COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on European Business Statistics amending Regulation (EC) No 184/2005 and repealing 10 legal acts in the field of business statistics
Date: 2017-03-06
Institutions: European Commission, Eurostat
Subjects: EU statistics, data collection, economic statistics, exchange of information, financial statistics, information system, production statistics, statistical method, trade statistics, type of business

EN 

   EN 

   EUROPEAN COMMISSION  Brussels, 6.3.2017  SWD(2017) 98 final   COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT  Accompanying the document Proposal for a  REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL  on European Business Statistics amending Regulation (EC) No 184/2005 and repealing 10 legal acts in the field of business statistics  {COM(2017) 114 final} {SWD(2017) 99 final}  
 
 
Table of Contents 

1.  

INTRODUCTION ...................................................................................................................... 4 

1.1   Background ............................................................................................................................. 4 

1.2   Context .................................................................................................................................... 5 

1.3 

1.4 

Consultation of interested parties ............................................................................................ 7 

Content of the Impact Assessment Report .............................................................................. 9 

2.  

PROBLEM DEFINITION ........................................................................................................ 10 

2.1  

Problem drivers ..................................................................................................................... 11 

2.2 

2.3 

Problems ............................................................................................................................... 12 

Link between problem drivers, problems and their consequences ........................................ 17 

2.4  

Scale of the problem ............................................................................................................. 17 

2.5   What would happen without an intervention ........................................................................ 18 

3.  WHY SHOULD THE EU ACT: RESPECT OF SUBSIDIARITY PRINCIPLE ......................... 20 

4.  OBJECTIVES ............................................................................................................................... 21 

4.1 

4.2 

General objectives and links to horizontal EU objectives .................................................... 21 

Specific objectives ................................................................................................................ 22 

5.  POLICY OPTIONS ...................................................................................................................... 23 

5.1 

5.2 

List of policy options ............................................................................................................ 24 

Discarded options .................................................................................................................. 26 

6. 

IMPACTS OF THE POLICY OPTIONS ..................................................................................... 29 

Impacts Option A: Baseline scenario: no EU policy change ...................................................... 29 

Option B: Implement legislative actions limited to certain business statistics domains .............. 30 

Option C: Modernisation of business statistics in a single framework (FRIBS) using a mix of 
measures ....................................................................................................................................... 33 

7.  COMPARISON OF OPTIONS .................................................................................................... 41 

8.  MONITORING AND EVALUATION: HOW WOULD ACTUAL IMPACTS BE 
MONITORED AND EVALUATED .................................................................................................... 46 

ANNEXES ............................................................................................................................................ 51 

ANNEX I: PROCEDURAL INFORMATION ................................................................................. 51 

ANNEX II: STAKEHOLDER CONSULTATIONS ........................................................................ 55 

ANNEX III: WHO IS AFFECTED BY THE INITIATIVE AND HOW ......................................... 62 

ANNEX IV: ANALYTICAL MODELS USED IN PREPARING THE IMPACT ASSESSMENT65 

ANNEX V: LIST OF THE CURRENT LEGAL ACTS GOVERNING EUROPEAN BUSINESS 
STATISTICS .................................................................................................................................... 72 

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ANNEX VI: LIST OF ABBREVIATIONS ...................................................................................... 74 

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1.  

INTRODUCTION 

1.1   Background 
Statistics and indicators are key elements for evidence-based decision making at both national 
and  European  Union  level.  A  number  of  important  EU  policy  measures,  like  the 
Macroeconomic  Imbalance  Procedure,  the  Excessive  Deficit  Procedure,  the  European 
Semester and the policy initiatives  of Europe  2020 strategy intensively  use  comparable EU 
statistical information and indicators.  

Additionally, the monitoring of the goals set through the Juncker Commission 10 priorities at 
Member State and Union level requires harmonised and comparable European statistics that 
decision makers need in order to design policy initiatives to meet the priorities and to monitor 
the implementation of these initiatives. 

European Statistics and the European Statistical System (ESS)1, with the quality guarantee of 
official statistics, are the main statistical sources for robust EU policy making.   

European business statistics are a crucial input for the production of National Accounts core 
figures  such  as  the  GDP,  and  widely  used  for  monitoring  the  performance  and  growth  of 
European  businesses  which  are  at  the  core  of  employment  creation,  innovation  and 
investments within the European Union economies.  

High  quality  European  business  statistics  are  also  an  essential  piece  of  information 
infrastructure not only for designing, implementing and assessing national and EU policies, 
but also a very important data source for economic research and (financial) markets. 

The envisaged proposal for a Regulation of the European Parliament and of the Council on 
European Business Statistics (hereinafter referred to as  "Framework Regulation Integrating 
Business  Statistics  (FRIBS)")  is  a  natural  follow-up  of  the  ESS  efforts  to  modernise  the 
production  of  business  and  trade  statistics,  a  need  recognised  already  in  2009  by  the 
European  Commission  with  the  launching  of  the  programme  for  the  Modernisation  of 
European Enterprise and Trade Statistics (MEETS)2.  

The  FRIBS  is  one  of  the  key  initiatives  of  the  Commission's  Regulatory  Fitness  and 
Performance  programme  (REFIT).  In  that  respect,  it  aims  to  increase  the  relevance  of 
business statistics by addressing existing user needs which are at present not served while at 
the same time removing some data requirements which are no longer relevant.  

1  The  ESS  is  the  partnership  between  Eurostat  and  the  national  statistical  institutes  (NSIs)  and  other  national 
authorities  (ONAs)  responsible  in  Member  State  for  the  development,  production  and  dissemination  of 
European statistics. 

2 Decision No 1297/2008/EC of the European Parliament and of the Council of 16 December 2008 on a 
Programme for the Modernisation of European Enterprise and Trade Statistics (MEETS) 

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Likewise,  reliable  and  comprehensive  EU  statistics  are  required  at  the  national  level,  as 
national policy makers need to compare their situation with the rest of the EU,  e.g. in terms 
of productivity, investments, production, research, innovation or exports. Additionally, high 
quality European business statistics are important for providing a sufficient knowledge base 
for the EU citizens and for scientific research, which can help identify important trends and 
future policy challenges, or explain why certain developments occur.  

1.2   Context 
The  users  and  uses  of  European  official  business  statistics  are  of  a  very  eclectic  nature 
comprising  policy  makers  at  national  and  EU-level,  businesses  and  their  associations, 
researchers providing advice on future policy initiatives as well as users from other statistical 
domains,  such  as  national  accounts,  who  use  business  statistics  as  a  crucial  input  for  their 
macro-economic indicators. European business statistics provide the basis for analysing and 
monitoring  issues  such  as  economic  developments  in  different  sectors,  productivity  and 
competitiveness  of  European  businesses,  their  globalisation,  growth  and  jobs,  trade,  the 
functioning of the single market and the performance of small and medium sized enterprises.  

Since many years  a core set of business statistics is  disseminated to  users comprising short 
term business statistics used for the analysis of business cycles (such as industrial production, 
producer  prices,  turnover,  employment),  structural  information  (e.g.  information  on  the 
business population and the births, deaths and survival of enterprises, turnover, value added, 
innovation),  production  output  (mainly  concerning 
employment,  gross 
manufacturing),  factor-input  (personnel  costs,  research  &  development  expenditure)  and 
international trade (imports and exports) and investment flows and prices.  

investment, 

The  relevant  international  developments  should  also  be  closely  followed.  For  instance 
international  manuals  such  as  the  Frascati  manual  regarding  R&D  statistics  and  the  Oslo 
manual  concerning  Innovation  statistics  as  well  as  international  agreements  adopted  by 
United  Nations,  OECD,  International  Monetary  Fund,  and  other  international  and 
supranational organisations, are of relevance for European business statistics and should, as 
far as necessary, be considered in European business statistics. 

The MEETS Programme  was used  to  undertake the first steps in  modernising business  and 
trade  statistics.  Several  actions  were  launched  aiming  for  better  integration,  simplification, 
and  modernisation  and  investments  were  made  across  the  ESS,  with  a  EUR  37  million 
contribution  by  the  Commission.  The  outcome  of  this  work  feeds  into  the  proposal  for 
FRIBS. 

At  the  same  time,  the  European  Statistical  Programme  (ESP)  2013-20173  defines  business 
statistics as one of the three pillars of the European Statistical System (ESS). Each of these 

3  Currently,  work  is  under  way  for  extending  the  European  Statistical  Programme  (2013-2017)  to  2018-2020 

and thus aligning it to the cycle of the Multi-annual Financial Framework (MFF) 

5 

 
 
 
                                                            
pillars  covers  a  set  of  primary  statistics  which  is  serving  multiple  policy  needs.  Business 
statistics  are  also  the  crucial  input  for  higher  level  accounting  systems  (e.g.  National 
Accounts)  and  for  the  development  of  indicators  for  different  policy  needs.  The  currently 
developed extension of the ESP would also be recognising the importance of FRIBS and the 
need  to  financially  ensure  its  modernisation  efforts  by  accordingly  reflecting  it  in  the  ESP 
budget. The ESP extension would also refer to E-commerce and ICT usage which would also 
be  better  covered  by  FRIBS  in  terms  of  allowing  for  building  a  broad  information  base  to 
develop better statistics on the drivers for technological changes and innovation as well as e-
commerce.  The  ESP  also  envisaged  enhancing  (an  increase  also  in  budgetary  terms 
envisaged)      the  availability  of  indicators  and  statistical  information  for  better  measuring 
economic globalisation; global value chains; and services. 

In addition, the Commission's REFIT programme  for making EU law  simpler and reducing 
regulatory costs has identified statistics as one of the priority areas for modernisation. In its 
action plan, FRIBS is mentioned as a key pillar of this reform agenda. 

The  Commission's  Smart  Regulation4  initiative  and  the  comprehensive  Better  Regulation 
package  from  May  2015  strongly  emphasise  the  significance  of  continuous  evaluation  and 
quality  control  of  EU  policies  which  should  foster  more  consistency,  transparency, 
effectiveness and efficiency in the European legislation. 

In  2014,  the  European  Statistical  System  Committee  (ESSC)  has  launched  its  ESS  Vision 
2020 strategy to make the European Statistical System (ESS) fit for the future and build upon 
the  modernisation  activities  on  European  statistics,  already  undertaken  by  the  Commission 
since 2009. The ESS Vision 2020 is a joint strategic response of the ESS to the challenges 
which official statistics are facing, such as the handling of big data, measuring globalisation 
in  official  statistics,  providing  high  quality  statistics  under  tight  budgets  or  addressing 
emerging  policy  needs  for  new  statistical  indicators  while  being  conscious  of  burden  on 
businesses.  The  ESS  Vision  2020  foresees  that  data  should  be  more  integrated  for  better 
analysing  new  phenomena  (such  as  globalisation)  and  for  better  serving  EU  policies  with 
high impact (e.g. trade or R&D policy). In order to benefit from emerging opportunities for 
burden  and  cost  reduction  the  ESS  should  increase  the  collaboration  within  the  system  by 
sharing methods, tools and even identifiable micro-data. The ESS should, moreover, become 
more  agile  and  be  using  innovative  solutions  by  harnessing  new  data  sources  to  produce 
meaningful statistics. 

The  aforementioned  initiatives  provide  the  context  within  which  Eurostat  has  embarked  on 
designing  the  Framework  regulation  integrating  business  statistics  (FRIBS)  together  with 
National Statistical Authorities (NSAs).  

4  Commission  Communication  COM  (2013)  686  "Strengthening  the  foundations  of  Smart  Regulation  – 

improving evaluation" 

6 

 
 
 
                                                            
A  FRIBS  roadmap  has  been  agreed  and  published  in  January  2013  by  the  Commission. 
Following  the  introduction  of  the  Better  Regulation  guidelines  in  2015,  the  roadmap  was 
revised under the form of an inception impact assessment that was published in January 2016. 
Further procedural information is available in Annex I.   

1.3 

Consultation of interested parties 

In order to prepare this initiative many regular meetings (more than 100) with producers of 
business  statistics  (NSIs  and  other  national  authorities-  Directors  Meetings,  Task  Forces, 
domain-specific  working  groups),  respondents  (businesses  and  European  Federations  by 
sector of industry - FEBI "Fédérations Européennes par Branche d'Industrie" meetings) and 
users  (public  and  private  decision  makers  and  in  particular  European  Commission 
Directorates General in annual hearings) have taken place since the start of the FRIBS project 
in  2011.  The  FRIBS  project  has  been  discussed  with  national  experts  covering  not  only 
business  statistics,  but  also  macro-economic  statistics,  National  Accounts  and  Balance  of 
Payments  statistics  (eg.  the  Committee  on  Monetary,  Financial  and  Balance  of  Payments 
Statistics - CMFB). 

Additionally to the regular and extensive consultations of the concerned parties, three rounds 
of  specific  stakeholder  consultations  were  organised  for  preparing  the  FRIBS  Impact 
Assessment.  The  first  round  covered  the  FRIBS  infrastructural  elements  (such  as  the 
Business  Registers,  micro-data  exchange,  quality  issues  and  confidentiality).  The  second 
round focussed on the changes to the data requirements to be introduced by FRIBS and the 
third  round  collected  stakeholders'  opinions  on  the  modernisation  of  Intrastat.    Each  round 
consisted  of  a  targeted  consultation  of  the  data  compilers  (NSAs)  and  an  open  public 
consultation.  While  the open  public  consultations  were  open  to  all  possible  respondents  (in 
the sense of the Better Regulation toolbox), the objective has been to get feedback especially 
from the data providers (businesses) and from the data users.  Thus, stakeholders have been 
intensively  involved  in  the  shaping  of  the  FRIBS  project  and  have  been  extensively 
consulted. Annex II provides the details on the consultations carried out. 

Consultation on FRIBS infrastructural elements 

The consultation on the FRIBS infrastructural elements took place between July and October 
2014 and aimed to collect input from the following three main categories of stakeholders:  

• 

• 

Data users: all actors who are frequently using European business statistics as an input 
in their daily work, such as other Commission services, national statistical authorities 
monitoring  the  business  sector,  National  Central  Banks  and  the  European  Central 
Bank, professional associations and researchers. 

Data  compilers:  national  statistical  authorities  (NSAs)  which  are  responsible  for  the 
collection,  compilation  and  dissemination  of  statistics  at  national  level.  In  the  first 

7 

 
 
 
 
place this includes National Statistical Institutes (NSIs), but also other compilers such 
as National Central Banks; 

• 

Data  providers:  enterprises  (including  SMEs)  responding  to  statistical  surveys  at 
national/regional level; 

In  line  with  the  geographical  scope  of  the  subsequent  cost-benefit  analysis,  the  data 
compilers' consultation targeted stakeholders from all 28 EU Member States and the 4 EFTA 
countries. 

NSAs were consulted on:  

• 

• 

• 

• 

The expected qualitative impacts of FRIBS; 

A qualitative comparison of FRIBS and alternative policy options; 

The expected quantitative impacts of FRIBS and alternative policy options for NSAs; 

The  expected  quantitative  impacts  of  FRIBS  and  alternative  policy  options  for  data 
providers. 

Consultation on FRIBS additional data requirements 

A supplementary consultation in the second half of 2015 was launched to assess the impact of 
the  changes  to  the  existing  data  requirements  envisaged  in  FRIBS.  Besides  new  additional 
data  requirements  also  the  reductions  in  data  requirements  were  included.  This  specific 
consultation is part of the larger FRIBS Impact Assessment and it complements in particular 
the  first  cost-benefit  analysis  of  the  infrastructural  elements  for  which  a  stakeholder 
consultation had been carried out during 2014. 

The consultation on the FRIBS additional data requirements took place between August and 
November 2015 and also consisted of a targeted consultation of the data compilers (NSAs) 
and an open public consultation – via which the feedback of the data users and data providers 
of  European  business  statistics  was  sought.  The  consultation  focused  on  the  impact  of  the 
additional data requirements that are foreseen in FRIBS. 

Stakeholders  were  asked  to  give  their  opinion  and  to  provide  factual  data  regarding  the 
expected impacts of the changes. These impacts can be summarised as follows: 

• 

• 

• 

Qualitative impacts for data users (quality, flexibility, timelines); 

One-off  implementation  costs  and  changes  in  yearly  operating  costs  for  data 
compilers; 

Changes  in  administrative  burden  and  one-off  implementation  costs  for  data 
providers. 

8 

 
 
 
 
Consultation related to Intrastat   

Separate targeted and open public stakeholder consultations have been carried out on Intrastat 
feeding into the impact assessment as  well  as to the modernisation of Intrastat. The overall 
aim  of  the  modernisation  project  is  to  assess  the  impacts  of  the  three  options5  proposed  – 
SIMSTAT, Revised Intrastat and Single Flow - in terms of their costs and benefits.  

The NSAs have been addressed in a targeted consultation for collecting data for a cost-benefit 
analysis.  This  cost-benefit  analysis  aims  at  providing  input  to  the  ESSC  to  take  a  strategic 
orientation  on  the  modernisation  of  Intrastat.  At  the  same  time  the  cost-benefit  analysis  is 
contributing to the more encompassing cost-benefit analysis of FRIBS.  

The methodology followed for the cost-benefit analysis consists of two actions: quantitative 
assessment (cost analysis) and qualitative assessment (SWOT analysis). 

The  aim  of  the  cost  analysis  was  to  estimate  the  costs  (current  costs,  development  and 
adaptation  costs,  future  costs)  incurred  by  the  NSAs  caused  by  the  implementation  of 
modernisation options for Intrastat.  

The  SWOT  assessment  for  the  Member  States  was  carried  out  in  autumn  2015  based  on  a 
standard methodology.  

For collecting data on the administrative burden, an extensive public consultation of the data 
providers has been organised during the first quarter of 2016.  

Additional information on the consultations of the relevant stakeholders and their outcomes is 
provided in Annex II. 

1.4 

Content of the Impact Assessment Report 

The  main  part  of  the  Impact  Assessment  report  starts  with  the  definition  of  the  problems 
(Chapter  2)  and  continues  with  justifying  the  need  for  an  EU  action  (Chapter  3).  Then,  the 
objectives of the proposed legislation are presented (Chapter 4), followed by an outline of the 
possible policy options (Chapter 5). The analysis of the impacts of the various policy options 
are  presented  in  Chapter  6  and  the  preferred  option  in  Chapter  7.  The  monitoring  and 
evaluation activities that are foreseen for tracing the effects of the envisaged legislation are 
explained in Chapter 8. Finally, additional relevant information is appended in the annexes. 
Namely,  Annex  I  –  regarding  the  procedural  information,  Annex  II  –  regarding  the 
stakeholder consultations, Annex III – regarding who is affected by the initiative, Annex IV – 

5 Please see more in detail in Chapter 5- Policy Options 

9 

 
 
 
 
 
 
 
                                                            
regarding  the analytical models used for the impact assessment and Annex V  – comprising 
the  list  of  abbreviations,  Annex  VI  -  List  of  the  current  legal  acts  governing  European 
business statistics.  

2.  

PROBLEM DEFINITION 

Generally,  the  users  of  business  statistics  are  concerned  about  the  risks  of  diminishing 
relevance of European official statistics because of their availability and quality deficiencies 
such  as  inadequate  coverage  of  emerging  user  needs,  insufficient  timeliness  and  limited 
comparability  and  coherence.  Simultaneously,  compilers  of  business  statistics  (NSIs  and 
NCBs) are concerned about the pressure to cover new information needs from the perspective 
of more globalised and interlinked economies while facing increasingly restrictive budgetary 
constraints.  
While  the  "core"  business  statistics  (listed  in  1.2)  used  to  focus  mainly  on  manufacturing, 
they  have  been  extended  to  increasingly  cover  more  services  sectors  over  the  years.  For 
instance,  statistics  on  business  services  have  been  developed  further.  The  environment  in 
which  businesses  function  keeps  evolving,  leading  to  continued  adaptation  in  the  way 
companies run their business. Phenomena such as digitalisation and globalisation have led to 
the  need  to  better  measure  the  knowledge  industries,  research  and  development  and 
innovation. Consequently, new data production has been launched in these areas. Attempts to 
measure  globalisation,  the  functioning  of  the  Single  market  and  the  development  of  global 
value  chains  have  resulted  in  the  establishment  of  separate  regulations  governing  data 
collections  e.g.  on  foreign  affiliates,  foreign  direct  investment  and  international  trade  in 
services.    On  the  one  hand,  these  expansions  of  business  statistics  created  several  domain 
specific  uncoordinated  solutions;  on  the  other  hand  consistency  across  business  statistics 
domains  was  weakened  considerably.  In  addition,  challenges  to  remain  responsive  to  new 
user  needs  and  to  promote  efficient  and  modern  data  production  methods  were  not 
sufficiently  addressed.  For  instance,  complex  and  interrelated  phenomena  like  globalisation 
increase  the  need  for  better  linked  business  statistics,  which  is  difficult  to  achieve  in  the 
current  dispersed  system.  Namely,  the  current  legal  basis  governing  European  business 
statistics  is  spread  among  10  separate  legislative  acts  (See  Annex  VI).  This  legal 
fragmentation makes it very difficult to achieve a coordinated and consistent approach when 
it  comes  to  modifications  introduced  independently  of  each  other  to  individual  legal  acts. 
Furthermore, the need to limit administrative burden is recognised both at national and EU-
level,  it  is  also  a  fact  that  high  administrative  burden  leads  to  risks  of  decreasing  response 
rates which effect data quality.  

To  address  these  problems  the  European  Parliament  and  the  Council  adopted  in  2009  the 
MEETS programme. The two most important reasons for launching this programme were the 
need for cost reductions and for increasing the relevance of European business statistics. The 
results of this programme have helped to pinpoint the current problems. 

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The strategic challenges that European business statistics are facing have been also addressed 
by  the  Riga  Memorandum  adopted  by  the  ESS  Committee  in  September  2014.  The 
Memorandum  recognised  that  business  statistics  have  to  be  reviewed  on  a  regular  basis, 
their 
making  sure 
internationalisation  bearing  in  mind  the  importance  of  comparability  of  statistics.  The  Riga 
Memorandum also acknowledges that measuring of economic globalisation should be based 
on consistent and harmonised primary statistics on international transactions and businesses. 

the  changing  organisation  of  businesses  and 

they  reflect 

that 

A  new  framework  is  needed  that  is  more  flexible  and  more  responsive  to  emerging  user 
needs,  and  at  the  same  time  facilitates  the  use  of  modern  and  efficient  data  production 
methods which would allow for the reduction of administrative burden and cost-efficient data 
production.  A  framework  that  modernises  the  business  statistics  system  by  replacing  the 
current  dispersed  structure  with  a more  harmonised and  streamlined  one  and integrates  and 
replaces  ten  legal  acts  currently  in  force.  This  new  framework  should  also  establish  a  true 
collaborative system, allowing Member States the possibility to draw benefits and synergies 
for the production of business statistics in a more efficient way in the context of continuous 
reduction of resources both at national and EU-level. 

European  business  statistics  should  support  the  main  priorities  of  the  Commission  by 
providing more consistent and relevant data to monitor growth, job creation, competitiveness, 
research  and  innovation,  the  implementation  of  the  digital  single  market  as  well  as  the 
impacts of globalisation and the functioning of the internal market.  

This chapter describes the problems, that currently exist in business statistics and which the 
initiative  is  tackling,  their  causes  and  consequences.  The  consultations  of  the  relevant 
stakeholders allowed for defining the list of problems and possible causal relations between 
problem drivers, problems and their consequences. 

2.1  

Problem drivers  

The main problem drivers behind the shortcomings currently existing in the business statistics 
set-up are: 

•  Reduced relevance and responsiveness of European business statistics 
•  Legal fragmentation in business statistics 

2.1.1 Reduced relevance and responsiveness of European business statistics 

European  business  statistics  have  built  over  the  last  20  years  a  solid  information  system. 
However, the system needs an upgrade in terms of burden reduction possibilities, improved 
agility  and  responsiveness  to  new  demands.  The  current  legal  setting  is  focussing  on 
manufacturing  and  only  limited  information  is  available  on  the  services  sector,  which 
represents  roughly  70  %  of  the  value  added  in  the  EU  economy  since  years.    The  Single 

11 

 
 
 
 
 
 
 
Market and globalisation have led to increases in cross-border activities and changed the way 
businesses are organised; data to monitor these developments are insufficient at present.  The 
regional  dimension  should  not  be  forgotten  either,  better  understanding  of  business 
demography on the local level would help national authorities to monitor developments and 
take actions when needed. A legal frame which allows for satisfactory and timely responses 
to  changing  user  needs  is  fundamental  for  the  relevance  of  official  statistics  in  a  market 
which  has  increasing  competition  from  private data  providers  who  can  provide information 
quickly  and  without  regard  on  burden  on  businesses.  Emerging  information  needs  for 
measuring  and  analysing    new  phenomena  (like  globalisation),  and  the  growing  needs  for 
developing  new  statistical  indicators  increasingly  stretch  the  ESS  ability  to  respond 
adequately to those challenges. Namely, those issues confront the statistical system's ability 
to respond to the user needs with sufficient timeliness and maintaining high quality of data 
while working under tight budgetary constraints. Thus, the fragmentation and inconsistency 
existing across business statistics domains is hampering the responsiveness of the European 
business statistics and undermining its relevance.  

2.1.2 Legal fragmentation in business statistics 

The current numerous legal acts which govern the production of business statistics have been 
built up in a compartmentalised and uncoordinated manner. Thus, the statistical information 
on  European  businesses  is  regulated  and  produced  based  on  a  high  number  of  European 
legislative  acts  which  are  not  integrated  and  consistent  in  terms  of  data  requirements, 
concepts,  definitions  and  methods  as  well  as  statistical  processes.  The  current  system  also 
lacks agility to respond appropriately to emerging and changing policy or user needs. 

2.2 

Problems 

2.2.1 Lack of consistency   

Producing  statistics  following  the  current  compartmentalised  approach,  i.e.  where  each 
business  statistics  domain  is  covered  by  a  separate  legal  framework  (that  is  known  as  the 
stovepipe model) is no longer sustainable as it is too costly and does not allow providing the 
necessary agility when responding to emerging user needs. Main challenges to respond to are: 

•  The  main  stakeholders  are  demanding  more  and  better  information  on  topics  not 
sufficiently  covered  by  the  existing  business  statistics.  Better  measurement  of  the 
competitiveness,  performance  and  international  activities  of  businesses  is  necessary. 
To fulfil these needs and to provide a comprehensive and coherent picture, data from 
different sources have to be integrated. 

•  Business  statistics  are  also  crucial  input  for  other  statistics,  in  first  instance  macro-
economic  statistics  (e.g.  national  accounts).  Better  business  statistics  will  therefore 
also improve the quality of macro-economic data.    

12 

 
 
 
 
 
•  Statistical production processes are dispersed and non-integrated. More efficient and 
integrated  statistical  processes  should  overall  reduce  the  statistical  burden  on 
respondents, notably businesses, and the costs for national statistical authorities. 

•  While statistical production is organised nationally, businesses do not regard national 
borders  as  limits  to  their  activity.  On  the  contrary,  businesses,  even  SMEs 
increasingly engage in cross border trade and multinationals adjust their value chains 
in order to remain competitive and have sufficient presence in different markets. The 
Digital  Single  Market  will  further  intensify  those  developments.  Hence,  the 
international  and  global  activities  of  businesses  are  currently  not  sufficiently 
increasingly 
recognised  by  official  statistics  and  statistical  data  production 
necessitates  cooperation  also  between  National  Statistical  Authorities  in  different 
countries for better measuring the business activities. 

Modern  information  technology  and  standards  are  becoming  increasingly  important  for 
statistical production, in particular to ensure integrated production processes. Such integrated 
integrated 
production  processes  comprise  multi-source/cross-domain  data  sources, 
management  of  registers,  use  of  standards  and  shared  tools  for  data  exchange  and 
dissemination  as  well  as  a  standardised  quality  management.  These  requirements  are 
challenging the current system of European business statistics and the current legal setup. The 
present fragmented legislation is not able to respond to these requirements appropriately. This 
hinders  putting  in  place  modern  and  integrated  multi-source  production  and  dissemination 
processes. 

Stovepipe-based  business  statistics  and  legal  fragmentation  have  resulted  in  a  series  of 
deficiencies, such as: 

• 

lack  of  methodological  consistency  across  business  statistics  domains,  e.g.  with 
regard to statistical variables, statistical registers and confidentiality rules; 

•  different business surveys organised at national level are not integrated and therefore 

create additional burden; 

•  administrative data sources are not used systematically; 
•  micro-data is in general not exchanged among NSAs within the European Statistical 

System; 

•  considerable  burden  on  businesses  exists  for  collecting  intra-EU  trade  (imports  and 

• 

exports) statistics (Intrastat); 
statistics on the services sector, including international trade in services (e.g.by mode 
of supply or by enterprise characteristics), are insufficient and do not respond to user 
needs;  
inability to respond quickly to new and upcoming user needs  

• 
•  quality  of  the  data  on  SMEs,  globalisation  or  employment  needs  to  be  improved  to 

better serve the policy needs; 

•  data-linking  across  business  statistics  domains  is  now  very  cumbersome  or  not 

possible because of lack of coordination when organising surveys.  

13 

 
 
 
The  barriers  that  the  domain  fragmentation  creates  in  the  area  of  business  statistics  is 
underlined by the fact that a number of cross-cutting variables (i.e. variables used in several 
business statistics domains) have similar, but not entirely the same definitions. For instance, 
turnover  is  used  in  6  business  statistics  domains  (Structural  Business  Statistics,  Foreign 
Affiliate  Statistics  (  both  inward  and  outward  control),  Short  Term  Statistics,  Community 
Innovation  Statistics  and  ICT  statistics)6,  but  across  domains  there  are  differences  as  to 
include  or  not  subsidies  and  excise  duties.  The  definitions  used  also  deviate  from  the 
concepts used in business financial statements and therefore make the use of administrative 
data sources more difficult. 

Another  example  concerns  the  breakdowns  of  enterprise  populations  into  size  classes  of 
employment, which allow for an analysis of businesses of different sizes. The size classes of 
employment used in R&D and Innovation statistics have been determined on the basis of the 
number of employees whereas for other business statistics the number of persons employed7 
is  used.  As  a  result  data  from  other  business  statistics  such  as  value  added  from  structural 
business statistics for a certain size class is not consistent with related data of a similar size 
class for R&D expenditure. Users who need a complete overview of all data of a certain size 
class of enterprises cannot be served by the current business statistics.  

2.2.2 Lack of flexibility 

The scattered domain-specific regulations on European business statistics fix simultaneously 
the  statistical  policy  programming  and  its  technical  implementation.  This  mixture  of 
programming  (policy)  and  implementation  (technical  requirements)  in  the  current  legal 
architecture  reduces  the  efficiency  of  decision-making.  The  business  statistics  legislation 
currently in force often refers technical issues to the European Parliament and Council, with 
the  risk  of  diverting  the  attention  from  striking  the  right  balance  between  receptiveness  to 
European  information  requirements  and  the  underlying  costs  and  response  burden.  This 
results in legislative delays and rigidity. Those shortcomings could be overcome if European 
business  statistics  legislation  reflected  better  the  principle  of  division  of  responsibilities  as 
envisaged in the Lisbon Treaty. 

The basic idea is that the European Parliament and Council should focus on policy-relevant 
strategic decisions at the level of programming (what statistics are to be produced in order to 
shape the policy agenda of the EU and to assess progress), but the technical provisions (how 
to produce the statistics and the indicators needed) should as far as possible be defined within 
the European Statistical System according to the principles and rules set out within the EU's 

6 SBS- structural business statistics; FATS- foreign affiliates statistics; STS- short-term business statistics; CIS- 
community  innovation  survey  (innovation  statistics);  ICT-  information  and  communication  technologies 
statistics 

7 "Persons employed" comprises both the "employees" and the "self-employed" 

14 

 
 
 
                                                            
statistical law (Regulation 223/2009). This division of decision making should lead to both an 
accountable  and  responsive  statistical  programming  and  an  efficient,  integrated  data 
production and dissemination.  

Under  the  existing  incoherent  and  scattered  legal  bases,  changes  to  the  existing  data 
collections,  small  modifications  of  technicalities  or  additional  data  breakdowns  or 
methodological innovations are very time-consuming to introduce and their implications for 
other business statistics domains difficult to assess. This also impairs an adequate matching  
the of user needs.  

2.2.3 Limited possibilities for applying innovative methods and sources 

Modern statistical production comprises increasingly integrated business processes in order to 
exploit  the  strongly  growing  capacity  of  information  technology.  Such  integrated  business 
processes  comprise  e.g.  multi-source/cross-domain  data  integration,  integrated  management 
of  registers and  statistical  frames,  creation/maintenance  of  common  infrastructure,  common 
standards and shared tools for data processing, exchange and dissemination and standardised 
quality  assessments.  Usually, improvements  in  one  Member  State  could  be  implemented  in 
others,  leading  to  cost  reduction,  under  the  condition  that  processes  are  standardised.  The 
efforts on standardising the statistical business processes undertaken by Eurostat, the UNECE 
(United Nations Economic Commission for Europe) and the NSIs (such as the definition of 
the  Generic  Statistical  Business  Process  Model  -  GSBPM  -  and  the  Common  Statistical 
Production  Architecture  –  CSPA)  aim  for  increased  use  of  common  standards  and  shared 
tools for the production of statistics. 

The  existing  business  statistics  legislation  is  not  sufficiently  accommodating  the  increased 
necessity to use innovative data collection methods that could foster reductions in production 
costs.  Some  Member  States  are  regarding  the  lack  of  relevant  provisions  in  European 
legislation  as  the  main  barrier  towards  developing  and  applying  innovative  methods.  The 
difficulties  in  introducing  innovative  methods  and  alternative  sources  clearly  illustrate  the 
limitations of the current business statistics legal setup.  

Innovative methods for producing new indicators could either be national such as linking data 
from different business statistics domains or collaborative efforts within the whole ESS such 
as  reducing  costs  and  burden  by  exchanging  micro-data.  Pilot  exercises  regarding  data 
linking, in the area of innovation, ICT and the in the area of international out-sourcing have 
demonstrated that data linking is an efficient technique enriching the existing data at a minor 
cost  and  making  better  use  of  the  information  collected.  The  Enterprise  Group  Register 
established at Eurostat based on input from the National Statistical Institutes (NSIs) provides 
a valuable service and information source on the structure of enterprise groups to the national 
compilers  of  data  on  foreign  affiliates.  Further  collaborative  efforts  in  other  statistical 
domains would support cost savings and burden reduction.  

15 

 
 
 
 
2.2.4 Sub-optimal quality8 of statistical data  

Quality issues arise from the lack of coherence and comparability among data collections in 
business statistics, which again is due to the historical development of business statistics in 
separate  stovepipes  with  different  methodologies  and  production  processes.  These 
deficiencies in coherence and comparability are problematic for the data users. 

The legislation governing business statistics is mainly output-based, NSAs have the freedom 
to  adopt  different  approaches  and  methods  for  statistical  data  production  influenced  by  the 
specific national contexts and needs. Data are produced according to agreed definitions and 
quality  reporting  is  in  place  to  ensure  a  sufficient  level  of  quality  of  the  statistics 
disseminated at EU-level. However, especially in  domains  where  "mirror"  data is produced 
such  as  imports  and  exports  of  goods  and  statistics  on  foreign  controlled  enterprises 
inconsistencies are evident and even pronounced in some cases.  

An example from the International Trade in Goods Statistics (ITGS) could be taken. For the 
reference year 2012, the ITGS show Intra-EU asymmetries between (-) 38,9 % and (+) 9,7 % 
at Member State level for imports. As the data is used to support policy analysis and serve as 
input  for  national  accounts,  the  quality  of  these  figures  are  of  primary  concern.  FRIBS 
foresees the collection of one additional variable9 which has the potential to reduce the Intra-
EU asymmetries to a great extent.   

2.2.5 High burden on data providers  

The existing stovepipe model is not favourable to providing data on cross-cutting topics. On 
the contrary it creates redundancies and duplication of work. This parallel work structure has 
led  to  inefficiencies  such  as  unnecessary  costs  for  NSIs  and  increasing  burden  for  data 
providers.  The  European  Statistical  Advisory  Committee  (ESAC)  also  points  out  the 
necessity  to  reduce  the  burden  on  data  providers  and  encourages  better  coordination  of  the 
various surveys. At this stage the inconsistencies in the legal requirements for data production 
mean that surveys cannot be aligned and used for producing statistics for many domains with 
one  data  collection.  High  burden  on  data  providers  may  also  trigger  lower  response  rates 
which would hence affect negatively the quality of the aggregate data output.  

For example the surveys organised for Structural Business Statistics and those organised for 
the  Innovation  Statistics  are  hardly  integrated  in  terms  of  concepts,  definitions  or  data 
structures to be produced. This leads to an increase of burden on the respondents and higher 
costs for the NSAs (e.g. when the same enterprise receives both questionnaires). 

8 In the context of the European Statistical Law (Regulation (EC) No 223/2009), the criteria defining statistical 

quality are: relevance; accuracy, timeliness; punctuality; accessibility, comparability, coherence.  

9 Exchange of the importer’s VAT number i.e. the exchange of the identification number of the partner in the 
Member State of imports. The current legislation does not require the collection of such an ID number. 

16 

 
 
 
                                                            
2.3 

Link between problem drivers, problems and their consequences 

PROBLEM 
DRIVERS 

Reduced relevance 
and responsiveness 

Legal fragmentation in 
business statistics 

PROBLEMS 

Lack of consistency  

 Lack of flexibility 

Limited possibilities for 
applying innovative 
models and sources 

 Suboptimal quality of 
statistical data 

High burden on data 
providers 

CONSEQUENCES 

Rigidity of European 
business statistics 

Increasing 
inefficiencies in the 
production of business 
statistics 

Dissatisfaction of users 

Dissatisfaction of data 
providers (businesses) 

2.4  

Scale of the problem 

Currently  a  number  of  key  cross-cutting  variables  are  used  in  more  than  one  statistical 
domain. These variables (such as e.g. turnover or employment) have often different meanings 
according to the various business statistics domains. This strongly hampers the comparability 
of the data, prevents their optimal use and can even lead to misleading policy input.  

Moreover,  the  inconsistency  also  leads  to  inefficient  data  production  methods  as  synergies 
between data collections cannot be used and data collected for one domain cannot serve the 
production of indicators in another domain.  

The public consultation of users shows that 95% of respondents believe that inconsistencies 
have  a  negative  impact  on  the  quality  of  their  work  whereas  81%  indicate  this  increases 
significantly the time needed for exploiting the data. Moreover, 70% of respondents indicate 
having  already  experienced  difficulties  in  combining  data  from  different  business  statistics 
domains. 

17 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The quality and the usability of the business statistics disseminated at present would benefit 
from further efforts, as foreseen by FRIBS, to remove not only inconsistencies, but also from 
collaborative efforts to remove e.g. the asymmetries in the international trade in goods data 
mentioned above. 

Based on the results from the consultations of the relevant stakeholders, the estimated burden 
on businesses of the collection of the current business statistics is around EUR 689 million. 
Although the burden of collecting business statistics corresponds to just about EUR 1.4 per 
person in the European Union, the subjective perception of statistical burden is higher. One of 
the aims of FRIBS is to reduce the burden on businesses.  

The  Treaty  on  the  Functioning  of  the  European  Union  requires  the  co-legislators  to  adopt 
measures for the production of statistics where necessary for the performance of the activities 
of  the  Union.  In  this  regard  and  to  overcome  the  problem  as  described  above,  the  existing 
legal provisions would have to be harmonised with each other for reaching more consistency 
between  them.  FRIBS  aims  at  securing  this  consistency  over  time,  notably  by  avoiding  the 
risk that changes  will  be made  in  just  one of the statistical areas in the future. Last but  not 
least, the adjusted legal acts must be implemented in a harmonised way in the Member States.  

When considering the above-mentioned constraints it looks impossible to produce more and 
better  information  in  using  the  output  of  the  current  non-integrated  business  statistics 
domains.  In  any  case,  the  importance  of  business  statistics  goes  much  beyond  their  own 
statistical  area  and  serving  their  own  purposes.  Namely,  business  statistics  play  an  integral 
role for the production of National Accounts  key figures such  as  GDP.  The significance of 
European  business  statistics  is  also  substantiated  by  the  major  number  of  extractions 
registered  in  the  Eurostat  databases:  over  20  %  of  the  around  31  million  extractions  from 
Eurostat's databases during the period May 2015 - April 2016 concerned business statistics.    

2.5   What would happen without an intervention 

If no policy action is undertaken, all the above-mentioned problems of a scattered stovepipe 
system for statistical production of European business statistics will persist. The current non-
harmonised  legal  frame  and  the  sub-optimal  legal  decision-making  process  cannot  be 
significantly improved under the context of the currently dispersed and non-harmonised legal 
acts for European business statistics.  

Continuing  in  this  way  could  even  lead  to  deterioration  of  European  business  statistics  in 
terms  of  relevance,  consistency,  quality  or  costs  over  time.  Many  users  would  remain 
dissatisfied. Additional user requirements could only be fulfilled when additional surveys are 
launched  or  when  additional  non-integrated  data  sources  are  exploited.  This  makes  the 
system  not  only  more  costly,  but  also  rather  inflexible.  As  changes  would  be  done  in  an 
isolated manner in each statistical area and as these changes will add on to a non-harmonised 
system, the inconsistency of the production output would increase. Moreover, the costs and 
burden  for  producing  any  additional  business  statistics  would  increase  over-proportionally 
over time.  

18 

 
 
 
 
Due to the present limited cooperation in data production in the European Statistical System, 
the  measurement  of  complex  phenomena  like  globalisation  would  be  less  consistent  and 
informative,  namely  in  the  domains  where  "mirror  data"  is  produced  such  as  Intrastat  and 
FATS.  European  business  statistics  are  already  losing  relevance  and  would  increasingly  do 
so..  

The  loss  of  relevance  make  users  look  for  alternative  data  sources  covering  their 
informational  needs  outside  official  statistics.  This  has  several  consequences  for  all 
stakeholders.  Apart  from  the  additional  costs  for  users,  the  quality  related  commitments  of 
these alternative data sources differ from official statistics and as such may form a less secure 
basis for decision-making. Private data providers may launch data collections to produce their 
figures  without  regard  to  burden  created  on  businesses.    This  leads  to an  actual increase  in 
burden  on  businesses  perceived  as  administrative  burden.  Lower  relevance  of  official 
statistics  could  lead  to  further  budget  constraints  for  NSAs.  Possible  cost  savings  and 
reduction  of  burden  e.g.  resulting  from  an  increased  use  of  administrative  data,  merging 
questionnaires or from the exchange of micro-data cannot fully be realised with the current 
system.  

Table 2: risks and potential impacts to the current European business statistics system   

RISK 

PROBABILITY OF RISK 

IMPACT 

Increasing 
Inconsistency 

High. (As information needs increase, 
additional requests could be 
implemented inconsistently) 

- misleading and incomparable 

information 

- dissatisfaction of users 

Loss of relevance 

High. (As new information needs 
emerge, official statistics cannot 
adequately serve policy-makers). 

Increased costs and 
burden  

Normal to high. (Additional information 
needs will increase costs and burden 
over proportionally).  

Increasing inflexibility 

Low to high (Long and domain-scattered 
legislation process in order to address 
additional information needs)  

- inadequate information for policy-

makers 

- decrease of means for official 

statistics as  it does not meet the  
needs of policy-makers 

- Lack of modernised and 

collaborative way of data 
production will hamper responding 
to new information needs 

- dissatisfaction/burden of data 

providers  

- users get their evidence base too 

late 

- users may look for other sources 

outside official statistics 
-  policy might be misguided  

Furthermore, some of the existing legal frameworks, such as the framework governing the 
production of ICT statistics is subject to a sunset clause which will expire in 2018.  

19 

 
 
 
 
 
 
 
 
3. 

WHY SHOULD THE EU ACT: RESPECT OF SUBSIDIARITY PRINCIPLE 

Article 338 of the Treaty on the Functioning of the European Union provides the legal basis 
for the EU legislators to adopt measures for the production of statistics where necessary for 
the performance of the activities10 of the Union. Reliable and comparable statistics are needed 
to underpin the planning and the monitoring of the implementation of Union policies.  

The  Commission  (Eurostat)  cannot  work  alone  to  provide  the  necessary  statistics.  The 
European Statistical System (ESS) is the partnership between the Union statistical authority, 
which  is  the  Commission  (Eurostat),  and  the  national  statistical  institutes  (NSIs)  and  other 
national  authorities  responsible  in  each  Member  State  for  the  development,  production  and 
dissemination  of  European  statistics.  The  ESS  is  established  by  Regulation  (EC)  No 
223/2009  on  European  Statistics.  The  Member  States  ensure  the  actual  compilation  of 
statistical information at the national level. For the compilation of statistics at European level, 
a harmonised methodology and the definition of a common output to be delivered by Member 
States are indispensable in order to guarantee the required high quality statistics necessary to 
support the Union policies and robust decision-making. As the difference in methodology is 
not  only  caused  by  the  diversity  of  statistical  domains,  but  also  by  heterogeneous 
methodology  in  Member  States,  attaining  harmonised  methodology  can  be  fully  achieved 
only by way of EU action. The proposed Regulation will guarantee the required data quality 
e.g.  in  terms  of  coherence  and  comparability  of  the  business  statistics  relevant  for  the 
activities of the Union.  

Only  the  Commission  (Eurostat)  is  in  a  position  to  propose  the  necessary  measures  for 
harmonisation  of  statistical  information  across  Member  States  and  produce  harmonised 
business statistics  at  the European level on the basis of the data compilation  carried out  by 
Member States. Consequently, the European Union may adopt measures in accordance with 
the principle of subsidiarity as set out in Article 5 of the Treaty on European Union (TEU). 
Thus, the proposed EU action is fully justified.  

Although  this  reasoning  is  also  valid  for  all  other  domains  where  statistical  information  is 
needed for EU policy-making and monitoring, specific phenomena of business statistics are 
transnational or increasingly global. These cannot be adequately addressed by actions on the 
Member States level alone. Better monitoring of globalisation, based on a better knowledge 
of multinational enterprises and their activities, can only be done at European level. Also the 
structured  and  regular  exchange  of  micro-data  between  Member  States,  which  is  needed  to 
alleviate the burden on businesses, can only be established at the EU level. 

Businesses  undertake  production,  sales,  research  and  development  where  it  is  the  most 
advantageous  and  not  necessarily  within  certain  national  borders.  This  has  to  be  taken  into 

10 There is a whole range of EU policy areas whose development and monitoring of implementation relies on 
data  covered  by  the  business  statistics  domain:  e.g.-  employment,  competitiveness,  innovation,  trade, 
industry, regional, economic and monetary policy. 

20 

 
 
 
 
                                                            
account by statisticians. A correct statistical picture of the European economy can no longer 
be  given  by  simply  adding  up  national  figures.  This  underpins  the  need  for  a  uniform  and 
coordinated EU action. 

4. 

OBJECTIVES 

Effective tackling of the issues defined under Chapter 2 would necessitate a more robust and 
streamlined  legislative  framework  for  European  business  statistics  that  should  ensure 
comparability and coherence of data in the future.  

Three types of objectives are distinguished: general, specific and operational (or "measures"). 
Firstly,  the  general  objectives  indicate  why  a  policy  action  is  needed  and  are  defined  by 
taking  into  account  the  different  aspects  of  the  problem.  Within  this  general  framework, 
specific and operational objectives are then identified, illustrating respectively what should be 
done to reach these general objectives, and how this should be done in practice.  

With  a  view  of  achieving  the  identified  objectives  and  ultimately  solving  the  problem,  a 
number of different policy options are set out and analysed in the following chapters.  

4.1  General objectives and links to horizontal EU objectives 

In order to define the general objectives of the policy initiative, a broader view of the general 
long  term  EU  policies  is  taken  within  which  the  initiative  should  be  placed.  More 
specifically, the monitoring of the goals set through the Juncker Commission 10 priorities 
requires harmonised and comparable European statistics to design policy initiatives to meet 
the priorities and to monitor the implementation of these initiatives. 

Furthermore, the EU 2020 Strategy envisages a Europe that would "be turned into a smart, 
sustainable  and  inclusive  economy  delivering  high  levels  of  employment,  productivity  and 
social  cohesion".  Monitoring  the  objectives  set  by  the  strategy  requires  an  information 
capacity that can deliver high quality, reliable and integrated European business statistics. 

Moreover,  ESS  Vision  2020  strategy  invigorates  the  modernisation  activities  on  European 
statistics,  already  started  in  2009  with  the  MEETS  programme.  The  ESS  Vision  2020 
recognises the need to address emerging policy requirements for new statistical indicators and 
calls for the more integrated and deeper analysis of new phenomena (such as globalisation) 
and for better serving EU policies with  high economic or  social  impact (e.g.  trade or  R&D 
policy).  

The  Commission’s  initiative  on  Smart  Regulation  underlines  that  the  evaluation  of  EU 
policies  would 
increasing  need  for  more  relevant  data  (Commission 
Communication  COM  (2013)  686  "Strengthening  the  foundations  of  Smart  Regulation  – 
improving evaluation"). 

to  an 

lead 

21 

 
 
 
 
 
The  FRIBS  is  one  of  the  key  initiatives  of  the  Commission's  Regulatory  Fitness  and 
Performance  programme  (REFIT).  In  that  respect,  it  aims  to  increase  the  relevance  of 
business  statistics,  streamline  and  simplify,  facilitate  the  use  of  modern  and  efficient  data 
production methods which would allow for the reduction of burden and costs in the long run. 

The European Statistical Programme (ESP) 2013-2017 defines business statistics as one of 
the  three  pillars  of  the  European  Statistical  System.  The  ESP  underlined  that  business 
statistics  need  to  support  the  decision-making  process  and  help  European  citizens  and 
businesses  understand  the  impact  of  EU  policies,  focused  on  European  businesses  with  an 
increasing need for detailed and harmonised statistics. Addressing globalisation, the ESP also 
envisaged among its objectives to enhance the indicators and statistical information available 
for better measuring economic globalisation and global value chains. This should be done by 
better analysing the global value chains through foreign trade and business statistics, in also 
linking the statistical micro-data.  

The FRIBS objectives set out below are fully in line and coherent with the objectives of the 
ESP relating to European Business Statistics. In particular, the ESP emphasises the need for 
more  efficiency  and  effectiveness  of  statistical production processes;  the  provision  of  high-
quality statistics; the requirements to reduce the administrative and reporting burden. 

The  European  Statistical  System  Committee's  Riga  Memorandum  recognises  the 
strategic challenges  that the business  statistics is  confronted with  and the need  for business 
statistics to be reviewed regularly so that comparability and relevance of data is guaranteed. 
The  Riga  Memorandum  confirms  that  measuring  of  economic  globalisation  should  be 
anchored  on  consistent  and  aligned  primary  statistics  on  international  transactions  and 
businesses. 

Given this context, the general objective can be formulated as follows: 

  streamline and rationalise the European business statistics in order to better respond to 
the changing user needs; simplify the respective European legislation; modernise and 
increase the efficiency of the production and dissemination of high quality European 
business  statistics  to  make  it  fit  for  the  future,  while  at  the  same  time  adhering  to 
impartiality,  reliability,  objectivity,  scientific  independence,  cost-effectiveness  and 
statistical confidentiality.11 

4.2 

Specific objectives 

From the general objective defined above, five specific objectives can be derived: 

 

Improve consistency; 

11 As provided for by Art 338 TFEU 

22 

 
 
 
 
 
 
 
                                                            
  Enhance flexibility; 
  Facilitate the use of innovative methods and sources; 
  Ensure quality of data production; 
  Reduce unnecessary burden on data providers. 

The  specific  objectives  listed  above  can  be  further  translated  into  a  number  of  operational 
objectives. The operational objectives would be defined on the basis of the policy options that 
will be set out in Chapter 5 of this report. 

OPERATIONAL 
OBJECTIVES 

See Chapter 8 

GENERAL OBJECTIVES 

SPECIFIC OBJECTIVES 

1. Streamline and 
rationalise the European 
business statistics; 

2. Simplify the respective 
European legislation; 

3. Modernise and increase 
the efficiency of the 
production and 
dissemination of high 
quality European business 
statistics 

1. Improve consistency; 

 2. Enhance flexibility; 

3. Facilitate the use of 
innovative methods and 
sources; 

4. Ensure quality of data 
production; 

5. Reduce unnecessary 
burden on data providers. 

5. 

POLICY OPTIONS 

In order to solve the problem described in Chapter 2 Eurostat has considered several policy 
options to achieve the objectives set out in Chapter 4.  

23 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
5.1 

List of policy options 

As a result of the consultations of stakeholders that took place in the context of the impact assessment 
and the extensive discussions with Member States, the following list of policy options, on which the 
detailed qualitative and quantitative assessment will focus, has been defined:  

  Option A - Baseline scenario – no EU policy change; 
  Option B - Implement legislative actions limited to certain business statistics domains, 

including alternative options for the modernisation of Intrastat. 

  Option C - Modernisation of business statistics in a single framework (FRIBS) using a 
mix of measures, including alternative options for the modernisation of Intrastat.  

5.1.1   Baseline scenario – no EU policy change (Option A) 

No  action  is  taken  and  therefore  the  current  legal  framework  of  business  statistics  divided 
into  10  heterogeneous  legislative  acts  with  the  shortcomings  described  previously  would 
continue to exist.  

This  option  A  refers  to  the  baseline  scenario  without  any  EU  policy  change  and  does  not 
require any particular measure or action.  

5.1.2  Implement legislative actions limited to certain business statistics domains, 
including alternative options for the modernisation of Intrastat. (Option B) 

This  option  would  implement  the  inclusion  of  additional  data  requirements,  the  identified 
simplifications  of  the  data  requirements  and  certain  modernisation  of  the  statistical 
production  facilitating  reduction  of  burden  on  data  providers  and  minimisation  of  costs  for 
data  compilers  through  separate  amendments  to  the  10  legislative  acts  currently  existing  in 
the  area  of  business  statistics.  This  option  requires  the  use  of  different  legal  instruments  to 
modify existing legislation on certain business statistics domains. Depending on the scope of 
the changes and the procedures foreseen in each individual legal act, an ordinary legislative 
procedure  or/and  the  adoption  by  the  Commission  of  delegated  or/and  implementing  acts 
would be necessary. 

For  the  collection  of  statistics  on  intra-EU  trade  (Intrastat),  this  option  B  includes  four 
possible sub-options - SIMSTAT, Revised Intrastat, Single Flow and a combination between 
SIMSTAT and Revised Intrastat (explained below in 5.1.3)). 

5.1.3  Modernisation of business statistics in a single framework (FRIBS) using a mix 
of measures, including alternative options for the modernisation of Intrastat (Option C) 

The structure of the framework integrating business statistics (FRIBS) project is designed in a 
modular way, with the different components being discussed at different levels and adopted 
by different means:  

24 

 
 
 
 
 
On the one hand, all infrastructural elements would be part of a framework Parliament 
- 
and Council Regulation. This would cover the business registers (including the EuroGroups 
Register), the basic data topics and their periodicity, the data sources, the exchange of micro-
data  for  Intrastat,  data  transmission,  data  quality,  data  confidentiality,  etc.  This  framework 
legal  text  would  repeal  the  existing  regulations  for  the  various  business  statistics  domains 
which will then be integrated into FRIBS.  

On  the  other  hand,  non-essential  elements  can  be  supplemented  or  amended  by 
- 
delegated acts (e.g. detailed topics for all business statistics and for business registers as well 
as  subjects  and  characteristics  of  the  dynamic  statistics-  ICT,  CIS,  GVC12),  while  the 
technical  provisions  (e.g.  detailed  data  requirements  in  terms  of  for  instance,  breakdowns, 
statistical populations etc. , data quality reports and the technical provisions for the exchange 
of data and micro-data) will be part of implementing acts. The procedure for the adoption of 
these provisions will be included in the framework Parliament and Council Regulation.. 

Similarly  to Option  B, for the collection  of Intrastat  statistics four sub-options  to  lower the 
burden  on  data  providers  are  considered  (SIMSTAT,  Revised  Intrastat,  Single  Flow  and  a 
combination between SIMSTAT and Revised Intrastat).  

Thus,  for  Intrastat,  option  C  (like  option  B)  is  sub-divided  into  the  following  four  sub-
options:  

Option C1: SIMSTAT –exchange of micro-data 

Under  the  SIMSTAT  sub-option,  Member  States  remain  responsible  for  compilation  and 
transmission of statistics on both intra-EU exports and imports. The novelty of the SIMSTAT 
approach in comparison to current Intrastat is the creation of an additional data source. Each 
Member  State  collects  data  on  intra-EU  exports  and  makes  it  available  to  other  Member 
States  via  a  hub.  Each  transaction  reported  in  one  Member  State  may  thus  serve  as  a  data 
source for two Member States: for compiling the intra-EU exports of the exporting Member 
State, and for compiling and/or verifying the intra-EU imports of the partner Member State. 
To  enhance  the  reusability  of  exports  data,  it  is  foreseen  that  it  will  need  to  have  a  quality 
requirement  on  the  collected  trade  (97  %  like  currently)  and  also  information  on  the 
importing  company  (VAT  number  of  partner  operator)  and  country  of  origin  of  goods.  For 
import statistics quality requirements will be for the statistical output rather than for the input 
(collection), making it possible to use either national data collection on imports or exchanged 
exports data or a combination of both. 

Option C2: Revised Intrastat 

12 GVC – Global Value Chains statistics 

25 

 
 
 
 
                                                            
 
Revised Intrastat means continuation of the current Intrastat system in a simplified form, but 
adjusting the coverage requirements. In this option Member States will need to compile and 
transmit  to  Eurostat  statistics  on  both  intra-EU  exports  and  imports  like  they  do  currently. 
Less  data  will  be  collected  from  both  companies'  flows  or  for  either  of  the  two  flows, 
depending  on  the  final  parameters  of  this  option.  The  quality  requirements  will  be  defined 
either  through  the  amount  of  collected  data  or  through  the  statistical  output.  This  option 
foresees  neither  mandatory  exchange  of  micro-data  nor  collection  of  new  data  from 
exporters. 

Option C3: Single flow 

Single flow differs from the other two options in the sense that Member States will need to 
compile  and  transmit  to  Eurostat  statistics  only  on  intra-EU  exports.  The  corresponding 
imports  statistics  are  created  by  mirroring.  Consequently,  this  option  foresees  no  data 
collection on intra-EU imports. A quality requirement based on the amount of collected data 
is maintained for the exports flow (97 %). This option foresees neither mandatory exchange 
of micro-data nor collection of new data from exporters. 

Option C4: Combination of SIMSTAT and Revised Intrastat 

At  the  beginning  of  the  so-called  REDESIGN  of  Intrastat  project  these  three  different 
approaches for Intrastat have been considered separately in order to assess their impacts. The 
results  from  the  extensive  consultation  exercise  on  Intrastat  (and  more  specifically  the 
analysis of costs and benefits for NSIs) revealed that Single Flow is not a viable option for 
MSs due to serious quality problems. On the basis of these assessments the preferred option 
for Intrastat is going to be the combination of sub-options C1- SIMSTAT and C2- Revised 
Intrastat,  as  decided  by  the  ESSC  in  May  2016,  in  order  to  maximise  the  benefits  while 
mitigating  the  risks  and  costs.  The  ESSC  decision  was  to  combine  elements  from  the 
SIMSTAT option (mandatory exchange of micro-data) and from the Revised Intrastat option 
(more flexibility in the choice of data sources used). 

Discarded options  

5.2 
Taking  into  account  the  broad  list  of  existing  preliminary  policy  options,  and  against  the 
background  of  the  results  from  the  stakeholder  consultations,  an  initial  analysis  was  firstly 
carried  out  regarding  the  overall  practicability  of  all  options.  The  goal  was  to  identify  any 
options  that  are  considered  unsuitable,  so  as  to  discard  them  from  the  detailed  assessment. 
This analysis has led to the conclusion that the three options set out below are not suitable for 
further assessment and were discarded. Additionally, it should be clarified that a  horizontal 
recast  of  the  ten  existing  legislative  acts  governing  European  Business  Statistics  (as  an 
alternative  to  a  framework  regulation)  has  not  been  suggested  as  an  option  during  the 
stakeholders'  consultation.  The  reason  for  that  was  the  guidance  provided  by  the 
Interinstitutional  agreement  ((2002/C  77/01))  setting  up  the  rules  for  the  use  of  recasts  and 
stipulating that: 
 "A new legal act shall not constitute a recast act if, …, it makes substantive amendments to 
all the provisions of the earlier act, which it replaces and repeals."  

26 

 
 
 
 
The  undertaken  initiative  to  modernise  and  streamline  European  Business  statistics 
necessitates  substantive  amendments  to  the  provisions  of  the  legislative  acts  currently  in 
force. That is why a framework regulation has been suggested instead of a recast. 

5.2.1  Better enforcement and implementation of existing legislation (the Statistical 
Unit Regulation- "Council Regulation 696/93") (Option B in the IAA) 

In  line  with  the  Impact  Assessment  Guidelines,  an  option  on  the  better  enforcement  and 
implementation of existing legislation, possibly with improved guidelines should always be 
considered.  Current  compliance  by  Member  States,  with  existing  legislation  in  the  field  of 
business statistics, is generally very good. This however is less the case for application of the 
Statistical  Unit  Regulation  (Council  Regulation  696/93)  in  the  different  business  statistics 
domains  for  which  implementation  problems  can  be  observed  in  many  Member  States. 
Currently, most of the Member States assume that legal units are identical to enterprises and 
thus take a juridical/administrative view instead of an economic view. This is not in line with 
the organisational development of the economy. Many enterprises consist of more than one 
legal  unit.  Moreover,  several  Member  States  have  indeed  implemented  the  Statistical  Unit 
Regulation, but not in a uniform way. Inconsistencies resulting from different applications of 
the  Statistical  Unit  Regulation  have  a  considerable  impact.  The  enterprises  stored  in  the 
national  business  registers  are  not  harmonised  across  countries  and  the  resulting  business 
statistics could be distorted. As mainly large entities are concerned, changes to the business 
statistics  due  to  the  harmonised  implementation  of  the  Statistical  Unit  Regulation  are 
expected to be significant. 

This  option  therefore  focusses  mainly  on  improving  the  application  of  the  Statistical  Unit 
Regulation (Regulation No 696/93).  

However, given the serious impacts of the non-compliance or non-uniform compliance with 
the Statistical Unit Regulation and the urgent need to tackle this issue, a decision was taken at 
the end of 2014 to immediately address the issue and support further Member States' efforts 
in better complying with the existing Statistical Unit Regulation through national action plans 
supported by EU grants and by clarifying existing definitions through developing operational 
rules.  These  action  plans  have  already  been  put  in  place  and  are  supposed  to  lead  to  full 
compliance  with  the  Statistical  Unit  Regulation  and  to  quality  improvements  of  European 
business statistics. Therefore, for the time being no further non-legislative measures could be 
implemented to improve the business statistics. All in all, due to the measures already taken 
to improve the application of the Statistical Unit Regulation, this option has become obsolete.   

5.2.2  Integration of business statistics in a single framework (FRIBS) using a mix of 
measures and including one option (SIMSTAT) for the modernisation of Intrastat 
(Option D in the IAA) 

27 

 
 
 
 
 
This  option  would  implement  the  simplification  (burden  and  cost  reduction)  and 
modernisation as well as respond to additional user needs. In addition, it would allow for the 
alignment and harmonisation of the collection, compilation, transmission and dissemination 
of business statistics, with a much more integrated and cross-cutting output for users.   

This option also envisages that clearer and better implementable definitions of the statistical 
units  will  be  included  in  FRIBS.  Regarding  the  modernisation  of  intra-EU  trade  in  goods 
statistics this option only encompasses SIMSTAT. 

Thus,  this  option  is  characterised  by  two  major  shortcomings.  Firstly,  (as  also  explained 
under  5.2.1)  due  to  the  serious  impacts  of  the  non-compliance  with  the  Statistical  Unit 
Regulation and the urgent need to address the problem, measures have already been taken to 
address  the non-compliance  and  support  further Member  States'  efforts  in  better  complying 
with  the  existing  Statistical  Unit  Regulation.  Therefore  this  option  has  become  obsolete  in 
terms of its objective to include in FRIBS better implementable definitions of the statistical 
units. Secondly,  limiting the  modernisation of Intrastat  only to  the SIMSTAT sub-option is 
too  restrictive.  The  NSA  consultations  have  demonstrated  that  different  alternatives  for  the 
modernisation of Intrastat should be considered, (SIMSTAT, Revised Intrastat, Single Flow, 
or  a  combination  of  them).  Consequently,  it  is  better  to  allow  for  an  analysis  covering  all 
three sub-options for the modernisation of Intrastat. Against this background, this option has 
been discarded.    

5.2.3  Implementation of a non-legislative strategy for the rationalisation of the 
statistical production of business statistics and the reduction of the burden on 
businesses 

This  option  would  focus  on  the  better  management  of  the  production  of  business  statistics 
from  the  procedural  point  of  view,  looking  for  synergies  in  the  collection  and  compilation 
processes,  enhancing  the  access  and  exploitation  of  existing  administrative  sources  and 
promoting the use of modern tools. This option would require the use of agreements between 
Eurostat  and  the  NSA  or  any  other  kind  of  bilateral  or  multilateral  instruments  outside  of 
legislation. 

However,  given  the  various  pieces  of  legislation  underpinning  the  European  system  of 
business statistics, not many corrective actions could be undertaken without revising one or 
more  elements  of  the  legal  texts.  For  instance,  definitions  are  mainly  fixed  by  legislation, 
which  means  that  reducing  the  existing  inconsistencies  in  definitions  of  certain  variables 
would  imply  reviewing  legislation.  This  would  be  contradictory  with  the  non-legislative 
nature of the policy option under consideration and this is why this option has been discarded. 
Additionally,  the  exchange  of  micro-data  for  intra-EU  trade  in  goods  statistics  (Intrastat), 
which  has  a  considerable  potential  for  burden  reduction  on  EU  businesses,  could  not  be 
undertaken unless a legal framework is  put in  place. Furthermore, the budgetary provisions 
for  the  statistical  production  of  the  NSAs  are  determined  on  the  basis  of  legislative  acts, 

28 

 
 
 
hence any initiatives which have cost impacts would be difficult to implement without a legal 
frame.    

 6. 

IMPACTS OF THE POLICY OPTIONS 

Each of the shortlisted policy options presented in Chapter 5 has been assessed on impact of 
the  actions  on  specific  stakeholders  (data  users,  data  providers  –  businesses  -,  and  data 
compilers). These assessments use on the one hand detailed qualitative information collected 
from  the  stakeholders  and  on  the  other  hand  quantitative  information  collected  from  data 
providers and data compilers. Given the fact that all expected benefits e.g. from the improved 
availability of data could not be monetised, an overall 'net benefit' in monetary terms cannot 
be obtained for each of the policy options. 

Impacts Option A: Baseline scenario: no EU policy change  

The baseline scenario foresees a continuation of the current system in terms of legislation, as 
well  as  the  structure  and  practices  of  the  collection,  compilation,  transmission  and 
dissemination  of  statistical  information  on  Member  States'  economic  activity  of  businesses. 
No action is undertaken to improve the degree of consistency of business statistics across the 
EU  and  their  quality,  nor  are  attempts  made  to  alleviate  administrative  burden  on  data 
providers.  The  problems  encountered  in  the  current  situation  continue  to  persist,  as  the 
current  stovepipe  approach  is  not  adapted  anymore  to  the  changes  in  the  business 
environment and changing user needs. Flexibility to more adequately and timely respond to 
these needs is not improved and it is not possible to use new methods or procedure to fulfil 
these new user needs. 

Based on the results of the stakeholders' consultations, the total cost of the production of the 
business  statistics  by  the  NSAs  is  estimated  to  be  EUR  290  million  annually  and  the  total 
burden by data providers at EUR 689 million.   

Effectiveness  of  fulfilling  the  objectives  of  this  policy  initiative  and  impact  on 
stakeholders 

This  option  does  not  fulfil  any  of  the  objectives  set  for this  policy  initiative.  The  problems 
identified under chapter 2 e.g. the lack of responsiveness of business statistics would remain 
unresolved. 

Efficiency  

The  combination  of  domain-specific  Regulations  and  non-integrated  production  processes 
contributes  to  inefficiencies  of  the  business  statistics  system.  The  current  system  maintains 
overlaps and redundancies in data compilation. The non-integrated system limits the potential 

29 

 
 
 
 
 
for  NSI  or  Eurostat  to  reduce  such  overlaps.  The  current  system  cannot  really  eliminate 
inefficiencies.  As  there  will  not  be  any  change  to  the  statistical  system,  no  additional  costs 
(for redevelopment and adaptation of the statistical system) for NSI are expected in the short 
term on top of the current running costs for maintaining the system.  However, possibilities to 
address current inefficiencies would be limited. 

Changes  to  the  sources  used  for  compiling  the  statistics  will  be  limited  as  access  to 
administrative sources will remain at its current level and the use of alternative sources such 
as big data and new procedures such as data linking will not be possible. The burden on the 
data providers will remain unchanged. The relevance of statistical information  will become 
increasingly obsolete. 

Coherence 

The  baseline  scenario  is  not  coherent  with  the  European  Statistics  Programme  2013-2017 
(and its ongoing extension) since the ESP already envisaged a number of modernisations and 
extensions of data collection in business statistics which would not be able to be put in place 
without a policy change - under this Option A. 

Option B: Implement legislative actions limited to certain business statistics domains  

The second policy alternative Option B foresees the amendment of some or all of the current 
legal  acts  in  force.  Hence,  current  data  requirements  could  be  simplified  with  the  aim  of 
reducing  the  cost  of  the  NSIs  and  the  burden  on  data  providers.  Also  additional  new  data 
requirements  can be  added for better  satisfying  the user needs.  All this would be organised 
through  updates  of  the  separate  legislative  acts  currently  in  use  for  business  statistics. 
Consequently, the production processes at Member State level may continue to be organised 
by different statistical domains.  

However,  the  streamlining  and  harmonisation  across  all  business  statistics  would  hardly  be 
achieved.  Separate  legal  texts  and  separate  statistical  production  processes  would  provide 
neither the necessary consistency across statistical domains nor allow for an integration of the 
collection, compilation, transmission and dissemination of business statistics. In addition, this 
option would not permit the users to use the statistical output in an integrated way. 

Effectiveness  of  fulfilling  the  objectives  of  this  policy  initiative  and  impact  on 
stakeholders 

This  option  may  fulfil  most  of  the  pre-identified  objectives.  In  fact,  a  series  of  distinct 
legislative  changes  enables  streamlining  and  rationalising  the  production  of  business 
statistics,  somewhat  reducing  unnecessary  burden  on  data  providers.  These  changes  could 
also  incorporate  the  provision  of  EU-wide  common  infrastructure  tools  (e.g.  business 
registers) to increase overall quality, accuracy and comparability of business statistics..  

30 

 
 
 
 
The  legislative  changes  foreseen  under  this  option  significantly  impact  all  categories  of 
stakeholders. This option opens up some possibilities for data compilers to use and combine 
new/innovative  methods  for  data  compilation.  It  also  allows  for  improving  the  production 
processes  and  statistical  output  quality  to  a  certain  extent.  The  maintenance  of  the  various 
domain-specific  Regulations  in  fact  hampers  the  possibilities  to  introduce  and  fully  apply 
innovative  methods,  and  as  such,  also  has  an  impact  on  the  efficiency  of  the  underlying 
statistical  processes.  The  maintenance  of  fragmented  production  processes  and  data 
collections  at  the  level  of  Member  States  counterweights  the  increased  consistency  which 
eventually could be achieved through this option. If Eurostat continues to request data from 
Member  States  using  the  traditional  fragmented  stovepipes,  NSIs  will  continue  to  have 
insufficient resources for modernising their systems.  

This option does not reduce the fragmentation of the business statistics system and it will not 
fully  serve  the  user  looking  for  consistent  business  statistics.  The  existing  domain-specific 
Regulations  require  Eurostat  to  apply  similar  or  identical  concepts,  methods  and  standards 
across  domains  for  ensuring  the  quality  of  the  output  across  the  various  domains  and  for 
increasing its comparability. There is a certain degree of hampering of desired results in view 
of  the  fact  that  coordination  of  implementation  between  statistical  domains  and  with  other 
operational  objectives  is  not  optimised  (which  e.g.  impacts  on  opportunities  for  re-use  and 
linking of data). This is not only a temporary effect but rather a continuous shortcoming. For 
instance, the removal of inconsistencies in the definitions of variables would create additional 
possibilities for improved re-use of data. In a non-integrated approach these inconsistencies 
are  not  necessarily  solved  in  a  sustainable  way  (e.g.  there  is  a  risk  they  will  diverge  again 
after future adaptations of the separate legal acts), so that the re-use of data in the long run is 
not  sufficiently  ensured.  Unnecessary  overlaps  and  redundancies  in  the  data  collections 
would  remain.  The  continuing  legal  fragmentation  would  therefore  still  hamper  Eurostat’s 
possibilities to ensure the quality of produced data in terms of comparability and coherence. 
Due to the need to amend domain specific regulations, also this option has considerable limits 
in responsiveness to changing user needs arising from societal changes.  

In  addition,  any  European  level  future  changes  to  the  contents  of  the  data  compilation  and 
data output to better satisfy users’ needs will be required to be legally incorporated across the 
10  domain-specific  legislative  acts,  through  separate  legal  procedures.  This  multiplies  the 
efforts  and  resources  needed  for  preparing  and  managing  these  legal  processes.  For  this 
reason, considerable limits in responsiveness to business and societal needs at the EU level 
continue to be in place. This policy option therefore does not improve the responsiveness of 
business statistics to user needs.  The national production processes would only be integrated 
across  statistical  domains  as  far  the  data  requirements  are  kept  consistent  over  possible 
changes  to  individual  legal  acts.  All  in  all,  this  option  might  achieve  some  degree  of 
harmonisation  across  the  10  different  business  acts,  however  this  would  be  a  cumbersome 
and partial solution only.       

31 

 
 
 
 
 
Efficiency 

Assuming that all of the existing legal acts would be amended, current user needs could be 
addressed  in  a  satisfactory  manner.  Given  that  new  data  requirements  would  be  added, 
investment  costs  to  adapt  the  current  systems  and  increases  in  the  initial  operational  costs 
would  be  incurred..  Bringing  non-harmonised  solutions,  this  option  B  would  reduce  the 
existing inconsistencies (present under the baseline scenario), but only to a limited extent. 

The additional implementation costs for NSAs will be partly offset by simplifications to the 
data requirements and from the modernisation of Intrastat. The additional costs, incurred by 
NSAs, for implementing this policy option are estimated to represent an annual increase on 
average per Member State by: 

  6.8 % (or EUR 700 000) of the annual operating costs for sub-option B1 (SIMSTAT); 
  6.7  %  (or  EUR  691  000)  of  the  annual  operating  costs  for  sub-option  B2  (Revised 

Intrastat); 

  4.3  %  (or  EUR  436  000)  of  the  annual  operating  costs  for  sub-option  B3  (Single 

Flow); 

  Between  6.7  %  (or  EUR  691  000)  and  6.8  %  (or  EUR  700  000)  of  the  annual 
operating costs for sub-option B4 (combination of SIMSTAT and Revised Intrastat) 

The estimated one-off investment costs per Member State are: 

  EUR 1.9 million for sub-option B1 (SIMSTAT); 
  EUR 1.25 million for sub-option B2 (Revised Intrastat); 
  EUR 1.16 million for sub-option B3 (Single Flow); 
  Between EUR 1.25 million and EUR 1.9 million for sub-option B4 (combination of 

SIMSTAT and Revised Intrastat) 

Applying a cost model (See Annex IV) for calculating the net present value of the total EU-
28 costs (NSIs' one-off investment costs + NSIs' annual implementation costs) over a 10-year 
implementation period, the following results have been obtained: 

sub-option B1: net cost increase of EUR (+) 103 million, 

sub-option B2: net cost increase of EUR (+) 83 million; 

sub-option B3: net cost increase of EUR (+) 29 million; 

sub-option B4: between minimum net cost increase of EUR (+) 83 million and maximum net 
cost increase of EUR (+) 103 million. 

32 

 
 
 
 
The  new  data  requirements  foreseen  would  increase  the  burden  on  the  respondents  (data 
providers). In order to off-set this increase in burden, simplifications would be introduced in 
the  existing  requirements  of  several  business  statistics  regulations.  Especially 
the 
simplifications  or  collaborative  ways  of  data  production  foreseen  in  statistics  on  intra-EU 
trade  (Intrastat)  would  enable  the  Member  States  to  materialise  the  untapped  potential  for 
burden reduction on data providers. The extent of the burden reductions will depend on the 
way  the  final  combination  of  sub-options  chosen  for  the  modernisation  of  Intrastat  is 
implemented  by  each  Member  State  following  the  subsidiarity  principle.  However,  under 
each  of  those  sub-options,  the  burden  reduction  would  be  more  than  off-setting  the  burden 
increases  associated  with  the  new  data  requirements.  The  burden  reductions  that  may  be 
introduced are the same for Option C, as further elaborated below. 

Coherence 

This  Option  B  which  foresees  the  implementation  of  legislative  actions  limited  to  certain 
business statistics domains is in line with the ESP 2013-2017 (and its extension). Namely, the 
measures  planned  in  the  ESP  2013-2017,  regarding  business  statistics,  could  indeed  be 
introduced  by  targeted  legislative  actions  in  the  respective  specific  business  statistics 
domains. 

Option C: Modernisation of business statistics in a single framework (FRIBS) using a mix of 
measures  

The third policy alternative proposes replacing the 10 existing statistical EU legislative acts 
for business statistics by a common coherent framework, by repealing the existing domain-
specific Regulations, simplifying and replacing these with a single legislative package. This 
package  covers  a  common  statistical  infrastructure  (i.e.  the  business  registers,  the 
EuroGroups Register, the basic data topics, the data sources, the exchange of micro-data for 
Intrastat, data transmission, data quality, data confidentiality, etc.) which will then create the 
possibility  to  integrate  the  production  processes  at  national  and  international  level.  The 
introduction of measures that remove the  stovepipes in the production processes of NSIs in 
combination with coherent business statistics legislation, will lead to the most comprehensive 
harmonisation  of  European  business  statistics.  Similarly  to  Option  B,  for  the  collection  of 
statistics  on  intra-EU  trade  (Intrastat),  this  option  C  also  includes  the  three  alternative  sub-
options for the modernisation of Intrastat. 

This option would implement the simplification and modernisation and create a system which 
facilitates increased cooperation in statistical production to respond to cross-cutting statistical 
needs,  the  reduction  of  burden  for  data  providers  and  the  minimisation  of  cost  impacts  for 
data compilers. In addition it would allow for better inherent consistency, the integration and 
harmonisation  of  the  collection,  compilation,  transmission  and  dissemination  of  business 
statistics, with a much more harmonised and cross-cutting output for users. 

33 

 
 
 
Effectiveness  of  fulfilling  the  objectives  of  this  policy  initiative  and  impact  on 
stakeholders 

This is the only option that enables to fulfil all objectives identified for the policy initiative. 
The  integration  of  EU  legislation  on  business  statistics  and  measures  to  enable  the  better 
integration  of  national  production  processes  contribute  to  a  higher  responsiveness  of  the 
business statistics to changing data needs due to economic and societal changes. When new 
(cross-domain)  issues  arise,  Eurostat  can  effectively  use  the  overarching  framework 
legislation  instead  of  changing  various  domain-specific  legislations.  At  the  same  time,  the 
production  processes  for  business  statistics  get  more  agile  for  accommodating  new  cross-
domain  issues,  which  will  become  increasingly  important.  As  the  framework  Regulation 
establishes  a  European  Network  of  Business  Registers  the  central  role  of  the  European 
business  registers  in  business  statistics  is  enhanced  making  it  easier  to  produce  additional 
statistics  by  means  of  data  linking.  All  this  responds  well  to  the  needs  of  users  and 
policymakers  asking  for  more  flexibility  of  the  business  statistics  system.  In  addition,  this 
option allows for the creation of a system which is more forward looking, with best potential 
for  modernisation and collaborative approaches to  statistical  production and  more openness 
for accommodating new and innovative production methods for statistics. 

A  reduction  of  fragmentation  in  data  production  processes  in  Member  States  creates 
incentives to use and combine alternative data sources and methods across various domains. 
The framework legislation will thus contribute to an increasing use of administrative sources 
and registers  as  input  for business statistics.  Such a focus not  only reduces the cost of data 
production  but  also  the  response  burden  of  data  providers.  Many  Member  States  already 
allow their NSIs to access these sources, and a strengthened EU support could provide further 
leverage  to  NSIs  to  convince  their  governments  to  expand  the  use  of  these  sources. 
Additional methodological work could be done to assess the quality of administrative or big 
data sources, to harmonise the concepts used with those used for the production of business 
statistics and then overall to decrease the production costs.  

Option C provides in addition more benefits for users in terms of data quality, transparency, 
comparability and additional statistics (e.g. through linking). In addition, the effectiveness to 
ensure  the  quality  of  data  production  and  output  is  maximised.  The  framework  legislation 
inherently  helps  Eurostat  in  increasing  the  consistency  of  statistical  output  across  different 
domains for instance by using the same definition for the same concept. Integrating business 
statistics in a harmonised data structure also makes the existing links between these statistics 
more  apparent  and  NSIs  will  then  adapt  their  production  processes  to  take  these  links  into 
account and profit from the harmonisation. This framework also facilitates to deal effectively 
with possible newly arising quality concerns that could come from innovative methods, like 
the use of new or big data sources. At the same time, the reduction of fragmentation of the 
production  processes  in  Member  States  will  lead  to  better data  quality  as  more  harmonised 

34 

 
 
 
 
standards are used. For new cross-domain data production the quality can be better ensured 
through  the  effective  integration  of  EU  legislation.  85%  of  respondents  in  the  first  public 
consultation  of  data  users  have  indicated  that  a  single  harmonised  regulation  and  quality 
requirements would further increase their already overall high level of confidence of quality 
in  European  business  statistics.  Although  improvements  in  quality  of  statistical  data  are 
highly appreciated by users, they also bring about breaks in time series resulting in problems 
to use the data in the short term. However, over time these problems will gradually disappear. 
In  addition,  some  existing  data  requirements  were  cut  to  make  room  for  new  data 
requirements.  For  users  who  need  these  data  for  their  analyses  this  could  pose  problems. 
However,  the  main  stakeholders  were  consulted  on  the  proposed  data  requirement 
simplifications and understood the need to balance the cost and burden as much as possible. 

This  policy  option  foresees  the  introduction  of  new  data  requirements.  The  additional  data 
requirements to be introduced by FRIBS are proposed on the basis of extensive consultation 
of the main stakeholders and based on the outcome of pilot studies carried out to ascertain the 
feasibility  of  the  data  collection  assessing  the  benefits  and  the  costs.  The  usefulness  of  the 
additional  data  requirements  has  been  confirmed  by  the  outcome  of  a  second  public 
consultation of data users. 

Nearly  85%  of  respondents  to  the  first  public  consultation  of  data  users  indicated  that  a 
single harmonised regulation and quality requirements (option C) would further increase 
their  confidence  in  European  business  statistics,  and  that  especially  those  elements  that 
aim to increase consistency across all business statistics domains and/or across countries 
are  very  welcomed.  75%  of  the  respondents  chose  Option  C  as  their  preferred  policy 
option.  Concerns  regarding  some  elements  of  this  option  that  were  raised  by  few  data 
users  include  less    consistency  with  previous  data  sets  (breaks  in  time-series)  and  a 
general decrease in quality of the currently existing statistics in view of the extension in 
data requirements. The majority of users however see the extension in data requirements 
as a positive evolution.  

For the different sub-options the impacts on the stakeholders are included in the paragraphs 
below.  The  qualitative  assessment 
(Strengths/Weaknesses 
relies  on 
Opportunities/Threats)  tool  and  is  based  on  consultation  of  the  National  Statistical 
Authorities for identifying positive and negative impacts which are expected to follow from 
the Member States' implementation of the sub-options. 

the  SWOT 

Sub-option C1: SIMSTAT 

Using the SIMSTAT sub-option for Intrastat has a substantial positive impact on the quality 
of  the  data  concerned  as  the  comparability  of  statistical  data  across  Member  States  will  be 

35 

 
 
 
 
 
 
 
 
 
 
 
 
enhanced as the exchange of micro-data allows for identifying asymmetries at the micro-data 
level.  In  addition,  it  encourages  the  harmonisation  of  production  methods  across  Member 
States. SIMSTAT implementation will increase the flexibility in the data collection and the 
relevance  of  the  data  thanks  to  the  use  of  multiple  data  sources.  The  availability  of  the 
identification number of the importer improves the re-usability of the data. The results of a 
SIMSTAT  pilot  study  indicate  that  smaller  economies  would  gain  information  when  using 
exchanged  instead  of  nationally  collected  data.  Data  providers  are  sensitive  to  data 
confidentiality  so  the  security  of  micro-data  exchange  between  National  (Statistical  and 
Other) Authorities must be ensured to address their concerns. 

Sub-option C2: Revised Intrastat 

Under the Revised Intrastat sub-option Member States would continue compiling their own 
statistics  independently.  This  option  implies  flexibility  in  both  collection  and  compilation 
methods:  if  an  exports-driven  approach  is  chosen  (Member  States  choose  to  maintain  the 
coverage rate for intra-EU exports), the impact is expected to have similarities to SIMSTAT 
because there is dependency on other NSAs. However, as this option does not foresee micro-
data exchange the impacts are assessed to be less pronounced than in SIMSTAT. As the share 
of  the  estimations  increases,  quality  of  data  is  lower.  The  current  level  of  trust  of  data 
providers over data security will not be affected.  

Sub-option C3: Single Flow 

The Single Flow sub-option is considered to cause significant quality problems. As only one 
flow is collected and import statistics are derived from export statistics, it will no longer be 
possible  to  check  the  quality  of  the  import  data.  Comparability  over  time  will  be  seriously 
hampered  as  there  will  be  significant  breaks  in  series  of  import  data.  This  could  have  a 
serious impact on trade balance and other relevant macro-economic statistics. The reliability 
and accuracy of imports data will be negatively affected because Member States are not able 
to control the data sources of the partner countries. It will not be possible to compile statistics 
on  characteristics  of  businesses  engaged  in  import  activities  anymore  (Trade  by  enterprise 
characteristics  (TEC))  as  imports  could  not  be  allocated  anymore  to  individual  companies. 
Negative  effects  on  timeliness  of  data  availability  are  expected  since  data  on  intra-EU 
imports  will  exclusively  depend  on other  countries.  The  current  flexibility  of  the  system  of 
collection  and  compilation  will  be  reduced  because  all  Member  States  have  to  collect  the 
same data elements and to apply the same methodology for estimation of imports, without the 
possibility  to  explore  different  data  sources.  NSAs  will  be  fully  dependent  on  NSAs  of 
partner Member States for the compilation of statistics on intra-EU imports.  

Sub-option C4: combination of SIMSTAT and Revised Intrastat 

This  sub-option  would  combine  elements  from  both  SIMSTAT  and  from  Revised  Intrastat. 
From SIMSTAT, the mandatory exchange of micro-data feature would be taken. While from 
Revised  Intrastat,  the  key  feature  taken  would  be      more  flexibility  in  the  choice  of  data 
sources used, meaning that less data will be collected from companies' imports and exports 

36 

 
 
flows  or  for  either  of  the  two  flows.  The  impact  of  this  combined  sub-option  should  be  a 
reduction  of  the  response  burden  in  Intrastat  of  at  least  25  %  which  would  hence  lead  to  a 
reduction of at least 13.5% of the overall burden of business statistics (for FRIBS as a whole) 
with a potential for an even larger reduction of burden. Sub-option C4 would provide a sound 
level of quality in response to stakeholders’ (i.e. users and respondents) needs. It would also 
allow  for  flexibility  in  data  sources  and  compilation  methods  used  by  Member  States  and 
would prepare international trade statistics for the challenges brought by globalisation. 

Efficiency  

legislation  replacing 

The efficiency gains to be made by including all existing business statistical legislation in an 
the  currently  existing  domain-specific 
overarching  framework 
Regulations  will  be  substantial.  The  lengthy  procedures  currently  associated  with  changing 
any  element  in  business  statistics  legislations  are  inefficient.  Streamlining  and  overall 
reducing  these  procedures  under  one  framework  legislation  will  lead  to  considerable 
efficiency gains for NSIs and also Eurostat and to fulfilling emerging user needs in a timelier 
manner. It creates the possibilities to develop more integrated data production processes and 
to use more innovative and alternative data sources, efficiency gains can also be expected on 
the response burden on businesses acting as respondents.  

Efficiency gains for the business statistics system are possible due to the combination of legal 
integration  and  the  better  integration  and  modernisation  of  national  production  processes. 
This policy option explicitly opens the possibility for NSIs to modernise their systems and to 
reduce  costs.  The  integration  of  data  production  processes  in  a  more  coherent  manner  is 
supported by the integration of legal instruments at the EU level. NSIs can use innovative and 
more cost-efficient methods of data production across the better integrated domains. This will 
further  contribute  to  an  expected  reduction  of  costs  for  NSIs  in  the  long  run  and  to  the 
reduction  of  burden  on  businesses,  but  it  is  not  possible  at  this  stage  to  quantify  these 
reductions.  

Despite  these  efficiency  gains  for  the  business  statistics  system  for  data  production  and 
dissemination,  NSAs  point  out  that  there  are  cost  increases  in  the  short-term  due  to  the 
necessary investments needed. This is mainly due to changes from heterogeneous processes 
to more integrated ones using more harmonised standards and methods. The costs for changes 
towards  harmonisation and consistency  are to  be carried by NSAs, who will have  to revise 
and modernise their statistical processes to  accommodate  the more consistent requirements. 
In  addition,  the  new  data  requirements  introduced  by  the  framework  Regulation  and  its 
implementing/delegated acts to fulfil longstanding user needs will also increase the costs for 
the data compilers. 

In general terms, all Member States will face one-off implementation costs for adapting their 
national statistical systems to the new data requirements in the short run. The implementation 
of the modernisation and rationalisation possibilities offered by FRIBS will also entail initial 

37 

 
 
 
investments  before  benefits,  increased  productivity  and  improved  cost  efficiency  can  be 
reached.  

The  countries  most  affected  by  the  changes  are  those  that  either  do  not  yet  collect  the 
additional  data  requested  by  FRIBS  for  national  policy  purposes  or  that  have  not  yet 
participated  in  (pilot)  actions  for  preparing  the  new  data  requirements  financed  by  the 
Commission by means of grants. In the short term those countries – representing a minority 
of  the  Member  States  -  would  indeed  face  increases  in  the  costs  of  compiling  business 
statistics.  

The FRIBS  Regulation is an output-oriented Regulation, meaning that it does  not  prescribe 
the  Member  States  which  sources  (input)  need  to  be  used  for  compiling  business  statistics, 
but  it  enforces  the  correct  implementation  of  agreed  definitions  and  data  requirements  for 
ensuring the comparability of the statistical output. Thus, Member States are free to choose 
the most cost and burden efficient data sources and production methods to provide the data 
requested. Due to the efficiency gains from other provisions of FRIBS which do not result in 
quick cost reductions, but will take more time, these initial cost increases are expected to be 
compensated in the medium and long run.  

A number of provisions are foreseen to alleviate the possible initial cost and burden impacts 
of  FRIBS.  For  example,  the  current  simplifications  exempting  smaller  countries  from 
delivering  all  the  requested  data  will  be  extended  to  the  domains  of  PRODCOM,  business 
services  and  global  value  chain  statistics.    Additionally,  financing  is  foreseen  (within  the 
limits  of  budget  availability)  for  actions  to  develop  new  data  collections  or  to  develop 
modernised  data  production  processes.  Furthermore,  the  provisions  for  improved  access  to 
administrative sources, a new data source for compiling the intra-EU trade in goods statistics 
at the national level (exchanged micro-data) and consistent definitions allowing for integrated 
surveys  are  examples  of  the  rationalisation  and  modernisation  potential  offered  by  FRIBS. 
This is creating cost reduction possibilities after the initial investment phase.  

The calculations for the long term development of costs (see below) were done on the basis 
of estimates at the European Statistical System level. Due to the lack of factual evidence on 
how  the  FRIBS  implementation  will  be  done  in  each  Member  State,  it  is  impossible  to 
estimate  whether  the  countries  with  the  highest  increase  in  initial  costs  will  be  fully 
compensated by efficiency gains induced by FRIBS in the long term. 

The additional implementation costs for NSAs will be partly offset by simplifications to the 
data  requirements  and  from  modernisation  of  Intrastat.  The  additional  costs,  incurred  by 
NSIs, for implementing this policy option (similarly to Option B) are estimated to represent 
an annual increase on average per Member State by: 

  6.8 % (or EUR 700 000) of the annual operating costs for sub-option C1 (SIMSTAT); 
  6.7  %  (or  EUR  691  000)  of  the  annual  operating  costs  for  sub-option  C2  (Revised 

Intrastat); 

38 

 
 
 
  4.3  %  (or  EUR  436  000)  of  the  annual  operating  costs  for  sub-option  C3  (Single 

Flow); 

  Between  6.7  %  (or  EUR  691  000)  and  6.8  %  (or  EUR  700  000)  of  the  annual 
operating costs for sub-option C4 (combination of SIMSTAT and Revised Intrastat). 

The estimated one-off investment costs per Member State are: 

  EUR 1.9 million for sub-option C1 (SIMSTAT); 
  EUR 1.25 million for sub-option C2 (Revised Intrastat); 
  EUR 1.16 million for sub-option C3 (Single Flow); 
  Between EUR 1.25 million and EUR 1.9 million for sub-option C4 (combination of 

SIMSTAT and Revised Intrastat) 

The results derived from the targeted NSAs' consultation on the additional data requirements 
show  that  the  changes  in  annual  operating  costs  do  however  vary  significantly  across 
Member States. For instance, the reported changes in annual operating costs, as forecasted by 
NSIs  during  the  targeted  consultation  on  the  changes  to  the  data  requirements,    due  to  the 
introduction of the new data requirements and deletion of obsolete data requirements range 
from  -1  %  to  +20  %  across  Member  States.    After  the  initial  investment  costs  and  the 
increases in annual operating costs, considerable efficiency gains should however be reached 
by  NSAs  using  more  integrated  processes.  These  efficiency  gains  are  expected  to 
significantly  compensate  for  the  initial  investment  and  annual  operating  costs  incurred  in 
NSAs.  A  model  for  estimating  the  impacts  on  costs  is  presented  in  the  box  below.  The 
Commission has already contributed around EUR 13 million in the form of grants in order to 
fund the additional costs that NSIs face in order to prepare and adapt their production systems 
to the changes introduced by the framework Regulation and will continue to make available 
financial resources in order to facilitate the implementation of the framework Regulation. It 
should  moreover  be  noted  that  part  of  the  increased  costs  for  data  compilers  is  related  to 
actions reducing the burden on data providers.  

To  summarise,  the  Option  C  impacts  both  the  annual  operating  costs  of  the  production  of 
business statistics and results in initial investments costs (one-off implementation costs) for 
the  NSA.  The  simplifications  and  modernisation  possibilities  included  in  the  Option  will 
allow for a gradual reduction of the running cost and the initial investment costs will be partly 
borne  by  the  Commission  (grants  to  be  given  within  the  constraints  of  the  Commission 
budget).    

Applying a cost model (See Annex IV) for calculating the net present value of the total EU-
28 costs (NSIs' one-off investment costs + NSIs' annual implementation costs) over a 10-year 
implementation period, the following results have been obtained: 

sub-option C1: net cost increase of EUR (+) 9 million, 

39 

 
 
 
 
sub-option C2: net cost savings of EUR (-) 10 million; 

sub-option C3: net cost savings of EUR (-) 62 million; 

sub-option C4: between maximum net cost savings of EUR (–) 10 million and maximum net 
cost increase of EUR (+) 9 million. 

The  new  data  requirements  introduced  to  fulfil  longstanding  user  needs  will  increase  the 
burden on data providers in the same way as for option B. The introduction of the new data 
requirements would amount to a burden increase of about EUR 24 million. This increase will 
be compensated by the simplifications and rationalisations foreseen in the different domains 
and by the modernisation of Intrastat.  

Based  on  information  collected  from  the  respondents  of  the  surveys  regarding  the 
administrative  burden,  the  burden  reduction  which  could  be  realised  would  depend  on  the 
approach chosen for the intra-EU trade data.   Notwithstanding that the final approach chosen 
for  the  intra-EU  trade  will  try  and  maximise  the  burden  reduction  while  guaranteeing  the 
quality  and  especially  the  timely  availability  of  the  statistics  on  intra-EU  trade,  the  total 
potential burden reduction for FRIBS (for the EU on total) is estimated to be: 

  26.8 %  (or EUR 184 million ) for sub-option C1 (SIMSTAT); 
  12.1 %  (or EUR 83 million) for sub-option C2 (Revised Intrastat); 
  33.6 % (or 231 million) for sub-option C3 (Single Flow); 
  13.5 %  (or EUR 93  million), at least, for sub-option C4 (combination of SIMSTAT 

and Revised Intrastat) 

Some of the additional data requirements covered by the FRIBS Regulation would increase 
the  burden on  SMEs  especially  with  regards to  the  extension  of  business  statistics  to  cover 
more  services  than  were  previously  not  covered.  This  is,  however,  to  respond  to  a  long-
standing specific user need to enable the monitoring of European and national policy actions 
with  regards  to  SMEs  for  which  sufficient  information  is  currently  lacking.  The  data 
compilers  are moreover encouraged to  use as  much as  possible  existing administrative data 
(e.g. from tax authorities) to respond to this data request and to minimise the use of surveys 
and therefore limit the burden on SMEs.  

The  simplifications  foreseen  by  FRIBS  in  the  area  of  intra-EU  trade  statistics,  on  the  other 
hand,  could  reduce  the  burden  for  SMEs.  However,  for  intra-EU  trade  statistics  the 
determining factor whether to be obliged to report or not is not the size of the company but 
the trade volume. Though usually  one can  expect  to  have  some sort  of  correlation between 
the two, small businesses can have large trade volumes while large companies have very little 
or no trade at all. The intra-EU trade statistics system however benefits from the availability 
of  VAT  data  on  intra-EU  sales  and  purchases  which  allows  exempting  the  smallest  traders 
from intra-EU trade statistics reporting. 

The ESSC agreed on 18 May 2016 on the principle of burden neutrality  on exporters. This 
could mean in practice that additional burden which exporters would face due to reporting of 

40 

 
 
the  new  data  elements  needed  for  exchanging  the  micro-data  could  be  compensated  by 
lowering  the  overall  minimum  collection  rate  (threshold)  of  exports.  Based  on  estimations, 
the burden neutrality could be ensured by lowering the collection rate from 97% to 95% of 
the total exports. In this case the exporters who would be exempted from reporting would be 
the  smallest  ones  of  which  the  majority  can  be  expected  to  be  SMEs.  In  addition,  any 
reduction  of  the  imports  data  collection  would  mostly  be  in  favour  for  the  SMEs  so  the 
overall  impact  on  the  SMEs  should  be  very  positive.  However,  the  system  will  be  all-
encompassing;  there  might  always  be  individual  SMEs  who  may  not  benefit  from  burden 
reductions and may even face more burden.  

Nevertheless,  any  possible  burden  increases  on  SMEs  would  be  kept  limited  also  because 
many  countries  will  use  administrative  data  for  fulfilling  new  data  requirements,  in  some 
cases  combined  with  model-based  estimation  methods.  In  addition,  some  of  the  new  data 
requirements  (e.g.  regarding  Global  Value  Chains)  are  specifically  directed  to  large 
enterprises  (there  is  a  threshold  in  terms  of  employment)  and  thus  the  SMEs  are  protected 
from excessive burden. Additionally, for the new data requirements for which surveys have 
to be organised, the practice to cover only a sample of small enterprises will also be applied 
(whereas  large  enterprises  are  covered  exhaustively).  What  is  more,  the  replies  from  the 
targeted consultation of the data compilers on the additional data requirements introduced by 
FRIBS  indicated  that  the  data  compilers  would  make  particular  efforts  to  minimise  the 
burden on SMEs for those new data requirements that are more burdensome on respondents.  

Coherence 

Option C is fully coherent with the ESP 2013-2017 and its extension to 2020. Modernisation 
of business statistics in a single framework (FRIBS) would fully and consistently address the 
measures  and  novelties  envisaged  for  European  business  statistics  by  the  ESP  and  its 
extension.  

7. 

COMPARISON OF OPTIONS 

In this chapter the proposed three policy options are compared. This will be done using the 
thorough impact analysis as outlined in the previous chapter. The following table gives a 
summary overview of the impacts of the different policy options on the different 
stakeholders. 

41 

 
 
 
 
 
 
Table 4: Comparison of policy options 

Net effects for data users 
Qualitative assessment of 
impacts on data users 

Option A: No policy change  - 
baseline scenario 

Option B: Implementation of legislative actions limited to certain business 
statistics domains 

Option C:  Modernisation of business statistics in a single framework (FRIBS)  

- 
Users remain not fully satisfied. 
(the more new emerging user 
needs, the less responsive and 
accommodating the current 
system)  

+  
A non-integrated approach could bring about similar advantages as an integrated 
approach; action that touch upon different domains are however expected to lead 
to less advantages (in terms of consistency, harmonisation etc.) in view of the 
risks of non-optimisation of the coordination of implementation. 

++ 
The harmonised European business statistics package fit for the future and agile 
enough to react to policy needs.     

Net effects for data providers 
Expected impact in the annual 
administrative burden 

No impact 

Current annual burden (total 
EU): EUR 689  million 
Continuous high burden on 
data providers  

Qualitative assessment of other 
impacts on data providers 

0 

Net effects for data compilers 
Expected impact on the Annual 
operating cost  

No impact 

Current annual operating cost: 
Around EUR 10,5 million per 
Member State on average, 
ranging from EUR 1,3 million 
to EUR 70,6 million per 
Member State; EUR 290 
million for the EU on total  

Expected one-off implementation 
cost 
Qualitative assessment of other 
impacts on data compilers 

EUR 0 

none 

+ 
Significant burden reductions (total EU) compared to option A  

++ 
Substantial burden reductions (total EU) compared to option A 

26.8 % 
12.1 % 
33.6 % 
13.5 %  
SIMSTAT and Revised Intrastat) 

 ( or EUR 184 million ) for sub-option B1 (SIMSTAT); 
 ( or EUR 83  million ) for sub-option B2 (Revised Intrastat); 
( or EUR 231  million ) for sub-option B3 (Single Flow); 
(or EUR 93 million), at least, for sub-option B4 (combination of 

-- 
separate legislative changes bring new risks of different time schedules as well as 
divergent concepts and definitions. 

6.8 % (or EUR 700 000 per MS) of the annual operating costs for sub-option B1 
(SIMSTAT); 
6.7 % (or EUR 691 000 per MS) of the annual operating costs for sub-option B2 
(Revised Intrastat); 
4.3 % (or EUR 436 000 per MS) of the annual operating costs for sub-option B3 
(Single Flow); 
Between 6.7 % (or EUR 691 000) and 6.8 % (or EUR 700 000) of the annual 
operating costs for sub-option B4 (combination of SIMSTAT and Revised 
Intrastat) 
At present, but the figure is potentially higher in the long run for this option since 
the (temporary) non-integrated business statistics are less efficient and will lead 
to a need of additional resources to cope with the data requirements.  
Between EUR 1.16 million and EUR 1.9 million on average per Member State 
(or between EUR 32  million and EUR 52 million  for the EU on total) 
- 
Exchange of micro-data might add challenges such as complexity of data 
compilation and dependency on other countries. 

 ( or EUR 184  million ) for sub-option C1 (SIMSTAT); 
 ( or EUR 83  million ) for sub-option C2 (Revised Intrastat); 
( or EUR 231  million ) for sub-option C3 (Single Flow); 
(or EUR 93 million), at least, for sub-option C4 (combination of 

26.8 % 
12.1 % 
33.6 % 
13.5 %  
SIMSTAT and Revised Intrastat) 
What is more, the integrated Business statistics should lead to an additional 
reduction of burden over time as fewer questionnaires will be used. More 
administrative and innovative data sources will be used, definitions of variables 
will be more aligned, (which is not likely to occur under the non-integrated 
option-B). 
- 
Changes in classifications and definitions require initial efforts from the 
businesses to adjust their responses to the new requirements.  

6.8 % (or EUR 700 000 per MS) of the annual operating costs for sub-option B1 
(SIMSTAT); 
6.7 % (or EUR 691 000 per MS) of the annual operating costs for sub-option B2 
(Revised Intrastat); 
4.3 % (or EUR 436 000 per MS) of the annual operating costs for sub-option B3 
(Single Flow); 
Between 6.7 % (or EUR 691 000) and 6.8 % (or EUR 700 000) of the annual 
operating costs for sub-option C4 (combination of SIMSTAT and Revised 
Intrastat) 
This increase should however be counterbalanced by regular efficiency gains of 
the data compilers to be expected through the continuous modernisation of 
national production processes.  
Between EUR 1.16 million and 1.9 million on average per Member State (or 
between EUR 32  million and EUR 52 million  for the EU on total) 
+ 
Exchange of micro-data might add challenges such as complexity of data 
compilation and dependency on other countries. These are however largely 
compensated by benefits coming from actions such as enhancement of the role of 
business registers (incl. unique ID), reduction of inconsistencies in definitions of 
variables etc. 

-- negative impact 

- slightly negative impact  

0 neutral impact 

+ slightly positive impact 

++ positive impact 

42 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
Option  A  is  keeping  the  status  quo.  This  option  does  not  look  acceptable  as  the  need  for 
modernising  European  Business  statistics  was  already  recognised  in  2008,  mainly  as  the 
current  business  statistics  serve  the  policy  and  other  user  needs  only  partially.  Since  then 
investments have been made to accelerate the modernisation of the system. These investments 
would be lost if the current system of European Business Statistics is maintained. Policy users 
would  be  increasingly  dissatisfied  with  the  data  disseminated  now  and  turn  to  other  data 
sources.  Over  time,  this  would  deteriorate  the  quality  of  European  or  national  policy 
decisions. What is more, this option is not coherent with the ESP 2013-2017 and its extension 
(under  preparation)  because  the  modernisation  and  modifications  which  the  ESP  envisages 
would  not  be  possible  without  undertaking  legislative  measures  in  the  area  of  business 
statistics.  That  is  why  keeping  the  status  quo,  would  even  negatively  affect  coherence  with 
other legal initiatives (see comparison table below). 

Option B tackles the modernisation of the current system of European Business Statistics to a 
certain  extent.  This  is  in  particular  true  for  the  upgrading  of  the  data  production  and  data 
output  for  policy  and  other  users  which  will  get  more  relevant.  It  is  also  true  for  the 
modernisation  of  the  Intrastat  system  which  should  lower  the  burden  on  data  provider. 
However this option leaves a series of current deficiencies unsolved. These are:  

 

 

 

Keeping 10 separate legislative acts for Business statistics means that more efforts are 
needed to reduce inconsistencies and to preserve the coherence of data and indicators 
produced for policy users in the future. In view of the risks of non-optimisation of the 
coordination of implementation of the different legal acts, indicators produced on the 
basis  of  such  a  dispersed  system  would  not  be  relevant  enough  and  misguide  policy 
users.    
Secondly  keeping  10  separate  legislative  acts  also  creates  a  high  work  load  for  the 
management  and  updates  of  these  pieces  of  legislation;  this  affects  NSAs,  but  also 
data providers (enterprises) who might need to answer to fast changing or sometimes 
inconsistent questionnaires.      
In addition, the improvement actions proposed in this option do not really create more 
agility and responsiveness to changing policy and other user needs. Heavy procedures 
and  long-lasting  discussions  do  prevent  more  agility  of  the  system  and  therefore 
hamper the relevance of the output for users.  

In  terms  of  coherence  Option  B  is  an  improvement  to  the  baseline  scenario,  since  the 
measures  planned  in  the  ESP  2013-2017  and  its  extension  could  indeed  be  introduced  by 
targeted legislative actions in the corresponding specific business statistics domains. 

   Option  C  as  outlined  above  is  the  most  advanced  and  most  forward-looking  one  as  it 
modernises  the  European  business  statistics  system.  This  option  covers  a  long-term 
investment  in  European  business  statistics  in  making  them  fit  for  the  future.  All  European 
business statistics will be put into one single legal framework FRIBS. This has – compared to 
the previous options – a series of clear advantages. These are:  

43 

 
 
 
 
 
 
 
 

 

 

 

The  assembling  of  10  separate  legislative  acts  including  the  Business  Register 
Regulation  into  one  single  legal  framework  will  implicitly  guarantee  much  higher 
consistency of business statistics (e.g. in terms of timing of changes and harmonisation 
of  definitions  etc.).  This  allows  for  the  drawing  of  higher  benefits  from  the  ESS 
system  as  a  whole  and  maximises  the  value  added  of  the  EU  at  the  same  time.  The 
frontiers  between  the  various  statistical  domains  will  diminish  or  even  completely 
disappear. This alignment will make it possible to serve the policy needs much better 
as more streamlined indicators and combinations of indicators can be disseminated. As 
an example, - contrary to the current situation - there will only be one single figure for 
the variable "number of active enterprises" for a certain industry which will be used all 
across the system.     
The  streamlining  of  all  business  statistics  in  FRIBS  and  the  underlying  FRIBS  legal 
architecture  will  increase  the  agility  of  the  system.  New  policy  needs  can  be 
accommodated  with  rather  short  delays  and  be embedded  in  a  functioning  and  well-
designed system. This assures a level of agility which is not really possible under the 
two previous options.  
In contrast with Option B the costs for adaptations of the statistics disseminated and of 
the  underlying  legal  framework  are  minimised  under  this  preferred  Option  C  as  all 
necessary revisions are introduced  more easily in one go. The framework Regulation 
contains  only  the  essential  statistical  elements.  Non-essential  elements  can  be 
supplemented  or  amended  by  delegated  acts,  while  the  technical  provisions  will  be 
part  of  implementing  acts.  This  brings  much  more  agility  and  responsiveness  to  the 
system.  
Most importantly Option C has – by far - the highest potential for reducing the burden 
on enterprises. Better harmonisation of business statistics will also streamline the data 
collection and production methods used by NSAs or also by Eurostat. For instance the 
"employment" figures will be asked from enterprises only once and then be reused for 
many different indicators made available to policy users.  In many Member States the 
number  and  coverage  of  questions  to  which  enterprises  need  to  respond  should 
considerably  decrease  over  time.  FRIBS  encourages  that  more  harmonised  methods 
and  processes  are  used  by  NSAs  with  the  effect  of  a  further  decrease  of  burden  on 
enterprises.  Thus,  the  increased  coordination  and  use  of  multipurpose  methods 
(administrative  data  sources,  combining  of  survey  questionnaires,  use  of  "big  data" 
data sources etc.) will create better opportunities for the reduction of data production 
costs. FRIBS also allows for enhanced use of micro-data exchange in various domains 
in  the  future  and  better  and  more  aligned  output  facilitating  e.g.  new  indicator 
production. 

Regarding coherence, Option C is fully in line with the ESP 2013-2017 and its extension and 
is therefore clearly superior to Option A. Only the integrated approach of Option C (FRIBS) 
could  completely  and  coherently  implement  the  actions  and  modernisations  envisaged  for 
business statistics by the ESP and its extension.  

44 

 
 
 
 
 
 
 
The table below summarises the scoring of each of the policy options regarding: 
- the extent to which different options would achieve the objectives (effectiveness); 
- the relation between costs and benefits; 
- the coherence with the overarching objectives of EU policies. 

Effectiveness 

Efficiency  

Coherence 

Streamline 
and improve 
consistency 

Improve 
flexibility and 
responsiveness to 
user needs 

Facilitate the use of 
innovative methods 
and sources, make the 
system fit for the 
future 

Ensure 
quality of 
data 
production 

Reduce 
unnecessary 
burden 
on 
data 
providers 

(Costs/ben
efits) 

- 

+ 
++ 

- 

+ 
++ 

0 

+ 
++ 

0 

0 
++ 

0 

+ 
++ 

0 

+ 
++ 

- 

+ 
++ 

Policy 
Options 

Option A  
Baseline  
Option B   
Option C  

-- negative impact    - slightly negative impact   

0 neutral impact     + slightly positive impact      ++ positive impact 

To conclude, all these advantages clearly favour Option C. It responds best to the objectives 
of the REFIT programme by simplifying and streamlining the heterogeneous and inconsistent 
legal  texts  currently  governing  business  statistics  into  one  coherent  legal  framework.  It  is 
based  on  extensive  user  consultations  and  has  the  highest  potential  for  reducing  regulatory 
burden. This option makes the European business statistics system fit for the future in meeting 
much  better  the  policy  user  needs  compared  to  the  rather  inflexible  system  of  today,  while 
being also best placed to introduce the innovations envisaged for business statistics in the ESP 
and  its  extension.  This  option  provides  more  possibilities  for  burden  reduction  as  explained 
above. Option C is the only option which takes fully advantage of the EU in  maximising its 
value  added;  this  option  creates  the  platform  for  a  more  collaborative  and  agile  system 
allowing for further modernisation in the future.  The increased cost for data compilers in the 
beginning  of  the  implementation  would  be    counterbalanced  by  potential  benefits  and 
efficiency gains that would be realised once the FRIBS measures start to take effect (see cost 
model  in  Annex  IV).  What  is  more,  these  increase  costs  would  be  completely  offset  by  the 
advantages for data users and the decrease in the burden for the data providers which Option 
C would allow for. Moreover, the results of the first consultation of the NSAs clearly showed 
that Option C - FRIBS was their preferred option. Namely, around 55 % of the NSIs indicated 
FRIBS  as  their  preferred  option,  while  only  around  10  %  preferred  Option  B  -  the  non-

45 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
integrated  approach  of  separate  revisions  of  the  individual  acts  and  only  7  %  of  the 
respondents preferred Option A - keeping the status quo (no policy change )13. 

MONITORING AND EVALUATION: HOW WOULD ACTUAL IMPACTS BE 

8. 
MONITORED AND EVALUATED 

The European Commission REFIT agenda makes evaluation of all new legislative measures a 
priority  for  the  Commission.  The  proposed  FRIBS  legislation  will  also  be  subject  to  a 
complete evaluation in order to assess, amongst other things, how effective and efficient it has 
been  in  terms  of  achieving  the  objectives  presented  in  this  report  and  to  decide  on  whether 
new measures or amendments are needed. 

It  is  not  expected  that  the  implementation  of  the  FRIBS  framework  Regulation  and  its 
accompanying delegated and implementing acts would be potentially more difficult in certain 
Member States. 

In  general the  existing monitoring and evaluation tools, in place  and valid  for the statistical 
production  and  dissemination  of  European  statistics,  will  be  used.  These  should  enable  a 
profound analysis of the effectiveness and efficiency of the new statistical initiative and of the 
quality of the data produced. These tools are:  

  The  European  Statistical  Programmes  (currently  based  on  Regulation  (EU)  99/2013) 
foresee  systematically  mid-term  and  final  evaluations.  Business  statistics  are  part  of 
this reporting mechanism14. 

  The Eurostat Management Plan foresees the follow up of key performance indicators, 

which also apply to business statistics15. 

  User satisfaction surveys are carried out on an annual basis16. 
  FRIBS also requires the production of standard quality reports, regularly produced by 
Member States and Eurostat, as part of the Statistical Quality Assurance Framework. 

13 Another 25 % of the respondents to the consultation did not have a clear preference 

14 See http://ec.europa.eu/eurostat/web/quality/general-evaluation-results 

15  The  five  key  performance  indicators  are  the  following  ones:  Number  of  data  extractions  made  by  external 
users  from  Eurostat  reference  databases  (EuroBase  and  Comext)  via  the  Eurostat  website,  Percentage  of 
users that rate as "Very good" or "Good" the overall quality of European statistics, Percentage of users that 
rate as "Very good" or "Good" the timeliness of European statistics for their purposes, Percentage of users 
that rate as "Very good" or "Good" the comparability of European statistics among regions and countries, 
Residual error rate (RER) 

16 See http://ec.europa.eu/eurostat/web/quality/general-evaluation-results 

46 

 
 
 
 
 
 
 
 
 
                                                            
Eurostat  and  the  NSAs  will  further  improve  the  standard  metadata  and  quality  reporting 
system for business statistics. This will allow a more sophisticated monitoring and evaluation 
of  the  statistical  processes  used  in  Member  states  and  of  the  output  disseminated.  For 
example, more detailed information will be available on the use of administrative data sources 
(leading  to  burden  saving)  by  Member  States  or  on  the  use  of  shared  services  or  IT  tools 
(leading to cost savings). The results and the effect of the FRIBS legislative initiative would 
regularly be monitored via the annual compliance and quality reports.  

Measuring the progress towards achieving the objectives of the initiative the following list of 
monitoring indicators has been defined. Those indicators are juxtaposed against a list of 
operational objectives which have been derived from the specific objectives (presented in 
Chapter 4). The indicators would be measured against the benchmark targets indicated in the 
last column of the table below. 

Table 5. Monitoring and evaluation indicators 

47 

 
 
 
 
 
 
 
 
 
 
 
 
SPECIFIC OBJECTIVES 

OPERATIONAL 
OBJECTIVES 

KEY PERFORMANCE 
INDICATORS 

TARGETS17 

 

Enhance the role of European 
business registers in creating a 
more inter-connected European 
Network of Business Registers  

KPI1  

90 % within 10 years 
of implementation of 
FRIBS  

percentage of 
consistency of data 
between EuroGroups 
Register and the 
national business 
registers 

95 %  within 10 
years of 
implementation of 
FRIBS 

Less than 10% over 
a 10 year period (all 
units) (we should 
take into account 
how likely it is to 
have FRIBS2 within 
10 year of 
implementation of 
FRIBS1) 

A draft reply to new 
data needs received in 
year t is discussed with 
the experts of the 
Business Statistics 
Directors' 
Group/relevant working 
group  in t+1 

Improve  consistency; 

 

Implement a unique identifier for 
the units recorded in the European 
Network of Business Registers 

KPI2 

percentage of units 
that have a unique 
identifier 

Source: quality reports of 

business registers 

Eliminate or reduce the existing 
inconsistencies in certain 
definitions of variables across 
statistical domains and  facilitate 
the consolidation of surveys in 
different business statistical 
domains 

Improve the legal architecture to 
gain more flexibility  

 

 

 

 

Introduce new data requirements 

Enhance flexibility; 

 

 

Facilitate the use of 
innovative methods and 
sources; 

Increase of the use of innovative 
data sources for the production of 
business statistics  

Introduce micro-data exchange 
processes in the field of intra-EU 
trade in goods statistics 

Source: quality reports of 

business registers 

KPI3 

reduction in number 
of surveys in business 
statistics 

Source: national metadata and 

quality reports 

KPI4 

percentage of changes 
to data requirements 
that need to be 
introduced by EP and 
Council Regulation in 
total changes to data 
requirements 

KPI5 

Inventory of new data 
needs and when they 
have been answered 

KPI6 

Number of innovative 
data sources used 

Source: national metadata and 

quality reports 

KPI7 

Number of Member 
States using 
exchanged  micro-data 
on intra-EU exports of 
goods for the 
compilation of 
imports of goods 

Source: national metadata and 

quality reports 

17 For KPIs 3, 6, 7, 12, 13: no exact benchmarks can be specified as FRIBS does not impose any obligation to the 

Member States but only enables use of  new sources and simplifications regarding those indicators. 

48 

 
 
 
 
                                                            
 
 
 
 
 
 
 
 
 
 
 
60% within 10 years 
of implementation of 
FRIBS  

60% within 10 years 
of implementation of 
FRIBS  

60% within 10 years 
of implementation of 
FRIBS  

Decrease as 
compared to 
previous year does 
not exceed 5%/  

KPI8 

  Define a harmonised data quality 
framework across business 
statistical domains 

KPI9 

Percentage of users 
that rate as "Very 
good" or "Good" the 
overall quality of the 
European business 
statistics provided by 
Eurostat 

Percentage of users 
that rate as "Very 
good" or "Good" the 
timeliness of 
European business 
statistics for their 
purposes 

Ensure quality of data 
production; 

 

 

Facilitate further the exchange of 
micro-data for statistical purposes 
(within NSI and between NSIs) 

  Optimise use of EGR (Euro 

Groups Register) 

 

Promote and facilitate the access 
to and use of administrative data 
for statistical purposes 

 
Reduce unnecessary burden 
on data providers 

Introduce changes that alleviate 
burden  generated by  the business 
statistics legal frame e.g.by 
removing coverage rate in 
Prodcom and increased output 
orientation in ITGS 

KPI10  Percentage of users 
that rates as "Very 
good" or "Good" the 
comparability of 
European business 
statistics among 
countries 

Source:  Annual user 

satisfaction survey 
(USS) carried out by 
Eurostat 

KPI11  Number of data 

extractions (in 
millions) made by 
external users from 
Eurostat public data 
bases of business 
statistics via the 
Eurostat website 

Source:  Monitoring reports in 

Eurostat electronic 
dissemination 

Please see  above KPI7 

Please see  above  KPI1  

KPI12  Number of 

administrative sources 
used replacing survey 
data  

Source: national metadata and 

quality reports 

KPI13  Number of measures 

implemented by NSAs 
to reduce burden on 
data providers 

Source: national metadata and 

quality reports 

  Use new and innovative data 

sources 

Please see  above  KPI6 

49 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(*) FRIBS does not impose a redesign of the national production systems to reduce the burden on data providers 
but makes it possible for the Member States to reduce their number of surveys, to use innovative or additional 
administrative sources or to reduce the burden on the data providers.  

50 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEXES 

ANNEX I: PROCEDURAL INFORMATION  

Basic information: 

Title of the initiative: Framework Regulation Integrating Business Statistics (FRIBS) 

Lead DG: Eurostat 

Agenda Planning Number: 2012/ESTAT/011 

In  its  Communication  on  EU  Regulatory  Fitness  of  December  2012  the  Commission 
committed  to  strengthen  its  various  smart  regulation  tools  (impact  assessment,  evaluation, 
stakeholder  consultation)  and  launched  the  REFIT  programme.  Through  REFIT,  the 
Commission services have mapped the entire EU legislative stock looking to identify burdens, 
gaps and inefficient or ineffective measures including possibilities for simplification or repeal. 
Thus, the Framework regulation integrating business statistics (FRIBS) falls under the scope 
of  the  REFIT  initiative.  Under  this  context,  Eurostat  started  the  preparation  of  this  impact 
assessment  in  2013  with  a  view  to  comparing  the  impacts  of  different  possible  options  for 
integrating and rationalising business statistics. As this was prior to the adoption of the Better 
Regulation guidelines in 2015, no specific full evaluation of the current situation was done to 
support this initiative. However, the regular evaluation mechanism in place at Eurostat  (e.g. 
the  European  statistical  programme, 
quality  reports,  rolling  reviews,  evaluation  of 
management plans) as well as an ex-post analysis of the current situation (through discussions 
with NSIs, interviews with main users, public consultation collecting feedback from general 
users and thorough desk research) provided a broad basis for the Impact Assessment. 
A  FRIBS  roadmap  has  been  agreed  and  published  in  January  2013.  A  revised  roadmap  has 
been prepared and published in January 2015 in order to reflect the latest state of play of the 
FRIBS  preparation.  Following  the  introduction  of  the  Better  Regulation  guidelines  in  2015, 
the roadmap has once again been revised under the form of an inception impact assessment 
that was published in January 2016.  

Consultation of Impact Assessment Steering Group (IASG) 

An inter-service steering group was set up in 2013 involving the following DGs: Secretariat-
General (SG), Competition (COMP), Economic and Financial Affairs (ECFIN), Employment, 
Social Affairs and Inclusion (EMPL), Internal Market, Industry, Entrepreneurship and SMEs 
(GROW),    Communications  Networks,  Content  &  Technology  (CNECT),  Trade  (TRADE), 
Taxation and Customs Union (TAXUD), Research and Innovation (RTD) and Legal Service 
(SJ).  The  inter-service  steering  group  met  5  times  (the  meetings  took  place  respectively  in 
October 2013, May 2014, the June 2015, and twice in April 2016). Following the results of 
the  latest  meeting  of  the  IASG,  a  revised  version  of  the  Impact  Assessment  Report  was 
prepared and sent to the Regulatory Scrutiny Board. 

51 

 
 
 
 
 
 
 
Consultation of Regulatory Scrutiny Board (RSB) 

The RSB examined the Impact Assessment Report on 8 June 2016. The RSB gave a positive 
opinion  and  provided  recommendations  for  further  improvements.  The  report  was  further 
adjusted in order to integrate the Board's recommendations. 

Board recommendations 

What has been done? 

Where? 

1. The range of options initially 
presented and analysed was not 
complete because the consultation 
process on the possible sub-options 
concerning the modernisation of 
the intra-EU trade statistics 
continued after the initial 
submission of the impact 
assessment report to the RSB's 
scrutiny. Therefore, the report 
should be extended with the 
combination of options on intra-EU 
trade statistics, as proposed by the 
European Statistical System 
Committee (ESSC). 

regarding 

2.  The  analysis 
the 
possible  budgetary  implications  in 
individual  Member  States  should 
be  strengthened  and  it  should  be 
defined if some of them would face 
more 
with 
difficulties 
than  others  and 
implementation 
whether  any  alleviating  measures 
were  planned  for  those  Member 
States. 

of 

The 

should 
it  should 

the 
analysis 
3. 
administrative  burden  impacts  on 
be 
data 
providers 
strengthened  and 
in 
particular 
nuanced 
be  more 
towards the SMEs, while indicating 
any  measures 
taken  for 
protecting  SMEs  from  increased 
burdens. 

to  be 

5.1.3,  Chapter  6,  Chapter  7, 
Annex  II  (section  2.3)  and 
Annex IV 

Chapter  6  under  efficiency  of 
Option C 

Chapter  6  under  efficiency  of 
Option C 

the 

Eurostat  updated 
the 
proposed  policy  options,  reflecting  the 
ESSC  conclusions  concerning 
the 
modernisation of the intra-EU trade.  

list  of 

Further clarifications as to the countries 
most affected by the changes were 
given.  

to 

A  number  of  examples  were  provided 
pertaining  to  foreseen  simplifications 
for  smaller  countries  and 
the 
and  modernisation 
rationalisation 
potential  offered  by  FRIBS  creating 
future  cost  reduction  possibilities.  It 
was  also  explained  that  financing  was 
foreseen  (within  the  limits  of  budget 
availability) for actions to develop new 
data collections.  

additional 
to 

the 
responding 

Eurostat  clarified  the  administrative 
impacts  on  data  providers. 
burden 
data 
Some 
of 
requirements 
long-
standing  specific  user  need  to  enable 
the  monitoring  of  policy  actions  with 
regards to SMEs would indeed increase 
the  burden  on  SMEs.  A  number  of 
examples  have  been  provided 
to 
in  many  Business 
vindicate 
Statistics domains special measures are 
in  place  to  guarantee  that  SMEs  were 
protected  from  excessive  burden  and 
data  compilers  would  make  particular 
efforts  to  minimise  the  burden  on 
SMEs for those new data requirements. 

that 

52 

 
 
 
 
 
 
Further  recommendations 
improvements by the Board: 

for 

What has been done? 

Where? 

Chapter  2  of  the  impact  assessment 
report  has  been  redrafted  to  explain 
better  the  existing  problems  and  their 
consequences. 
and 
quantitative evidence has been added.  

Qualitative 

Throughout Chapter 2. 

The  general  objective  and  the  specific 
objectives  have  been  redrafted  in  line 
with the recommendation. 

Section 4.1 and Section 4.2 

Sections 5.1 and 5.2 

the  mapping  of 

The  list  of  policy  options  has  been 
redrafted  and 
the 
options  (compared  to  ones  from  the 
inception  report)  was  deleted.  The 
discarded  options  paragraph  was 
redrafted  to  explain  why  the  recast 
option was not considered. 

criterion  of 

The 
assessed for all retained options. 

coherence  was 

Chapter 6  

For  each  of  the  options  the  effect  on 
coherence  was  added  under 
the 
comparison. 

Chapter 7 

Targets for key performance indicators 
for  each  of  the  operational  objectives 
were included in the report. 

Overview  table  at  the  end  of 
Chapter 8. 

It  has  been  clarified  that  all  public 
consultations  were  open  and  that  other 
issues than costs were consulted upon. 

Section 1.3 and Annex II 

The  problem  definition  should  be 
clearer.  The  presentation  should 
follow the logic outlined in the BR 
Toolbox.  All  elements  should  be 
supported  with  qualitative  and/or 
quantitative evidence.  

The  general  objectives  should  be 
treaty-based goals which the policy 
aims  to  contribute  to.  The  general 
objectives  included  in  the  report 
are broadly identical to the specific 
objectives.  

the  options 
The  description  of 
should  be 
improved.  Not  all 
options  of  the  inception  impact 
assessment 
to  be 
quoted.  It  should  be  explained  in 
the  report  why  the  option  of  a 
recast  of  the  existing  regulations 
was not included in the report. 

report  need 

All  retained  options  should  be 
assess  against  three  basic  criteria, 
i.e.  effectiveness,  efficiency  and 
coherence.  The  report  lacks  the 
assessment of the latter. 

The  comparison  of  options  should 
include narrative on coherence. 

The report should specify when the 
objectives  of 
initiative  are 
the 
considered  as  having  been  met  or 
not. 

The report should explain if any of 
the  conducted  public  consultation 
were open public consultations and 
should  not  be  limited  only  to  the 
queries  on  costs  but  also  on  other 
elements consulted upon. 

Evidence used 

In  reference  to  the  evidence  that  constitutes  the  basis  for  the  Impact  assessment,  it  is  first 
pertinent  to  mention  the  evaluation  tools  currently  in  place  that  already  allow  for  good 
analysis of the effectiveness and the efficiency of new statistical initiatives and the quality of 
the  data  produced.  These  tools  include:  the  European  Statistical  programmes  (currently 
regulation  99/2013),  which  foresee  systematic  mid-term  and  final  evaluation  of  the 

53 

 
 
 
 
 
programme, of which business statistics represent an integral part18;  the follow-up of a series 
of  performance  indicators,  as  planned  by  the  Eurostat  management,  which  also  applies  to 
business  statistics19;  and  the  Users  satisfaction  surveys  carried  out  on  a  regular  basis20.In 
addition,  the  ongoing  assessment  of  the  quality  of  the  statistics  undertaken  by  Eurostat, 
presented  in  the  form  of  Quality  reports21,represent  a  source  of  extensive  and  reliable 
evidence  for  the  preparation  of  the  impact  assessment  and  at  the  same  time  a  tool  for 
monitoring and evaluating the impacts of the new legislative proposal. 

Systematic  Rolling  Reviews,  in  accordance  with  the  binding  standards  approved  by  the 
Commission,  were  also  carried  out.  They  formed  part  of  the  Quality  Assurance  Framework 
developed by Eurostat in 200722. 

Further  evidence  for  this  impact  assessment  was  collected  from  the  consultations  of  the 
relevant stakeholders –Directorate Generals of the European Commission, National Statistics 
Institutes  (NSIs)  and  National  Central  Banks  (where  relevant),  and  businesses  and  their 
associations  and    the  public  (i.e.  academics/researches,  interest  groups,  media  and  non-
governmental  organisation,  and  individuals)  –conducted  as  part  of  the  preparation  of  this 
impact assessment. The combination of the information  provided  from the data users  –from 
within (DGs and EU agencies) and outside of the EU administration (e.g. external micro-data 
users);  from  data  providers  (businesses);  and  from  the  data  compilers  (National  Statistics 
Institutes) and extensiveness of the consultations ensures the robustness and the relevance of 
the  information  collected.  An  additional  aspect  that  contributes  to  the  robustness  and 
comprehensiveness of the evidence gathered thorough the stakeholders' consultation is the use 
of several modes of data collections (i.e. the use online questionnaires addressed to the open 
public,  the  data  users  and  data  providers,  the  targeted  consultation  of  data  compilers,  in 
combination with in-depth discussions to data users and data producers), which broadened the 
scope  of  the  exercise,  and  allowed  to  undergo  a  more  detailed  analysis  of  the  problems  at 
hand,  and  a  thorough  assessment  of  the  possible  solutions  from  the  perspectives  of  the 
different stakeholders. 

External expertise used 

The inter-service group (ISG) created in the context of this impact assessment, in which the 
above-mentioned DGs were represented, constituted –besides its already established function 
of steering the IA process and contributing to the collective preparation of the IA report, and 

18 See http://ec.europa.eu/eurostat/web/quality/general-evaluation-results  
19  The  five  key  performance  indicators  are  the  following:  Number  of  data  extractions  made  by  external  users 
from Eurostat reference databases (EuroBase and Comext) via the Eurostat website, Percentage of users that 
rate  as  "Very  good"  or  "Good"  the  overall  quality  of  European  statistics,  Percentage  of  users  that  rate  as 
"Very good" or "Good" the timeliness of European statistics for their purposes, Percentage of users that rate 
as "Very good" or "Good" the comparability of European statistics among regions and countries, Residual 
error rate (RER) 

20 See http://ec.europa.eu/eurostat/web/quality/general-evaluation-results   
21 See: http://ec.europa.eu/eurostat/web/quality/quality-reporting 
22 More detail can be found under http://ec.europa.eu/eurostat/web/quality/evaluation 

54 

 
 
 
 
                                                            
in relation to the fact that the DGs are main data users of the business statistics provided by 
Eurostat–,  a  most  relevant  source  of  external  expertise  for  the  preparation  the  Impact 
assessment of new legislation.  

Besides the expertise and the advice sought from the inter-service steering group of the DGs, 
also the assistance of two external contractors has been used. Namely, the contractors assisted 
in executing the stakeholders' consultations, summarising the main results and analysing the 
evidence gathered.  

The  expertise  of  the  NSIs  has  also  been  profoundly  relied  upon.  Namely,  there  have  been 
extensive  discussions  and  exchange  of  views  as  part  of  regular  domain-specific  working 
groups, 
through  various  bilateral 
consultations. 

task-forces,  directors  groups  and  also 

informally 

ANNEX II: STAKEHOLDER CONSULTATIONS 

1. Introduction  

Besides  the  regular  and  extensive  consultations  of  the  concerned  parties  (more  than  100 
meetings in total with Member states, EFTA countries and others) during the development of 
the  FRIBS  proposal  (including  the  problem  definition  and  the  need  for  a  EU  rather  than  a 
national  solution  (subsidiarity)),  three  rounds  of  specific  stakeholder  consultations  were 
organised for the preparation of the FRIBS Impact Assessment. The first round covered the 
FRIBS infrastructural elements (such as the Business Registers, micro-data exchange, quality 
issues  and  confidentiality).  The  second  round  focussed  on  the  changes  to  the  data 
requirements to be introduced by FRIBS and the third round collected stakeholders' opinions 
on the modernisation of Intrastat.  Each round consisted of a targeted consultation of the data 
compilers (NSAs)23 and an open public consultation also aiming at collecting feedback from 
the  data  providers  (businesses)24  and  data  users25.  .  The  consultations  meet  the  minimum 
standards of the European Commission for the consultation of interested parties. This Annex 
will first give an overview of the different consultations undertaken. In addition, the outcomes 
of the respective consultations are summarised.  

1. 1. The first round of consultations on the FRIBS infrastructural elements26 

23 National statistical authorities (NSAs) of the 28 EU Member States and 4 EFTA countries responsible for the 
collection,  compilation  and  dissemination  of  statistics  at  the  national  level;  this  includes  the  National 
Statistical Institutes (NSIs), but also other compilers such as National Central Banks. 

24 Businesses (including SMEs) responding to statistical surveys at national/regional level. 

25 All actors who are frequently using European business statistics, such as other Commission services, national 
policy  makers,  NSAs,  National  Central  Banks  and  the  European  Central  Bank,  professional  associations, 
businesses and researchers. 

26  The  infrastructural  elements  include  the  Business  Registers,  micro-data  exchange,  quality  issues  and 

confidentiality 

55 

 
 
 
 
 
                                                            
The  consultation  on  the  FRIBS  infrastructural  elements  took  place  in  2014  In  the  targeted 
consultation  of  the  NSAs,  the  data  compilers  were  in  particular  consulted  on  the  expected 
qualitative  impacts  of  FRIBS,  the  qualitative  comparison  of  FRIBS  and  alternative  policy 
options,  the  expected  quantitative  impacts  of  FRIBS  and  alternative  policy  options  and  the 
expected quantitative impacts of FRIBS and alternative policy options for data providers. 

29  of  the  32  NSAs  which  were  invited  to  participate  in  the  targeted  consultation  of  data 
compilers  provided  their  contribution.  27  EU  Member  States  and  2  EFTA  countries  finally 
responded.  

In total, 54 respondents answered to the public consultation of data users and providers on the 
expected  qualitative  impacts  of  FRIBS  and  the  qualitative  comparison  of  FRIBS  and 
alternative  policy  options.  Professional  associations  were  responding  most,  followed  by 
academic and research institutes and by business themselves. Most respondents were users of 
European  business  statistics,  only  a  few  were  providers  of  statistical  data  (i.e.  enterprises). 
The  remaining  responses  came  from  organisations  linked  to  national  and/or  European 
institutions. 

1.2. The second round of consultations on the FRIBS additional data requirements 

During the Business Statistics Directors Group (BSDG) meeting in 12/2014, Member States 
asked  for  an  additional  consultation  on  the  impacts  of  the  additional  data  requirements  in 
FRIBS. Therefore, this second consultation was organised in 2015 assessing the impact of the 
data  requirements  as  changed  by  FRIBS  (both  for  increases  and  reductions).  This  second 
round  of  consultations  complements  the  first  cost-benefit  analysis  of  the  infrastructural 
elements as described under section 1.  

This  second consultation phase also aimed at receiving  input  data compilers, data providers 
and data users.  The data users were asked to describe the qualitative impacts of the proposed 
changes (quality, flexibility, timeliness),  

The  data  compilers  were  asked  to  assess  the  one-off  implementation  costs  and  changes  in 
yearly  operating  costs  as  well  as  the  estimated  changes  in  administrative  burden  for  data 
providers caused by the changes in the data requirements of FRIBS. 

All  28  NSIs  from  EU  Member  States  and  1  NSI  from  EFTA  countries  answered  to  this 
consultation. In addition 17 replies came from NCBs (9 of those were joint replies from the 
NCB and the NSI).  

For this round of public consultation separate questionnaires were addressed to data providers 
and data users respectively.  The data users were asked to describe the qualitative impacts of 
the  proposed  changes  (quality,  flexibility,  timeliness)  and  the  data  providers  to  assess  the 
impact  on  administrative  burden  (  qualitative  assessment)  caused  by  the  changes  in  the 
proposed data requirements of FRIBS. 

52 data users answered; many replies came from National Accounts departments and business 
associations.  In  addition  EU  institutions,  research  institutes,  public  authorities'  individual 

56 

 
 
 
 
businesses and central banks replied. In spite of many extensive efforts from Eurostat, only a 
limited number of replies from data provides were received.  

1.3. The third round of stakeholder consultations related to Intrastat   

Separate targeted and open public stakeholder consultations have been carried out on Intrastat 
feeding  into  the  impact  assessment  as  well  as  to  the  modernisation  of  Intrastat.  The  overall 
aim  of  the  modernisation  project  is  to  assess  the  impacts  of  the  three  options  proposed  – 
SIMSTAT, Revised Intrastat and Single Flow - in terms of their costs and benefits.  

The NSAs have been addressed in a targeted consultation for collecting data for a cost-benefit 
analysis.  This  cost-benefit  analysis  aims  at  providing  input  to  the  ESSC  to  take  a  strategic 
orientation  on  the  modernisation  of  Intrastat.  At  the  same  time  the  cost-benefit  analysis  is 
contributing to the more encompassing cost-benefit analysis of FRIBS.  

The methodology followed for the cost-benefit analysis consists of two actions: quantitative 
assessment (cost analysis) and qualitative assessment (SWOT analysis). 

The  aim  of  the  cost  analysis  was  to  estimate  the  costs  (current  costs,  development  and 
adaptation  costs,  future  costs)  incurred  by  the  NSAs  caused  by  the  implementation  of 
modernisation  options  for  Intrastat.  24  Member  States  provided  data  for  all  three  types  of 
costs. Eurostat finally estimated the complete EU costs for the NSAs.    

The  SWOT  assessment  for  the  Member  States  was  carried  out  in  autumn  2015  based  on  a 
standard  methodology.  26  Member  States  provided  their  SWOT  assessments,  with  some 
updates in 2016.  

For collecting data on the administrative burden, an extensive open public consultation of the 
data providers has been organised during the first quarter of 2016. More than 20.000 replies 
have been collected.  

2. Outcome of the consultations   

The  three  rounds  of  consultations  have  been  summarised  in  this  section  by  category  of 
stakeholder  in  order  to  provide  a  comprehensive  picture,  given  that  the  consultations  have 
been complementary.  

2.1.  Data users 

In the first round, 48 users responded to the consultation, in particular reporting the following 
issues:    

1.  Combining  data  from  different  business  statistical  domains:  many  problems  with 

inconsistencies between statistical domains exist.   

57 

 
 
 
 
 
 
 
 
2.  Consistency  of  statistical  data  across  Member  States:  many  respondents  believe  that 
inconsistencies exist and that those have a negative impact on both the quality of their 
work  and  the  time  required  for  exploiting  the  data.  Around  80%  of  respondents 
consider  that  an  increased  coherence  and  consistency  of  data  would  significantly 
improve both, the quality of their work and the time needed for exploiting the data. 

3.  Additional  data  needs:  The  majority  of  users  judge  the  extension  of  the  FRIBS  data 

requirements positive. 

4.  Confidence  of  users  in  the  European  business  statistics  system:  nearly  80%  of  the 
respondents are very/rather confident in the quality of the current European business 
statistics;  

5.  Nearly  85%  of  the  respondents  have  indicated  that  a  single  harmonised  regulation 

would further increase their confidence in European business statistics. 

The  second  consultation  focused  on  the  FRIBS  additional  data  requirements  (i.e.  new  data 
requirements as well as deletion of some existing requirements). 52 data users responded to the 
consultation,  covering  EU  institutions  and  research  institutes  (28%),  National  Accounts 
departments  (25%),  business  associations  (23%)  and  other  public  authorities,  individual 
businesses or central banks (22%).  

Around  50%  of  the  data  users  emphasised  that  the  FRIBS  additional  data  requirements  are 
crucial  or  highly  important  for  them.  Crucial  new  requirements  are  in  particular  indicators  on 
globalisation and global value chains of enterprises in Structural Business Statistics and in FATS 
statistics;  and  the  improved  coverage  of  the  services  sector,  especially  the  introduction  of  a 
monthly  production  index  for  services  in  Short-Term  Statistics  and  the  level  of  detail  of 
Structural Business Statistics available for National Accounts.   

2.2. The data compilers (NSAs)    

The  results  presented  here  summarize  the  information  collected  on  costs  using  the  three 
targeted  consultations  of  the  data  compilers.  The  NSAs  that  provided  details  regarding  the 
current costs, caused by European business statistics, report total yearly costs of about EUR 
290  million.  This  total  translates into  an  average  amount  of  EUR  10.5  million  per Member 
State (27). 

The  total  yearly  costs  caused  by  European  business  statistics  can  –  as  an  average  -  be 
distributed as follows over the different statistical domains and the Business Registers (BR)28. 

27 Median value: EUR 4.9 million 

28 The business register is considered at the same level as the statistical domains.  

58 

 
 
 
 
 
 
 
 
                                                            
Importance of statistical domains in current annual costs of NSAs related to 
business statistics 

15,3% 

8,0% 

26,4% 

4,6% 

13,4% 

32,3% 

3,9% 

3,6% 

3,1% 

1,7% 
0,6% 
0,5% 

ITGS

STS

SBS

BR

Prodcom

ITSS

R&D/CIS

FDI

ISS

OFATS

IFATS

On average, the current annual costs are EUR 0.57 per EU inhabitant. An increase in yearly 
operating costs of NSAs between 4.3 % (EUR 436 000) and 6.8 % (EUR 700 000) (depending 
on  the  different  Intrastat  sub-options  consulted  and  analysed)  is  expected  due  to  FRIBS 
implementation as a whole, encompassing the infrastructural changes and the upgrade in the 
FRIBS data requirements.  

FRIBS  would  also  cause  one-off  investment  costs,  on  average  per  Member  State  between 
EUR 1.16 million and EUR 1.9 million (or between EUR 32  million and EUR 52 million  for 
the EU on total) depending on the different Intrastat sub-options consulted and analysed.  

These  increases  (operational  cost  increase  and  one-off  implementation  cost)  represent 
additional costs between EUR 0.08 and 0.14 per EU inhabitant. Cost increases are caused by 
all  statistical  domains,  except  International  Trade  in  Goods  Statistics  (ITGS).  The  new  data 
requirements for STS and SBS statistics cause most of the additional costs. For the ITGS, a 
reduction  of  costs  through  a  modernised  Intrastat  system  can  be  expected  (between  EUR  8 
million  and  EUR  18  million  depending  on  the  different  Intrastat  sub-options  consulted  and 
analysed).  

During  the  preparatory  phase  of  the  FRIBS,  the  Commission  (Eurostat)  provided  a  total  of 
EUR  37  million,  mostly  to  NSIs,  through  the  MEETS  programme  on  the  modernisation  of 
enterprise and trade statistics in addition to other pilot studies financed and carried out to test 
the  feasibility  of  new  data  requirements.  Eurostat    aims  to  provide  financing  (  within  the 
Commission  budgetary  constraints)  to  offset  some  of  the  investments  costs  needed    for  the 
further  modernisation  of  the  data  production  processes  and  systems  as  well  as  for  capacity 
building  and  piloting  of  data  production  related  to    new  data  requirements.  It  can  also  be 
expected that once the initial investments have been made the yearly operating costs for the 
NSA  would  gradually  decrease  when  multi-source  and  multi-purpose  data  collections  and 

59 

 
 
 
 
 
access  to  alternative  data  sources  –  administrative  or  collaboratively  generated  by  the  ESS 
(i.e. EGR and micro-data exchange) – will be increasingly used in many Member States. 

Regarding  the  preferred  policy  option,  the  results  of  the  first  targeted  consultation  of  the 
NSAs show that around 55 % of the NSIs indicated FRIBS as their preferred option, around 
10 % preferred Option B - the non-integrated approach of separate revisions of the individual 
acts  and  7  %  of  the  respondents  preferred  Option  A  -  keeping  the  status  quo  (no  policy 
change). Same ranking of the policy options was indicated by the data users during the open 
public  consultation.  The  results  however  depict  even  greater  support  for  FRIBS  -  Option  C 
with 74 % of the respondents supporting it, followed by Option B (non-integrated revision of 
separate legislative acts) with 13 % and finally Option A – no policy change was supported by 
4 % of the respondents. 

2.3.  Data providers (businesses)   

In spite of considerable efforts from Eurostat to advertise and encourage the participation of 
data users in the open public consultation, only a limited number of replies by data providers 
were  received  on  qualitative  impacts  in  the  first  two  rounds  of  the  public  consultations. 
Consequently, the responses could not be considered representative and not analysed further. 
Namely,  during  the  first  open  public  consultation  only  6  partial  responses  (from  1  micro-
enterprise, 1 small enterprise, 1 large company and 3 professional associations, all originating 
from  different  EU  countries)  were  recorded.  During  the  second  consultation  round  (on  the 
additional data requirements) only 5 replies were received. These came from: two individual 
businesses;  a  federation  of  businesses;  a  chamber  of  commerce,  and  a  national  statistical 
office. 

From  the  targeted  consultations  on  FRIBS  infrastructural  elements  and  changed  data 
requirements (other than intra-EU trade statistics), information on the current burden and on 
changes in the burden for data providers (businesses) were estimated by the NSAs. For most 
statistical  domains,  between  26  and  28  NSAs  provided  estimates  regarding  the  costs  for 
businesses  obliged  to  fill  in  business  statistics  surveys.  Information  on  the  administrative 
burden  caused  by  the  intra-EU  trade  statistics  and  the  effects  of  its  modernisation  was 
collected by a public consultation of data providers (businesses).  When the inputs from the 
consultation on businesses regarding the burden of the collection of Intrastat data is also taken 
into  account  the  total  administrative  burden  of  business  statistics  is  estimated  to  be  around 
EUR 689 million.  

Three statistical domains cause around 89% of this total burden: 

60 

 
 
 
 
 
 
 
 
Importance of statistical domains in current annual burden on businesses 
related to business statistics 

12,83% 

8,39% 

4,03% 

7,43% 

67,32% 

2,34% 

2,16% 

1,59% 
0,49% 
0,47% 
0,38% 

ITGS

STS

SBS

ITSS

Prodcom

FDI

R&D/CIS

IFATS

ISS

OFATS

67  %  of  the  burden  on  businesses  is  caused  by  statistics  on  International  Trade  in  Goods. 
Structural  Business  Statistics  and  Short  Term  Statistics  are  ranking  second  and  third.  The 
potential  reduction  of  the  total  burden  on  businesses  will  depend  on  the  level  of  national 
implementation of the simplifications and modernisation possibilities provided by FRIBS and 
is estimated to be: 

26.8 %  (or EUR 184 million) for sub-option C1 (SIMSTAT); 
12.1 %  (or EUR 83 million) for sub-option C2 (Revised Intrastat); 
33.6 % (or EUR 231 million) for sub-option C3 (Single Flow); 

13.5  %  (or  EUR  93  million),  at  least,  for  sub-option  C4  (combination  of  SIMSTAT  and 
Revised Intrastat). 

61 

 
 
 
 
 
  
 
 
  
 
 
 
ANNEX III: WHO IS AFFECTED BY THE INITIATIVE AND HOW 

The  production  and  use  of  European  business  statistics  involves  3  main  categories  of 
stakeholders:  

• 

• 

• 

Data  users:  this  includes  institutional  users  –national  administrations,  other 
international  organisations,  or  professional  staff  working  within  the  Commission 
services or DGs and other EU institutions, and other external users, such as mass 
media and academics. 
Data  compilers:  this  category  comprises  the  authorities  responsible  for  the 
collection and compilation of business statistics. It mainly includes the NSIs and 
Eurostat.   

Data providers: this category includes businesses which respond to surveys 

The preferred policy option has a significant impact on each of the stakeholder categories.  

1. Data users of European business statistics 

Currently  the  possibilities  for users to  analyse data  across domains of business statistics are 
hampered by differences in concepts, definitions and classifications. Data users will benefit of 
an  increased  coherence  of  the  business  statistics.  The  use  of  common  concepts  and 
definitions, classifications and breakdowns, will improve the quality perceived by the users of 
statistics.  

The preferred policy option allows for greater flexibility in the statistical work programme by 
providing for improved mechanisms to accommodate emerging information needs. Under the 
preferred  policy  option,  the  system  will  increase  flexibility  as  well  as  harmonise  business 
statistics; this has the double advantage of covering new information needs by producing new 
data and by combining them with those already collected.  

The  producers  of  macro-economic  accounts  will  benefit  from  the  increased  consistency  as 
well as from the improved quality of the business statistics which are used as critical inputs 
for the calculation of main economic indicators such as the GDP. 

To  benefit  of  greater  flexibility,  users  have  to  closely  work  with  statistical  authorities  to 
achieve  proportionality  in  the  satisfaction  of  information  needs  and  production  efforts.  This 
implies  ensuring  an  effective  mechanism  for  the  identification  of  negative  priorities.  At  the 
European  Commission  level,  the  institutional  users  (mainly  (DGs)  will  continue  working 
closely  with  Eurostat  on  defining  their  needs  and  will  develop  the  mechanisms  for  budget 
delegations.  This  is  normally  formalised  through  Memorandum  of  Understanding  between 
each user DG and Eurostat and the annual formal "hearing" with each DG that supports the 
definition of the annual and multi-annual statistical programmes. 

62 

 
 
 
 
 
 
 
 
 
 
2. Data compilers, the National Statistical Authorities 

The production of European business statistics is mostly done at national level by NSIs and 
NCBs,  which  are  public  institutions  and  therefore  with  public  budgets.  Additional 
requirements  of  information  lead  to  the  need  for  higher  budgets,  unless  measures  to 
significantly increase efficiency are taken.  

The cost of accommodating new information needs includes new methodological work, new 
data  collection,  new  processing  or  dissemination  methods.  The  bulk  of  costs  go  to  data 
collection.  The  increased  information  requirements  foreseen  in  the  preferred  option 
necessitate  an  assessment  at  the  national  level  on  the  most  cost-efficient  way  of  data 
production,  but  an  initial  investment  -  irrespective  of  the  choice  on  the  production  method- 
can be expected. As a consequence, the  preferred option also foresees provisions which allow 
for the modernisation of production (e.g. using more administrative data, better technology or 
sharing methodological solutions among NSIs) and by data sharing ( as foreseen by the EGR 
and the modernisation of Intrastat) and collaborative approaches to data compilation.  

National production processes would benefit from a network of integrated business registers, 
from  the  improved  access  to  administrative  and  other  data  sources  as  well  as  from  the 
possibility to use micro-data collected by other national statistical authorities. More integrated 
processes should also lead to increased cooperation between the national statistical authorities 
concerned and facilitate long term overall cost savings for them.   

Carrying  out  new  surveys  or  increasing  the  frequency  of  data  collections  has  a  significant 
impact on cost. Unless constraints on the rising cost are put in place, policy options increasing 
the flexibility may highly impact the budgetary needs of NSIs.  

It  has  to  be  mentioned  that  the  most  expensive  surveys  are  those  carried  out  with  large 
samples or with high frequency (e.g. STS).  Policy options that consider mechanisms for (1) 
evaluating the relevance of additional information requirements and (2) simplifying the work 
programmes  by  excluding  the  data  collections  which  are  not  deemed  relevant  anymore 
(negative priorities) would provide safeguards for increases in cost.  

NSIs would however benefit of a simpler, integrated legislation that would allow for reducing 
the legal work to update the statistical regulations, that would consider the whole system of 
business statistics when planning and designing each data collection and that would promote 
the  modernisation  of  processes  (e.g.  by  facilitating  access  to  administrative  data  and  other 
sources) and increase the methodological coherence across surveys.  

In  practice,  the  joint  work  of  Eurostat  and  the  NSIs  to  integrate  business  statistics  will 
continue with the elaboration of the necessary implementing measures. The role of the BSDG 
will  thus  be  reinforced  as  the  main  technical  forum  of  discussion  on  business  statistics, 
advising the ESSC and the Commission. The balance of costs and benefits, in financial terms, 
is difficult to assess since it depends on the actual implementation of changes in existing data 
collections.  In  some  Member  States  such  collections  existed  or  have  already  been 
implemented. Progress in the harmonised and comparable measurement of production costs in 

63 

 
 
 
 
NSIs would not only improve the management at the national level, but also provide a sound 
basis  for  monitoring  and  evaluating  the  impact  of  any  modernisation  process  –  be  it  or  not 
related to legal obligations.  

3. Data providers, the businesses 

While some of the new information needs proposed by the preferred policy option could be 
accommodated using administrative sources or data sharing, there will be impacts also on data 
providers.  The increased coverage of the services sector and the increased frequency of some 
of  the  short-term  statistics  to  be  produced  may  create  more  burden  on  the  respondents. 
However, this potential increase is expected to be more than offset by the possibility to re-use 
data  collected  by  other  NSAs  for  intra-EU  trade  in  goods  statistics  and  by  modernising  the 
trade  in  goods  statistics.  The  SIMSTAT  exchange  of  micro-data  has  the  potential  to  reduce 
the overall burden created by business statistics by about 10 %. In addition, a reduction of the 
coverage rates (of imports and exports) for intra-EU trade in goods statistics , foreseen in the 
Revised Intrastat sub-option would also relieve some businesses from the burden to provide 
data for intra-EU trade in goods statistics. 

Impact on SMEs: 

The  additional  data  requirements  might  result  in  additional  burden  for  SMEs  especially  as 
regards  the  extended  information  on  the  services  sector.  In  the  qualitative  consultation 
responses provided by the data compilers the NSAs have assured that the utmost care is taken 
to  ensure  that  the  burden  on  the  SMEs  is  as  limited  as  possible  by  e.g.  the  use  of 
administrative  data  or  advanced  statistical  methods.  The  modernisation  of  Intrastat  as 
mentioned above would also reduce the burden of SMEs. 

64 

 
 
 
 
 
 
 
 
ANNEX IV: ANALYTICAL MODELS USED IN PREPARING THE IMPACT 
ASSESSMENT 

The  impact  assessment  has  been  based  on  a  cost-benefit  analyses  of:  on  one  hand  the 
REDESIGN of Intrastat (i.e. the options for modernising the collection of Intrastat statistics) 
and on the other hand, all the envisaged modifications in all other statistical domains which 
FRIBS  is  covering.  Those  two  cost-benefit  analyses  have  been  combined  with  the  goal  to 
evaluate  and  compare  in  detail  the  ability  of  the  policy  options  to  achieve  the  objectives, 
identified for solving the current problems. This cost-benefit analysis has utilised as much as 
possible  the  use  of  quantitative  data,  having  in  mind  a  principle  of  proportionality.  For  the 
assessment of some of the impacts quantitative data could however not be collected and for 
these  elements  qualitative  elements  have  been  collected.    In  summary,  the  following 
assessments are made for each of the shortlisted policy options: 

• qualitative assessment of their impacts; 

• quantitative assessment of:  expected  costs  for  NSAs;  expected  costs  for  data  providers 
(administrative burden); 

The analysis thus implies that the outcome of the comparison of quantified costs (in Euros) 
and  benefits  is  confronted  with  the  qualitative  assessment  of  other  advantages  and 
disadvantages.  

Common  to  all  approaches  presented  is  the  fact  that  in  an  impact  assessment,  impacts  are 
typically to be expressed as an expected effect in comparison to what would happen under the 
no policy change option. As a consequence, the cost-benefit analysis will provide estimations 
of the additional costs and additional benefits compared to the baseline scenario. Indeed, the 
main objective of the impact assessment is to enable comparison between the options, which 
implies 
that  expressing  the  correct  relations  between  values  and  options  (relative 
relationships) are of higher importance than determining the total cost/benefit of each option. 
An  effort  has  however  been  made  to  quantify  the  baseline  scenario.  There  was  a  lack  of 
existing harmonised and comprehensible data. A targeted data collection was necessary. 

The cost-benefit analysis brings together the comparative results of the different approaches, 
so  as  to  allow  an  integrated  comparison  over  all  types  of  impacts  of  the  different  policy 
options. Namely: 

- qualitative assessment of the impacts of each policy option; 

- assessment of the costs for NSIs; 

- assessment of the costs for data providers 

Qualitative assessment of the impacts of each policy option 

65 

 
 
 
 
 
 
 
One  of  the  cornerstones  of  a  detailed  comparative  assessment  of  the  policy  options  is  a 
qualitative assessment of the way in which the options address the different objectives (i.e. the 
effectiveness of the policy options). In this way, it is possible to take account of impacts that 
cannot be quantified in Euros, such as the benefits. 

For the qualitative assessment, a set of expected impacts relating to the identified objectives, 
are  defined,  and  subsequently  reviewed  per  policy  option,  in  order  to  identify  the  most 
advantageous option. By linking the impacts directly to these objectives, the degree to which 
the  options  will  reach  the  objectives  will  become  apparent  in  a  very  straightforward  way. 
Information on the impacts was collected via an open and a more targeted consultation. 

The appropriate objectives for a suchlike analysis in this case are the operational objectives, 
as this level of detail allows a well-founded analysis and by consequence a true comparison of 
options. 

Assessment of the costs for NSAs 

A second part of the cost-benefit analysis consists of the assessment of the costs for NSAs for 
implementing  the  different  policy  options.  This  assessment  is  for  the  largest  part  based  on 
information that was specifically collected from the individual NSAs during the consultation 
rounds  (first  one  on  FRIBS  infrastructural  elements  and  second  one  on  introduction  of  new 
data  requirements  and  on  a  separate  track  the  consultation  on  the  costs  of  different  sub-
options for modernising Intrastat). NSAs were asked to provide a baseline and to assess the 
cost  of  the  changes  brought  about  by  the  envisaged  changes.  NSAs  have  provided  their 
estimations of costs (current and future) per statistical domain and an estimate for the one-off 
implementation costs of the changes which would also be incurred.  

Assessment of the costs for data providers (administrative burden) 

The  third  part  of  the  cost-benefit  analysis  relates  to  the  assessment  of  the  costs  for  data 
providers  (i.e.  administrative  burden)  linked  to  the  implementation  of  the  different  policy 
options. In order to give a complete overview of the impact on the administrative burden, the 
assessment is not limited to the costs directly linked to the completion of statistical surveys, 
but  will  consider  the  administrative  burden  of  data  provider  (businesses)  in  a  broad  sense, 
including  also  qualitative  elements  ,  as  well  as  non-staff  costs  (e.g.  investments  in  IT-
systems). 

Regarding  all  the  business  statistics  domains,  except  for  the  Intrastat  part  of  International 
Trade in Goods (ITGS), the individual contributions of NSAs from the targeted consultations 
represent  the  main  sources  for  the  assessment  of  the  costs  for  data  providers29.  Regarding 

29 Through the consultation of stakeholders, it was also attempted to obtain direct inputs from data providers, but 

this has not resulted in usable information. 

66 

 
 
 
 
 
 
                                                            
Intrastat, the assessment of the costs for data providers is based on public consultations of the 
data providers themselves. 

The  Standard  Cost  Model  (SCM)  methodology  was  applied  to  the  figures  obtained  through 
these consultations: by combining the total time spent on filling out surveys on a yearly basis 
and (cost) level of the employee completing the survey, the (current and future) administrative 
burden could be derived.  

Overview of the costs of data production under different policy options: 

In Chapter 6, the final results of a model based scenario were presented for the cost of data 
production under the different policy options.  The cost model and its assumptions for Options 
B and C respectively are presented in the following two boxes: 

Option B: Modelling implementation costs against the benefits in data collection and production 

Even though there are severe limitations to estimating the long term impacts on costs of data collection and 
production, this box contains a modelling example to compare the increase in one-off costs of implementation of 
a new data production design and in operational costs due to the new data requirements foreseen at this stage 
against the long term benefits of more efficient data collection and production. Another limitation of the model is 
that the implementation speed of the initiative might significantly vary across Member States. This hence would 
also imply heterogeneous rates of the potential implementation cost reductions and productivity gains over time 
triggered by the underlying modernisations undertaken by Member States. 

The information regarding the increase in one-off costs and initial operational costs has been estimated based on 
the information collected from the data compilers. The potential decrease of cost in data collection and 
production facilitated by legislative actions under this Option B over a ten year period is estimated based on a 
conservative model assuming an annual (diminishing) decrease of costs of 1% over a period of 10 years. It is 
assumed that the annual decrease of costs diminishes with 0.05 % per year (eg. 1 % in year N and 0.55 % in year 
N+9). In addition, a decrease in costs over time due to annual (diminishing) productivity gains of 2 % (based on 
Eurostat calculations) is forecasted. It is assumed annual productivity gains would be diminishing with 0.1 % per 
year (eg. 2 % in yean  N and  1.1 % in year  N + 9). As it is difficult to assess when exactly the cost reductions 
will occur, a linear model has been applied. Costs related to non yearly surveys have been annualised. All 
amounts are presented in present values, with a discount rate of 4 %. 

Combining this assumption, and the input received from NSAs results, for the EU on total, in: estimated one-off 
costs plus increased annual operational costs (over the 10 years) of: EUR 230 million for sub-option B1, EUR 
209 million for sub-option B2, EUR 144 million of sub-option B3, and between EUR 209 million and EUR 230 
million of sub-option B4 while leading to a (EU on total) decrease of EUR -120 million for all sub-options in the 
data collection and production during the 10 years of implementation. This results in a net increase (for the EU 
on total and over the 10 years): of EUR +103 million for sub-option B1; EUR +83 million for sub-option B2, of 
EUR  +29  million  of  sub-option  B3,  and  between  EUR  83  million  and  EUR  103  million  of  sub-option  B4  in 
present value terms. 

67 

 
 
 
 
 
 
  
 
Option C: Modelling implementation costs against the benefits in data collection and production 

Even though there are severe limitations to estimating the longer term impacts on costs of data collection and 
production, this box contains a modelling example to compare the increase in one-off costs of implementation of 
a new data production design and in initial operational costs due to the new data requirements foreseen at this 
stage against the longer-term benefits of more efficient data collection and production. Another limitation of the 
model is that in reality the implementation speed of the initiative might significantly vary across Member States. 
This  hence  would  also  imply  heterogeneous  rates  of  the  potential  implementation  cost  reductions  and 
productivity gains over time triggered by the underlying modernisations undertaken by Member States. 

The information regarding the increase in one-off costs and initial operational costs has been estimated based on 
the  information  collected  from  the  data  compilers.  The  potential  decrease  of  cost  in  data  collection  and 
production facilitated by legislative actions under this Option C over a ten year period is estimated based on a 
conservative model assuming an annual (diminishing) decrease of costs of 2 % over a period of 10 years. It is 
assumed that the annual decrease of costs diminishes with 0.1 % per year (eg. 2 % in year N and 1.1 % in year 
N+9). In addition, a decrease in costs over time due to annual (diminishing) productivity gains of 2 % (based on 
Eurostat calculations) is forecasted. It is assumed annual productivity gains would be diminishing with 0.1 % per 
year ( eg. 2 % in yean  N and  1.1 % in year  N + 9). As it is difficult to assess when exactly the cost reductions 
will  occur,  a  linear  model  has  been  applied.  Costs  related  to  non  yearly  surveys  have  been  annualised.  All 
amounts are presented in present values, with a discount rate of 4%. 

Combining this assumption, and the input received from NSAs results in, for the EU on total, estimated one-off 
costs plus increased annual operational costs (over the 10 years) of: EUR 224 million for sub-option C1, EUR 
203 million for sub-option C2,  EUR 140 million of sub-option C3, and between EUR 203 million and EUR 224 
million  of  sub-option  C4  while  leading  to  a  decrease  of  EUR  -235  million  for  all  sub-options  in  the  data 
collection and production during the 10 years of implementation. This results in a present value (for the EU on 
total  and  over  the  10  years)  of:  net  increase  of:  EUR  +9  million  for  sub-option  C1,  net  savings  of  EUR  -10 
million for sub-option C2, net savings of EUR -62 million of sub-option C3, and between EUR + 9 million and 
EUR – 10 million for sub-option C4. 

It is important to note that the model is based on data collected from the data compilers and 
on assumptions summarised in the following table, together with the results aggregated for all 
the data collections. 

The yearly details of the various sub-options30 are presented in the following table. 

30 Sub-option B4 and sub-option C4 are not explicitly inserted in the table since, as indicated in the boxes above, 
their values are the ranges between the values of sub-options B1 and B2; and C1 and C2 respectively. 

68 

 
 
 
 
 
 
 
 
 
                                                            
Change 
in costs 
as 
compare
d to the 
baseline 
EU-total 
annual 
cost 
increase 
including 
one-off 
investme
nt 
EU-total 
cost  
decrease 

EU-total 
annual 
cost 
increase 
including 
one-off 
investme
nt 
EU-total 
cost  
decrease 

Source of 
data/Assumpti
ons 

Subopti
on B1 

targeted 
consultations 
of data 
compilers 

SIMSTA
T 

normal 
decrease in 
cost due to 
productivity 
gains = 2% in 
first year 
(reduced with 
0.1% for every 
consecutive 
year); 
additional 
decrease due 
to changes to 
existing legal 
acts = 1% in 
first year 
(reduced with 
0.05% for 
every 
consecutive 
year)  

Subopti
on B2 

targeted 
consultations 
of data 
compilers 

revised 
Intrastat 

normal 
decrease in 
cost due to 
productivity 
gains = 2% in 
first year 
(reduced with 
0.1% for every 
consecutive 
year); 
additional 
decrease due 
to changes to 
existing legal 
acts = 1% in 
first year 
(reduced with 
0.05% for 
every 
consecutive 
year)  

year
1 

year
2 

year
3 

year
4 

year
5 

year
6 

year
7 

year
8 

year
9 

year1
0 

Total 

Net 
prese
nt 
value 

72.9
2 

19.1
6 

18.6
4 

18.1
7 

17.7
3 

17.3
3 

16.9
7 

16.6
4 

16.3
4 

16.07 

229.9
5 

-
2.90 

-
5.52 

-
7.88 

-
10.0
0 

-
11.9
2 

-
13.6
3 

-
15.1
7 

-
16.5
5 

-
17.7
8 

-
18.86 

-
120.2
1 

54.4
3 

18.8
8 

18.3
7 

17.9
0 

17.4
7 

17.0
8 

16.7
2 

16.3
9 

16.1
0 

15.83 

209.1
5 

-
2.90 

-
5.52 

-
7.88 

-
10.0
0 

-
11.9
2 

-
13.6
3 

-
15.1
7 

-
16.5
5 

-
17.7
8 

-
18.86 

-
120.2
1 

102.7
1 

83.08 

Subopti
on B3 

targeted 
consultations 
of data 

EU-total 
annual 
cost 

44.9
5 

12.1
1 

11.7
9 

11.4
9 

11.2
1 

10.9
6 

10.7
3 

10.5
2 

10.3
3 

10.16 

144.2
5 

69 

 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
single 
flow 

Subopti
on C1  

SIMSTA
T 

Subopti
on C2 

compilers 

normal 
decrease in 
cost due to 
productivity 
gains = 2% in 
first year 
(reduced with 
0.1% for every 
consecutive 
year); 
additional 
decrease due 
to changes to 
existing legal 
acts = 1% in 
first year 
(reduced with 
0.05% for 
every 
consecutive 
year)  

targeted 
consultations 
of data 
compilers 

normal 
decrease in 
cost due to 
productivity 
gains = 2% in 
first year 
(reduced with 
0.1% for every 
consecutive 
year); 
additional 
decrease due 
to changes to 
existing legal 
acts = 2% in 
first year 
(reduced with 
0.1% for every 
consecutive 
year)  

targeted 
consultations 
of data 
compilers 

increase 
including 
one-off 
investme
nt 
EU-total 
cost  
decrease 

EU-total 
annual 
cost 
increase 
including 
one-off 
invetme
nt 
EU-total 
cost  
decrease 

EU-total 
annual 
cost 
increase 
including 
one-off 
investme
nt 

-
2.90 

-
5.52 

-
7.88 

-
10.0
0 

-
11.9
2 

-
13.6
3 

-
15.1
7 

-
16.5
5 

-
17.7
8 

-
18.86 

-
120.2
1 

72.9
2 

18.9
7 

18.2
9 

17.6
7 

17.1
0 

16.5
9 

16.1
2 

15.7
0 

15.3
3 

14.99 

223.6
8 

29.69 

-
5.80 

-
10.9
8 

-
15.6
0 

-
19.7
3 

-
23.4
0 

-
26.6
7 

-
29.5
8 

-
32.1
5 

-
34.4
3 

-
36.43 

-
234.7
6 

54.4
3 

18.6
9 

18.0
2 

17.4
1 

16.8
5 

16.3
4 

15.8
9 

15.4
7 

15.1
0 

14.77 

202.9
7 

9.26 

70 

 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
cost  
decrease 

-
5.80 

-
10.9
8 

-
15.6
0 

-
19.7
3 

-
23.4
0 

-
26.6
7 

-
29.5
8 

-
32.1
5 

-
34.4
3 

-
36.43 

-
234.7
6 

44.9
5 

12.0
0 

11.5
6 

11.1
7 

10.8
1 

10.4
9 

10.2
0 

9.93 

9.69 

9.48 

140.2
8 

-10.29 

-
5.80 

-
10.9
8 

-
15.6
0 

-
19.7
3 

-
23.4
0 

-
26.6
7 

-
29.5
8 

-
32.1
5 

-
34.4
3 

-
36.43 

-
234.7
6 

EU-total 
annual 
cost 
increase 
including 
one-off 
investme
nt 
EU-total 
cost  
decrease 

revised 
Intrastat 

Subopti
on C3 

single 
flow 

normal 
decrease in 
cost due to 
productivity 
gains = 2% in 
first year 
(reduced with 
0.1% for every 
consecutive 
year); 
additional 
decrease due 
to changes to 
existing legal 
acts = 2% in 
first year 
(reduced with 
0.1% for every 
consecutive 
year)  

targeted 
consultations 
of data 
compilers 

normal 
decrease in 
cost due to 
productivity 
gains = 2% in 
first year 
(reduced with 
0.1% for every 
consecutive 
year); 
additional 
decrease due 
to changes to 
existing legal 
acts = 2% in 
first year 
(reduced with 
0.1% for every 
consecutive 
year)  

-62.00 

71 

 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
ANNEX V: LIST OF THE CURRENT LEGAL ACTS GOVERNING EUROPEAN 
BUSINESS STATISTICS 

1) Business Registers domain: 

REGULATION (EC) No 177/2008 OF THE EUROPEAN PARLIAMENT AND OF THE 
COUNCIL of 20 February 2008 establishing a common framework for business registers for 
statistical purposes and repealing Council Regulation (EEC) No 2186/93; 

2) Structural Business Statistics (SBS) domain: 

REGULATION (EC) No 295/2008 OF THE EUROPEAN PARLIAMENT AND OF THE 
COUNCIL of 11 March 2008 concerning structural business statistics; 

3) Short-Term Business Statistics (STS) domain: 

 COUNCIL REGULATION (EC) No 1165/98 of 19 May 1998 concerning short-term 
statistics; 

4)  Statistics on the production of manufactured goods (PRODCOM) domain: 

COUNCIL REGULATION (EEC) No 3924/91 of 19 December 1991on the establishment of 
a Community survey of industrial production;  

5) Foreign Affiliates Statistics (FATS) domain: 

REGULATION (EC) No 716/2007 OF THE EUROPEAN PARLIAMENT AND OF THE 
COUNCIL of 20 June 2007 on Community statistics on the structure and activity of foreign 
affiliates; 

6) Statistics on trade with non-member countries (Extrastat) domain: 

REGULATION (EC) No 471/2009 OF THE EUROPEAN PARLIAMENT AND OF THE 
COUNCIL of 6 May 2009 on Community statistics relating to external trade with non-
member countries and repealing Council Regulation (EC) No 1172/95;  

7)  Statistics on trade between EU Member States (Intrastat) domain: 

REGULATION (EC) No 638/2004 OF THE EUROPEAN PARLIAMENT AND OF THE 
COUNCIL of 31 March 2004 on Community statistics relating to the trading of goods 
between Member States and repealing Council Regulation (EEC) No 3330/91; 

8) Research and Development Statistics and Innovation Statistics (R&D and CIS) 
domain: 

72 

 
 
 
 
 
 
DECISION No 1608/2003/EC OF THE EUROPEAN PARLIAMENT AND OF THE 
COUNCIL of 22 July 2003 concerning the production and development of Community 
statistics on science and technology;  

9) International Trade in Services Statistics (ITSS) and Foreign Direct Investment 
Statistics (FDI) domain: 

 REGULATION (EC) No 184/2005 OF THE EUROPEAN PARLIAMENT AND OF THE 
COUNCIL of 12 January 2005 on Community statistics concerning balance of payments, 
international trade in services and foreign direct investment;  

10) Information and Communication technologies statistics (ICT) domain: 
REGULATION (EC) No 808/2004 OF THE EUROPEAN PARLIAMENT AND OF THE 
COUNCIL of 21 April 2004 concerning Community statistics on the information society. 

73 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX VI: LIST OF ABBREVIATIONS 

BSDG - Business Statistics Directors Group  

CIS - Community Innovation Survey (innovation statistics) 

EGRs – EuroGroups Register 

ESS - European Statistical System 

ESSC - European Statistical System Committee  

Extrastat – Statistics on trade with non-member countries 

FATS - Foreign Affiliates Statistics 

FRIBS - Framework Regulation Integrating Business Statistics 

GVC – Global Value Chains statistics 

ICT- Information and Communication technologies statistics 

Intrastat – Statistics on trade between EU Member States 

ISS – Information Society Statistics 

ITGS - International Trade in Goods Statistics  

ITSS - International Trade in Services Statistics 

MEETS - Modernisation of European Enterprise and Trade Statistics 

NCB – National Central Bank 

NSA – National Statistical Authority 

NSI – National Statistical Institute 

PRODCOM  -  "Production  Communautaire"  or  statistics  on  the  production  of  manufactured 
goods 

SBS- Structural Business Statistics 

STS- Short-term Business Statistics 

74