REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the application of Regulation (EU) 2019/516 of the European Parliament and of the Council of 19 March 2019 on the harmonisation of gross national income at market prices and repealing Council Directive 89/130/EEC, Euratom and Council Regulation (EC, Euratom) No 1287/2003 (GNI Regulation)
Date: 2022-12-19
Institutions: European Commission, Eurostat
Subjects: EU Member State, EU statistics, data collection, general budget (EU), gross domestic product, market prices, national income, own resources, statistical method

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 19.12.2022  COM(2022) 733 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the application of Regulation (EU) 2019/516 of the European Parliament and of the Council of 19 March 2019 on the harmonisation of gross national income at market prices and repealing Council Directive 89/130/EEC, Euratom and Council Regulation (EC, Euratom) No 1287/2003 (GNI Regulation)  
 
 
1. 

INTRODUCTION 

Regulation (EU) 2019/516 of the European Parliament and of the Council of 19 March 2019 on the 
harmonisation of gross national income at market prices and repealing Council Directive 89/130/EEC, 
Euratom  and  Council  Regulation  (EC,  Euratom)  No 1287/2003  (GNI  Regulation)1  establishes  the 
procedures to facilitate the verification, and where necessary the improvement, of the comparability, 
reliability and exhaustiveness of Member States’ estimates of gross national income (GNI). The GNI 
Regulation entered into force on 18 April 2019. 

In applying the European System of Accounts (ESA 95) under Council Regulation (EC) 2223/962, GNI 
was the basis for the Communities’ fourth own resource as from 1 January 2002. GNI replaced gross 
national product (GNP), which was used to assess the fourth own resource for the years before 2002. 

In applying the European System of Accounts (ESA 2010) under Regulation (EU) No 549/20133, GNI 
has been the basis for the EU budget’s fourth own resource since 1 January 2014. 

The  predecessors  of  the  GNI  Regulation  were  Council  Directive  89/130/EEC,  Euratom4  (GNP 
Directive), and Council Regulation (EC, Euratom) No 1287/20035, both having been repealed with the 
entry  into  force  of  the  GNI  Regulation.  To  verify  and  assess  the  comparability,  reliability  and 
exhaustiveness of GNP, the GNP Directive set up a procedure in its GNP Committee in which Member 
States and the Commission cooperated closely from 1989 to 2003. A similar procedure to verify and 
assess GNI was set up by the repealed Regulation (EC, Euratom) No 1287/2003 in its GNI Committee 
in which Member States and the Commission cooperated closely from 2004 to 2019. A good level of 
reliability,  comparability  and  exhaustiveness  was  achieved  with  respect  to  the  data  for  use  for  own 
resource purposes. 

The GNI Regulation builds on and adjusts this procedure to take account of GNI for the purposes of 
own resources. It provides for a formal expert group to assist the Commission with the procedures and 
checks on the calculation of GNI for own resources. The Gross National Income Expert Group was set 
up to this effect6. 

This  report,  as  required  by  Article 9  of  the  GNI  Regulation,  summarises  the  progress  made  by  the 
Commission  and  the  Gross  National  Income  Expert  Group  on  the  harmonisation  of  GNI  and  the 
application of the GNI Regulation since its entry into force. Chapter 2 describes the measures taken to 
ensure adherence to the definition and calculation of gross national income at market prices laid down 
in the GNI Regulation. Chapter 3 describes the measures taken to ensure the timely  transmission of 
GNI data and additional information by Member States to the Commission. Chapter 4 describes the 
actions taken by the Commission to verify the sources and methods used by Member States to calculate 
GNI. Chapter 5 draws conclusions on the application of the GNI Regulation since its entry into force. 

2. 

DEFINITION AND CALCULATION OF GROSS NATIONAL INCOME AT MARKET 
PRICES 

Regulation (EU) No 549/2013 of the European Parliament and of the Council of 21 May 2013 on the 

OJ L 91, 29.3.2019, p. 19. 
Council  Regulation  (EC)  2223/96  of  25 June  1996  on  the  European  system  of  national  and  regional 

1 
2 
accounts in the Community, OJ L 310, 30.11.1996, p. 1. 
3 
European system of national and regional accounts in the European Union, OJ L 174, 26.6.2013, p. 1. 
4 
gross national product at market prices, OJ L 49, 21.2.1989, p. 26. 
5 
income at market prices (GNI Regulation), OJ L 181, 19.7.2003, p. 1. 
6 
income, OJ C 174, 21.5.2019, p. 5. 

Commission  Decision  of  17 May  2019  setting  up  the  Commission  expert  group  on  gross  national 

Council Regulation (EC, Euratom) No 1287/2003 of 15 July 2003 on the harmonisation of gross national 

Council Directive 89/130/EEC, Euratom of 13 February 1989 on the harmonisation of compilation of 

1 

 
                                                           
 
 
Article 1 of the GNI Regulation provides that GNI and gross domestic product (GDP) is to be defined 
in accordance with the European System of Accounts 2010 (ESA 2010) established by Regulation (EU) 
No 549/2013. 

As stipulated by Article 1, Member States calculate GDP according to the three approaches: production 
approach, expenditure approach and income approach. In calculating GDP, and in the transition from 
GDP  to  GNI,  Member  States  have  used  the  concepts  and  definitions  of  ESA 2010  since  the  first 
application of this accounting standard in 2014. 

GNI in application of ESA 2010 was verified within the GNI verification cycle 2016-2019. The cycle 
entailed an enhanced verification of the transition from the ESA 95 concepts to those of ESA 2010, 
including thorough checks of the individual main conceptual changes between the two standards. The 
verification cycle 2016-2019 was successfully completed after entry into force of the GNI Regulation 
in 2019. 

For the GNI verification cycle 2020-2024, the same concepts and definitions (ESA 2010) in line with 
Article 1 of the GNI Regulation continue to apply. 

Relating to the appropriateness of GNI data for use for own resource purposes with respect to reliability, 
comparability  and  exhaustiveness,  the  relevant  provisions  of  Article 10b(4)  of  Regulation  (EU, 
Euratom) No 609/20147 apply where relevant, especially the possibility of placing a reservation on the 
quality of GNI data on points notified either by the Commission or by the Member State. 

3. 

TRANSMISSION OF GNI DATA AND ADDITIONAL INFORMATION 

Annual transmission of GNI data and of reports on the quality of GNI data 

In accordance with Article 2 of the GNI Regulation, Member States must calculate GNI and provide 
the  Commission  (Eurostat),  before  1 October  each  year,  with  figures  for  GNI  aggregates  and  their 
components. This deadline is aligned to the cut-off date for the transmission of other annual national 
accounts data within the ESA 2010 transmission programme, which facilitates the preparation of  all 
relevant data sets by Member States. 

Member  States  are  to  provide  the  GNI  aggregates  and  their  components,  in  accordance  with  the 
definitions referred to in Article 1 of the Regulation. Data are to be transmitted for the preceding year 
and any changes made to the data for previous years  is to be communicated at the same time. This 
requirement is reflected in the templates of the transmission tables (GNI questionnaires) prepared by 
Eurostat before each annual data transmission. 

Each year, in the spring meeting of the Gross National Income Expert Group, an agreement is reached 
on a common structure of the GNI questionnaire to be used by Member States. This is to facilitate the 
provision of their GNI data. Eurostat sends to each Member State a template of the agreed questionnaire, 
requesting a timely return of the completed tables. 

The questionnaire also includes additional tables and formulas that help to check the consistency of the 
data provided and to prevent or detect possible errors. In addition, the questionnaire is accompanied by 
detailed instructions on how to fill it in correctly. These measures have greatly helped to harmonise and 
further improve the data submitted by Member States to Eurostat. 

The GNI Regulation also obliges Member States to transmit to Eurostat an annual report on the quality 
of their GNI data (Article 2(3)). The main purpose of this report is to supply the Commission with the 

Council Regulation (EU, Euratom) No 609/2014 of 26 May 2014 on the methods and procedure for 

7 
making available the traditional, VAT and GNI-based own resources and on the measures to meet cash 
requirements (Recast) OJ L 168, 7.6.2014, p. 39. 

2 

 
 
                                                           
 
 
information on changes made – since the previous GNI transmission - to sources and methods used to 
compile GNI aggregates and their components. The common content and format of this report are also 
agreed in the spring meeting of the Gross National Income Expert Group. This procedure has been in 
place for many years, so the reports are generally of good quality and give the Commission and the 
Gross National Income Expert Group the necessary background information to assess Member States’ 
GNI data and their revisions. 

Member  States  transmit  the  relevant data  in  the  GNI  questionnaire accompanied  by  a  report  on the 
quality of GNI data by electronic means to the single entry point for data at Eurostat (via the dedicated 
platform called EDAMIS). 

As the GNI Regulation is a legal act with EEA relevance, EFTA8 countries transmit the GNI data in the 
same way as EU Member States. Furthermore, in accordance with the Agreement on the withdrawal of 
the  United  Kingdom  from  the  European  Union9,  the  applicable  EU  law  concerning  the  EU’s  own 
resources  relating  to  financial  years  up  to  2020  continues  to  apply  to  the  United  Kingdom  after 
31 December 2020, including where the own resources concerned are to be made available, corrected 
or subject to adjustments after that date. Therefore, the United Kingdom also transmits GNI data for the 
period up to 2020 in accordance with the GNI Regulation. 

In  2019,  all  countries  but  one  (an  EU  Member  State)  transmitted  their  2019  GNI  returns  before 
1 October, in line with the deadline. The last Member State sent them on 1 October. 

In 2020, all countries but one (an EFTA country) transmitted their 2020 GNI returns before 1 October, 
in line with the deadline. The last EFTA country sent its GNI questionnaire on 15 October and its report 
on quality on 28 October. 

In 2021, all 32 countries transmitted their 2021 GNI returns before 1 October, in line with the deadline. 

In  2022,  all  32  countries  but  one  (an  EFTA  country)  transmitted  their  2022  GNI  returns  before 
1 October, in line with the deadline. The last EFTA country sent only the GNI questionnaire in line with 
the deadline. 

GNI inventories 

While  the  report  on  quality  is  intended  to  provide  an  update  on  changes  to  a  Member  State’s 
methodology and GNI data, a full detailed account of the methods and sources used to calculate  the 
final GNI estimates is given in the GNI inventories of the sources and methods used to produce GNI 
aggregates  and  their  components.  These  inventories  are  the  basis  for  Eurostat’s  assessment  of  the 
quality of Member State GNI data in terms of comparability, reliability and exhaustiveness. 

Article 3 of the GNI Regulation obliges Member States to provide Eurostat with a GNI Inventory. It 
also stipulates that the Commission must establish, by means of implementing acts, the structure and 
detailed arrangements of the inventory, in accordance with ESA 2010, and the timetable for its updating 
and transmission. Article 3 further stipulates that the implementing acts in question  may not impose 
significant additional costs as these could result in a disproportionate and unjustified burden on Member 
States. In addition the inventory is to be consistent with ESA 2010 and duplication and overloading 
should be avoided. 

These aspects have been addressed in Commission Implementing Regulation (EU) 2020/154610, which 
was adopted following the above-mentioned provisions, and in the GNI Inventory Guide agreed by the 

Liechtenstein has a derogation from the implementation of the GNI Regulation; nevertheless it 

8 
transmits the annual GNI questionnaire. 
9 
European Union and the European Atomic Energy Community, OJ C 384 I, 12.11.2019, p. 1. 
10 
Commission Implementing Regulation (EU) 2020/1546 of 23 October 2020 establishing the structure 
and detailed arrangements of the inventory of the sources and methods used to produce gross national income 

Agreement on the withdrawal of the United Kingdom of Great Britain and Northern Ireland from the 

3 

 
                                                           
 
 
Gross  National  Income  Expert  Group.  In  particular,  concerning  the  structure  of  the  inventories, 
Regulation (EU) 2020/1546 specifies that they are to consist of 10 chapters and the GNI process tables. 
The individual chapters of the inventory cover the following issues: 

Chapter 1  Overview of the system of accounts 

Chapter 2  The  revision  policy  and  the  timetable  for  revising  and  finalising  the  estimates. 

Major revisions since the last version of the GNI Inventory 

Chapter 3  The production approach 

Chapter 4  The income approach 

Chapter 5  The expenditure approach 

Chapter 6  The balancing or integration procedure, and validation of the estimates 

Chapter 7  Overview of the adjustments for exhaustiveness 

Chapter 8  The transition from gross domestic product (GDP) to GNI 

Chapter 9  Main classifications used 

Chapter 10  Main data sources used 

The GNI inventories include, as an annex, the process tables giving numerical information on the results 
of all consecutive stages of the GNI compilation process, from the statistical sources, through various 
adjustments, to the final national accounts data. They also contain numerical information on the relative 
size  of  the individual types  of  sources  used  and  adjustments  made  in  that  compilation  process,  and 
references to the relevant chapters of the GNI Inventory. 

The GNI Inventory Guide, drawn up in close cooperation with the Gross National Income Expert Group 
and reflecting the detailed arrangements laid down in Regulation (EU) 2020/1546, defines the detailed 
structure and content requirements of the individual chapters. It also gives to Member States guidance 
on  how  a  good  quality  inventory  should  be  written  by  highlighting  the  main  principles  and aspects 
needing particular attention in that process. It also includes provisions on the choice of the reference 
year and on the submission and subsequent updates of the GNI Inventory. 

When designing the GNI Inventory Guide, due attention was given to the need to avoid duplication and 
overloading in the description, and the use, of ESA 2010 terms and definitions. Furthermore, the update 
of the Guide for the 2020-2024 GNI verification cycle introduced only limited changes, where it was 
deemed necessary to modify the existing requirements or give additional guidance. 

The deadline for transmitting the GNI Inventory under Regulation (EU) 2020/1546 was 31 December 
2021. Most Member States had transmitted their GNI Inventory by this deadline. A general reservation 
was placed by the Commission on five Member States due to the late transmission of the GNI Inventory. 
For  four  of  these  Member  States,  the  general  reservation  was  subsequently  lifted  following  the 
submission of their respective GNI inventories. 

Directly after the transmission of the GNI inventories and process tables, Eurostat performed an initial 
general  analysis  of  their  completeness  and  of  their  consistency  as  part  of  the  GNI  risk  assessment 
exercise. This check did not reveal major deficiencies that would  hinder detailed verifications of the 
GNI inventories during the 2020-2024 cycle. 

Since  the  procedures  and  basic  statistics  for  compiling  final  GDP  and  GNI  data  do  not  change 
significantly from year to year, but only during major revisions at longer intervals, it is not necessary 
to rewrite the GNI inventories every year. Regulation (EU) 2020/1546 specifies that subsequent updates 
of the  GNI  Inventory  are  to  be  made  and  transmitted  to  Eurostat  within  12  months  after  any  major 

aggregates and their components in accordance with the European System of Accounts (ESA 2010), OJ L 354, 
26.10.2020, p. 1. 

4 

 
                                                           
 
 
change of sources or methods for compiling GNI. In any case, the GNI Inventory must be updated at 
least every 5 years. 

4. 

PROCEDURES AND CHECKS ON THE CALCULATION OF GNI 

Gross National Income Expert Group 

In accordance with Article 4 of the GNI Regulation, the Commission must establish a formal expert 
group,  composed  of  representatives  of  all  Member  States  and  chaired  by  a  representative  of  the 
Commission. This expert group serves: 

 

 
 

to  advise  the  Commission,  and  to  express  its  views,  on  the  comparability,  reliability  and 
exhaustiveness of GNI calculations; 
to examine issues of implementation of the Regulation; and 
to issue annual opinions on the appropriateness of the GNI data submitted by Member States 
for own resources purposes. 

Shortly after the entry into force of the GNI Regulation, the Commission adopted, on 17 May 2019, a 
decision on setting up the Commission expert group on gross national income11. The Gross National 
Income Expert Group met for the first time in May 2019 and adopted its rules of procedure. Since then, 
the Gross National Income Expert Group has been meeting regularly twice a year, in spring and autumn. 
Since the entry into force of the GNI Regulation, the Gross National Income Expert Group has met 
eight times (until November 2022) for its regular meetings. The Gross National Income Expert Group 
also held three ad hoc meetings related to the issue of globalisation. 

The Commission (Eurostat) may set up subgroups to the Gross National Income Expert Group for the 
purpose of examining specific questions related to GNI on the basis of terms of reference defined by 
the Commission. 

In November 2019, Eurostat set up a subgroup on missing trader VAT fraud. The subgroup aims to 
exchange  practices,  discuss  sources  and  methods,  and  prepare  recommendations  in  view  of  further 
ensuring comparability in the treatment of missing trader VAT fraud. The work of this subgroup was 
accomplished in November 2020 through the approval of its final report by the Gross National Income 
Expert Group. 

In June 2020, Eurostat set up a subgroup on exhaustiveness. This subgroup aims to examine specific 
questions  in  the  area  of  exhaustiveness  to  further  ensure  exhaustiveness  of  GNI  data,  to  exchange 
practices,  and  to  develop  practical  guidelines  in  view  of  further  ensuring  comparability  of  the 
exhaustiveness adjustments. The work of this subgroup is ongoing and is  planned to be finalised in 
2023. 

Formal opinion on the appropriateness of GNI data for own resource purposes 

Article 4 of the GNI Regulation also specifies that the Gross National Income Expert Group is to issue 
annual opinions on the appropriateness of the GNI data submitted by Member States for own resources 
purpose. To  this  end,  a  document  drawn  up by  Eurostat that  includes  the transmitted  GNI  data  and 
summary reports on quality is presented for examination to the Gross National Income Expert Group 
in  its  autumn  meetings.  In  the  annex  to  the  opinion,  Eurostat  presents  in  a  concise  form  some 
quantitative and qualitative information on the main results of the verification. 

Since the entry into force of the GNI Regulation, the Gross National Income Expert Group successfully 
adopted each year the opinion confirming that the data submitted in the GNI questionnaires by Member 
States and the United Kingdom are appropriate for own resource purposes. Once the appropriateness of 

11 
income (Text with EEA relevance.) C/2019/3651. OJ C 174, 21.5.2019, p. 5-8. 

Commission Decision of 17 May 2019 setting up the Commission expert group on gross national 

5 

 
                                                           
 
 
the data is established, the opinion, together with the data, is forwarded to DG Budget. This process has 
been functioning smoothly, enabling DG Budget to calculate in good time each country’s budgetary 
contributions under the GNI own resource. 

Verification model 

The sources and methods used by Member States to calculate GNI – as described in the GNI inventories 
-  are  to  be  verified  by  the  Commission  (Eurostat)  under  a  verification  model.  Article 5  of  the  GNI 
Regulation stipulates that the model is to be drawn up by the Commission in close cooperation with the 
Gross National Income Expert Group. Such a model for the GNI verification cycle 2020-2024, based 
on the one that was successfully used in the GNI verification cycle 2016-2019, has been developed by 
Eurostat and approved by the Gross National Income Expert Group in its meetings in 2020 and 2021. 
All its relevant elements are described in the framework documents that constitute the model12. 

Apart from the document GNIG/121 ‘Outline of the verification model for GNI for own resources’ that 
outlines the whole model, the following framework documents have been prepared for the 2020-2024 
GNI verification cycle: 

- 

- 

- 

- 

- 

- 

- 

ESA 2010 GNI Inventory Guide - Guidelines for writing the ESA 2010 GNI Inventory and for 
compiling the GNI process tables (GNIG/068 Rev. 1); 

GNI Inventory Assessment Questionnaire (GIAQ) (GNIG/099); 

Guidelines for the Direct Verification exercise in the framework of the verification of Member 
States’ GNI inventories (GNIG/100); 

Note on GNI reservations (GNIG/101); 

Note on materiality threshold (GNIG/102); 

Documentation guidelines (GNIG/122); and 

Risk assessment model for verification of GNI for own resource purposes (GNIG/130). 

The model comprises annual verification of the data transmitted with the GNI questionnaires and reports 
on quality, and multiannual verification of the statistical sources and methods used to calculate GNI. 

The annual part of the verification  process consists  of verification of data transmitted with the GNI 
questionnaires and reports on quality. The GNI questionnaires are checked by Eurostat for, inter alia, 
the formal and numerical correctness of the tables delivered, the consistency of the data over time and 
their  consistency  with  published  national  accounts  figures. The revisions  described  in  the  report  on 
quality  are  verified  with  regard  to,  inter  alia,  the  plausibility,  quality  of  sources  and  methods  used, 
reconciliation  of  the  total  revision  against  the  individual  revisions,  and  consistency  with  previously 
announced changes. Member States can be asked to provide any clarifications on the data and on the 
report  on  quality  and  to  send  corrections. This  process  leads to  the  adoption  by  the  Gross  National 
Income  Expert  Group  of  the  above-mentioned  opinion  on  the  appropriateness of  GNI  data  for  own 
resource purposes. 

The multiannual part of the verification process consists of verification of the statistical sources and 
methods  used  to  calculate  GNI.  This  is  done  in  a  harmonised  way  for  all  Member  States,  and  it  is 
conducted  within  multiannual  verification  cycles  that  ensure  a  structured  and  coherent  verification 
framework. The main stages of the cycle, after the preparation of the set of the framework documents, 
are:  submission  of  the  GNI  inventories  and  process  tables;  risk  assessment;  desk  checks  of  the 
inventories and process tables; cross-country comparisons of transversal issues; GNI information visits; 
direct verifications; placing action points; and reservations. 

12 
Group: https://circabc.europa.eu/ui/group/7eb29b7b-33b0-4c9f-851b-e370277bb9e5. 

The framework documents are available on the public site of the Gross National Income Expert 

6 

 
                                                           
 
 
The GNI inventories and the process tables are the main reference documents used at all stages of the 
multiannual  verification  process,  Eurostat  checks  them  using  the  GNI  Inventory  Assessment 
Questionnaire  approved  by  the  Gross  National  Income  Expert  Group,  and  by  performing  direct 
verifications  of  selected  compilation  areas.  The  questionnaire  is  a  comprehensive  verification  and 
documentation  tool.  Its  structure  is  closely  aligned  with  that  of  the  GNI  Inventory  Guide.  The 
questionnaire is mainly focused on verifying the compliance of the described sources and methods with 
the  requirements  of  ESA  2010,  related  legislation  and  methodological  guidelines.  These  tools  have 
served their purpose well over the years, ensuring a systematic, consistent and fair analysis of the GNI 
inventories and process tables. 

Some areas of national accounts - as identified in the risk assessment - are considered as being of high 
risk for all Member States. They call for a detailed comparative analysis of the solutions applied by the 
countries. In some cases, they may also require agreement on conceptual aspects in the Gross National 
Income Expert Group. These issues are verified in a uniform way across all countries through cross-
country comparisons. In the 2016-2019 verification cycle, Eurostat completed an extensive programme 
of  cross-country  comparisons  for  a  number  of  transversal  issues.  This  covered  issues  like 
exhaustiveness,  balancing  of  GDP,  dwelling  services,  financial  services  (including  financial 
intermediation  services  indirectly  measured),  global  production,  balance  of  payments,  and  changes 
between ESA 95 and ESA 2010. The cross-country comparisons on exhaustiveness, global production 
and balance of payments, and changes between the ESA 95 and ESA 2010 were further subdivided into 
more  detailed  areas.  Altogether,  16  cross-country  comparisons  were  carried  out  and  contributed  to 
greater assurance about the quality of the sources and methods used for compiling the respective areas. 
Two more cross-country analyses are being performed in the 2020-2024 verification cycle. 

The GNI Regulation provides that the GNI verification model should be based on the principles of peer 
review  and  cost-effectiveness.  Consequently,  they  are  the  main  principles  followed  in  the  GNI 
verification work and they are applied throughout the whole verification process. 

Peer review in the GNI verification is manifested through the active involvement of Member States in 
the verification work, both in the  Gross National Income Expert Group and through participation in 
GNI  information  visits.  To  facilitate  the  implementation  of  the  peer  review  principle,  Eurostat  has 
ensured the transparency of the verification process by making all relevant documentation available to 
the Gross National Income Expert Group. This includes the GNI inventories and process tables and all 
outcomes of the verification process in terms of visit reports and action points, a list of identified non-
material  issues,  progress  and  final  reports  on  transversal  issues  verified  through  cross-country 
comparisons, the state of play on reservations, and (for the 2020-2024 GNI verification cycle) all letters 
placing and lifting GNI reservations. 

With regard to the application of cost-effectiveness, it materialises in the GNI verification model in a 
two-fold way; firstly, through the use of risk assessment and, secondly, by application of a materiality 
threshold. A comprehensive risk assessment model for verification of GNI for own resource purposes 
has  been  developed in  close  cooperation  with,  and approved  by,  the  Gross  National  Income  Expert 
Group. It results in structuring the verification process and concentration of the verification activities 
on the areas showing a relatively high level of risk. It is the Commission’s view that the use of this tool 
has streamlined the process and made it more cost-effective. 

When  judging  the  potential  size  and  significance  of  specific  activities  or  transactions,  the  cost-
effectiveness principle entails the application of a materiality threshold. The  Gross National Income 
Expert Group approved a threshold of 0.1% of GNI to be used to this end. The materiality threshold is 
taken into consideration throughout the whole verification process, but it comes to the fore when placing 
and lifting action points and reservations. 

Delegated acts and implementing acts 

Article 5 of the GNI Regulation provides that the Commission is to adopt delegated acts defining the 
list of issues to be addressed in every verification cycle to ensure the reliability, exhaustiveness and 
highest  possible  degree  of  comparability  of  GNI  data,  in  line  with  ESA  2010.  Furthermore,  the 

7 

 
Commission is to establish, by means of implementing acts, specific measures to make GNI data more 
comparable, reliable and exhaustive, based on that list of issues. 

The  Commission  adopted  Delegated  Regulation  (EU)  2020/214713  supplementing  Regulation  (EU) 
2019/516  by  defining  the  list  of  issues  to  be  addressed  in  every  verification  cycle.  The  following 
subjects are listed: 

- 

- 

- 

- 

- 

definition of geographic territory; 

principles of estimating dwelling services; 

treatment of repayments of VAT; 

measures on exhaustiveness; and 

treatment of non-collected VAT. 

These  issues  have  been  appropriately  taken  into  account  in  the  verification  model  as  their  relevant 
aspects have been treated accordingly in the framework documents (e.g. in the GNI Inventory Guide, 
the GNI Inventory Assessment Questionnaire, and the risk assessment model). 

Based on the above list, the Commission established, by means of the following implementing acts, 
specific measures to make GNI data more comparable, reliable and exhaustive for the first three issues: 

- 

- 

- 

Commission  Implementing  Regulation  (EU)  2021/1947  on  the  definition  of  the  geographic 
territory of Member States14; 

Commission Implementing Regulation (EU) 2021/1949 on the principles for estimating dwelling 
services15; and 

Commission Implementing Regulation (EU) 2021/1948 on the treatment of repayments of VAT 
to non-taxable persons and to taxable persons for their exempt activities16. 

The implementing acts for the remaining two issues (measures on exhaustiveness, treatment of non-
collected VAT) are under preparation. 

GNI information visits 

Article 6 of the GNI Regulation stipulates that GNI information visits may, where deemed appropriate, 
be carried out in Member States17 by the Commission (Eurostat). The purpose of GNI information visits 

Commission Implementing Regulation (EU) 2021/1949 of 10 November 2021 on the principles for 

Commission Implementing Regulation (EU) 2021/1947 of 10 November 2021 on the definition of the 

13 
Commission Delegated Regulation (EU) 2020/2147 of 8 October 2020 supplementing Regulation (EU) 
2019/516 of the European Parliament and of the Council by defining the list of issues to be addressed in every 
verification cycle (Text with EEA relevance). OJ L 428, 18.12.2020, p. 9. 
14 
geographic territory of Member States for the purposes of Regulation (EU) 2019/516 of the European 
Parliament and of the Council on the harmonisation of gross national income at market prices (GNI Regulation) 
and repealing Commission Decision 91/450/EEC, Euratom and Commission Regulation (EC) No 109/2005 (Text 
with EEA relevance). OJ L 398, 11.11.2021, p. 1. 
15 
estimating dwelling services for the purposes of Regulation (EU) 2019/516 of the European Parliament and of 
the Council on the harmonisation of gross national income at market prices (GNI Regulation) and repealing 
Commission Decision 95/309/EC, Euratom and Commission Regulation (EC) No 1722/2005 (Text with EEA 
relevance). OJ L 398, 11.11.2021, p. 6. 
16 
repayments of VAT to non-taxable persons and to taxable persons for their exempt activities for the purposes 
of Regulation (EU) 2019/516 of the European Parliament and of the Council on the harmonisation of gross 
national income at market prices (GNI Regulation) and repealing Commission Decision 1999/622/EC, Euratom 
and Commission Regulation (EC, Euratom) No 116/2005 (Text with EEA relevance). OJ L 398, 11.11.2021, p. 4. 
17 GNI information visits can also take place in the UK and EFTA countries. 

Commission Implementing Regulation (EU) 2021/1948 of 10 November 2021 on the treatment of 

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is  the  verification  of  the  quality  of  GNI  aggregates  and  their  components  and  the  verification  of 
compliance with ESA 2010. To this end, the visits aim to collect additional information that is necessary 
to identify possible shortcomings of the GNI Inventory or of the statistical sources and methods used to 
calculate GNI and its components. The GNI information visits may also include direct verifications of 
parts of the GNI compilation. The principal objectives of direct verification are to verify whether the 
description of sources and methods in the GNI Inventory adequately reflects the compilation practice 
actually  applied,  and  whether  the  basic  data  as  shown  in  the  sources  have  been  transformed  in  an 
appropriate  way  into  the  national  accounts  figures  provided  by  Member  States  for  the  GNI  own 
resource. The result of a GNI information visit is a report (presented by Eurostat to the Gross National 
Income Expert Group) with action points for the Member State to introduce methodological changes, 
correct compilation errors or to clarify or supplement the information contained in the GNI Inventory. 

The minimum number of GNI visits planned in a given Member State during a verification cycle is 
based on the results of the risk assessment. As a rule, at least one GNI information visit is carried out 
to each Member State during the verification cycle. 

Since  the  entry  into  force  of  the  GNI  Regulation  on  18 April  2019,  Eurostat  has  carried  out  (until 
October 2022) 19 GNI information visits in Member States and the United Kingdom. This was achieved 
despite difficult circumstances linked to the COVID-19 pandemic, thanks to a very good cooperation 
with  Member  States.  Eurostat  has  systematically  invited  the  national  accounts  experts  representing 
national statistical authorities of other Member States to take part in GNI visits. Consequently, 11 of 
the 19 visits involved the participation of national accounts experts from other Member States, which 
contributed to the realisation of the peer review principle governing the GNI verification process. 

Examination of the Commission’s verifications by the European Court of Auditors 

The Commission’s work on verifying Member States’ GNI data has been thoroughly examined by the 
European  Court  of  Auditors  on  an  annual  basis.  Furthermore,  there  are  special  performance  reports 
relating to the multiannual verifications. A detailed account of the Court’s activities with respect to the 
GNI for own resources can be found in its annual reports on the implementation of the EU budget. 

5. 

CONCLUSIONS 

Gross national income constitutes the basis for calculating the largest share of own resources in the EU 
general  budget,  and  the  proper  application  of  the  GNI  Regulation  is  of  utmost  importance  in  that 
context. This being said, the correct application of the ESA 2010 definitions and accounting rules, which 
is  a  prerequisite for  the high-quality  GNI  data,  is essential for the quality  of  national accounts as a 
whole. Thus, the assurance about the reliability, comparability and exhaustiveness of GNI data gained 
from  the  verification  carried  out  by  the  Commission  under  the  provisions  of  the  GNI  Regulation 
contributes  to  sounder  economic  analyses  and  better-informed  economic  policymaking  based  on 
national accounts data. 

The  current  verification  model  of  GNI  for  own  resources  builds  to  a high  extent  on the  procedures 
introduced in the past when applying Council Directive 89/130/EEC, Euratom and Council Regulation 
(EC, Euratom) No 1287/2003. Since the entry into force of Regulation (EU) 2019/516, the verification 
model has been further developed, taking into account the relevant provisions of the GNI Regulation, 
including those relating to the principles of peer review and cost-effectiveness, and capitalising on the 
achievements of previous GNI verification cycles. As a result, a formalised verification framework has 
been put in place that ensures a rigorous and comprehensive, yet flexible, verification process. 

Actions have also been taken to ensure the timely and harmonised transmission of GNI data and to 
improve  and  update  the  documentation  of  methods  and  sources  used  to  calculate  GNI  and  its 
components. 

Through  these  measures,  good  progress  has  been  made  on  the  examination  and  checks  of  GNI 
calculations, both in annual and multiannual verifications. 

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The  relevant  delegated  and  implementing  acts  required  by  the  Regulation  were  adopted.  Work  is 
ongoing to take into account other potential issues to further improve the comparability, reliability and 
exhaustiveness of GNI data. 

The Commission  has put in place significant resources to ensure proper implementation of the GNI 
Regulation.  The  smooth  application  of  the  Regulation  was  possible  also  thanks  to  the  very  good 
cooperation between the Commission and Member States. It was manifested during the work of the 
Gross National Income Expert Group that was set up to assist the Commission with examination of 
issues of implementation of the GNI Regulation, but also in the GNI information visits. 

In the coming years, the Commission and the Gross National Income Expert Group will continue their 
efforts to maintain the high quality, and to further improve comparability, reliability and exhaustiveness, 
of GNI data. 

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