and EDP deadline extensions

Annex VI illustrates how the EDPs introduced for the Member States in the sample have evolved. In each case 
the blue cells show the year of the EDP deadline, with blue arrows pointing to any extensions. Other colours 
show whether the Member State complied (green) or not (red) with the targets set in the Council’s EDP recom‑
mendations for the relevant indicators (headline deficit, structural effort and, for recommendations issued after 
the ‘Six‑pack’ entered into force, the adjusted structural deficit and bottom‑up indicator). The first number in 
a cell represents the target, and the second is the actual value achieved. Finally, yellow cells indicate that no 
annual target was set for the year in question, black cells that the specific indicator was not applicable (not yet 
in force) and grey cells that, although the data were available, the Commission did not take them into account in 
its assessment of effective action.

Source: ECA, based on the Council’s EDP decisions and recommendations, Commission’s Article 126(3) reports and staff working documents 
underlying the assessments of SCPs, draft budgetary plans and the 4th, 6th and 7th reviews of the economic adjustment programme for Cyprus.

 
Annexes 

I

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Annexes

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94

Annexes 

I GERMANY
V
x
e
n
n
A

LEGEND:

MEETING THE TARGET
NOT MEETING THE TARGET
NO TARGET SET (nts)
NOT APPLICABLE (n/a)
DATA NOT AVAILABLE
DATA AVAILABLE, BUT NOT TAKEN INTO ACCOUNT BY COMMISSION

ENILDAED PDE

Assessment

2010

2011

2012

2013

EDP initiated on
 30 November 2009

2010 SP (31.03.2010)
EDP deadline
Headline deficit
Structural effort
Adjusted structural effort
Bottom-up approach

Assess. of effective action 
(15.06.2010)
EDP deadline
Headline deficit
Structural effort
Adjusted structural effort
Bottom-up approach

2011 SP (07.06.2011) 
EDP deadline
Headline deficit
Structural effort
Adjusted structural effort
Bottom-up approach

2012 SP (30.05.2012)
EDP deadline
Headline deficit
Structural effort
Adjusted structural effort
Bottom-up approach

nts → - 5.7 %
nts → - 1.7 %

nts → - 5.7 %
0.5 % → 0.1 %

nts →
0.5 % → 0.1 %

> - 3 % →
0.5 % →

nts → - 5.7 %
nts → 0.5 %

nts → - 5.7 %
0.5 % → 0.0 %

nts →
0.5 % → 

> - 3 % →
0.5 % →

nts → - 3.3 %
nts → 0.0 %

nts → - 2.0 %
0.5 % → 0.5 %

nts → - 1.2 % 
0.5 % → 0.6 %

> - 3 % →
0.5 % →

nts → - 1.0 %
0.5 % → 1.1 %

nts → - 0.9 % 
0.5 % → 0.4 %

> - 3 % → - 0.7 %
0.5 % → 0.1 %

EDP abrogated on
22 June  2012

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95

MEETING THE TARGET
NOT MEETING THE TARGET
NO TARGET SET (nts)
NOT APPLICABLE (n/a)
DATA NOT AVAILABLE
DATA AVAILABLE, BUT NOT TAKEN INTO ACCOUNT BY COMMISSION

EDP DEADLINE

EXTENSION OF EDP DEADLINE

0102

EDP initiated on
 06 July 2010

1102

2102

3102

4102

5102

6102

 - 6 % →- 5.9 %
nts → 0.0 %

nts → - 5.7 %
1,5 % → + 0.7 %

> - 3% →
1,5 % → %

 - 6 % →- 5.3 %
nts → + 0.7 %

nts → - 5.1 %
1,5 % → + 0.5 %

> - 3 % → - 4.9 %
1,5 % → - 0.2 %

nts → - 6.7 %
1,5 % → - 0.2 %
1,5 % → - 0.2 %

> - 3 % → - 2.7 %
cum 1,5 % → + 0.7 %
cum 1,5 % → + 0.8 %

> - 3 % → - 1.8 %

nts → - 6.3 %
> 1 % → - 0.4 %

> - 3 % → - 3.4 %
> 1 % → + 2.9 %

> - 3 % → - 2.5 %
> 1 % → + 1.0 %

nts → - 5.3 %
nts → + 0.8 %

nts → - 6.3 %
> 1 % → - 0.9 %
> 1 % → + 2.2 %
> 1 % → + 1.5 %

> - 3 % → - 6.3 %
> 1 % → - 0.1 %
> 1 % → + 2.4 %
> 1 % → + 4.25 %

MS placed under a programme
of financial assistance on
  02 April 2013

Unexpected adverse economic
events with major unfavourable
consequences for government
finances

- 6.5 % → - 8.4 %
+ 1.3 % (min 0.5 %) → + 1.2 %
+ 1.3 % (min 0.5 %) → + 0.9 %
+ 4.75 % → + 4.5 %

- 8.4 % → - 8.4 %
+ 0.3 % (min 0.5 %) → + 0.1 %
+ 0.3 % (min 0.5 %) → + 0.7 %
+ 1.75 % → + 2.5 %

- 6.5 % → - 5.4 %
+ 1.3 % (min 0.5 %) → + 3.0 %
+ 1.3 % (min 0.5 %) → %
+ 4.75 % → %
- 6.5 % → - 5.4 %
+ 1.3 % (min 0.5 %) → + 3.0 %
+ 1.3 % (min 0.5 %) → %
+ 4.75 % → %

- 8.4 % → - 5.3 %
+ 0.3 % (min 0.5 %) → - 0.2 %
+ 0.3 % (min 0.5 %) → %
+ 1.75 % → %
- 8.4 % → - 5.3 %
+ 0.3 % (min 0.5 %) → - 0.2 %
+ 0.3 % (min 0.5 %) → %
+ 1.75 % → %

- 6.3 % → %
+ 0.7 % (min 0.5 %) → %
+ 0.3 % (min 0.5 %) → %

- 2.9 % →
+ 1.8 % (min 0.5 %) → %
+ 1.8 % (min 0.5 %) → %

- 6.3 % → - 5.1 %
+ 0.7 % (min 0.5 %) → + 0.2 %
+ 0.7 % (min 0.5 %) → %

- 2.9 % → - 2.4 %
+ 1.8 % (min 0.5 %) → + 1.7 %
+ 1.8 % (min 0.5 %) → %

- 6.3 % → - 5.1 %
+ 0.7 % (min 0.5 %) → + 0.2 %
+ 0.7 % (min 0.5 %) → %

- 2.9 % → - 2.4 %
+ 1.8 % (min 0.5 %) → + 1.7 %
+ 1.8 % (min 0.5 %) → %

- 6.5 % → - 4.9 %
+ 1.3 % (min 0.5 %) → + 4.3 %
+ 1.3 % (min 0.5 %) → %
+ 4.75 % → %

- 8.4 % → - 0.2 %
+ 0.3 % (min 0.5 %) → - 0.7 %
+ 0.3 % (min 0.5 %) → %
+ 1.75 % → %

- 6.3 % → - 1.5 %
+ 0.7 % (min 0.5 %) → + 1.4 %
+ 0.7 % (min 0.5 %) → %

- 2.9 % → - 0.1 %
+ 1.8 % (min 0.5 %) → + 0.1 %
+ 1.8 % (min 0.5 %) → %

- 6.5 % → - 4.9 %
+ 1.3 % (min 0.5 %) → + 4.4 %
+ 1.3 % (min 0.5 %) → %
+ 4.75 % → %

- 8.4 % → - 8.8 %
+ 0.3 % (min 0.5 %) → + 3.9 %
+ 0.3 % (min 0.5 %) → %
+ 1.75 % → %

- 6.3 % → - 0.9 %
+ 0.7 % (min 0.5 %) → - 1.6 %
+ 0.7 % (min 0.5 %) → %

- 2.9 % → - 0.1 %
+ 1.8 % (min 0.5 %) → + 0.0 %
+ 1.8 % (min 0.5 %) → %

EDP held in abeyance

Annexes 

LEGEND:

I CYPRUS
V
x
e
n
n
A

tnemssessA

Assess. of effective action 
(27.01.2011)
EDP deadline
Headline deficit
Structural effort
Adjusted structural effort
Bottom-up approach

2011 SP (07.06.2011)
EDP deadline
Headline deficit
Structural effort
Adjusted structural effort
Bottom-up approach

Assess. of effective action 
(11.01.2012)
EDP deadline
Headline deficit
Structural effort
Adjusted structural effort
Bottom-up approach

2012 SP (30.05.2012)
EDP deadline
Headline deficit
Structural effort
Adjusted structural effort
Bottom-up approach

Assess. of effective action 
(07.05.2013)
EDP deadline
Headline deficit
Structural effort
Adjusted structural effort
Bottom-up approach

Assess. of effective action  
(06.09.2013)
EDP deadline
Headline deficit
Structural effort
Adjusted structural effort
Bottom-up approach

4th Programme Review
(cut-off date: 20 May 2014)
EDP deadline
Headline deficit
Structural effort
Adjusted structural effort
Bottom-up approach

6th Programme Review
 (cut-off date: 15 May 2015)
EDP deadline
Headline deficit
Structural effort
Adjusted structural effort
Bottom-up approach

7th Programme Review
 (cut-off date: 24 July 2015)
EDP deadline
Headline deficit
Structural effort
Adjusted structural effort
Bottom-up approach

S:\PUB\4 REPORTS\3_Reports and Opinions not published\RS\SR-10-2016 EDP\4_PAO\AnnexVI_FR.xlsxAnnex VI CY

 
 
96

Annexes 

I

V
x
e
n
n
A

ITALY

LEGEND:

MEETING THE TARGET
NOT MEETING THE TARGET
NO TARGET SET (nts)
NOT APPLICABLE (n/a)
DATA NOT AVAILABLE
DATA AVAILABLE, BUT NOT TAKEN INTO ACCOUNT BY COMMISSION

EDP DEADLINE

Assessment

2010

2011

2012

2013

2014

2015

EDP initiated on
 30 November 2009

nts → - 5.3 %
0.5 % → 0.0 %

nts → - 5.1 %
0.5 % → 0.0 %

> - 3 % →
0.5 % →

nts → - 5.7 %
+ 0.5 % → - 0.5 %

nts → - 5.7 %
+ 0.5 % → 0.0 %

> - 3 % →
0.5 % →

nts → - 4.6 %
+ 0.5 % → + 2.3 %

nts → - 4.0 %
+ 0.5 % → + 0.4 %

> - 3 % → - 3.2 %
+ 0.5 % → + 0.4 %

nts → - 3.9 %
+ 0.5 % → - 0.9 %

> - 3 % → - 2.0 % > - 3 % → - 1.1 %
+ 0.5 % → - 0.6 %

> - 3 % → - 3.0 % > - 3 % → - 2.9 % > - 3 % → - 2.5 %
+ 0.5 % → + 2.2 %

EDP abrogated on
21 June  2013

2010 SP (31.03.2010)
EDP deadline
Headline deficit
Structural effort
Adjusted structural effort
Bottom-up approach

Assess. of effective action 
(15.06.2010)
EDP deadline
Headline deficit
Structural effort
Adjusted structural effort
Bottom-up approach

2011 SP (07.06.2011)
EDP deadline
Headline deficit
Structural effort
Adjusted structural effort
Bottom-up approach

2012 SP (30.05.2012)
EDP deadline
Headline deficit
Structural effort
Adjusted structural effort
Bottom-up approach

2013 SP (29.05.2013)
EDP deadline
Headline deficit
Structural effort
Adjusted structural effort
Bottom-up approach

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97

Annexes 

CZECH REPUBLIC

LEGEND:

I

V
x
e
n
n
A

MEETING THE TARGET
NOT MEETING THE TARGET
NO TARGET SET (nts)
NOT APPLICABLE (n/a)
DATA NOT AVAILABLE
DATA AVAILABLE, BUT NOT TAKEN INTO ACCOUNT BY COMMISSION

EDP DEADLINE

Assessment

2010

2011

2012

2013

2014

2015

EDP initiated on
30 November 2009

nts → % - 5.5 %
1 % → % + 1.4 %

nts → % - 5.7 %
1 % → % - 0.2 %

nts → %
1 % → %

> - 3 % →
1 % → %

nts → - 5.7 %
1 % → 0.5 %

nts → - 5.7 %
1 % → 0 %

nts → %
1 % →

> - 3 % →
1 % →

nts → - 4.7 %
→ + 2.2 %

nts → - 4.4 %
1 % → + 0.6 %

nts → - 4.1 %
1 % → -0.1 %

> - 3 % →
1 % →

nts → - 3.1 %
1 % → + 1.5 %

nts → - 2.9 %
1 % → + 0.2 %

> - 3 % → - 2.6 %
1 % → + 0.3 %

nts → - 4.4 %
1 % → + 0.9 %

> -3 % → - 2.9 %
1 % → + 0.1 %

> - 3 % → - 3.0 %

> - 3 % → - 1.5 %
1 % → + 1.5 %

> -3 % → - 1.9 %

> - 3 % → - 2.4 %

EDP abrogated on
20 June  2014

2010 SP (31.03.2010)
EDP deadline
Headline deficit
Structural effort
Adjusted structural effort
Bottom-up approach

Assess. of effective action 
(15.06.2010)
EDP deadline
Headline deficit
Structural effort
Adjusted structural effort
Bottom-up approach

2011 SP (07.06.2011)
EDP deadline
Headline deficit
Structural effort
Adjusted structural effort
Bottom-up approach

2012 SP (30.05.2012)
EDP deadline
Headline deficit
Structural effort
Adjusted structural effort
Bottom-up approach

2013 SP (29.05.2013)
EDP deadline
Headline deficit
Structural effort
Adjusted structural effort
Bottom-up approach

2014 SP (02.06.2014)
EDP deadline
Headline deficit
Structural effort
Adjusted structural effort
Bottom-up approach

S:\PUB\4 REPORTS\3_Reports and Opinions not published\RS\SR-10-2016 EDP\4_PAO\AnnexVI_FR.xlsxAnnex VI CZ

 
98

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Annexes 

100

I

I Differences between Commission and Council recommendations
V
x
e
n
n
A

Commission recommendation

Council recommendation

Cyprus
6.7.2010

the Cypriot authorities should ensure an average annual fiscal effort of 
at least 1¾ % of GDP over the period 2010-2012

the Cypriot authorities should ensure an average annual fis-
cal effort of at least 1½ % of GDP over the period 2011-2012

the Council invites the Czech authorities to continue with the 
necessary pension and healthcare reforms, reforms aimed at raising 
labour supply and skill levels, and reforms increasing the amount and 
effectiveness of public R&D

the French authorities should stand ready to implement the necessary 
annual efforts going beyond those foreseen in the subsequent years 
of the correction period in order to ensure that the annual targets 
are respected and that the deficit is brought below the reference 
value by 2012 even if downside risks to the budgetary targets were to 
materialise

the Council invites the Czech authorities to continue with the 
necessary pension and healthcare reforms 

the French authorities should implement the necessary ef-
forts to bring the deficit below the reference value by 2012

the French authorities should ensure an average annual structural 
budgetary adjustment of 1¼ % of GDP over the period 2010-2013

the French authorities should ensure an average annual fiscal 
effort of above 1 % of GDP over the period 2010-2013

France should improve the overall competition framework, with 
particular emphasis on network industries, further reform the pension 
system, modernise employment protection and enhance life-long 
learning to improve potential GDP growth

France should further reform the pension system as planned 
which would contribute to long-term fiscal sustainability

the French authorities should report on progress made in the imple-
mentation of these recommendations at least every six months, as 
well as in a separate chapter of the stability programmes, until full 
correction of the excessive deficit has taken place

Nil

the Council invites the German authorities to implement reforms with 
a view to raising potential GDP growth. This includes (…) reforms to 
improve the framework for competition in services and promote the 
integration of the low-skilled and long-term unemployed into the 
labour market through a flexicurity approach which combines better 
access to qualifications with improved incentives to work

the Italian authorities should ensure an average annual fiscal effort of 
0.5 percentage points of GDP over the period 2010-2012

the Council invites the German authorities to implement 
reforms with a view to raising potential GDP growth

the Italian authorities should ensure an average annual 
fiscal effort of at least 0.5 percentage points of GDP over the 
period 2010-2012

the Italian authorities are also invited to step up efforts to strengthen 
competition in product and services markets, simplify legislation, 
reduce the administrative burden at all levels of government and, 
within a ‘flexicurity’ approach and with a view to reducing regional 
disparities, improve the functioning of the labour market and the 
efficiency, outcomes and standards of the education system

Nil

Czech Republic
30.11.2009

France
6.4.2009

France
30.11.2009

France
18.6.2013

Germany
30.11.2009

Italy
30.11.2009

Source: ECA.

 
Annexes 

101

I
I

I Implementation of planned structural reforms
V
x
e
n
n
A

2011

2012

France

Some progress

Some progress

Some progress

Substantial progress

Limited progress

Some progress

Fully addressed / some progress

Some progress

Some progress

Limited progress

Some progress

Not implemented

No progress

Some progress

No progress

Limited progress

Some progress

CSR1

CSR2

CSR3

CSR4

CSR5

Italy

CSR1

CSR2

CSR3

CSR4

CSR5

CSR6

Malta

CSR1

CSR2

CSR3

CSR4

CSR5

CSR6

Germany

CSR1

CSR2

CSR3

CSR4

Partly implemented

Partly implemented

Partly implemented

Partly implemented

Partly implemented

Partly implemented

Partly implemented

Partly implemented

Partly implemented

Partly implemented

Partly implemented

Partially implemented

Not implemented

Partially implemented

Not implemented

Partially implemented

Partially implemented

Partially implemented

Partially implemented

Partially implemented

2013

Some progress / limited progress / some 
progress

Some progress / some progress / some 
progress

Some progress / some progress / some 
progress

Limited progress/limited progress / some 
progress

No progress / no progress / some progress

Limited progress

Limited progress

Some progress

Limited progress

Limited progress

Limited progress

Some progress

Limited progress

Some progress

Limited progress

Some progress

 
Annexes 

I
I
I

V
x
e
n
n
A

Cyprus
CSR1

CSR2

CSR3

CSR4

CSR5

CSR6

CSR7

102

2011

2012

2013

Partially implemented

Partially implemented

Partially implemented

Partially implemented

Partially implemented

Partially implemented

Partially implemented

Partially implemented

Partially implemented

Partially implemented

Partially implemented

Partially implemented

Partially implemented

Partially implemented

Czech Republic
CSR1

Implemented all / not addressed fully

Some progress

CSR2

CSR3

CSR4

CSR5

CSR6

CSR7

Partially implemented

Partially implemented

Partially implemented

Partially implemented

Partially implemented

No progress

Limited progress

Some progress

Some progress

Limited progress

Some progress

Limited progress

No progress

Limited progress

Limited progress

Limited progress

Limited progress

Source: ECA, based on the Commission’s assessments of stability/national reform programmes.

 
Reply of the Commission

103

Executive summary

V
Detailed procedures and guidelines have been put in place regarding data quality assessment as well as the analysis 
and assessment of compliance under the fiscal rules. The Commission would like to stress that the EDP data report‑
ing by Member States has been greatly refined since 2005. EDP questionnaires with a wealth of detailed additional 
data and information complement Member States’ obligatory EDP reporting and support the Commission’s data 
quality assessment.

The Commission does not agree with the conclusions of inadequate feedback and poor record‑keeping, as material 
information has been properly assessed and documentation has significantly improved over recent years.

The Council recommendations and decisions implementing the Stability and Growth Pact are prepared by the 
Economic and Financial Committee (EFC). The Commission systematically reports to the EFC on the implementation 
of the SGP, in particular the EDP. In addition to the Commission’s reporting to the EFC, the legal texts and accompa‑
nying Staff Working Documents (SWDs), which are publicly available, contain extensive additional information and 
explanations on EDP‑related decisions. The members of the EFC include representatives from all the Member States, 
the European Commission and the European Central Bank. Minutes are kept for all the EFC meetings to record the 
Committee’s work for present and future reference. The minutes summarise the exchange of views among members 
and record the decisions that were taken. The Secretariat prepares draft minutes after each meeting and circulates 
them to the members for their comments. The minutes are adopted at the subsequent meeting of the EFC. Mem‑
bers may take notes for their own use during the meetings, although unauthorised disclosure of any non‑public 
information is prohibited.

Following the endorsement by the EFC of the draft Council documents implementing the SGP, the Secretariat of the 
EFC forwards the draft documents to the Secretariat of the Council. The Council recommendations and decisions are 
adopted by the Economic and Financial Affairs Council (Ecofin). The relevant European Commissioner participates in 
the meetings of the Ecofin. Minutes are also kept for all the meetings of the Ecofin.

VI
The Commission considers that transparency has recently been enhanced significantly. The Commission however 
does not agree that information was generally unavailable.

On the contrary, the Commission is fully committed to transparency. In the statistical field, the Commission pub‑
lishes methodological advice and guidance, provided it does not breach statistical confidentiality enshrined 
in Council Regulation 479/2009. With the European System of Accounts, the Commission’s approach is clearly 
rules‑based and the Commission does not depart from established procedures. Applying sound judgement in line 
with the rules instead of a purely mechanistic approach is, however, a core task of the Commission and is the only 
means to properly reflect the diversity of Member States and issues at stake.

In recent years, the EU fiscal framework has undergone several changes with a view to introducing complementary 
rules, strengthening compliance mechanisms and raising national ownership.

Reply of the Commission

104

The legislative changes introduced had to be technically operationalised. To this end, the methodologies and clas‑
sifications utilised in assessing compliance with the Stability and Growth Pact (SGP) had to be adapted. This process 
took place through extensive discussions in the Economic and Financial Committee (EFC) and other competent 
instances of the Council. These discussions were facilitated through a series of explanatory notes. The increased 
complexity of the surveillance framework called for additional explanation in a spirit of transparency.

Therefore, all the approaches to the implementation of the revised framework were summarised in the Vade Mecum 
on the Stability and Growth Pact, publicly available on the Commission’s website. The Vade Mecum will now be 
updated annually in line with a commitment in the Commission Communication of 21 October 2015 on Completing 
EMU.

In order to further increase transparency, since spring 2014 the Commission agreed to provide Member States with 
all the necessary information to replicate the underlying computations related to the compliance assessment with 
both the preventive and the corrective arm, including detailed excel spreadsheets providing step‑by‑step calcula‑
tions. Regarding discretionary measures, the Commission has made fully public aggregate data series on the impact 
of discretionary measures and the level of one‑offs since spring 2014 and, in line with the Ecofin Council Conclu‑
sions of June 2014, has made further progress by sharing with the Member States the yield of key individual tax 
measures incorporated in the bottom‑up approach for EDP countries as of spring 2015.

Furthermore, the Commission has made available detailed information on the main measures in the Staff Working 
Documents which accompany new EDP recommendations, including the forecast of key variables for the compu‑
tation of the fiscal effort under the baseline scenario (e.g. the point of reference to which future forecasts will be 
compared in order to compute both the top‑down and the bottom‑up approach).

VII
In relation to the implementation of structural reforms, the Commission would like to clarify that although appro‑
priate structural reforms can play a key role in eliminating excessive deficits, their implementation is not a legally 
relevant component in the abrogation of an EDP.

In terms of enforcement, the focus of the legislation which governs the EDP is fiscal outcomes and, as such, the 
relevant legislation does not contain specific provision to enforce the implementation of structural reforms. Indeed, 
it is important to re‑state that the assessment of effective action under an EDP is focussed on the delivery of the 
required budgetary adjustment and is not affected by the evaluation of structural reforms. The implementation of 
structural reforms, including those undertaken under an Economic Partnership Programme (EPP), is monitored in 
the context of the European Semester, including under the Macroeconomic Imbalances Procedure. However, the 
Article 9 of Regulation (EU) No 473/2013 of 21 May 2013 does not foresee specific steps in cases where the imple ‑
mentation of structural reforms falls short of what is recommended in the analysis of the EPP. For countries subject 
to specific monitoring due to the presence of excessive imbalances, the implementation of reforms is monitored 
under the Excessive Imbalances Procedure.

That said, at the point of examining whether an EDP needs to be opened for a given Member State, the Commission 
analyses carefully all relevant medium‑term developments regarding the economic, budgetary and debt positions. 
These ‘relevant factors’ include the implementation of structural reforms in the context of the European Semester 
such as within the Excessive Imbalances Procedure. The Commission considers that a lack of implementation of 
structural reforms constitutes an aggravating relevant factor.

Reply of the Commission

105

The Commission does not agree that the EDP over‑emphasises the deficit dimension at the expense of debt. In 
particular, since the 2011 reform of the legislation known as ‘the Six‑pack’, the breach of the debt threshold of 60% 
of GDP has been elevated to the trigger of the EDP. The Commission has opened a debt‑based (and deficit‑based) 
EDP for Malta in 2013, which has successfully exited the procedure in 2015. At the same time, the concept of debt 
diminishing at a satisfactory pace was operationalised through the debt‑reduction benchmark and is now assessed 
as part of the Commission’s regular monitoring of Member States’ fiscal positions.

VIII
The Commission is committed to equal treatment of Member States. Where shortcomings in this respect have been 
identified, the Commission has taken action to ensure the consistent application of rules and will continue to do so.

The Commission has greatly improved transparency since 2005. In the field of EDP data and methodological ques‑
tions, the Commission is publishing all mission reports, bilateral advice given to Member States and other relevant 
information.

While the Commission acknowledges that there has been a lack of transparency regarding the fiscal surveillance 
process until a number of years ago, the Commission stresses that these shortcomings have been decisively tackled 
in recent years through the actions mentioned above (see Commission’s reply to paragraph VI), including the provi‑
sion of more detailed information as well as the advance codification of the key concepts and methodologies.

IX (a)
The Commission accepts similar (while not exactly the same) recommendations made in the ‘Conclusions and rec‑
ommendations’ section of the report (recommendations 1 to 4).

IX (a) (i)
The Commission considers the current quality assessment procedures appropriate. It will continue to endeavour to 
better document this work.

IX (a) (ii)
The Commission considers that control systems are assessed in the dialogue visits and in specific questionnaires.

IX (a) (iii)
The Commissions considers that the on‑spot verifications are effective (fit for purpose) and would like to recall that 
extensive verification is also done in‑house. This recommendation would not be neutral in terms of resources.

IX (b) (i)
The Commission only partially accepts the recommendation. Due to the significant and effective achievements in 
recent years in codifying concepts and methodologies used in the assessment of compliance with the EDP and in 
making available to the Member States all the calculations underpinning its assessments, transparency has already 
been improved. The process of independent verification will be strengthened by the recently set up European Fiscal 
Board as a functionally independent body comprised of five experts, tasked with assessing horizontal consistency 
of the decisions and implementation of budgetary surveillance.

Reply of the Commission

106

IX (b) (ii)
The Commission accepts the recommendation. As per the Commission’s reply to paragraph VII, since the 2011 
reform of the legislation known as ‘the Six‑pack’, there has been a much greater operational focus upon debt levels. 
In effect, the breach of the debt threshold of 60% has been elevated to the trigger of the EDP. Concretely, the Com‑
mission has opened a debt‑based (and deficit‑based) EDP for Malta in 2013, which has successfully exited the proce‑
dure in 2015. At the same time, the concept of debt diminishing at a satisfactory pace was operationalised through 
the debt‑reduction benchmark and is now assessed as part of the Commission’s regular monitoring of Member 
States’ fiscal positions.

IX (b) (iii)
The Commission partially accepts the recommendation. As per reply to paragraph VII, the implementation of struc‑
tural reforms, including those undertaken under an Economic Partnership Programme (EPP), is monitored in the 
context of the European Semester, including under the Macroeconomic Imbalances Procedure. However, Article 9 
of Regulation (EU) No 473/2013 of 21 May 2013 does not foresee specific steps in cases where the implementation 
of structural reforms falls short of what is recommended in the analysis of the EPP. For countries subject to specific 
monitoring due to the presence of excessive imbalances, the implementation of reforms is monitored under the 
Excessive Imbalances Procedure. The Commission considers that it already operates to the full extent of the powers 
available to it under the legislation.

IX (b) (iv)
The Commission partially accepts the recommendation on its obligations relating to Member States’ reporting as 
the use of the infringement procedure should be assessed against the requirements of the EDP.

IX (b) (v)
The Commission does not accept the recommendation as the stepping‑up of the EDP and the imposition of sanc‑
tions are governed by clear legal rules and processes which the Commission is bound to follow. The Commission will 
continue to recommend the Council to impose sanctions where appropriate in line with the legislation.

Introduction

10
The description of Eurostat’s assessments is in fact more complex. Eurostat’s assessments also include other tools/
steps, such as internal consistency/plausibility checks (both within EDP data and between EDP and GFS data), 
checks of the quarterly data, etc.

16
The Council sets annual fiscal targets for multi‑annual EDPs, while the Commission may make recommendations 
in that regard. In terms of structural fiscal measures, the Six‑Pack and Two‑Pack include specific requirements on 
medium‑term fiscal planning. In particular, the Directive on Budgetary Frameworks (part of the Six‑Pack) lays out 
(in chapter V) requirements on Medium‑Term Budgetary Frameworks, including procedures for setting multi‑annual 
objectives for fiscal aggregates, medium‑term policy projections, and assessment of long‑term impacts, while 
ensuring consistency between annual budgets and multi‑annual figures. The Two‑Pack also calls for the presenta‑
tion of national medium‑term fiscal plans based on independent forecasts.

Reply of the Commission

107

20
The Commission notes that Member States have an obligation to report also on the measures planned and/or 
adopted and on developments in their fiscal and economic situation.

Observations

Reply to the heading above paragraph 32
The framework has undergone several changes in recent years with a view to improving the quality of the EDP data, 
introducing complementary rules, strengthening compliance mechanisms and raising national ownership. The 
budgetary surveillance system in the EU has become thus more complex. This complexity has arisen partly from 
a desire to better capture the economic reality.

The legislative changes introduced had to be technically operationalised. To this end, the methodologies and clas‑
sifications utilised in assessing compliance with the Stability and Growth Pact (SGP) had to be adapted. This process 
took place through extensive discussions in the Economic and Financial Committee (EFC) and other competent 
instances of the Council. These discussions were facilitated through a series of explanatory notes. The increased 
complexity of the surveillance framework called for additional explanation in a spirit of transparency.

Therefore, all the approaches to the implementation of the revised framework were summarised in the Vade Mecum 
on the Stability and Growth Pact, publicly available on the Commission’s website. The Vade Mecum will now be 
updated annually in line with a commitment in the Commission Communication of 21 October 2015 on Completing 
EMU.

In order to further increase transparency, since spring 2014 the Commission agreed to provide Member States with 
all the necessary information to replicate the underlying computations related to the compliance assessment with 
both the preventive and the corrective arm, including detailed excel spreadsheets providing step‑by‑step calcula‑
tions. Regarding discretionary measures, the Commission has made fully public aggregate data series on the impact 
of discretionary measures and the level of one‑offs since spring 2014 and, in line with the Ecofin Council Conclu‑
sions of June 2014, has made further progress by sharing with the Member States the yield of key individual tax 
measures incorporated in the bottom‑up approach for EDP countries as of spring 2015.

Furthermore, the Commission has made available detailed information on the main measures in the Staff Working 
Documents which accompany new EDP recommendations, including the forecast of key variables for the compu‑
tation of the fiscal effort under the baseline scenario (e.g. the point of reference to which future forecasts will be 
compared in order to compute both the top‑down and the bottom‑up approach).

Reply of the Commission

108

35
The Commission would like to point out that all relevant documents, including the Code of Conduct and the Vade 
mecum on the Stability and Growth Pact and the Code of Conduct, as well as other relevant explanatory documents 
on the functioning of the Stability and Growth Pact are available on the DG ECFIN website  http://ec.europa.eu/
economy_finance/economic_governance/sgp/legal_texts/index_en.htm.

41
The Commission points out that the process is already fully transparent vis‑a‑vis all concerned Member States. The 
Commission services provide the necessary details on forecasting assumptions.

42
While the documentation, notably including the country desks assumptions (to be distinguished from the common 
external assumptions mentioned above) is undoubtedly complex, it has significantly improved in recent years and 
complies with good practices.

45
The Commission underlines that the assumptions underlying the forecasts are described in the Position Paper that 
is produced at the beginning of each forecast round. The assumptions are then updated ahead of each subsequent 
forecast storage, and they are published in each forecast. Several meetings during the preparation of the Commis‑
sion’s regular forecasts bring together country desk officers, experts from horizontal units and top management. 
The discussion of the assumptions underlying the forecasts is a key part of these meetings.

48
Eurostat considers that the quality assessments are done in a consistent manner. The in‑house verification is under‑
pinned by ESA 2010 and the Manual on Government Deficit and Debt.

Moreover, the consistency of Eurostat’s assessments is ensured by explicit and highly centralised internal proce‑
dures. This includes procedures for analysing and deciding on methodological issues, including in‑house methodo‑
logical meetings, official advice, or findings from EDP visit.

Box 2 – First indent
The Commission is always and systematically basing its assessment on evidence. This can take various forms, like full 
documentation on the particular issue provided by Member States, discussions during the dialogue visits and fur‑
ther explanations in the regular and continuous exchanges with Member States. Moreover, major issues are docu‑
mented in the EDP Inventory. Overall, classification issues are clarified in comprehensive assessment process.

Box 2 – Fourth indent
Eurostat is not making systematic or detailed analysis of the bridge tables for the purpose of EDP. The bridge tables 
detail all GFS transactions reported in the ESA transmission programme and are generally not relevant for EDP data. 
Where it is important, Eurostat may look at a bridge table for clarification.

Reply of the Commission

109

49
The Commission does receive mandatory data, which it considers necessary for the purpose of its quality assess‑
ment. For technical reasons, data in EDP tables may not be fully complete, which is usually justified by the data 
sources and collection system in the specific country, described in the EDP inventory. For example, in the spring 
notification data on the year n‑1 is reported for the first time, but not all data sources might be available at that 
time, making estimates necessary.

50
The Commission consistently applies the rules and guidelines across Member States. The Commission underlines 
that the delimitation of general government is enshrined in the legal framework. ESA, underpinned by the MGDD, 
specifies the criteria for sector classification, including a very detailed decision tree (which is consistently applied).

In addition, for the purpose of checking the delimitation of general government, Eurostat has at its disposal the 
register of government entities, the EDP Inventory, the questionnaire on government controlled entities classified 
outside government (available since 2011) and documents on reclassifications requested before EDP visits.

Moreover, the issue of the delimitation of government is one of the central topics in each EDP visit and thus covered 
in the mission findings.

Finally, these records are up to date as all Member States are obliged to report on an annual basis the list of govern‑
ment controlled entities, including information on their NACE classification, liabilities and for the entities with larg‑
est debt the results of the latest market/non‑market tests.

Comments on Annex III are provided below.

51
The Commission does ensure that Member States apply ESA. To this end, and to ensure consistent treatment across 
cases and Member States as well as to close possible interpretation gaps, Eurostat has been providing guidance 
through the MGDD. The Commission would like to clarify that Eurostat and its Director‑General have sole responsi‑
bility for statistical decisions according to Regulation 223/2009.

Regarding the time spans used for analysing and classifying public units, the Commission considers differences not 
only as legitimate but necessary as they reflect different legal, administrative or business arrangements.

Reply of the Commission

110

Box 3 – First indent
When it comes to completeness of registers and the analysis of each single entity, Eurostat has exceptionally agreed 
that in Member States having thousands (or tens of thousands) of smaller entities at local government level, the 
market‑non‑market test can be done at group level. For large and complex units, a detailed analysis is conducted at 
unit level (and not on a group basis). Eurostat has also agreed on a prudent approach in another Member State. It is 
the most cost‑effective approach in a context of limited resources both in NSIs and in Eurostat.

Eurostat cannot check individually every single unit in Member States. Eurostat checks annually the information 
provided in the questionnaire of government controlled entities classified outside general government, and any 
other material at hand.

Furthermore Eurostat agrees on reclassifications in benchmark revisions provided that there is no or negligible 
impact on deficit and debt data.

Box 3 – Second indent
The Commission considers the ESA95 rules have been respected in the examples included.

Just to take the first example in this section (it applies to all examples, just for the sake of efficiency), it is said in 
Annex III:

‘one Member State classified the supervisory unit for financial markets, which is an institutional unit, within the 
general government sector. According to ESA 95, units of this kind should be classified outside the general govern‑
ment sector (namely, as financial auxiliaries within the financial corporations sector). Other Member States correctly 
classified these institutional units outside general government’.

However, supervisory units for financial markets can be classified in general government. In addition, it puts into 
question the methodological treatment agreed by experts in Member States and Eurostat.

Box 3 – Third indent
Eurostat recommends Member States to analyse and reclassify units every year. This is currently the case for all units 
having a debt larger than 0.01% of GDP and all Member States are moving towards a more frequent annual reclas‑
sification schedule also for smaller units.

The Commission collects annually the Questionnaire on Government Controlled entities and analyses it to check if 
all units continue to satisfy the 50% test.

Reply of the Commission

111

53
The Commission uses its risk analysis to select Member States and topics for its dialogue visits. High‑risk topics have 
always been included in the agenda for both Upstream Dialogue Visits (UDV) and Standard Dialogue Visits (SDVs) 
(either coming from the risk assessment or from other sources). Apart from the general high‑risk issues which are 
always part of the mission agendas, specific issues based on risks are also included. After UDVs were incorporated in 
SDVs, the results have been used to identify risky areas which were then addressed during a dialogue visit. Eurostat 
considers that it has addressed high risk issues in a visit (e.g. for Italy, the discussions on the recording of GFCF on 
a cash basis was the result of the risk assessment of 2012).

While in the past there was no justification for marking a change, in the form of a comment, this practice has already 
been changed and comments are now mandatory.

While the EDP risk assessment exercise is well documented, throughout the annual process, it has been voluntary to 
provide specific comments on each dimension of the risk assessment exercise. Eurostat agrees that changes in the 
risk level require more detailed reasoning and comments to be put in writing.

54
Eurostat considers that the duration of the visits is sufficient to adequately examine data quality issues. If needed, 
Eurostat has the possibility to prolong the visits or make follow‑up visits. The Commission considers the ‘number of 
topics’ is one criterion, but the complexity of an issue and/or the potential impact on EDP data are also important.

The Commission underlines that the dialogue visit is not a stand‑alone tool to examine data quality issues. The 
dialogue visit is rather intended to identify risks or potential problems about the quality of the reported data (Council 
Regulation 479/2009), whilst the data is assessed biannually in April and October. All dialogue visits are followed up 
and complemented by the regular assessment work and vice versa.

55
Institutional arrangements and supervisory and control systems have been part of both UDV and SDV agendas, and 
there is a section in all agendas for visits in order to deal with these issues. In addition, a dedicated questionnaire on 
these issues was launched in 2012. Finally, additional information on institutional arrangements is provided via the 
‘peer review’ exercise conducted on NSIs, the EDP inventories, and the memoranda of understanding signed by the 
national institutions on EDP.

The Commission agrees to analyse how this issue could be further documented in the future.

Reply of the Commission

112

56
It should be pointed out that this observation is calculated using the most extreme cases instead of averages, which 
would be more appropriate (Figure 6). Those ‘extremes’ have justification in most cases: for example in the case of 
Germany the 2013 EDP upstream dialogue visit to Germany comprised two meetings of Eurostat with the national 
authorities. After each meeting provisional findings and action points were drafted, however, the final joint report 
with the main conclusions and recommendations was prepared once the entire two‑part visit had been completed, 
i.e. following the second meeting. The same reasoning is valid for the Czech Republic: in 2012 the UDV was sent 
after 14 weeks but was only published after 25 weeks, together with the SDV findings.

Action points are agreed between Eurostat and the MSs in and after the dialogue visit, and they are transmitted to 
the Member State the week after the visit (so they are extremely punctual). Member States commit themselves by 
agreeing with Eurostat both on content and the deadline. Depending on the nature of the action and whether it has 
an impact on the deficit and debt data, deadlines are set and closely monitored before each EDP notification. The 
list of pending action points is revised at each visit. There are some action points which, because of institutional 
arrangements needed in the country or the need to implement new data collection systems, take more time to be 
implemented. In addition, action points are included in the reports of the visits, which are publicly available on the 
website of Eurostat.

Action points with impact on the reported deficit and debt data are taken into account in the quality assessment. 
Unresolved actions points on issues with a material impact on deficit and debt may also lead to a reservation.

57 (b)
Methodological issues are regularly discussed with Member States experts in the EDP statistics working group twice 
per year.

In addition, Eurostat has chaired in recent years a task‑force on the MGDD which meets two‑three times per year in 
order to agree on an updated version of the Manual.

58
Eurostat’s policy is to publish all advice given to Member States. However, in case a Member State objects to pub‑
lication due to confidentiality (for example, because it contains business‑sensitive information as guidance is very 
often on specific cases, or because the operation will not take place after the guidance), Eurostat accepts this.

Eurostat agrees with this observation and, in this context, it is prepared to discuss with Member States how to com‑
municate on advice given, without violating confidentiality. It has already started this process by including informa‑
tion on advice given in the latest report to the EFC.

Reply of the Commission

113

59
The ability to correctly identify ‘one‑off’’ measures, as defined in the Stability and Growth Pact, is crucial for car‑
rying out fiscal surveillance. Specific guidance, including an indicative and open list of ‘one‑off’ measures was 
developed in the wake of the 2005 reform of the Stability and Growth Pact, and published in the 2006 Report on 
Public Finance in the EMU (see Report on Public Finances in EMU 2006: ‘Definition and identification of one‑off and 
temporary measures’, Section II.4.2, available at: http://ec.europa.eu/economy_finance/publications/publication423_
en.pdf). The Commission has since been using this guidance as a point of reference for its surveillance activities. The 
2006 guidance has been recently extended with the establishing of ‘guiding principles’ and the update of the list of 
‘typical’ examples. This re‑vamped guidance has been published in the 2015 Report on Public Finances in the EMU: 
‘One‑off measures – classification principles used in fiscal surveillance’, Section II.3 (published in December 2015), avail‑
able at: http://ec.europa.eu/economy_finance/publications/eeip/pdf/ip014_en.pdf).

60
The definition of one‑off measures, as well as an indicative and open list of ‘typical’ cases has been published on 
the Report on Public Finances in EMU 2006: ‘Definition and identification of one‑off and temporary measures’, Part 
II, Section 4.2., available at: http://ec.europa.eu/economy_finance/publications/publication423_en.pdf.

The Commission points out that it has recently extended the guidance and published the classification principles 
used in the identification of ‘one‑off’ measures, as well as an indicative list of ‘standard’ cases in the Report on Pub‑
lic Finances in EMU 2015: ‘One‑off measures – classification principles used in fiscal surveillance’, Section II.3 (published 
in December 2015), available at: http://ec.europa.eu/economy_finance/publications/eeip/pdf/ip014_en.pdf).

It should be emphasised, however, that expert judgement is always required, as the characteristics of each individ‑
ual measure need to be examined carefully on the basis of the classification principles applied by the Commission.

Box 4
Following the list updated in December 2015 (subsequent to the Court’s audit) of ‘standard’ cases of ‘one‑off’ meas‑
ures, as published in the Report on Public Finances in EMU 2015: ‘One‑off measures – classification principles used in 
fiscal surveillance’, Section II.3, Box 4 does not reflect the current situation.

Deficit‑increasing measures
The Commission underlines that the budgetary costs of such exceptional events tend to be larger relative to the size 
of the economy in smaller countries.

Reply of the Commission

114

61
The Commission points out that in order to be able to better capture the economic reality, the commonly agreed 
rules of the SGP include provisions designed to respond to and accommodate unanticipated developments and 
unexpected events. Its operationalisation has been defined in the Note for the Alternates of the Economic and 
Financial Committee: ‘Improving the assessment of effective action in the context of the Excessive Deficit Procedure − 
a specification of the methodology’, of 12 June 2014.

62
The Commission recognizes that the concept of ‘unexpected adverse economic events’ has not been definitively set 
out in advance. However, the methodology for assessing effective action, as detailed in the note for the alternates 
of the Economic and Financial Committee: ‘Improving the assessment of effective action in the context of the Exces‑
sive Deficit Procedure − a specification of the methodology’, of 12 June 2014, made clear that lower growth than in 
the forecast underlying the EDP recommendation typically represents a case of an ‘unexpected adverse economic 
event’.

Therefore, the Commission does not agree with the Court’s observation in relation to France1.

The Council opened the EDP for France on 27 April 2009 with an initial deadline in 2012. This deadline was extended 
to 2013 on 2 December 2009 and to 2015 on 21 June 2013 based on the finding that effective action had been taken 
but that unexpected adverse economic events with major unfavourable consequences for government finances had 
occurred.

The Commission applied the existing legal framework, as explained in the recommendations of 2009, 2013 and 2015, 
and the accompanying SWDs.

Reply to the heading above paragraph 63
The Commission would like to stress that the basis for data quality assessment has greatly improved, given EDP data 
reporting by Member States has been greatly refined since 2005 and supplemented by detailed additional data.

While the Commission agrees that there was traditionally a greater focus upon the deficit than the debt in the 
implementation of the SGP, the Commission underlines that gross government debt and its sustainability have 
always been taken into account as a relevant factor in the Reports under Article 126(3).

Since the 2011 reform of the legislation known as ‘the Six‑pack’, there has been a much greater operational focus 
upon debt levels. The breach of the debt threshold of 60% of GDP has been elevated to the trigger of the EDP and. 
the concept of debt diminishing at a satisfactory pace was operationalised through the debt‑reduction benchmark 
and is now assessed as part of the Commission’s regular monitoring of Member States’ fiscal positions.

1  http://ec.europa.eu/economy_finance/economic_governance/sgp/deficit/countries/france_en.htm

Reply of the Commission

115

64
Council Regulation 479/2009 provides the general framework for expressing reservations on the quality of the 
actual data and amending the actual data reported by Member States. According to this regulation, Eurostat may 
use such powers if there is evidence that the data reported by Member States do not comply with the accounting 
rules and, in particular, with the EDP methodology.

Reservations are expressed by Eurostat only in exceptional cases and are justified only under certain conditions. 
Eurostat uses its professional judgement on this. However, the lack of a specific reservation or amendment does 
not mean that there are no on‑going issues to be resolved with the Member State, but that Eurostat considers these 
issues to have no significant impact on Maastricht deficit and debt. The alternative would be to place reservations 
on all countries in every notification exercise, which would be disproportionate and would not serve the purpose of 
reservations.

In addition, it often happens that Member States adapt their data following questions raised by Eurostat during the 
clarification period. Such adaptations are not visible in the final press release as no reservation or amendment by 
Eurostat has been made.

65
Eurostat has a procedure specifying the steps, timetable and role of each actor during the analysis of the notifica‑
tions prior to the press release. This procedure includes regular meetings with senior management and with the 
Director General, acting as the Chief Statistician of the European Union.

Reservations or amendments to the data are based on professional judgment, on the basis of the qualitative and 
quantitative information available before and during the clarification process, and they are reflected upon very 
carefully, as mentioned above. This process is done on a statistical basis only, using the statistical authority provided 
to Eurostat for this purpose and without any interference from other Commission services or from any other exter‑
nal body.

Subsequent revisions to the data have proved, as a matter of principle, that Eurostat’s approach for reservations is 
efficient and effective: ‘no big surprises’, i.e. when an issue was known but Eurostat decided that putting a reserva‑
tion was not warranted, no significant revisions to deficit or debt data were necessary.

Box 5
Czech Republic – First indent
Since 2010 the market/non‑market test is carried out each year for public non‑financial corporations and also for 
non‑profit institutions classified in S.15. The results of the test are presented to Eurostat in the Questionnaire on 
government controlled entities classified outside general government or in a list of government units which is 
requested before the EDP dialogue visit.

Reply of the Commission

116

France – First indent
The treatment of decommissioning of nuclear facilities and possible related lump sum payments is still under 
discussion (even under ESA 2010). Until an agreement is reached, there is currently no specific guidance for the 
treatment of nuclear decommissioning and related lump sum payments.

France – Second indent
Due to the very high number of government units in France (more than 80,000 units in S.13 and more than 8000 
government controlled entities classified outside government), Eurostat has agreed with the grouping of units at 
local government level.

Eurostat cannot set reservations on an issue for which there are no rules in the ESA or MGDD.

Germany – First indent
No major, regular reclassifications of units with material impacts on government deficit and debt ratios (i.e. at 
close to or over 0.1% of GDP), occurred in the years 2011‑2013. Hence, the size of related revisions would not have 
impacted on government deficit and debt ratios compiled for the purpose of the fiscal surveillance.

For all reclassifications undertaken in the context of: 1) one‑off methodological revisions, 2) the 2011 benchmark 
revision of the German national accounts and 3) changeover to the ESA 2010, for which impacts on government 
deficit and debt figures were substantial (at close to or over 0.1% of GDP) the data for the whole of the EDP refer‑
ence period was properly revised.

Germany – Second indent
The matter in question constitutes a risk to the data quality and, as provided for under Council Regulation 479/2009, 
once it had been identified it was addressed by Eurostat, taking stepwise approach given the complexity of the Ger‑
man statistical system and size of the German general government sector.

The Commission is not aware that the risk in question has materialised. No related quality problems have been iden‑
tified by Eurostat on the basis of the data assessment.

Within the complex statistical system in Germany, legal mandate underpinning the regular collection of statistical 
data collection, and limited resources, the process of implementation of relevant procedures for outstanding – small 
in terms of size – individual operations at state and local level requires a structural solution.

Given the size of the transactions and the fact that no conclusions about the outcome of the analysis can be drawn 
at this stage, the Commission does not consider that a reservation on these grounds should have been put on the 
German deficit data.

Malta – First indent
The novation agreement to transfer the legal ownership of the project to Malita was signed on 28 December 2011 
(amended in February 2012) and thus after the October 2011 EDP notification. Likewise, the leasing arrangements 
were signed on 26 June 2012, also well after the October 2011 EDP Notification.

In the April 2012 EDP notification, the Maltese National Statistical Office had correctly treated all relevant points. 
In its letter of August 2012, Eurostat confirmed after thorough analysis that Malita should be classified within the 
non‑financial corporations sector.

Therefore the Commission considers that no reservation was necessary.

Reply of the Commission

117

Italy – First indent
The Commission (Eurostat) has been following progress on this issue closely. A step by step approach, including set‑
ting up of new data sources and making estimates, has been implemented by Italy.

Box 6
The Court refers to the basic macroeconomic assumptions underlying the deficit and debt thresholds stipulated in 
the Treaty. While the macroeconomic environment is subject to change, the Commission remains obliged to operate 
as per the provisions of the Treaty and the secondary legislation which supports it.

The overall fiscal framework has evolved significantly, not least due to the reforms introduced through the Six‑pack 
and the Two‑pack in recent years, with the goal of delivering ‘smart rules’ that allow to react to and accommodate 
better the prevailing economic realities.

While there was traditionally a greater focus upon the deficit than the debt in the implementation of the SGP, the 
Commission underlines that the framework has consistently addressed the issue of debt. In particular, it should 
be recalled that the component of the Medium‑Term Budgetary Objective related to implicit liabilities and debt 
(MTOILD) has a built‑in element representing the budgetary balance that would stabilise the debt ratio at 60% of GDP 
and a complementary component representing the additional budgetary balance necessary for countries with debt 
exceeding 60% of GDP.

Since the 2011 reform of the legislation known as ‘the Six‑pack’, there has been a much greater operational focus 
upon debt levels. The breach of the debt threshold of 60% of GDP has been elevated to the trigger of the EDP and 
the concept of debt diminishing at a satisfactory pace was operationalised through the debt‑reduction benchmark 
and is now assessed as part of the Commission’s regular monitoring of Member States’ fiscal positions.

70
The Commission points out that the initial level of debt enters into the definition of the debt‑reduction benchmark 
through the differential to the 60% threshold.

For Member States with debt above 60% of GDP, the recommended adjustment path has to take into account the 
need for the debt to comply at least with the forward‑looking debt benchmark at the end of the correction period. 
As a result, the level of the deficit recommended for the final year may be below 3% of GDP and, in case of heavily 
indebted Member States, the deadline for correction may be longer as the magnitude of the structural adjustment 
to be delivered needs to be weighed against its feasibility under a certain number of years.

The fact that, in order to meet the debt benchmark, the public deficit must be brought below 3% of GDP has been 
reflected in the EDP recommendations issued so far based on breach of the debt criterion.

71
The Commission notes that the projections quoted are on an unchanged‑policy basis. Assuming a scenario where 
Member States fully respect their obligations under SGP would give more positive results.

Specifically under a scenario of full compliance with the SGP, Italy would respect the debt reduction benchmark 
(forward looking variant) by 2019 and France by 2018. The IMF data used for Cyprus present a significant discrep‑
ancy with those used by the Commission.

Reply of the Commission

118

72
The analysis of relevant factors is conducted in line with the requirements of the Council Regulation (EC) No 1467/97.

The legislation indeed provides a broad list of possible relevant factors which is not exhaustive, since it requires the 
Commission to also consider factors deemed relevant by the Member State concerned.

The Commission specifies and to the extent possible quantifies the effect of the different relevant factors. There is 
no formula weighting all the different factors which leads to an automatic conclusion. The Commission publishes its 
detailed analysis in the Staff Working Documents.

73
The Commission does not agree with the assertion that the reasoning behind its conclusions is unclear. The analy‑
sis of relevant factors is provided for in the legislation (Council Regulation (EC) No 1467/97) according to which the 
Commission shall take into account all relevant factors in so far as they significantly affect the assessment of compli‑
ance with the deficit and debt criteria. Moreover, the legislation requires the Commission to also consider factors 
deemed relevant by the Member State concerned. This is done in order to ensure an appropriate economic assess‑
ment of the situation before deciding on the opening of an EDP.

In case of a breach of the deficit criterion, the legislation provides a broad list of possible relevant factors, which 
however is not exhaustive, nor makes reference to any kind of prioritisation. If the general government debt is 
above 60% of GDP, the relevant factors will only be considered in the decision regarding whether to launch an EDP 
if the deficit remains close to the reference value and the breach is judged to be temporary.

In case of a breach of the debt criteria, all relevant factors can be taken into account irrespective of the level of the 
deficit.

In line with the provisions described above, when preparing a report under Article 126 (3), the Commission specifies 
and to the extent possible estimates the effect of the different relevant factors.

In this respect, the Commission points out that in the reports under Article 126(3) that have been issued on Italy, 
Belgium (February 2015) and Finland (February, May and November 2015) significant efforts have been put in place 
to make the analysis of the relevant factors much more extensive and transparent than in the past.

At the same time, and in line with the spirit of the legislation, there is no formula weighting all the different factors 
leading to an automatic conclusion.

74
The Commission endeavours to work closely with Member States in the ongoing process of the implementation of 
the Stability and Growth Pact, including the EDP. A crucial element of this cooperative approach is the interaction 
and discussion facilitated through the relevant economic committees, in particular, the Economic and Financial 
Committee Alternates (EFC‑A). The Commission regularly prepares analytical and operational notes for the EFC‑A in 
order to explain to Member States the approach it is taking to interpreting and implementing the SGP and obtain 
their input on the Commission’s rationale.

Reply of the Commission

119

In order to increase transparency, since spring 2014 the Commission has provided Member States with all the nec‑
essary information for them to fully replicate the computation of the effective action assessment thus including 
detailed excel spreadsheets providing step‑by‑step calculations of both the top‑down and bottom‑up approach. 
Beside this, all of the data and computations on compliance with the debt‑reduction benchmark and the MLSA are 
provided to Member States. However, based on a specific request from the Member States, data are not fully public, 
but shared via a common platform named CIRCA, to which only the members of the EFC and their alternates are 
granted access.

75
The Commission acknowledges that the staff working documents published before February 2015 could have been 
more transparent regarding the data included in the baseline scenario underlying the EDP recommendations. How‑
ever, the Commission points out that such information was available from spring 2014 in the detailed excel spread‑
sheet providing step‑by‑step calculation of the Commission’s compliance assessment and circulated to Member 
States through the CIRCA platform. As a consequence, Member States enjoyed full access to the set of data needed 
to replicate the calculations of the fiscal efforts and the other variables underlying the assessment of compliance 
with the EDP recommendation as in the case of France in February 2015. Moreover, starting in February 2015, the 
relevant information is provided in the forecast files published in the public version of AMECO database and accessi‑
ble to the general public.

The information contained in these files is sufficient to replicate the calculation of the bottom‑up effort as com‑
puted by the Commission. It notably includes the total amount of discretionary measures on the revenue side 
(including and excluding one‑offs), expenditure developments, interest rates developments and unemployment 
figures. These are the only metrics needed to compute the baseline scenario. In addition, the staff working docu‑
ment clearly explains how the baseline scenario is built.

76
The Commission points out that in case of a breach of the debt criteria, the Regulation stipulates that all relevant 
factors shall be taken into account irrespective of the level of the deficit.

Box 7 (i)
The Commission considers that the cyclically adjusted debt‑reduction benchmark does not fully capture the impact 
of very low inflation over extended periods. While the cyclically adjusted debt level is developed with the aim of 
excluding the influence of the economic cycle on the assessment on compliance with the debt rule, it is worth 
emphasizing that the adjustment only corrects for the difference in the potential and the actual GDP growth rate 
over three years. Therefore, the protracted subdued nominal GDP growth experienced by several Member States 
in the last couple of years can still impact the compliance with the debt rule even when assessed on the basis of 
the cyclically adjusted debt level. In addition, the debt benchmark does not control for the evolution of prices. The 
cyclically adjusted debt level uses the outturn GDP deflator, i.e. there is no correction for unexpectedly low infla‑
tion. However, for several countries the unexpected lowering of inflation has led to a significant increase in the 
real financing costs on debt. The increase in difference in the real financing cost and the real GDP growth rate had 
a substantial negative impact on the debt dynamics for several countries.

Reply of the Commission

120

Box 7 (ii)
Regarding Italy’s compliance with the debt‑reduction benchmark, the Commission underlines that it could not yet 
carry out an assessment regarding 2016 when the 126(3) report was produced in early 2015.

Before an assessment for the next year can be made, a legally valid Council requirement has to be set. Coun‑
cil recommendations are given in spring. For Member States in the preventive arm of the SGP, such require‑
ments are set on the basis of the cyclical position of the economy of the Member State concerned (as measured 
by the output gap) and its sustainability risks (details are found in the Commission Communication on Flex‑
ibility of January 2015 which is available at http://ec.europa.eu/economy_finance/economic_governance/sgp/
pdf/2015‑01‑13_communication_sgp_flexibility_guidelines_en.pdf

The first assessment of compliance for 2016 was done in spring 2015 and pointed to broad compliance with the 
requirements. Details can be found in the relevant SWDs available at http://ec.europa.eu/economy_finance/
economic_governance/sgp/deficit/countries/italy_en.htm.

Box 7 (iii)
The Commission underlines that a methodological framework for assessing the impact of structural reforms upon 
fiscal sustainability was outlined in a note provided to Member States through the EFC‑A in February 2015. In the 
assessment of Italy’s Stability Programme, carried out in May 2015, the Commission stated that it had carried out an 
assessment of the potential impact on public finance sustainability of the structural reforms plan put forward by the 
authorities and that given the methods used to simulate their effects (in particular QUEST) the quantified impact of 
the reforms was assessed by the Commission to be plausible.

78
The Commission acted in full compliance with the rules. The obligation (rather than possibility) of taking into 
account relevant factors is explicit in the Regulation, which refers to the non‑exhaustive lists of factors to be consid‑
ered. Among these, the adjustment toward the MTO, the implementation of policies to prevent and correct imbal‑
ances and the implementation of policies in the context of the common growth strategy of the Union are explicitly 
mentioned.

The debt rule does not automatically imply that a Member State is put in EDP once the quantified target is missed. 
This non‑automaticity is explicitly foreseen in the Regulation.

80
The Commission considers that the measure concerned should not be classified as a one‑off in line with the guid‑
ing principles updated in the 2015 Report on Public Finances in EMU in order to ensure their consistent application. 
According to this guidance, the surcharge was, intrinsically, of neither a temporary nor non‑recurrent nature − it 
was expected to have a durable impact (from 2012 to 2017) − and, as a result, could not have been classified as 
a one‑off. The 2015 Report on Public Finances is available at: http://ec.europa.eu/economy_finance/publications/
european_economy/public_finances_emu_en.htm

Reply of the Commission

121

81
On 10 March 2015, the Council considered that the available evidence did not allow concluding on no effective 
action as the cumulated fiscal effort was found to be in line with the level required by the Council (based on the 
bottom‑up methodology, the top down being impacted by low inflation) and that an extension of the correction 
deadline was therefore warranted. Moreover, the outturn data (and also the Commission 2015 spring forecast on the 
headline balance for 2015) was better than expected by the Commission in March 2015.

82
The Commission does not agree with this observation as according to the information available at the time of the 
assessment, a timely correction by 2015 appeared no longer within reach. In such circumstances, it is appropriate 
within the legal framework of the SGP: (i) to investigate the causes for this, which resulted in the finding that ‘overall 
the available evidence does not allow concluding that the recommended effort has not been delivered in 2013 – 
2014’, and (ii) to provide a new, valid adjustment path in order to provide adequate policy guidance to the country 
concerned.

83
The Commission recalls its obligation under the Regulation to take account of the relevant factors. The legislation 
sets out a non‑exhaustive lists of factors to be considered. Among these, the adjustment towards the MTO, the 
implementation of policies to prevent and correct imbalances and the implementation of policies in the context of 
the common growth strategy of the Union are explicitly mentioned.

For the reasoning applied in the specific cases, the relevant documents are available at http://ec.europa.eu/
economy_finance/economic_governance/sgp/deficit/countries/france_en.htm and http://ec.europa.eu/economy_
finance/economic_governance/sgp/deficit/countries/italy_en.htm for France and Italy respectively.

84
The Commission underlines that according to the legal framework, the Council is the decision‑making institution. 
Therefore, it has the right to overrule the Commission’s EDP recommendation and it is not liable to the Commission.

Member States’ reporting on corrective action could be improved
The Commission considers that the existing provisions and/or guidelines on the content of fiscal surveillance docu‑
ments, including on reporting on EDP corrective action, provide a solid basis for the Commission to pursue effective 
fiscal surveillance and monitoring if adequately followed by the Member States. The Commission therefore does 
not see any specific need to change existing legislation in order to impose stronger reporting obligations on the 
Member States.

Reply of the Commission

122

85
To enforce compliance with reporting requirements, the possibility for sanctions under the EDP is limited to 
non‑compliance with the EDP budgetary targets. However, a lack of adequate reporting can be to the disadvantage 
of the concerned Member State as a lack of sufficiently detailed information made available to the Commission on 
action taken and budgetary developments could potentially lead to the stepping up of the EDP if this leads to the 
conclusion that the EDP targets are not met.

In any event, the Commission engages in continuous monitoring of Member States’ fiscal positions through the rele‑
vant country‑desks, which engage in regular surveillance missions to the Member States. In relation to more regular 
reporting, such as that introduced under the Six‑pack and Two‑pack through the stability programmes in the spring 
and draft budgetary plans in the autumn, there are detailed requirements set out regarding what a Member State is 
obliged to report. According to Article 7(2) of Regulation 473/2013, in the case where the Commission is not satisfied 
that a Member State’s DBP adequately demonstrates its fiscal plans to be in compliance with its requirement, the 
Commission may request that the Member State concerned re‑submit its DBP. However, where the Member State 
does not comply with the more general reporting requirements, it is true that the Commission’s options for enforce‑
ment are limited, in particular concerning the stability programmes.

86
Fiscal surveillance documents (such as the Stability and Convergence Programmes or the Draft Budgetary Plans) 
including those reporting on compliance with the Council recommendations (reports on action taken), may some‑
times lack concrete information on corrective measures, notably for the outer years. This is reflected in the Commis‑
sion forecasts, which form the basis of the risk assessments of the Member States’ plans. Indeed, in cases where the 
corrective measures are considered to be insufficiently specified, they are not taken into account in the forecast. 
Furthermore, if the lack of concrete information weights on the balance of risks, risks are always clearly mentioned 
in the Commission assessments.

Box 8 – First indent
The list of measures with fiscal impact is part of the convergence programme and not primarily the national reform 
programme.

Box 8 – Second indent
The Commission highlights the fact that convergence programme 2012 presents the impact of measures in three 
separate tables – one from the perspective of direct tax reform (revenue side measures), the second providing 
a detailed breakdown of planned consolidation measures with an impact on the deficit and the third summariz‑
ing smaller changes valid since 2012 (only expenditure side). Although not every single measure is described in the 
accompanying text, the titles are sufficiently detailed and understandable.

Reply of the Commission

123

Reply to the heading above paragraph 88
The Commission does not agree that its monitoring and surveillance lack transparency. The EU fiscal framework has 
undergone several changes in recent years with a view to introducing complementary rules, strengthening compli‑
ance mechanisms and raising national ownership. The Commission considers this a welcome development.

The legislative changes introduced had to be technically operationalised. To this end, the methodologies and clas‑
sifications utilised in assessing compliance with the Stability and Growth Pact (SGP) had to be adapted. This process 
took place through extensive discussions in the Economic and Financial Committee (EFC) and other competent 
instances of the Council. These discussions were facilitated through a series of explanatory notes. The increased 
complexity of the surveillance framework called for additional explanation in a spirit of transparency.

Therefore, all the approaches to the implementation of the revised framework were summarised in the Vade Mecum 
on the Stability and Growth Pact, publicly available on the Commission’s website. The Vade Mecum will now be 
updated annually in line with a commitment in the Commission Communication of 21 October 2015 on Completing 
EMU.

In order to further increase transparency, since spring 2014 the Commission agreed to provide Member States with 
all the necessary information to replicate the underlying computations related to the compliance assessment under 
both the preventive and the corrective arm, including detailed excel spreadsheets providing step‑by‑step calcula‑
tions. Regarding discretionary measures, the Commission has made fully public aggregate data series on the impact 
of discretionary measures and the level of one‑offs since spring 2014 and, in line with the Ecofin Council Conclu‑
sions of June 2014, has made further progress by sharing with the Member States the yield of key individual tax 
measures incorporated in the bottom‑up approach for EDP countries as of spring 2015.

Furthermore, the Commission has made available detailed information on the main measures in the Staff Working 
Documents which accompany new EDP recommendations, including the forecast of key variables for the compu‑
tation of the fiscal effort under the baseline scenario (e.g. the point of reference to which future forecasts will be 
compared in order to compute both the top‑down and the bottom‑up approach).

The methodological framework for assessing the impact of structural reforms upon fiscal sustainability was outlined 
in a note provided to Member States through the EFC‑A in February 2015.

89 (ii)
The Commission would like to clarify in relation to the Court’s observation 89 (ii) that the effective action meth‑
odology, which was endorsed by the Council in 2014, is wider‑ranging than just the bottom‑up methodology, also 
incorporating a top‑down approach to assessing effective action. The methodology is explained in Part II.1 of the 
Public Finance Report 2014.

Reply of the Commission

124

90
The compliance with EDP recommendations is ultimately checked using actual data, verified by Eurostat, rather 
than the Commission’s forecasts. Moreover, an assessment of effective action, known as a careful analysis, is con‑
ducted if the Member State fails to meet either its headline deficit targets or required improvement in the structural 
balance.

Box 9 – Sixth indent
The Commission broadly agrees that the assessment of effective action has become increasingly complex. It takes 
better account of more complex economic situations as well as adding new surveillance elements, ensuring equality 
of treatment across countries and time required transparent operationalisation of the rules (see Commission’s reply 
to paragraph 89).

91
The top‑down and bottom‑up approaches are the reflection of the need to better capture prevailing economic situ‑
ations. The note reviewing the methodology on the effective action assessment, including the operationalization of 
the bottom‑up approach (Review of the methodology for assessing effective action) was first discussed on 26 Feb‑
ruary 2014 at the EFC‑A, approved by the EFC on 12 June 2014 and endorsed by the Ecofin Council on 20 June 2014.

The Commission recognises that there is a natural trade‑off between defining the approach taken as much as possi‑
ble in terms of capturing the underlying macroeconomic situation and developments, and the degree of complexity 
of the system of rules.

In order to increase transparency, the Commission agreed to provide Member States with all the necessary informa‑
tion for them to replicate the computation of the effective action assessment including detailed excel spreadsheets 
providing step‑by‑step calculations of both the top‑down and bottom‑up approach. However, following a specific 
request from the Member States, these data are not fully public, but shared via a common platform named CIRCA, 
to which only the members of the EFC and their alternates in the Ministries are granted access.

92
The assessment of the fiscal effort is centred around the structural balance since the 2005 reforms of the SGP, which 
sought to better take account of the effect of the economic cycle on Member States’ fiscal positions. It is true that 
the structural balance is intrinsically linked to estimates of potential growth, which is an unobservable variable. This 
reflects the limits of macroeconomics and cannot be escaped as long as the structural balance remains a key ele‑
ment of fiscal measurement as mandated by the Regulation.

A detailed common approach to estimating potential output is agreed with Member States through the long‑stand‑
ing Output Gap Working Group and endorsed by the Council.

Reply of the Commission

125

94
The Code of Conduct suggests that a ‘bottom‑up’ estimation of the fiscal effort (that is, one that typically focuses 
on the estimated budgetary impact of discretionary fiscal measures) should complement the estimation of the fiscal 
effort yielded by the change in the structural balance (or ‘top‑down’ approach). The note reviewing the methodol‑
ogy on the effective action assessment, including the operationalization of the bottom‑up approach (Review of the 
methodology for assessing effective action) was first discussed on 26 February 2014 at the EFC‑A, approved by the 
EFC on 12 June 2014 and endorsed by the Ecofin Council on 20 June 2014.

This methodology builds on the estimated budgetary impact of discretionary measures on the revenue side and 
takes into account both explicit and implicit measures on the expenditure side.

In terms of discretionary measures, the Commission has ensured a concrete follow‑up to its transparency commit‑
ments by (i) making available for each country the impact of discretionary measures (current/capital revenue as well 
as current/capital expenditure) and the level of one‑offs in the AMECO database online (i.e. the fully public Commis‑
sion database) since spring 2014 ii) sharing with the Member States through the CIRCA platform, the main discre‑
tionary tax measures incorporated in the bottom‑up approach for EDP countries as of spring 2015.

Furthermore, the Commission has made available detailed information on the main measures in the Staff Working 
Documents which accompany new EDP recommendations, including the forecast of key variables for the compu‑
tation of the fiscal effort under the baseline scenario (e.g. the point of reference to which future forecasts will be 
compared in order to compute both the top‑down and the bottom‑up approach).

95
The Commission does not agree that its analysis have become less transparent.

The EU fiscal framework has undergone several changes in recent years with a view to introducing complementary 
rules, strengthening compliance mechanisms and raising national ownership. The rule were also made more apt to 
deal with differing economic conditions.

The legislative changes had to be technically operationalised. To this end, the methodologies and classifications 
utilised in assessing compliance with the Stability and Growth Pact (SGP) had to be adapted. This process took place 
through extensive discussions in the Economic and Financial Committee (EFC) and other competent instances of the 
Council. These discussions were facilitated through a series of explanatory notes. The increased complexity of the 
surveillance framework called for additional explanation in a spirit of transparency.

Therefore, all the approaches to the implementation of the revised framework were summarised in the Vade Mecum 
on the Stability and Growth Pact, publicly available on the Commission’s website. The Vade Mecum will now be 
updated annually in line with a commitment in the Commission Communication of 21 October 2015 on Completing 
EMU (see Commission’s replies to paragraphs 88‑94).

Reply of the Commission

126

96
In relation to the top‑down approach, while the necessary data to replicate the Commission’s calculations were not 
systematically available outside the Commission until 2014, the Commission has made significant efforts to correct 
this and now aims at insuring full transparency by giving access to all relevant data to the Member States. To that 
end, the Commission has made available detailed information on the main measures in the Staff Working Docu‑
ments which accompany new EDP recommendations, including the forecast of key variables for the computation of 
the fiscal effort under the baseline scenario (e.g. the point of reference to which future forecasts will be compared 
in order to compute both the top‑down and the bottom‑up approach). Furthermore, after each forecast round (as of 
the Commission 2014 spring forecast) the Commission provides Member States with an excel spreadsheet tool with 
all the relevant input data in order that they can exactly replicate the Commission’s calculations.

97
The Commission would like to clarify that a bottom‑up quantification of the measures as part of the careful analysis 
that needs to be undertaken in cases of a shortfall from the recommended budgetary targets, was first proposed in 
a Commission note on the ‘Assessment of effective action’ to the Alternates of the Economic and Financial Commit‑
tee (the relevant instance of the Council) in December 2012 and since then carried out as a complementary indica‑
tor of the fiscal effort in the careful analysis, notably in the Staff Working Documents accompanying EDP recom‑
mendations or in the budgetary surveillance notes regularly discussed with the Member States. In the attempt of 
providing greater transparency on the methodologies used to assessing compliance with EDP recommendations, 
a note reviewing the methodology and detailing the bottom‑up operationalisation (Review of the methodology for 
assessing effective action) was first presented on 26 February 2014 at the EFC‑A. The Economic and Financial Com ‑
mittee (EFC, the Parent Committee) approved the note on 12 June 2014, which was endorsed by the Ecofin Council 
on 20 June 2014.

The Commission found that structural fiscal targets were expected to be met by France, according to the com‑
monly–agreed methodology and decided to put the procedure in abeyance. The reasoning is detailed in the 
Commission SWD available at http://ec.europa.eu/economy_finance/economic_governance/sgp/pdf/30_edps/
communication_to_the_council/2015‑07‑01_fr_communication_swd_en.pdf

98
The Commission agreed to provide Member States with all the necessary information for them to replicate the 
computation of the effective action assessment thus including detailed excel spreadsheets providing step‑by‑step 
calculations of both the top‑down and bottom‑up approach. However, according to a specific request from the 
Member States, data are not fully public, but shared via a common platform named CIRCA, to which only the mem‑
bers of the EFC and their alternates in the Ministries are granted access.

Reply of the Commission

127

99
The ex‑post assessment of the impact of individual measures may not yield conclusive results. Indeed, such an 
impact can be difficult to calculate due to problems in isolating the effect of the measure from wider drivers of the 
changes in revenue and expenditure, such as the economic environment, as against the no‑policy change trend 
that would have prevailed. Generally, the effectiveness of discretionary budgetary measures ex‑post is essentially 
reflected in the budget execution and in the fulfilment (or not) of the budgetary targets that have been set. The 
Commission assesses whether the Member State has taken sufficient policy measures to meet the recommended 
budgetary targets based on two complementary tools e.g. the top‑down and the bottom‑up approach for the 
assessment of effective action.

The Commission (and Member States) also monitor the yield of individual discretionary fiscal measures. Aggregate 
series are available in the AMECO database. Yields are estimated ex ante and revised as needed during implementa‑
tion (e.g. in case the design of the measures is amended, if these are only partially implemented, if there is ground 
for the revision of the underlying assumptions, inter alia).

100 (i)
In the case of Malta, the report on action taken was submitted on 1 October 2013 (3 months after the Council rec‑
ommendation of 21 June 2013). It specified the measures for 2013 while for 2014 it remained vague. In particular, the 
report announced expansionary measures on the expenditure side compensated by increases in indirect taxation 
and restrictions to recruitment, but for all the details it just referred to the forthcoming budget.

The lack of details was a consequence of the fact that in Malta the budgetary process was not aligned with the 
European calendar. In particular, it was not possible for the Maltese authorities to reveal the budget measures in 
both the report on action taken and the draft budgetary plan which, therefore, did not provide sufficient details 
on the discretionary measures underpinning the budgetary targets. All the necessary details were made available 
only after the presentation of the 2014 budget (that was presented to Parliament on 4 November 2013 and adopted 
on 21 November 2013). The Commission’s assessment, which was based on the Autumn forecast published on 5 
November did not incorporate the measures announced for 2014. These measures were finally included in the fol‑
lowing Winter forecast.

100 (ii)
The report on action taken submitted by France in October 2013 was indeed merged with the ‘Rapport économ‑
ique social et financier’ (RESF) which routinely provides an assessment on public finances as part of the prepara‑
tion of the draft budget. In its analysis of the draft budgetary plan, the Commission considered that the document 
did not breach the formal reporting requirements but rather that, at that stage, the measures outlined were con‑
sidered insufficient to bring the deficit to 3%. Being a case of a multi‑annual correction, the assessment focused 
on 2013 and 2014, as required in the code of conduct. However, risks associated to the lack of information for the 
later years were duly flagged in the accompanying Staff Working Document available at: http://ec.europa.eu/
economy_finance/economic_governance/sgp/pdf/dbp/fr_2013‑11‑15_swd_en.pdf

The Commission reassessed again the situation in Malta in the following Winter forecast published in February 2014. 
According to this new deficit forecast, which incorporated the measures announced with the 2014 budget, the EDP 
requirements for 2014 were fulfilled in nominal terms.

Reply of the Commission

128

101
The Commission does not agree with this observation as the assessment of action taken is at the same time back‑
ward and forward‑looking, insofar as it involves an analysis of compliance with EDP targets for the past years (based 
on outturns) current and future years (based on forecast), notably through the assessment of the adequacy and 
credibility of the measures envisaged by the Member State in question to achieve future EDP targets. This is the 
approach generally followed in all related Commission documents such as the Communication on action taken, the 
SWD accompanying the assessment of the SCP or the Commission opinion on the DBP, including in the ‘Implica‑
tions of the Commission forecast for budgetary surveillance’ notes that regularly provide an overview of compliance 
with the SGP requirements for all MS after each forecast round and are discussed with the relevant instance in the 
Council.

However, as procedural EDP steps in case of non‑effective action in response to the Council recommendation have 
to be based on a solid set of evidence, they have largely been taken based on observed data. The Commission con‑
siders that the initial assessment of compliance following the report on action taken quoted in the Vademecum has 
a preliminary character reflecting government announcements, as also explained in the Code of Conduct.

Moreover, the Commission would like to recall that, following the entry into force of the Six‑Pack, compliance with 
the preventive and corrective arms of the Stability and Growth Pact is now subject to continuous monitoring. The 
Commission forecasts, which are issued three times a year – winter, spring and autumn – constitute the key mile ‑
stones for these regular fiscal assessments, including the assessment of effective action for Member States whose 
EDP is in abeyance. Should the Commission assessment conclude on non‑compliance with the EDP recommenda‑
tions this would lead to a stepping up of the EDP. Therefore, the implications from too relaxed targets for first year 
are not material to the assessment of effective action.

102
The 2 June 2014 Commission recommendation for a Council recommendation on the national reform programme 
and the stability programme included the recommendation to ‘reinforce the budgetary strategy, including by 
further specifying the underlying measures, for the year 2014 and beyond to ensure the correction of the excessive 
deficit in a sustainable manner by 2015 through achieving the structural adjustment effort specified in the Council 
recommendation under the EDP’. Moreover, the Commission adopted its opinion on the Draft Budgetary Plan and 
published on 28 November 2014 a staff working document. Overall, the position of the Commission, based on its 
forecast, was that France was at risk of non‑compliance with the provisions of the Stability and Growth Pact as the 
headline deficit and the adjustment in the structural balance were projected to fall short of the 2013 recommenda‑
tion. The Commission invited the authorities to take the necessary measures within the national budgetary process 
in order that the 2015 budget will be compliant with the Stability and Growth Pact.

106
When recommendations were phrased in terms of average annual figures, the Commission noted that it fre‑
quently resulted in a lack of effective action in early years, not giving rise to stepping‑up of the EDP. This is why 
the Commission decided to revise its practice regarding how to draft EDP recommendations and this explains why, 
starting from 2011, all the new article 126 (7) recommendations have annual nominal and structural targets over 
a multi‑annual period.

Reply of the Commission

129

Common Commission reply to paragraphs 108 and 109
The Commission would like to clarify the role of structural reforms under an EDP.

The Commission highlighted that the implementation of growth‑enhancing structural reforms that can ultimately 
improve the long‑term sustainability of public finances, as a relevant factor to be considered when deciding 
whether to open or extend an EDP. In this regard, it should be noted that the Commission is obliged under Article 2 
of Regulation 1467/97 to take account of such relevant factors in making its recommendations. However, in terms of 
enforcement, the focus of the legislation which governs the EDP is the fiscal outcome and, as such, the relevant leg‑
islation does not contain specific provision to enforce the implementation of structural reforms. Indeed, it is impor‑
tant to re‑state that the assessment of effective action under an EDP is focussed on the delivery of the required 
budgetary adjustment and is not affected by the evaluation of structural reforms. The implementation of structural 
reforms, including those undertaken under an Economic Partnership Programme (EPP), is monitored in the context 
of the European Semester, including through the Macroeconomic Imbalances Procedure.

110
In the Opinion on the EPP of December 2013, while acknowledging that all reforms were in progress, the Coun‑
cil pointed to the need to fully address some CSRs, notably the debt bias in corporate taxation in CSR1 and the 
long‑term sustainability of public finances in CSR2.

In fact, the Commission’s Staff Working Document assesses the authorities’ progress with implementing the previ‑
ous year’s country‑specific recommendations adopted by the Council. The regulation does not foresee specific fol‑
low up to the Council Opinion on the EPP, neither by the Commission nor by the Member State. Additional informa‑
tion on the planned and implemented measures after the publication of the previous year’s CSRs was provided in 
the Annex to the 2014 National Reform Programme, as requested from all Member States. The quality and credibility 
of the information provided was fully reflected in the assessment of implementation and the Commission proposal 
for new CSRs.

Box 11 – First indent – Spending review
All documents recently issued by the Commission on Italy’s public finances, for instance the Article 126 (3) report 
of February 2015, the opinions on the DBP of 2015 and of 2016, mention the need to make the spending review an 
integral part of the budgetary process at all levels of government.

Box 11 – Second indent – Tackling corruption
The Commission does not agree with the Court’s observation in Box 11, as all assessments produced by the Com‑
mission since the creation of the Italian anti‑corruption authority (ANAC) by the November 2012 anti‑corruption law 
highlighted the challenges, both procedural and substantial, hindering the operational effectiveness of the new 
institution.

The Commission staff working document ‘SWD(2013)362final’ of May 2013 already pointed out that, concerning 
the recently approved anti‑corruption law, ‘not only does the law still require implementing acts but it also does 
not tackle some critical issues’. After the approval of different implementing decrees of the anti‑corruption law, the 
Commission staff working document ‘SWD(2014)413 final’ of June 2014 highlighted: ‘the National Anti‑corruption 
Authority for the Evaluation and Transparency of Public Administrations (ANAC), in charge of coordinating preven‑
tive anti‑corruption policies nation‑wide, of which members have been increased from three to five in 2013 counts 
only limited staff and lacks sanctioning powers’. Moreover, the Commission has systematically focussed on the need 
for Italy to revise its statute of limitations in order to enhance the effectiveness of the repression of corruption since 
2012, when a country‑specific recommendation for Italy on this issue was issued for the first time.

Reply of the Commission

130

Box 11 – Third indent – Tackling tax evasion
The Commission does not agree with any suggestion that it does not pay sufficient attention to tax‑evasion in Italy 
with the examination of all relevant figures taken account of in the Commission’s broader assessment. For instance, 
the 2015 Country Report for Italy amply discussed the extent of the challenge represented by tax evasion in Italy. 
Namely, it highlighted that ‘tax compliance remains low and time‑consuming, which could harm the level playing 
field and social equality’ (pages 70 and following). Moreover, the ‘technical assessment of the 2015 Stability Pro‑
gramme’ features a critical assessment by the Commission of the effectiveness –also in terms of expected revenues‑ 
of the measures implemented by the Italian government to step up the fights against tax avoidance/evasion (see 
page 10): ‘measures to improve compliance through communications from the tax administration to the tax payers 
based on the cross‑check of databases (including the so‑called spesometro) and the subsequent possibility for the 
latter to autonomously revise their tax return well before the litigation phase (so‑called adempimento volontario). 
While the latter measure, if properly implemented in line with expectations, could be promising, the Commission 
forecast does not incorporate the related projected revenues from it, considering that implementation is still at the 
initial phase’.

Reply to the heading above paragraph 113
In connection with the effectiveness of the EDP, the Commission notes that of the 23 Member States under an EDP 
in November 2011, 15 exited the procedure by end‑2015, all the member States examined improved both their 
budget and structural balance. Acccording to the Commission’s 2016 Winter Forecast, in addition to Greece, Spain, 
France and Finland were the only Member State with a headline deficit still exceeding the 3% threshold in 2015.

118
In France, general government debt increased in line with the still relatively high general government deficit in 
a context of low nominal growth.

In Italy, the debt ratio increased on average by 4.7 pps of GDP per year during the 2008‑2014 crisis period, bring‑
ing the debt‑to‑GDP ratio to just above 132% in 2014 from the pre‑crisis (2007) trough of around 100%. The driver 
of this substantial increase was the debt‑increasing impact originated by the large difference between rather high 
implicit interest rates paid on debt (4.2% on average) and nearly zero average annual nominal GDP growth (‑1.3% 
real and +1.4% deflator), i.e. the so‑called snow‑ball effect. By contrast, the primary balance remained on average 
in surplus (1.2% of GDP), continuing to give a debt‑decreasing contribution. The latter was however offset by the 
large stock‑flow adjustment (SFA) mainly related to the financial support to euro‑area programme countries and the 
accumulation of liquidity in those years.

In Germany, Malta and the Czech Republic (where it remains under the threshold), the increase over the 2008‑2015 
period was moderate (1.3% in Malta, 6.6% in Germany and 12.3% in the Czech Republic) and the ratio is now on 
a downward path. Cyprus has had to cope with an unprecedented banking crisis and experienced an increase of 
63.3% in its debt‑to‑GDP ratio from 2008 to 2015, with the sharpest rise coming between 2008 and 2013 (from 45.1% 
to 102.5%). However, since 2013, when it was placed under a programme of financial assistance, the debt dynamics 
started turning, and the ratio stabilised in 2014 (108.2%) and 2015 (108.4%). Finally, both, France and Italy experi‑
enced a continuous increase of around 30% in their debt‑to‑GDP ratio over the 2008‑2015 period.

Box 12
In relation to Box 12, the Commission would point out that the statistically validated outturn data for 2015 will only 
be available in April 2016.

Reply of the Commission

131

120
The Commission considers that while high levels of debt in Italy hampered the effectiveness of the Italian EDP, 
Italy’s 2009 EDP Recommendation set a deadline for correction of 2012 and this was met, with the EDP being abro‑
gated in 2013. This helped to reduce the risk premium on the high public debt and thus facilitate its reduction.

123
The Commission is fully committed to apply sanctions when this is appropriate and foreseen according to the rules.

124
The EDP traditionally carries a fiscal focus and was not built with the enforcement of structural reforms in mind. 
Indeed, the possibility for sanctions is limited to non‑compliance with EDP budgetary targets.

Policy measures with a potential fiscal effect and a considerable impact on specific structural areas are monitored 
in the context of the European Semester. However, for countries subject to specific monitoring due to the presence 
of excessive imbalances, the implementation of reforms is monitored under this specific process within the overall 
Macroeconomic Imbalances Procedure. Different enforcement possibilities exist for SGP and MIP:

Fiscal policies: enforcement measures both under the preventive arm and corrective arm of the SGP

Macro‑economic imbalances: enforcement measures under the corrective arm (i.e. Excessive Imbalance 
Procedure)

The Commission concurs that the degree of implementation is not adequate and should be improved. To this aim 
a number of actions have been undertaken as follows:

The Commission supports regular dialogue with Member States (i.e. via bilateral meetings), social partners and 
stakeholders at all levels to ensure close monitoring and follow‑up, as well as to review performance and support 
exchange of experience. In last year’s European Semester cycle the Commission intensified its contact with the 
Member States on the recommendations. In addition, the Commission strengthened its presence in the Member 
States and stepped up political contacts, including with national Parliaments and social partners.

The new streamlined process followed for last year’s European Semester cycle allows for more time to examine and 
discuss EU guidance to the Member States. The country‑specific analyses for each Member States (i.e. the Country 
Reports) are available two and a half months before the CSRs, together with the In‑Depth Reports that follow on 
the Alert Mechanism Report. This allows for greater transparency and feedback from the Member States before the 
adoption of the CSRs and is expected to increase ownership and ultimately the effective implementation of the 
recommendations.

The Commission is also making sure that EU funding is steered towards EU and national priorities. The EU’s Struc‑
tural and Investment Funds are the principal EU level investment tools for delivering on the Europe 2020 goals and 
the CSRs. The new Investment Plan for Europe and the creation of a European Fund for Strategic Investments will 
also serve this purpose. EU funds will be paid out mainly for growth‑boosting investments like the ones identified in 
the CSRs and that enable the EU meet the Europe 2020 targets. In addition, the Commission has concluded Partner‑
ship Agreements with Member States for these funds only where the conditions are fulfilled. If needed, the Com‑
mission can ask Member States to modify their plans to support key structural reforms and can suspend funding if 
recommendations are repeatedly and seriously breached.

Finally, to increase the effective implementation of reforms (CSRs) and make the best use of structural funds, the 
Commission may also provide technical assistance to all Member States upon request.

Reply of the Commission

132

127
The Commission underlines the plans for the improving the economic governance framework set out in the Five 
Presidents’ Report.

Conclusions and recommendations

128
The Commission highlights the very significant progress in improving the EDP as a tool for economic governance.

Since spring 2014, the Commission has given access to Member States to all relevant data, indicators and the tools 
for the calculation of the relevant indicators applied in the fiscal surveillance process. On this basis, Member States 
are able to fully replicate the Commission’s calculations. In order to further enhance transparency in the EDP, as of 
the 2015 spring forecast, the Commission also shares with Member States the yield of the key individual discretion‑
ary tax measures for Member States under EDP for which the bottom‑up approach applies.

131
The examination of statistical data is documented in a range of internal and external documents describing the 
processes for the checking of EDP notifications and questionnaires, and mission guidelines.

The basis for the delimitation of general government is detailed in ESA2010 and in the MGDD, including a decision 
tree. For the purpose of checking the delimitation of general government, Eurostat also has at its disposal the regis‑
ter of government entities, part of the EDP Inventory, the questionnaire on government controlled entities classified 
outside government, available since 2011 and documents on reclassifications requested before EDP visits. The issue 
of delimitation of government is one of the main topics in each EDP visit.

Recommendation 1 – First paragraph
The Commission accepts the recommendation.

Recommendation 1 – Second paragraph
The Commission accepts the recommendation.

The Commission has appropriate internal procedures guiding its quality assessment work. They are established by 
internal documents and are fit for purpose.

The Commission will nevertheless review its procedures in these areas and do its utmost to improve them where 
needed.

132
The Commission assesses control systems in Member States during its visits, EDP questionnaires, peer reviews, 
questionnaires, and other instruments. As an example, it has promoted the signature of memoranda of understand‑
ing between the main institutions responsible for EDP data, even though it is not a legal obligation. Accordingly 
Eurostat’s system, composed of various building blocks, is fit for purpose.

The Commission can enhance the documentation on the components identified by the Court, where appropriate 
(supervisory and control systems in Member States).

See also Commission reply to paragraph 59.

Reply of the Commission

133

Recommendation 2
The Commission accepts the recommendation.

Institutional arrangements and supervisory and control systems are part of both upstream and standard dialogue 
visit agendas. The Commission will analyse how this issue could be better documented in the future.

133
The Commission considers that the duration of the visits is sufficient to adequately examine data quality issues. 
When needed, Eurostat has the possibility to make longer or more frequent visits. In addition, Eurostat has always 
managed to adjust agenda points during the missions and, if not the case, to follow up points after the mission. This 
is increasingly effective with available IT technology.

See also Commission replies to paragraphs 52 and 54.

The number, length and scope of these visits is dependent on the availability of human and financial resources.

134
Direct verification is performed on some issues during the visits (and not only during the visits: for example, when 
Eurostat officials review contracts for Public‑private Partnerships (PPPs) in the office).

High‑risk topics have been included in the agenda for both upstream and standard dialogue visits. Apart from the 
general high‑risk issues which are always part of the mission agendas, specific issues based on risks are included.

See also Commission replies to paragraph 53.

135
The Commission will ensure that final reports of the dialogue visits are published within a reasonable delay. How‑
ever, sharing good‑practices does not hinge on the publication date of the mission report as Member States and the 
Commission has various well‑established fora to do so (e.g. EDP Working Group, Task Force on methodology etc.).

See also Commission reply to paragraph 56.

Reply of the Commission

134

Recommendation 3 – First paragraph
The Commission accepts the recommendation.

The Commission considers that the duration of its dialogue visits is appropriate.

More frequent visits would have resource implications, both in human and financial terms. The Commission will bal‑
ance the costs and merits of this recommendation.

Recommendation 3 – Second paragraph
The Commission accepts the recommendation.

Recommendation 3 – Third paragraph
The Commission accepts the recommendation.

The Commission will ensure that final reports of the dialogue visits are published within a reasonable delay.

136. If an action point concerns a material issue, the Commission always follows it up. Sometimes deadlines have to 
be extended for pragmatic or organisational reasons.

Eurostat’s quality assessments include all important and material issues which are addressed that are addressed by 
action points.

See Commission reply to paragraph 56.

Recommendation 4
The Commission accepts the recommendation.

The Commission will investigate whether and in which areas it should more fully exercise its powers.

137
Eurostat only publishes advice in agreement with Member States. In a step towards increased transparency, Eurostat 
has started to include information to the EFC on non‑published advice.

See Commission replies to paragraphs 57 and 58.

Reply of the Commission

135

Recommendation 5
The Commission accepts the recommendation.

138
Eurostat has a procedure specifying the steps, timetable and role of each actor for the analysis of the notified EDP 
data. This includes regular meetings with senior management and with the Director General. A few days before the 
press release, the Director General, acting as the Chief Statistician of the European Union, assesses the situation for 
every Member State and decides on reservations and amendments.

Reservations or amendments to the data are based on professional judgment, on the basis of the qualitative and 
quantitative information available before and during the clarification process. This process is done exclusively on 
a statistical basis, exercising Eurostat’s statistical authority provided for this purpose and enshrined in legislation.

See Commission reply to paragraph 65.

139
Eurostat has a procedure specifying the steps, timetable and role of each actor for the analysis of the notified EDP 
data. This includes regular meetings with senior management and with the Director General. A few days before the 
press release, the Director General, acting as the Chief Statistician of the European Union, assesses the situation for 
every Member State and decides on reservations and amendments.

Reservations or amendments to the data are based on professional judgment, on the basis of the qualitative and 
quantitative information available before and during the clarification process. This process is done exclusively on 
a statistical basis, exercising the statistical authority provided to Eurostat for this purpose.

See Commission reply to paragraph 65.

Recommendation 6
The Commission accepts the recommendation.

The Commission ensures that all methodological problems with a potential/actual impact on net lending/net bor‑
rowing are addressed in a consistent way. The Commission will however complement the written internal documen‑
tation for setting reservations or amending data where necessary.

140
The Commission does not agree with the observation that the analysis underlying its recommendations in the 
context of the EDP lacks transparency. The transparency of the Commission’s assessments and subsequent recom‑
mendations has significantly increased over the last number of years.

The EU fiscal framework has undergone several changes in recent years with a view to introducing complementary 
rules, strengthening compliance mechanisms and raising national ownership. The legislative changes had to be 
technically operationalised and methodologies adapted.

Reply of the Commission

136

This has involved the Commission setting out the methodologies which it utilises in assessing compliance with the 
Stability and Growth Pact (SGP) ‑ such as the effective action methodology for the assessment of compliance in 
the context of the EDP and the classification principles on one‑off measures as published in the Report on Public 
Finances in EMU 2015 – and has mainly been facilitated through a series of explanatory notes brought to the com‑
petent instances of the Council, the contents of which are summarised in the Vade Mecum, publicly available on the 
Commission’s website. The latter will now be updated annually in line with a commitment in the Commission Com‑
munication of 21 October 2015 on Completing EMU.

In order to further increase transparency, since spring 2014 the Commission agreed to provide Member States with 
all the necessary information to replicate the underlying computations related to the compliance assessment with 
both the preventive and the corrective arm, including detailed excel spreadsheets providing step‑by‑step calcula‑
tions. Regarding discretionary measures, the Commission has made fully public aggregate data series on the impact 
of discretionary measures and the level of one‑offs since spring 2014 and, in line with the Ecofin Council Conclu‑
sions of June 2014, has made further progress by sharing with the Member States the yield of key individual tax 
measures incorporated in the bottom‑up approach for EDP countries as of spring 2015.

Furthermore, the Commission has made available detailed information on the main measures in the Staff Working 
Documents which accompany new EDP recommendations, including the forecast of key variables for the compu‑
tation of the fiscal effort under the baseline scenario (e.g. the point of reference to which future forecast will be 
compared with in order to compute both the top‑down and the bottom‑up approach).

The Commission recognises that the complexity of the surveillance framework has increased. Indeed, there is 
a natural trade‑off between defining rules and approaches as much as possible in terms of capturing the underly‑
ing macroeconomic situation and developments, and the degree of complexity of the entire framework. Transpar‑
ent codification and publication of the methodologies reduced the discretion and scope for interpretation in the 
system.

As indicated in its Communication of 21 October 2015, the Commission intends to make further efforts to improve 
clarity and reduce the complexity of the existing framework, in cooperation with the Member States, wherever pos‑
sible within the existing legislative framework. The Commission will aim to streamline the methodology for assess‑
ing compliance with the SGP.

141
A large degree of the growing complexity referred to by the Court has arisen as a result of an attempt to provide 
greater transparency. At the same time, the increased complexity of the surveillance framework called for detailed 
explanation in a spirit of transparency.

The Commission considers that transparency has recently been enhanced significantly and while recognising room 
for improvement, it does not agree that the efforts so far have been insufficient. Indeed, the Commission is fully 
committed to transparency. In the statistical field, the Commission publishes methodological advice and guidance, 
provided it does not breach statistical confidentiality enshrined in Council Regulation 479/2009. With the European 
System of Accounts, the Commission’s approach is clearly rules‑based and the Commission does not depart from 
established procedures. Applying sound judgement in line with the rules instead of a purely mechanistic approach 
is, however, a core task of the Commission and is the only means to properly reflect the diversity of Member States 
and issues at stake.

Reply of the Commission

137

Moreover, the legislative changes introduced in recent years in the EU fiscal framework had to be technically opera‑
tionalised. To this end, the methodologies and classifications utilised in assessing compliance with the Stability and 
Growth Pact (SGP) had to be adapted. This process took place through extensive discussions in the Economic and 
Financial Committee (EFC) and other competent instances of the Council. These discussions were facilitated through 
a series of explanatory notes. The increased complexity of the surveillance framework called for additional explana‑
tion in a spirit of transparency.

Therefore, all the approaches to the implementation of the revised framework were summarised in the Vade Mecum 
on the Stability and Growth Pact, publicly available on the Commission’s website. The Vade Mecum will now be 
updated annually in line with a commitment in the Commission Communication of 21 October 2015 on Completing 
EMU.

The formalisation of such methodologies, however, tends to reduce the discretion and scope for interpretation in 
the system, due to the imperative to abide by the published methodology.

In order to further increase transparency, since spring 2014 the Commission agreed to provide Member States with 
all the necessary information to replicate the underlying computations related to the compliance assessment with 
both the preventive and the corrective arm, including detailed excel spreadsheets providing step‑by‑step calcula‑
tions. Regarding discretionary measures, the Commission has made fully public aggregate data series on the impact 
of discretionary measures and the level of one‑offs since spring 2014 and, in line with the Ecofin Council Conclu‑
sions of June 2014, has made further progress by sharing with the Member States the yield of key individual tax 
measures incorporated in the bottom‑up approach for EDP countries as of spring 2015.

Furthermore, the Commission has made available detailed information on the main measures in the Staff Working 
Documents which accompany new EDP recommendations, including the forecast of key variables for the compu‑
tation of the fiscal effort under the baseline scenario (e.g. the point of reference to which future forecasts will be 
compared in order to compute both the top‑down and the bottom‑up approach).

Recommendation 7 – First indent – Assessment process
The Commission partially accepts the recommendation given the very substantial progress in making its analyses 
more transparent.

In relation to one‑off and temporary measures, the Code of Conduct specifies that one‑off and temporary measures 
are measures having a transitory budgetary effect that does not lead to a sustained change in the inter‑temporal 
budgetary position and goes on to provide several examples. However, owing to the very wide variation in country 
specificities, it is eminently possible that measures which do not neatly fit into any previously encountered cat‑
egory will arise and, in such circumstances, it is highly desirable that the Commission retains the leeway to apply its 
economic judgement. In this regard, the Commission has published work in previous Public Finance Reports which 
sets out the analytical approach and rationale which is taken and internal work has been undertaken updating this 
material. Updated and more detailed internal guidance (including a number of guiding principles and typical cases) 
on one‑off measures have been published externally in the Public Finance Report 2015.

Similarly, the concept of ‘unexpected adverse economic events’ has not been definitively set out in advance as it is 
not possible to exhaustively define the set of individual country circumstances which this may apply to ex‑ante, par‑
ticularly when considering that these events are by nature unanticipated. However, the Commission considers that 
the agreed methodology for assessing effective action provides a comprehensive approach on the matter.

Reply of the Commission

138

The Commission provides the analysis of relevant factors as required by the Council Regulation (EC) No 1467/97, tak‑
ing into account the factors listed directly in the legislation as well as those deemed relevant by the Member State 
concerned.

The Regulation stipulates that in a case where the deficit criterion is breached and the general government debt is 
above 60% of GDP, the relevant factors will only be considered in the decision regarding whether to launch an EDP 
if the deficit remains close to the reference value and the breach is judged to be temporary.

The legislation indeed provides a broad list of possible relevant factors which is not exhaustive, since it requires 
the Commission to also consider factors deemed relevant by the Member State concerned. This is a crucial element 
of accounting for the underlying country‑specific circumstances which differ in their character and gravity across 
countries, and which may not always be quantifiable.

Moreover, the assessment of effective action on the basis of the top‑down approach also allows to correct for the 
impact of unexpected events.

Recommendation 7 – Second indent – Accessibility of data
The Commission accepts the recommendation.

Recommendation 7 – Third indent – Bottom‑up assessment
The Commission does not accept the recommendation as the Commission does not have the legal power to enlist 
the services of the independent national fiscal councils.

Recommendation 7 – Fourth indent – Robustness of analysis
The Commission accepts the recommendation.

142
The Court’s observation regarding the focus of the EDP traditionally lying more on government deficits than on 
debt is well‑founded. Prior to the entry into force of the Six‑pack, the debt component of the SGP was insufficiently 
active in terms of the regular surveillance processes. For this reason, one of the key reforms contained within the 
Six‑pack was the operationalization of the debt‑rule, notably by elevating the breach of the 60% of GDP debt 
threshold to the EDP trigger and defining what constituted debt that was declining at a sufficiently diminishing 
pace, as stipulated under the Regulation.

Countries that were in EDP on the date that the Six‑Pack amendments to the SGP were adopted – that is 8 Novem ‑
ber 2011 – are subject to transitional arrangements for the three years following the correction of their excessive 
deficit. During those three years, compliance with the debt criterion is judged according to whether the Member 
State in question makes sufficient progress towards compliance.

Reply of the Commission

139

This arrangement represents a practical recognition of the fact that Member States which were already in an EDP at 
the time of the adoption of the Six‑Pack already had agreed fiscal consolidation paths, which were not necessarily 
in line with the requirements of the newly operationalised debt rule. Hence, there would have been an inconsist‑
ency between the ongoing EDP procedures and the requirements of the debt rule. The transition period is therefore 
a necessary recognition that these Member States require time to adapt their structural adjustments to the level 
needed to comply with the new benchmark. It is important to note that countries still need to be moving towards 
compliance during this period and face possible procedural consequences in case of non‑compliance; it is not the 
case that the debt requirement does not apply at all during the transition. Moreover, although the transition period 
is defined as lasting three years, during the last year Member States must show compliance with the debt criterion, 
so that in reality the transitional arrangements only differ from the usual debt reduction benchmark over the first 
two years.

143
The Commission does not agree that the Communication on making the best use of the flexibility within the exist‑
ing rules of the Stability and Growth Pact has in any way undermined the credibility of the process, or risked debt 
sustainability. Indeed, the Communication did not represent a departure from the pre‑existing scenario as it did not 
extend the concept of factors to be taken into account in the decision not to launch an EDP. Article 2 of Regulation 
1467/97, dealing with the launch of an EDP, clearly states that when preparing a report under Article 126(3), the Com‑
mission shall take into account all relevant factors in so far as they significantly affect the assessment of compliance 
with the deficit and debt criteria ‑ including developments in medium term potential growth, the implementation 
of policies in the context of prevention and correction of excessive macroeconomic imbalances, and the implemen‑
tation of policies in the context of the common growth strategy of the Union.

The debt rule (both the full rule as well as the transitional rule) does not automatically imply that a Member State 
is put in EDP once the quantified target is missed. This non‑automaticity is explicitly foreseen in the regulation and 
is economically warranted given that debt developments are (more than deficit developments) not fully under the 
control of the government. Indeed, the debt‑to‑GDP ratio is particularly dependent on developments in both real 
GDP growth and inflation. In addition, this also concerns the stock‑flow adjustment, which is influenced i.a. by for‑
eign exchange rates and statistical reclassifications.

Recommendation 8
The Commission accepts the recommendation.

Realistic and credible EDP targets should speak to the need for caution in considering the provision of debt‑to‑GDP 
targets as a component of EDP recommendations.

Governments do not exert the same level of control on the development of debt‑to‑GDP ratios as they do in rela‑
tion to the deficit. In particular, non‑deficit related financial transactions (so‑called stock‑flow adjustments) can 
have a significant impact upon debt‑ratios in a given year. As it the nature of debt dynamics that one year builds 
upon the other, such one‑off occurrences can have knock‑on implications for subsequent years that would create an 
inconsistency between deficit and debt‑based targets.

Reply of the Commission

140

144
In terms of enforcement the focus of the legislation which governs the EDP is fiscal outcomes and, as such, the rele‑
vant legislation does not contain specific provision to enforce the implementation of structural reforms. Indeed, the 
assessment of effective action under an EDP is focussed on the delivery of the required budgetary adjustment and 
is not affected by the evaluation of structural reforms. The implementation of structural reforms, including those 
undertaken under an Economic Partnership Programme (EPP), is monitored in the context of the European Semes‑
ter. However, the Regulation does not foresee specific steps in cases where structural measures fall short compared 
to what is recommended in the analysis of the EPP. For countries subject to specific monitoring due to the presence 
of excessive imbalances, the implementation of reforms is monitored under the Excessive Imbalances Procedure.

145
The need to avoid duplication and unduly complicate surveillance procedures explains why monitoring is not 
ensured in the EDP related documents.

Such a monitoring is warranted during the European Semester, that was created in order to ensure that economic 
and budgetary policy are treated in an integrated manner, taking their interactions and interdependencies into 
account.

The changes introduced by the Commission to the 2015 European Semester aimed at increasing ownership at 
national level and accountability of European and national decision‑making.

As part of the reinforced European Semester, since 2015, a Country Report is produced for each of the Member 
States and for the euro area in February each year, identifying country‑specific challenges, notably linked to the 
reform process, and the progress made in addressing the issues identified in the previous round of Country Specific 
Recommendations. These detailed assessments inform the formulation of the next round of CSRs.

Moreover, for countries subject to specific monitoring due to the presence of excessive imbalances, the implemen‑
tation of reforms is monitored under this specific process within the overall Macroeconomic Imbalances Procedure.

Concerning the Commission’s recent decision to take greater account of the implementation of structural reforms, it 
should be stressed that it does not impact the assessment of effective action under the EDP.

Recommendation 9 – First paragraph
The Commission accepts the recommendation.

The introduction of Economic Partnership Programme (EPPs) is based on the fact that excessive public deficits may 
be rooted – at least in part – on structural weaknesses. If these weaknesses are not directly addressed, budget‑
ary measures may be insufficient to produce a lasting correction of the deficit. Instead, addressing the underlying 
weaknesses is likely to be effective and more efficient from an economic point of view, over the medium and longer 
terms. Since the entry into force of the Two‑pack, Member States for which an EDP has been opened/the EDP dead‑
line has been revised following effective action, shall present an EPP at the same time as the report on action taken 
that is due 3 to 6 months since EDP steps have been taken.

Reply of the Commission

141

The EPPs are one‑off documents whose role is to act as a roadmap for the fiscal structural reforms which Member 
States consider to be necessary to ensure an efficient and lasting correction of their excessive deficit. In their EPP, 
the Member States should identify and select their priorities in terms of competitiveness, long‑term sustainable 
growth and addressing their structural weaknesses. The EPP serves to complement the budgetary measures taken 
over the course of an EDP with a wider strategy aimed at avoiding the occurrence of excessive deficits. However, its 
one‑off nature does not imply that there is no follow‑up. The Commission and the Council monitor the implementa‑
tion of the fiscal‑structural reforms in the context of the European Semester. In this regard, one should bear in mind 
the need to avoid duplication and unduly complicated surveillance procedures.

Recommendation 9 – Second paragraph
The Commission does not accept the recommendation as it considers that it already operates to the full extent of 
the powers available to it under the legislation and has repeatedly publicly stressed the need for Member States to 
undertake necessary structural reforms.

146
Regarding the new reporting requirements, there are no (explicit) legislative provisions to ensure that Member 
States comply with them, nor sanctions in case of non‑compliance. However, as this is a requirement stemming 
from a Regulation they could be enforceable given the possibility for the Commission to launch an infringement 
procedure in case of non‑compliance. The effectiveness of this remedy should be judged against the requirements 
of the EDP.

147
As replied to rec. b (iv), the Regulation does not always foresee a systematic evaluation/feedback to be made public 
by the Commission. Additional reporting is fully taken into account by the Commission in its regular surveillance (i.e. 
in each forecast round; a short assessment is generally provided in the country‑specific section of the ‘ Implications 
of the forecast for budgetary surveillance’ notes since AF2013). Only in cases of non‑compliance with the require‑
ments, this would be clearly flagged and pointed out in an appropriate Commission document (depending on the 
specific situation, this can be either a dedicated note or part of the documents assessing the SCP or DBP). Infringe‑
ment procedures can be launched in case of non‑compliance with the requirements.

Recommendation 10 – First paragraph
The Commission accepts the recommendation.

Recommendation 10 – Second paragraph
The Commission does not accept the recommendation since the effectiveness of this remedy should be judged 
against the requirements of the EDP.

149
The Commission restates its commitment to apply sanctions as appropriate in line with the provisions of the 
Six‑pack.

Recommendation 11
The Commission does not accept the recommendation.

The Commission has always acted in compliance with the Treaty. The Commission will continue to recommend that 
the Council step up the procedure and apply sanctions where appropriate in line with the legislation.

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‘The excessive deficit procedure (EDP) is a key element of 
economic governance in the EU. It is used where necessary 
to correct the trajectory of deficit and debt in the Member 
States. For this audit we examined the quality of the EDP in 
the difficult recent economic climate, from the data 
underlying decisions to initiate the procedure through to 
the final results. We found that effective implementation is 
still a work in progress, but that the Commission is 
committed to continuing with the necessary 
improvements.’

EUROPEAN
COURT
OF AUDITORS