COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT REPORT Accompanying the document Proposal for a Regulation of the European Parliament and of the Council on European labour market statistics on businesses, repealing Council Regulation (EC) No 530/1999 and Regulations (EC) No 450/2003 and (EC) No 453/2008 of the European Parliament and of the Council
Date: 2023-07-28
Institutions: European Commission, Eurostat
Subjects: EU employment policy, EU statistics, data collection, economic statistics, employment statistics, exchange of information, labour force, pay, statistical method, type of business

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 28.7.2023  SWD(2023) 265 final  COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT REPORT  Accompanying the document Proposal for a Regulation of the European Parliament and of the Council on European labour market statistics on businesses, repealing Council Regulation (EC) No 530/1999 and Regulations (EC) No 450/2003 and (EC) No 453/2008 of the European Parliament and of the Council         {COM(2023) 459 final} - {SEC(2023) 295 final} - {SWD(2023) 266 final}  
 
 
Table of contents 

1. 

2. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT ............................................................... 2 

PROBLEM DEFINITION .................................................................................................................... 6 

3.  WHY SHOULD THE EU ACT? ........................................................................................................ 20 

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? ............................................................................... 21 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? .................................................................... 23 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ........................................................... 31 

7.  HOW DO THE OPTIONS COMPARE? ............................................................................................ 42 

8. 

PREFERRED OPTION ...................................................................................................................... 46 

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? .................................. 48 

ANNEX 1: PROCEDURAL INFORMATION ............................................................................................ 56 

1. 

LEAD DG, DECIDE PLANNING/CWP REFERENCES .................................................................. 56 

2.  ORGANISATION AND TIMING ...................................................................................................... 56 

3. 

4. 

CONSULTATION OF THE RSB....................................................................................................... 57 

EVIDENCE, SOURCES AND QUALITY ......................................................................................... 59 

ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) ................................................ 62 

1. 

CONSULTATION STRATEGY ........................................................................................................ 62 

2.  METHODOLOGY AND TOOLS USED TO PROCESS THE RESULTS........................................ 63 

3. 

STAKEHOLDER PARTICIPATION ................................................................................................. 64 

4.  MAIN RESULTS FROM THE STAKEHOLDER CONSULTATION ............................................. 66 

5. 

CONCLUSIONS ................................................................................................................................. 68 

ANNEX 3: WHO IS AFFECTED AND HOW? .......................................................................................... 70 

1. 

2. 

PRACTICAL IMPLICATIONS OF THE INITIATIVE..................................................................... 70 

RELEVANT SUSTAINABLE DEVELOPMENT GOALS ............................................................... 91 

ANNEX 4: ANALYTICAL METHODS ..................................................................................................... 92 

ANNEX  5:  ASSUMPTIONS  USED  FOR  THE  DISTRIBUTION  OF  COSTS  (ONE  OFF  AND 

RECURRENT) TO THE BR TYPOLOGY ........................................................................................ 94 

 
 
 
 
 
 
Glossary 

Term or acronym 

Meaning or definition 

ECB 

EPSR 

ESP 

ESS  

ESSC  

EEA 

EFTA 

EU  

Eurobase 

Eurostat 

FTE 

GPG 

ISG 

JVS 

LMB 

LCI 

LCS 

MS  

NSI 

OECD 

PC  

PEEIs 

SES 

European Central Bank 

European Pillar of Social Rights 

European statistical programme 

European Statistical System 

European Statistical System Committee 

European Economic Area 

European Free Trade Association 

European Union 

Public database of European statistics disseminated by Eurostat 

Statistical office of the European Union 

Full-time equivalent 

Gender pay gap 

Inter-service group of the European Commission 

Job vacancy statistics 

Labour Market Statistics on Businesses 

Labour cost index 

Labour cost survey 

Member State(s) of the European Union 

National statistical institute 

Organisation for Economic Co-operation and Development 

Public consultation 

Principal European Economic Indicators 

Structure of earnings survey 

 
 
1. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT 

Eurostat and the European Statistical System 

Eurostat, the statistical office of the European Union (EU), ensures the production of high quality, 
comparable European statistics1  according to  the  legal  framework Regulation  (EC) No 223/20092 
(the  “Statistical  law”)  and  the  statistical  principles,  notably  those  laid  down  in  the  European 
statistics  Code  of  Practice3.  These  rules  and  principles  aim  to  ensure,  among  others,  the 
independence,  impartiality,  objectivity  and  reliability  of  European  statistics,  and  through  those 
objectives, public trust in the statistics. The main uses of European statistics are to serve EU policy 
design, implementation and monitoring, and their main users are EU Institutions.  

The  European  Statistical  System  (ESS)  is  the  partnership  between  Eurostat  and  the  national 
statistical  institutes  (NSIs),  as  well  as  other  national  authorities  responsible  for  the  development, 
production  and  publication  of  European  statistics  in  each  Member  State.  This  partnership  also 
includes  the  European  Economic  Area  (EEA)  and  European  Free  Trade  Association  (EFTA) 
countries,  i.e.  Iceland,  Liechtenstein,  Norway  and  Switzerland.  Eurostat  issues  statistical 
regulations  and  methodological  guides,  organises  expert  groups,  and  assesses  the  quality  of 
statistics  and  Member  States’  legal  compliance.  In  accordance  with  the  EU  principles  of 
subsidiarity  and  proportionality,  each  ESS  member  develops  a  statistical  system  suitable  to  their 
individual institutional context, while still following the common rules.  

Eurostat’s  activities  are  further  influenced  by  overarching  policies  such  as  the  EU’s  Better 
Regulation agenda4, which promotes open and transparent EU decision-making and evidence-based 
decisions,  and  European  Commission  President  Ursula  von  der  Leyen’s  six  political  priorities, 
among them “An economy that works for people”. Implementing, monitoring and assessing these 
policies and priorities requires impartial and objective data – that is, official statistics.  

Labour Market Statistics on Businesses (LMB)  

Labour  market  statistics  on  businesses  (LMB)  are  official  statistics  that  describe  businesses 
functioning  in  relation  to  labour  markets.  The  areas  covered  by  LMB  mostly  relate  to  level  and 
composition  of  labour  costs,  distribution  and  structure  of  earnings,  labour  cost  index,  and  job 
vacancy statistics. First statistics related to the level and structure of labour costs had already been 

1 Statistics in the ESS context are defined according to Article 3(1) of Regulation (EC) No 223/2009 (see footnote 2) as 
“quantitative  and  qualitative,  aggregated  and  representative  information  characterising  a collective  phenomenon  in  a 
considered population.” 
2 Regulation (EC) No 223/2009 of the European Parliament and of the Council of 11 March 2009 on European statistics  
and  repealing  Regulation  (EC,  Euratom)  No  1101/2008  of  the  European  Parliament  and  of  the  Council  on  the 
transmission of data subject to statistical confidentiality to the Statistical Office of the European Communities, Council 
Regulation  (EC)  No  322/97  on  Community  Statistics,  and  Council  Decision  89/382/EEC,  Euratom  establishing 
a Committee on the Statistical Programmes of the European Communities (OJ L 87, 31.3.2009, p. 164). 
3 European statistics Code of Practice, revised version endorsed by the European Statistical System Committee on 16 
November 2017 (KS-02-18-142). 
4 https://ec.europa.eu/info/law/law-making-process/planning-and-proposing-law/better-regulation-why-and-how_en. 

2 

 
 
 
                                                 
  
collected since 19595, with a periodicity of two to four years based on specific legislation for each 
data  collection  and  covering  different  sectors  of  the  economy  (industry,  wholesale  and  retail 
distribution,  road  transport,  banking  and  insurance,  services).  Council  Regulation  (EC)  No 
530/1999  introduced  systematic  data  collections  on  the  level  and  composition  of  labour  costs 
(labour  cost  survey,  LCS)  for  the  calendar  year  2000  and  at  four-yearly  intervals  thereafter.  The 
same act established the statistics on the structure and distribution of earnings (structure of earnings 
survey, SES) for the  calendar  year 2002  and for a representative month  in  that  year, and  at  four-
yearly intervals thereafter. Before Regulation (EC) No 450/2003 of the European Parliament and of 
the  Council  of  27  February  2003  on  labour  cost  index  (LCI)  was  adopted,  the  data  had  been 
collected on a voluntary basis since 1996. Similarly, Regulation (EC) No 453/2008 of the European 
Parliament established for the first time and regulated  the data collection on job vacancies (JVS). 
Earlier on, the job vacancies data used to be collected on a voluntary basis, since 2001.  

LMB  statistics  are  relevant  to  policymaking  in  various  areas  including  macroeconomic 
convergence, social cohesion, price stability and gender equality. They are the reference source for 
all  key  indicators  on  labour  demand  (job  vacancy  statistics),  on  labour  costs  structure  and  levels 
across countries and distribution of earnings. The labour cost index supports the assessment of the 
inflation/deflation  risks  within  the  euro  area  conducted  by  the  ECB;  job  vacancy  statistics  show 
labour  shortages,  structure  of  earnings  survey  data  offer  evidence  to  analyse  wage  determinants. 
The  latter  also  allows  calculating/adjusting  the  gender  pay  gap  which  is  an  indicator  for  gender 
equality listed under the Sustainable Development Goals scoreboard (SDG 2030) and the European 
Pillar of Social Rights (EPSR). Both the labour cost index and the job vacancy are in the list of the 
Principal Economic Indicators for the Euro monitoring. 

High  quality  and  internationally  comparable  LMB  statistics  covering  all  Member  States6  are 
essential  to  support  EU evidence-based  policy  making  and  a  range  of  other  initiatives  by  the  EU 
institutions,  Member  States,  and  other  statistical  users  (e.g.,  trade  unions,  non-governmental 
organisations, research institutes, the media, etc.). LMB statistics are used in many publications of 
Commission services, for instance the annual and quarterly Employment and Social Developments in 
Europe (ESDE) reports or the annual review of Labour Market and Wage Developments in Europe7. 
They  are  also  very  important  for  monetary  policy  and  used  by  the  ECB  in  the  preparation  of  the 
Governing Council8 meetings, many Economic Bulletins9 and analyses published occasionally10.  

As  LMB  statistics  play  a  pivotal  role  in  policy-making,  the  fast-changing  social  and  policy 
landscape is  demanding  further improvements  of  LMB statistics in  terms  of flexibility to  address 
new  needs  of  users  and  compilers,  better  data  timeliness,  comparability,  consistency  and  quality 
reporting.  Megatrends  such  as  automation  and  shocks  to  the  economy  as  those  caused  by  the 

5  Council  Regulations:  No  10/1960,  No  14/1961,  No  28/1962,  No  151/1962,  No  101/66/EEC,  (EEC)  No  1899/68, 
(EEC) No 2259/7, (EEC) No 328/75, (EEC) No 494/78, Regulations (EEC) No 2053/69, (EEC) No 3192/73 and (EEC) 
No  494/78,  (EEC)  No  1596/81,   (EEC) No 3149/83,  (EEC)  No  1612/88,  (EEC)  No  3949/92,    No  2744/95,  (EC)  No 
23/97,  

6 The study scope covers the 27 EU Member States plus the EEA Member States of Norway, Iceland and Lichtenstein. 
7 https://ec.europa.eu/social/main.jsp?catId=113#LMD  
8 The Governing Council is the main decision-making body of the ECB. It consists of the six members of the Executive 
Board, plus the governors of the national central banks of the 19 euro area countries. 
9For instance: https://www.ecb.europa.eu/pub/economic-bulletin/html/eb201801.en.html#IDofArticle1, 
https://www.ecb.europa.eu/pub/economic-bulletin/articles/2021/html/ecb.ebart202008_02~bc749d90e7.en.html#toc7 
10 For instance: 
https://www.ecb.europa.eu/pub/pdf/scpops/ecb.op232~4b89088255.en.pdf?1ccf533dc92317c07a71721418088bd4 

3 

 
 
                                                 
 
financial crisis of 2008 or the COVID-19 pandemic show that researchers and policy makers need 
accurate and timely information on the functioning of labour markets, in particular LMB statistics. 
The COVID-19 pandemic led to decreases in the number of hours worked and vacant posts and to 
changes  in  the  labour  cost  structure  due  to  labour  subsidies.  Some  groups  of  workers  have 
benefitted from improved employment conditions, including increased earnings, while others have 
seen  their  employment  prospects  and  conditions  decline.  This  also  had  an  impact  on  labour 
shortages and the relative earnings levels of employees. 

LMB indicators are used to monitor important European policies such as the EPSR11 or the SDG12. 
In particular, the gender pay gap (GPG) is an SDG indicator under Goal 5 “gender equality” and is 
part of the EPSR dashboard, under the ‘Fair working conditions’ (Principle 6: “wages”). 

Over  time,  the  policy  context  for  LMB  has  steadily  evolved.  In  2009,  the  Commission  released 
a Communication to the European Parliament and the Council giving its vision for the production 
method of EU statistics for the decade (2010-2020)13. This document has explored the key changes 
in  the  business  environment  of  the  European  Statistical  System,  and  the  implications  for 
policymaking. It highlighted the importance of having an integrated system that allows countries to 
gather  data  from  different  sources,  increasing  the  availability  and  reach  of  the  analysis.  It  also 
highlighted  the  importance  of  increasing  the  quality  of  the  data,  considering  that  many  external 
sources do not match the expected requirements for European statistics.  In 2014, the Commission 
(Eurostat)  began  the  process  of  modernising  social  statistics.  This  led  to  the  adoption  of  the 
framework regulation for European statistics relating to persons and households, based on data at 
individual level collected from samples of persons and households14. In parallel, on 27 November 
2019,  the  European  Parliament  and  the  Council  adopted  the  Regulation  on  European  Business 
Statistics (EBS), repealing 10 legal acts in this field. The LMB is at the intersection between both 
domains, belonging to social statistics in terms of topic covered and to business statistics according 
to the type of respondents (enterprises). This initiative on LMB should be seen as completing the 
modernisation round of social statistics. 

Current issues with LMB statistics 

As recognised by the evaluation, LMB statistics allow collecting high quality information that are 
widely  used  for  the  intended  purposes.  The  strengths  of  LMB  statistics  lie  in  their  coherence, 
efficiency,  comparability  and  the  fact  that  they  are  well  established,  reliable  and  widely  used  by 
organisations  and  policy  makers  at  all  levels.  Moreover,  no  alternative  data  at  the  EU  or  wider 
levels exist.  

However, some shortcomings that were already identified at the time of adoption of the legal acts 
were  differently  approached  (by  requiring  feasibility  studies  that  lead  to  amendment  of  the 
legislation, by making available financial support for creating the capabilities needed to give effect 
to the legal base), and in the case of some data collections not sufficiently  resolved. They mainly 
concern the partial coverage of LMB data on earnings which limits their use for policy purposes. 

11 https://ec.europa.eu/info/strategy/priorities-2019-2024/economy-works-people/jobs-growth-and-
investment/european-pillar-social-rights_en  
12 https://ec.europa.eu/eurostat/web/sdi/overview  
13 https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2009:0404:FIN:EN:PDF . 
14  Regulation  (EU)  2019/1700  of  the  European  Parliament  and  of  the  Council  of  10  October  2019  establishing  a 
common  framework  for  European  statistics  relating  to  persons  and  households,  based  on  data  at  individual  level 
collected from samples […] (Text with EEA relevance) (OJ L 261I, 14.10.2019, p. 1) 

4 

 
 
                                                 
For several EU Member States, structure of earnings survey and/or labour cost survey do not cover 
enterprises with one to nine employees or part of the public sector (NACE Rev. 2 section O: ‘Public 
administration, defence,  compulsory social security’). This  creates  biases  in  key statistics such as 
the average earnings and labour costs and therefore, for the gender pay gap as well (see Table 1). 

Table 1.  Gender pay gap by size class of the enterprise, 2018  

Source: Eurostat, calculation based on the SES 2018 

Those  limitations  became  more  visible  further  to  the  recent  policy  developments  in  the  areas  of 
equality,  skills,  working  conditions  and  monetary  union  monitoring  to  which  the  data  at  the  EU 
level is essential and provides clear added value. 

For instance, the monitoring of the new directive15 on adequate minimum wages requires unbiased 
estimates  of  the  median  wages  as  a  (country-specific)  benchmark.  This  requires  that  Structure  of 
Earnings data cover all segments of the economy, including enterprises with less than 9 employees 
and the public sector, whose importance varies across EU countries.  

15 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022L2041  

5 

Enterprises employing 10 and more persons Enterprises employing 1 and more personsEnterprises employing from 1 to 9 personsBelgium5.8::Bulgaria14.014.411.7Czechia19.718.34.0Denmark14.6::Germany20.120.615.9Estonia21.818.38.1Ireland11.310.16.6Greece10.7::Spain11.912.413.4France16.7::Croatia11.4::Italy5.5::Cyprus10.49.614.4Latvia19.517.38.8Lithuania14.011.92.0Luxembourg1.4::Hungary14.2::Malta13.0::Netherlands14.716.425.8Austria20.4::Poland8.5::Portugal8.8::Romania2.2::Slovenia9.37.21.4Slovakia19.819.38.3Finland16.9::Sweden12.1::Iceland13.8::Norway13.213.010.9Switzerland18.619.121.0 
 
 
                                                 
In  other  respects,  the  lack  of  a  legal  obligation  to  provide  information  on  gender  pay  gap  (GPG) 
became  more  problematic  as  the  current  data  collection  is  voluntary  and  does  not  cover  all  EU 
countries nor all GPG variables. This brings a risk factor for the monitoring of principle 2 (‘Gender 
equality’) of the European Pillar of Social Rights.  

The frequency of SES and LCS is not sufficient anymore for a number of users and the timeliness 
of the LCI, SES and LCS need to be improved. 

Moreover, some stakeholders consulted in the public consultation and interviews, expressed needs 
for more breakdowns  (e.g.,  ISCO or NUTS) or  additional variables,  allowing  a  better  analysis of 
wage determinants including for the gender pay gap. In the interviews, they shared the view that it 
would  be  beneficial  to  assess  innovative  data  collection  methods  (e.g.,  web  scraping  for  job 
vacancies), that have the potential to decrease the burden on data providers, provided they ensure 
sufficient quality. 

The evaluation  has shown that those shortcomings reduce the relevance,  effectiveness,  coherence 
and  comparability  of  statistics  across  Member  States,  with  negative  impacts  for  decision-making 
based on them. 

2.  PROBLEM DEFINITION 

2.1.  What is/are the problems? 

The evaluation identified issues that could be structured around three main problems.  

Problem 1: LMB statistics does not address new needs, sources and methods.  

The current legal framework does not cover new and emerging users’ needs. For example, policy 
users  expressed  a  growing  interest  in  data  on  the  skills  of  the  employees  (the  occupation  data 
collected at the detailed levels of the ISCO classification can be used as a proxy for skills) and their 
net  earnings  (e.g.  to  monitor  the  purchasing  power  of  low  wage  and  of  minimum  wage  earners). 
LMB also miss a quarterly index of hours worked that would have allowed monitoring the impact 
of COVID-19 and other possible crises on the volume of work. Job vacancy statistics by region and 
occupation are not  available either, except for a few EU countries.  These were deemed crucial to 
build more comparable vacancy data, estimate needs and assess job shortages at the regional level. 

At  the  moment,  the  data  collection  framework  is  not  flexible  enough  to  allow  for  adjusting  new 
variables  or  the  timeliness  of  statistics.  There  is  also  growing  interest  in  non-discrimination  and 
gender equality, but the collection of gender pay gap data is currently collected voluntarily and not 
delivered  by  all  Member  States.  This  results  in  data  that  are  not  as  precise  and  comparable  as 
possible or required by some data users. Moreover, data on the earnings of people with disabilities 
are not collected, even those based on a national (non-harmonised) concept of disability. This fails 
in supporting users in making evidence-based policies and to follow the requirements of Article 8 
TFEU and the UN Convention on the Rights of Persons with Disabilities. 

Users  are  also  seeking  timelier  data,  for  some  LMB  statistics,  namely  more  frequent  data 
collections and releases (note that the frequency of collection and release currently varies by type of 
LMB statistics) and/or that statistics become available faster. 

Another  emerging  trend  not  fully  considered  in  the  current  LMB  framework  is  the  use  of 
administrative data. Several Member States are making increasing uses of this type of source. This 

6 

 
 
facilitates  more  frequent  data  collection  (e.g.,  quarterly).  The  current  legal  framework  is  not, 
however,  able  to  accommodate  appropriate  quality  reporting  for  this  type  of  data  across  Member 
States.  

Therefore,  some  user  needs  are  likely  to  remain  unmet,  representing  a  missed  opportunity  to 
maximise  the  impact  of  LMB  statistics  across  stakeholders  and  especially  policy  makers  and 
researchers making use of this data. The provision of data closer to users’ needs, coordinated across 
the  Member  States,  would  provide  policymakers  with  the  opportunity  to  make  more  rapid  and 
reliable assessments and respond quicker to changing issues/needs.   

Problem 2: LMB statistics do not capture important actors or phenomena of the EU economy 

As  the  current  data  collection  on  the  gender  pay  gap  is  voluntary,  some  Member  States  do  not 
provide the data, or only partially so that estimates are not fully available for comparisons across 
countries and time. This hampers users to have a full overview of gender pay disparities across EU 
countries and act in order to promote equality between men and women as requested by article 10 
TFEU, SDG 5 and the second principle of the European Pillar of Social Rights. 

Interviewed stakeholders representing users stressed that extending the coverage of LMB statistics 
to  micro  enterprises  would  also  be  important,  at  least  for  the  main  variables  of  SES,  and  to  the 
public sector  as  no coverage of these impacts  the proportion of minimum  wage  earners  and low-
wage  workers.  This  would  also  correct  the  existing  biases  in  key  figures  such  as  the  mean  and 
median earnings which are used in many policy indicators such as the minimum wage to median 
earnings ratio (‘Kaitz index’).  Covering only part  of the  economy also  distorts  derived indicators 
such as the gender pay gap. It prevents users from analysing the adequacy of wages in the public 
sector and assessing the corresponding wage policies of EU governments.  

Similarly, adding more variables in structure of earnings survey would enrich the scope and depth 
of analysis and modelling based on this data source. This would allow refining further the existing 
decompositions  of  the  unadjusted  gender  pay  gap  which  face  limitations  in  possibility  for 
disaggregation (not accounting for wage penalties related to family situation, career breaks, etc.). 

Problem 3: LMB statistics are not aligned with related statistical domains 

The evaluation results show that the current legal framework can be further improved to align with 
other  EU  policies  and  legislations  as  those  that  are  new  or  evolved  since  the  LMB  legislation 
adoption. For instance, more pressing needs have emerged with the adoption of the new directive 
on minimum wage adequacy16. It becomes even more important than before to collect and publish 
mean and median earnings for the whole economy, as a benchmark for minimum wage levels. It is 
also useful to develop concepts such as the net wages received by employees after deduction of all 
social contributions. 

The  same  applies  to  recent  developments  on  gender  equality,  for  which  the  gender  pay  gap  has 
become a prominent indicator and should be possibly adjusted for all social contributions and more 
precise estimates of the skills levels.  

Due to  the time elapsed since the adoption of the current  LMB legislation, the latter is no longer 
aligned on the latest versions of the related legal texts. This concerns in particular the latest edition 

16 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32022L2041  

7 

 
 
                                                 
of the European System of Accounts (ESA 201017) which defines the main concepts (e.g. notions of 
employees, labour costs, wages) used in labour statistics. It is also relevant for European Business 
Statistics18 whose general concepts have been updated with the adoption of the revised framework 
regulation and implementing acts. 

A  few  stakeholders  highlighted  some  issues  of  consistency  in  terminologies  used  across  Member 
States.  This  was  mentioned  for  example  about  labour  costs,  namely,  the  elements  included 
some 
capturing 
inconsistencies in collective agreement across different countries.  

security  contribution.  Similarly,  other 

stakeholders  mentioned 

social 

Coherence between different data collections is another dimension of quality as it is fundamental to 
address multi-dimensional issues. The fragmented legal framework poses an immediate risk of the 
lack of coherence and comparability between data collections. 

Stakeholders affected 

The persistence of the problems affects users of the LMB statistics who do not have the evidence 
that meets their demands and those of policy makers that miss it for an efficient decision-making 
process.  Ultimately,  EU  citizens  could  be  considered  not  to  be  able  to  fully  capitalise  on  high 
quality research and efficient policies. 

The  next  section  explains  more  in  detail  these  problems  and  assesses  how  significant  they  are  in 
terms of scale and impact. It also examines the main drivers leading to the problems and reflects on 
the expected evolution of the problems in the absence of targeted action. 

2.2.  What are the problem drivers? 

Each of the problems has specific causes, also known as drivers. The main causes of the problems 
identified so far are grouped under each problem. That is, each problem has specific drivers. 

For each problem, the list of all relevant drivers is detailed in the next paragraphs.  

Problem 1: LMB statistics do not address new needs, sources and methods 

D1 – LMB statistics do not cover emerging needs 

Over the time, policy data users alerted Eurostat that there are particular variables or breakdowns 
missing in the LMB that would allow them better analysis and policy monitoring. In that context, 
also  during  the  public  consultation  several  improvements  needed  were  confirmed,  for  instance 
collecting  and  publishing  the  numerator  (labour  costs)  and  the  denominator  (index  of  hours 
worked) of the LCI ratio for several NACE aggregates was found crucial or highly important by 13 
data users out of 35 replying to the public consultation, another 15 considered this improvement of 
medium importance and only 7 as low. For 5 out of 18 data producers this was unimportant, other 9 
producers gave medium importance and 4 high or crucial importance. Similarly, quarterly data on 
the ‘total number of hours worked’ was needed by both types of stakeholders: data users (29 replies 
out of 36, of which 13 scored this improvement as crucial or highly important and 16 of medium 

https://ec.europa.eu/eurostat/documents/3859598/5925693/KS-02-13-269-EN.PDF/44cd9d01-bc64-40e5-bd40-

17 
d17df0c69334  
18 https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32019R2152 

8 

 
 
                                                 
 
importance)  and  producers  (only  7  out  of  18  gave  it  a  low  importance).  Those  needs  were 
confirmed in the interviews with EU policy makers (e.g. DG EMPL; DG ECFIN). For lack of this 
information,  it  was  not  possible  to  monitor  the  impact  of  the  COVID-19  crisis  on  the  volume  of 
work. This will also be relevant for future crises.  

The  results  of  interviews  with  main  stakeholders  (in  particular  European  policy  users)  confirmed 
that  there  is  a  set  of  unmet  needs  related  to  missing  variables  that  prevent  from  fully  adequate 
analysis.  Regarding  SES,  in  the  interviews,  policy  users,  in  particular  DG  JUST,  DG  EMPL, 
expressed interest in intersectional analyses that would build on sex, age, possibly disability, etc. as 
far  as  feasible  in  a  harmonised  fashion.  This  would  allow  a  better  analysis  of  wage  determinants 
and  the  refining  existing  adjustment  of  the  gender  pay  gap.  Indeed,  the  gender  pay  gap  is  very 
difficult to interpret without adjustment for the structure of the male versus female labour force in 
terms  of  occupations,  economic  activities,  seniority,  family  situation,  etc.  Refined  adjustments 
would therefore contribute to a better benchmarking between Member States and to the monitoring 
of  the  Gender  Equality  Strategy,  European  Pillar  of  Social  Rights,  the  Sustainable  Development 
Goals  (gender  pay  gap  is  an  indicator  for  gender  equality  listed  under  the  EU  SDG  indicators  set 
Goal  5:  ‘Gender  Equality’).  Collecting  SES  information  on  net  earnings  and  detailed  occupation 
would  allow  users  to  better  monitor  the  promotion  of  equality  enshrined  in  the  Charter  of 
Fundamental Rights. Getting data on vacancies and occupied posts (JVS) by occupation at the 2nd 
digit  level  of  the  ISCO  classification19  was  considered  crucial  or  highly  important,  in  the  public 
consultation,  by  18  data  users  out  of  31  replying  the  question,  other  8  considered  it  as  medium 
important and only 5 as unimportant. Out of 17 data producers, 7 put low importance to having JVS 
data by occupation. The JVS data by NUTS 2 region were found crucial or highly important by 14 
out  of 31 data users  and 8 found this improvement as medium  important.  Among data producers 
replying to  the question only 3 out of 16 found it  unimportant.  The JVS  data by  NUTS 2  region 
were found crucial in the interviews with DG REGIO. This data would allow identifying regional 
mismatches  and  measuring  labour  shortages  for  different  skills.  They  would  also  be  needed  to 
check the quality of non-official vacancy data (online job vacancies). 

Yet, the LMB statistics legal framework does not facilitate incorporating new elements on  an ad-
hoc approach. As underlined by the policy users at several occasions (e.g. meeting of the working 
groups,  hearings),  the  new  legal  basis  should  as  much  as  possible  include  the  variables  or 
breakdowns identified as ‘emerging needs’ and be open for future updates if the situation requires.  

D2 – The quality framework of  LMB statistics is not fit for  the use of  administrative data  and 
innovative sources  

In  the  past  two  decades,  an  increasing  number  of  Member  States  has  switched  to  administrative 
sources for the compilation of some LMB datasets, as least for some variables. In the case of the 
LCI,  the  use  of  administrative  sources  is  already  the  standard  in  most  countries;  labour  cost 
variables are generally taken from social security data whereas the number of hours worked is still 
collected via surveys. This is also the case for annual gender pay gap data which are compiled from 
the four-yearly SES data for the years when survey data are available and which are extrapolated 
with social security sources in some countries. In the latest structure of earnings survey (SES 2018), 

19See also: 
https://ec.europa.eu/eurostat/ramon/nomenclatures/index.cfm?TargetUrl=LST_NOM_DTL&StrNom=ISCO_88_CO&S
trLanguageCode=EN&IntPcKey=&StrLayoutCode=HIERARCHIC 

9 

 
 
                                                 
 
10  out  of  27  Member  States  reported  using  a  combination  of  survey  data  and  administrative 
sources.  Administrative  sources  are  less  common  for  job  vacancies  domain  as  data  from  public 
employment services tend to overestimate the real levels, some filled vacancies being still recorded 
in the register of vacant post. 

Without  incorporating  this  type  of  data  into  the  framework  of  LMB,  there  will  be  an  untapped 
potential for adding variables and breakdowns as well as reducing the cost and burden. However, 
increasing the use of administrative data and potential innovative data sources requires an updated 
quality  reporting  framework  for  documenting  those  sources,  assessing  their  quality  and 
communicating to the users. 

Administrative data have not been primarily collected for statistical purposes and they only partly 
match the concepts to be measured. In addition, non-statistical sources may have other impacts such 
as the lack of timeliness (due to the administrative process before their availability). Hence, using 
these  sources,  requires  specific  quality  assessments  (e.g.  in  quality  reports)  such  as  on  the  biases 
introduced by the original purposes for which these data are collected and measuring the extent and 
impact  of  the  biases  introduced  in  the  quality  of  the  statistics  based  on  them.  Specific  quality 
reporting on administrative or hybrid data sources does not exist yet for LMB statistics. The current 
reporting  is  focused  on  the  survey  collection  and  the  quality  is  mainly  measured  through  the 
statistical variance and on possible deviations of the statistical sample from the target population of 
enterprises or employees.  

Similarly,  the  experimental  work  on  use  of  innovative  data  sources  (for  instance  information  on 
online job advertisements available on the internet) showed so far that the web-scrapped data (data 
extracted  from  the  internet)  provide  results  that  differ  in  levels  from  the  official  statistical 
information collected by the members states directly from the enterprises but are following roughly 
the  same  time  trends.  Online  job  advertisements  do  not  cover  all  job  offers  but  they  can 
complement  the  existing  statistics  with  further  comprehensive,  detailed,  and  timely  insights  into 
labour  market  trends,  allowing  the  early  identification  of  new  emerging  jobs  and  skills.  Being 
a potential important source for the future, the quality of these data collected from the web should 
be correctly assessed. Public consultation showed that for 18 users of the data adding a description 
of administrative sources/registers to the SES quality report was crucial or highly important, for 13 
importance was medium and for 5 low. In total 36 users replied. Only 2 out of 20 data producers 
considered it unimportant.  

Similarly  for  LCS,  13  data  users  out  of  35  were  stated  that  adding  description  of  administrative 
sources was crucial or highly important, 16 that it was moderately important and only 6 that it was 
not important. Only 2 data producers out of 18 who replied considered it unimportant.  

In case of LCI, only 3 out of 36 data users and 3 out of 18 data producers were not interested in 
information on administrative sources in the quality reporting.  

For JVS, 9 data users (out of 31 who replied) and 1 data producers (out of 16) considered adding 
information on administrative sources in the quality reporting unimportant. For 11 data producers 
this was crucial of highly important and for other 11 moderately important. 

10 

 
 
 
 
D3 – Some LMB statistics are not timely or frequent enough 

Data that are published with a long lag after the reference period lose their relevance and usability, 
in particular when the observed phenomenon quickly varies over time. Expectations are also higher 
and,  although  LMB  data  generally  comply  with  the  deadlines,  they  are  not  considered  timely  or 
frequent enough nowadays, at least by some users. 

Stakeholders expressed a view that a higher frequency of data and quicker updates of some LMB 
datasets are needed. In the public consultation, the timeliness and the collection frequency were two 
of the less positively assessed elements of the statistical quality for SES: 30 % of respondents to the 
public  consultation  were  not  satisfied  with  the  frequency  of  the  survey  (18  replies  out  of  59) 
whereas 51 % expressed satisfaction (30 out of 59) and 19 % being neutral (11 replies out of 59). 
For LCS dissatisfaction on the frequency reached 24 % (14 replies out of 58), with 48 % expressing 
satisfaction (28 replies out of 58), and 28 % being neutral (16 replies). Satisfaction with frequency 
was  much  higher  for  GPG,  JVS  and  LCI  with  dissatisfaction  only  amounting  to  2 %  for  each  of 
these. 

The results of the public consultation also showed that collecting SES data every 2 years instead of 
every 4 years, was considered crucial or highly important by 20 out of 36 data users replying this 
question against 7 out of 18 producers of LMB statistics. For 10 data users this improvement was of 
medium importance and for 10 data producers low.  

At the same time, collecting LCS data every 2 years instead of every 4 years was considered crucial 
or highly important by 15 data users out of 33 who replied, for 10 of them it has medium and for 8 
low importance. 12 out of 18 producers considered doubling frequency of LCS of low importance. 

More  frequent  SES  would  provide  more  relevant  figures  for  derived  indicators  such  as  the  mean 
and median earnings. Some users (e.g. trade unions), during the stakeholders workshop, underlined 
this  need  that  became  crucial  in  time  of  quick  changes  (e.g.,  high  inflation)  to  see  if  wages  are 
adapted to the inflation. In addition increased SES frequency would allow more timely analysis of 
pay gap determinants. 

Similarly to frequency, the timeliness of the SES and LCS data was also not satisfactory for 32 % 
of the respondents to the public consultation (19 replies), 39 % of them were satisfied (23 replies) 
and 29 % (17 replies) did not have an opinion.  

11 

 
 
 
Figure 1.  Public consultation respondents’ satisfaction with data timeliness across datasets 

User of European labour market statistics on
businesses

1

13

9

11

2

S
E
S

S
C
L

I

C
L

Producer of European labour market statistics on
businesses
Provider of administrative records as input for
European labour market statistics on businesses
User of European labour market statistics on
businesses

Producer of European labour market statistics on
businesses
Provider of administrative records as input for
European labour market statistics on businesses
User of European labour market statistics on
businesses

Producer of European labour market statistics on
businesses
Provider of administrative records as input for
European labour market statistics on businesses
User of European labour market statistics on
businesses

S
V
J

Producer of European labour market statistics on
businesses
Provider of administrative records as input for
European labour market statistics on businesses

2

6

5

4

1

1

1

1

3

1

1

1

1

3

1

1

11

8

7

6

13

8

2

4

2

1

14

13

1

9

1

1

11

12

5

1

6

8

2

Very satisfied

Satisfied

Neutral/no opinion

Not satisfied

Very dissatisfied

Source: Public consultation 

Among  the  data  users,  almost  the  same  number  was  satisfied  (14)  as  dissatisfied  (13)  with  SES 
timeliness. For the LCS, 10 users were dissatisfied with timeliness against 12 satisfied.  

Satisfaction  with  timeliness  was  much  higher  for  JVS  and  LCI  with  dissatisfaction  amounting  to 
only 6 negative replies for JVS and 1 for LCI.  

Improving  timeliness  was  considered  one  of  the  three  most  supported  priorities  for  the  SES  and 
LCS in the public consultation. Improving timeliness of SES (by 5 months) was considered crucial 
or highly important by 22 data users out of 36 who replied the question, 10 considered it medium 
important and only 4 as not important. Similarly, 15 data producers out of 18 who replied thought 
the timeliness improvement is either highly or medium important (9 and 6 replies respectively) and 
only 3 that it is low. When it comes to the LCS, shortening the time of data publication by 6 months 
was unimportant only to 4 out of 35 data users and 4 out of 18 data producers.  

12 

 
 
 
 
The  interviews  with  EU  policy  makers  (DG  JUST,  DG  EMPL,  DG  ECFIN)  confirmed  those 
findings that were further strengthened by the  employment  organisations and trade unions during 
the stakeholders’ workshop.  In particular,  due to the COVID-19 pandemic  and the current rise in 
inflation,  the  timeliness  of  data  has  become  even  more  important  to  stakeholders.  With  the  fast-
paced changes in the labour market, stakeholders highlighted the need for more timely statistics to 
inform  policy making.  No alternative data sources exist at  the EU level,  therefore not  addressing 
this issue will put in question correct and timely monitoring of EU policies LMB is used for.  

Problem 2: LMB statistics do not capture important actors or phenomena of the EU economy 

D4 – The public sector and micro enterprises are not captured by LMB statistics 

The coverage of LMB statistics was a shortcoming identified already at the time of adoption of the 
legal  acts.  Those  were  differently  approached  (by  requiring  feasibility  studies  that  lead  to 
amendment  of  the  legislation,  by  making  available  financial  support  for  creating  the  capabilities 
needed to  give  effect  to  the legal  base) and, in  the case of some data collections, not  sufficiently 
resolved. While there are only three Members States with difficulties in providing JVS data for the 
whole  economy,  more  than  half  of  them  did  not  progress  over  time  in  gathering  information  on 
labour costs and structure of earnings for enterprises employing less than 10 persons or for NACE 
Rev. 2 section O (public administration, defence, compulsory social security), in the SES and LCS.  

The economic activities required to be covered by the SES in the legislation are NACE sections B 
to  S  excluding  O.  Although  most  of  the  countries  go  beyond  this  requirement  and  provide 
information  for  section  O,  the  lack  of  data  from  some  of  them  prevents  from  calculating  the  EU 
aggregates.  The  above-mentioned  shortcoming  of  the  coverage  of  the  SES  influence  also  the 
comparisons of the earnings of men and women.  Moreover, the section  O  covers enterprises that 
are female dominated.  

Following  the  difference  described  above,  the  gender  pay  gap  calculated  for  the  whole  economy 
(sections  B  to  S)  differs  from  the  one  in  the  aggregate  not  covering  section  O  (sections  B  to  S 
except  O).  The  lack  of  the  data  for  section  O  in  some  countries  does  not  allow  full  comparisons 
across the EU.  

13 

 
 
 
 
Table 2.  Gender pay gap by economic activity of enterprise, 2018 

Industry, construction and 
services (except public 
administration, defense, 
compulsory social security) - 
NACE B to S except O 

Industry, construction and 
services (except activities of 
households as employers and 
extra-territorial organisations 
and bodies) - NACE B to S 

Public administration and 
defence; compulsory social 
security - NACE O 

Belgium 
Bulgaria 
Czechia 
Denmark 
Germany  
Estonia 
Ireland 
Greece 
Spain 
France 
Croatia 
Italy 
Cyprus 
Latvia 
Lithuania 
Luxembourg 
Hungary 
Malta 
Netherlands 
Austria 
Poland 
Portugal 
Romania 
Slovenia 
Slovakia 
Finland 
Sweden 
Iceland 
Norway 
Switzerland 

5.8 
13.9 
20.1 
14.6 
20.1 
21.8 
11.3 
10.4 
11.9 
16.7 
11.4 
5.5 
10.4 
19.6 
14.0 
1.4 
14.2 
13.0 
14.7 
20.4 
8.5 
8.9 
2.2 
9.3 
19.8 
16.9 
12.1 
13.8 
13.2 
18.6 

: 
13.6 
19.5 
14.3 
19.0 
20.7 
11.4 
7.4 
11.2 
16.1 
10.9 
6.2 
11.0 
17.6 
13.2 
1.6 
13.7 
11.8 
14.2 
: 
8.8 
: 
1.0 
9.0 
19.7 
16.6 
11.9 
13.6 
13.4 
18.6 

: 
8.3 
15.7 
9.3 
6.9 
7.2 
10.8 
-16.7 
6.3 
9.9 
9.2 
8.6 
13.9 
-2.8 
5.1 
0.4 
6.7 
-5.5 
2.6 
: 
15.1 
: 
2.3 
10.4 
19.0 
13.8 
7.6 
9.6 
15.8 
17.8  
Source Eurostat, [earn_gr_gpgr2] 

Extension of the coverage of the SES to micro firms was perceived as crucial or highly important 
by  22  out  of  36  of  data  users  replying  the  question,  for  8  of  them  this  improvement  had  low 
importance  and  for  6  medium.  Out  of  18  data  producers,  only  one  was  considering  this  change 
unimportant.  

Extension to NACE Rev. 2 section O was considered unimportant by only 5 data users and one data 
producer  (out  of  36  and  18  of  them  respectively).  For  21  data  users  this  change  was  crucial  or 
highly important and for 10 the importance was medium. 10 data producers considered this change 
as crucial of highly important and 7 gave it a medium importance.  

For  the  LCS,  the  level  of  satisfaction  with  the  coverage  was  higher  for  size  classes  than  for 
economic activities for both data users and providers. 

14 

 
 
 
  
Figure 2.  Public  consultation  respondents’  satisfaction  with  size  classes  covered  by  LCS  (all 

enterprises except those with less than 10 employees) 

User of European labour market
statistics on businesses

Producer of European labour
market statistics on businesses

Provider of administrative records
as input for European labour
market statistics on businesses
satisfied

very satisfied

14

11

6

1

11

2

3

3

2

1

1

neutral/no opinion

not satisfied

very dissatisfied
Source: Public consultation 

Figure 3.  Public consultation respondents’ satisfaction with economic activities covered by LCS 

User of European labour market
statistics on businesses

4

Producer of European labour
market statistics on businesses

2

6

12

5

5

Provider of administrative records
as input for European labour…

1

1

10

7

2

very satisfied

satisfied

neutral/no opinion

not satisfied

very dissatisfied

Few countries provide LCS data for micro enterprises. Not covering all sizes of enterprises leads 
to  biased  results  for  the  average  labour  costs  which  are  generally  lower  in  microenterprises 
compared  with  enterprises  employing  10  persons  and  more,  as  illustrated  in  Figure  4  for  the 
countries for which this information is available. 

Source: Public consultation 

15 

 
 
 
Figure 4.  Total labour costs20 in Euro, per employee in full-time equivalents, per hour, by size of 

enterprise, 2016 

56,7

47,1

35,1

32,3

4,5

2,7

2,8

5,4

5,3

7,4

7,7

5,3

10,3

6,5

10,8

7,2

10,2

7,5

21,2

13,7

16,8

12,7

13,5

8,0

60

50

40

30

20

10

0

From 1 to 9 employees

Source : Eurostat, [lc_ncost_r2] 

Since the adoption of the LMB legislation and following the policy developments (e.g. introduction 
of  the  European  Pillar  of  Social  Rights),  the  data  became  more  prominent  and  widely  used, 
therefore requiring necessary improvements in quality.  

For  the  structure  of  earnings  survey  reference  year  2006,  11  Member  States  provided  data  on 
enterprises employing from 1 to 9 employees21. The situation did not improve significantly in the 
following waves  of the  survey (2010, 2014)  and  only  12 Member States  (and 2 EFTA countries) 
transmitted those data in the latest data collection available for reference year 201822. Similarly to 
the structure of earnings survey, only 11 Member States provided data for enterprises with 1 to 9 
employees in the last labour costs survey (2016)23.   

Section O is covered on voluntarily basis in the structure of earning survey by 23 Members States, 
in labour cost survey by 22 and by 24 Members States in the JVS24. 

This  illustrates  that  voluntarily  extension  of  the  surveys  coverage  did  not  provide  satisfactory 
outcome.  

20 Costs of apprentices not included  

21 Czechia, Denmark, Estonia, Spain, Cyprus, Latvia, Lithuania, Netherlands, Poland, Slovenia, Slovakia. Additionally, 
three MS (Ireland, Hungary and Finland) provided data for enterprises with 3 or 5 and more employees. 

22  Bulgaria,  Czechia,  Germany,  Estonia,  Ireland,  Spain,  Cyprus,  Latvia,  Lithuania,  Netherlands,  Slovenia,  Slovakia. 
Additionally, Hungary and Finland provided data for enterprises with 5 and more employees. 

23  Bulgaria,  Czechia,  Estonia,  Spain,  Latvia,  Lithuania,  Netherlands,  Portugal,  Romania,  Slovenia,  Slovakia. 
Additionally, Hungary and Ireland provided data for enterprises with 3 or 5 and more employees. 

24  In  France  and  Italy,  public  institutions  are  not  covered  within  the  sectors  of  public  administration,  education  and 
human health (NACE Rev. 2, sections O, P and Q) Denmark provides data for NACE sections B to N.  

16 

 
 
 
 
                                                 
D5 – GPG data are provided on a voluntary basis 

Data on the gender pay gap are provided by Member States on a voluntary basis leading to a partial 
coverage of countries (Ireland and Greece do not transmit) and statistical variables thus hampering 
cross-country comparisons.  

More than half of LMB data producers responding to the public consultation would find it crucial 
or of high importance to create a legal basis for the mandatory transmission of annual adjusted GPG 
data. Interestingly, only one data producer found this unimportant. Out of 37 data users replying the 
question,  only  8  found  that  a  legal  basis  on  GPG  is  not  needed.  In  the  interviews,  the  data  users 
(e.g.  DG  EMPL,  DG  JUST)  offered  detailed  examples  on  how  the  data  is  used  and  stressed  it´s 
importance  as  well  as  the  problems  caused  by  its  voluntary  status  (e.g.  incomplete  coverage). 
Moreover, some miss certain determinants of the pay gap (e.g. number of children, work spell, total 
experience)  to  conduct  research  on  the  gender  pay  gap  based  on  available  statistics.  Another 
problem they highlighted was that the gender pay gap statistics go through sizeable revisions, when 
SES  becomes  available.  Finally,  the  proposal  for  directive  on  pay  transparency25  requires 
a sustainable production of annual GPG. 

Figure 5.  For  you,  how  important  would  it  be  to  add  the  following  measures  to  the  GPG  data 
collection  process:  Creating  a  legal  basis  for  the  mandatory  transmission  of  annual 
unadjusted GPG data? 

User of European labour market
statistics on businesses

2

14

13

8

Producer of European labour
market statistics on businesses

1

9

6

1

crucial (please explain)

high importance

medium

low importance

 Source: Public consultation 

Problem 3: LMB statistics are not fully consistent with related statistical domains 

D6 – Lack of alignments with definitions, concepts and approaches in related statistical domains 

The  evaluation  found  that  the  current  legal  framework  for  LMB  statistics  is  internally  coherent 
although  this  could  be  improved  further  by  simplifying  the  legal  architecture  (replacing  the  three 
framework  regulations  currently  in  force  by  a consolidated  text).  This  unified  legal  framework 
would  benefit  from  systematic  references  to  the  corresponding  concepts  used  in  closely  related 
domains such as the National Accounts and European Business Statistics. The legislation has been 
updated  in  both  domains  and  their  methodology  revised  (ESA  2010,  EBS  regulation)  since  the 
LMB legislation has been adopted. Aligning LMB is needed with a view to foster coherence across 
domains and clarity to the users of LMB legislation and the statistical offices of the Member States. 

25 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52021PC0093&from=EN 

17 

 
 
 
                                                 
 
Moreover,  the  exclusion  of  “public  administrations  and  defence,  compulsory  social  security” 
(NACE  Rev.  2  section  O)  from  SES,  leads  also  to  a deviation  from  the  scope  used  in  national 
accounts. Civil servants and other government employees are covered in national accounts data but 
not always in LMB statistics. 

The legal framework can also be further improved to align with other EU policies and legislations 
as  those  that  are  new  or  evolved  since  the  LMB  legislation  adoption.  This  problem  has  rather 
limited impact on stakeholders and would be resolved by the above policy measures related to the 
extension of the scope of the LMB and updated referencing. Therefore, no specific policy measures 
addressing the alignment with other policies and legislations are needed.  

2.3. 

Size of the problem(s) 

Different problems or weaknesses identified in the evaluation of the legislation have different levels 
of severity that  can be assessed based  on the consequences of the identified shortcomings. Those 
mainly depend on the importance of the policy concerned and of the type of institutional user. The 
most  important  problems  of  the  current  legal  framework  is  that  it  does  not  reflect  the  latest 
evolution of user needs and is not flexible enough to address those that will emerge in the future. 
This  includes  the  fact  that  the  gender  pay  gap  data  collection  is  provided  on  voluntary  basis  and 
therefore is not transmitted by all member states.  

The timeliness of the data defined in the legislation currently in force is not sufficient anymore for 
the most important policy users (Problem 1). For instance, the labour cost index, could be provided 
to  the  Governing  Council  of  the  European  Central  Bank  one  month  earlier  than  now,  allowing 
quicker reactions to inflation/deflation risks stemming from by wages. This type of analysis and the 
timeliness of the LCI data have become even more crucial since inflation has regained momentum 
in  EU  economies.  Timeliness  and  frequency  of  data  are  closely  related.  The  data  collected 
frequently to monitor phenomena changing quickly in time should be published almost immediately 
to be relevant. The data collected with lower frequency usually do not describe phenomena that are 
volatile  but  should  be  available  with  short  delay  to  be  useful  for  users who  wait  for  it longer  (in 
between  the  data  collections).  The  policy  users,  in  various  occasions  (expert  groups  meetings, 
hearings between the Commission services) often underlined the need for more timely and frequent 
LMB  data.  For  instance,  DG  JUST,  would  need  SES  microdata  more  frequently  than  every  four 
years in order to conduct detailed analyses of gender pay gap determinants.  

Additional variables such as for instance career and family situation in the SES would also enhance 
the  analysis  of  the  gender  pay  gap.  Similarly,  information  on  net  earnings  would  help  good 
monitoring of the wages adequacy (problem 1). The indicators defined based on the LMB data are 
used to monitor policy initiatives that gained importance over time. For instance, the broader use of 
median wages data (coming from the structure of earning survey, SES) for policy monitoring, in the 
context  of  the  directive  on  minimum  wages,  requires  comparable  data  across  EU  countries 
whatever the share of SMEs in the economy or the relative size of the public versus private sectors 
(Problem 2). As illustrated in the evaluation report, the mean earning differs depending on the size 
of enterprises (Figures 1 and 9, evaluation SWD). Similarly, the current gender pay gap indicator is 
not provided for the whole economy as it is based on the same SES source (as illustrated in Table 
1). 

Moreover, the annual gender pay gap is provided on a voluntary basis only and in consequence not 
by all member states (Greece and  Ireland do not  provide data) and is  on a potential risk to being 
discontinued.  

18 

 
 
Hence,  the  implementation  and  monitoring  of  the  two  new  and  very  important  directives  on 
adequate minimum wages and (forthcoming) on pay transparency would not be accurate with the 
current LMB statistics. 

2.4.  How likely is the problem to persist? 

LMB statistics are the only data source on the structure of earnings, labour costs and labour demand 
at EU level. No alternative data sources exist. Hence, without any changes, over a 10-year horizon, 
users’  needs  are  likely  to  remain  increasingly  unmet,  missing  an  opportunity  for  evidence-based 
policy  and  good  quality  research.  Considering  the  importance  of  LMB  statistics  for  policies  that 
generate impacts (e.g., inflation, gender pay gap, labour market performance, convergence), there is 
room for improving the LMB evidence provided for optimal decision-making process. 

For  instance,  the  partial  coverage  of  EU  economies  leads  to  biases  in  key  figures  used  for  EU 
policies such as the job vacancy rate or the mean and median earnings. Without a revision of the 
current  legislation,  this  problem  will  persist  as  observed  in  the  past  years  despite  Eurostat’s 
repetitive warnings (e.g. through the three-yearly report to EP/Council on job vacancy statistics). 

Likewise,  strategic  policies  related  to  equal  rights  will  remain  sub-optimal  until  the  annual  GPG 
data  collection  is  made  mandatory  and  SES  data  are  complemented  with  additional  wage 
determinants such as detailed occupations; new variables such as net earnings and (possibly) new 
information on discriminated and/or segregated sub-populations such as persons with disabilities. 

In economic terms, users will continue to bear additional costs and burdens to search for data that 
are not available at the EU level. 

The problem tree 

Figure  6  below  shows  the  links  of  the  problems  and  their  drivers  as  well  as  their  main 
consequences. 

Figure 6.  Problem tree 

19 

 
 
 
 
3.  WHY SHOULD THE EU ACT? 

3.1.  Legal basis 

The legal basis for EU intervention in the area of European statistics is Article 338 of the Treaty on 
the Functioning of the European Union (TFEU), which confers on the European Parliament and the 
Council  the  power  to  adopt  measures  for  the  production  of  statistics  where  necessary  for  the 
performance of the activities of the Union, in accordance with  the ordinary legislative procedure. 
Article  338(2)  TFEU  mentions six  general  principles that  Union  statistics  must  follow,  namely 
impartiality,  reliability,  objectivity,  scientific  independence,  cost-effectiveness,  and  statistical 
confidentiality while not entailing excessive burdens  on economic operators. These principles are 
defined  in  Article  2(a)–(f)  of  Regulation  (EC)  No.  223/2009  on  European  Statistics  and  further 
detailed  in  the  European  statistics  Code  of  Practice  adopted  according  to  Article  11  of  the 
regulation.  Article  338(2)  TFEU  also  stipulates  that  Union  statistics  shall  not  entail  excessive 
burdens  on  economic  operators.  This  provision,  together  with  that  of  Article  338(1)  TFEU, 
according to which statistics shall only be produced where necessary, reflect an expression of the 
principle of proportionality.  

Article  5  of  the  Treaty  on  European  Union  (TEU)  enshrines  three  principles:  conferral, 
proportionality  and  subsidiarity.  In  line  with  the  principle  of  conferral,  Article  338  TFEU 
empowers  the  Union  to  establish  European  statistics,  so  this  is  a  clear  specific  objective  to  be 
pursued at EU level.  

LMB statistics are part of the European statistics which are framed by Article 338 of the Treaty on 
the  Functioning  of  the  European  Union  (TFEU)  as  the  legal  basis.  This  is  done  following  the 
ordinary  legislative  procedure  in  which  case  the  European  Parliament  and  the  Council  adopt 
measures to produce statistics for the Union to deliver on its role. Hence, according to Article 338, 
LMB  statistics  must  conform  to  standards  of  impartiality,  reliability,  objectivity,  scientific 
independence, cost-effectiveness and statistical confidentiality. 

Finally,  legislative  action  on  LMB  statistics  falls  under  supporting  competences,  where 
the principle of subsidiarity authorises an intervention of the Union only if a specific issue cannot 
be addressed by the individual intervention of the Member States and provided the objective can be 
better achieved “by reason of the scale and effects of the proposed action” at EU level. 

In this  context,  this  section assesses whether  a revision of the current  legal  framework governing 
European  statistics  on  labour  market  on  businesses  is  appropriate  and  justified,  in  view  of  its 
purpose  to  ensure  high-quality  data  on  the  EU  in  line  with  the  statistical  principles  and  quality 
criteria applicable to European statistics.  

3.2. 

Subsidiarity: Necessity of EU action 

Currently,  LMB  data  collections  are  undertaken  under  three  separate  Regulations  that  do  not 
sufficiently  address  new  needs;  sources  and  methods  neither  cover  important  actors  of  the  EU 
economy.  

Voluntary  data  collections  are  appropriate  instruments  to  pilot  the  production  of  new  topics  or 
characteristics,  and  to  foster  the  incremental  capability  of  national  statistical  systems  to  provide 
such new data. However, they tend to  become inefficient over time as  recurrent production  costs 

20 

 
 
eventually fail to generate substantial EU value added in terms of completeness and timeliness for 
all Member States. 

The ESS provides an infrastructure for statistical information needed at the EU level. The system is 
designed  to  meet  the  needs  of  multiple  users  for  decision-making  in  democratic  societies. 
It complements the national needs assuring harmonised approaches and data comparability without 
duplicating the effort. The action does not go beyond the necessary activities of ESS partners while 
better ensuring the quality and comparability of statistics. Among the main criteria to be fulfilled by 
official  statistics  are  consistency  and  comparability.  Member  States  cannot  achieve  those  criteria 
without  a  clear  European  framework,  that  is  to  say  Union  legislation  laying  down  the  common 
statistical concepts and transmission requirements. 

In light of the variety of measures adopted at national level and given that providing a robust legal 
framework  for  the  collection  of  LMB  statistics  is  essential  to  maintain  relevant  and  comparable 
statistics at EU level based on harmonised concepts and approaches to methodology, further action 
at  EU  level  is  justified.  Moreover,  while  some  problems  are  limited  to  some  countries  (e.g., 
coverage of JVS statistics incomplete in DK, FR, IT only), the general problems and requests from 
stakeholders apply to all Member States.  

Moreover, the legislative action is necessary and proportionate as the problems identified can only 
be solved via the appropriate EU legislation  and  have a genuine EU-wide scope clearly linked to 
gaps  of  the  current  legislation  (section  2).  Without  further  EU  legislative  action,  these  problems 
will persist. 

3.3. 

Subsidiarity: Added value of EU action 

The added value of complete and  comparable  LMB statistics  lies in  their important  input to  feed 
into  strategic  EU  policies  (monetary  and  economic  policies,  Gender  Equality  Strategy, 
the European  Pillar  of  Social  Rights,  Sustainable  Development  Goals).  LMB  statistics  are  also 
designed to meet the needs of multiple users, for the purpose of decision-making at all levels in the 
EU, as well as research and informing the general public.  

For  this  purpose,  statistics  that  are  consistent  and  comparable  across  EU  Member  States  are 
required. Coordinated action is essential to  deliver coherent,  reliable, timely and comparable data 
based  on  harmonised  concepts.  It  is  clear  that  without  a  European  framework,  Member  States 
would not achieve the same results in terms of data, harmonised methodology and comparability of 
outputs and consistence, which can only be fully achieved by way of EU action.  

Moreover, in order to ensure compliant provision of national data, a regulation is the most adapted 
type of EU action 

Therefore, actions within this area will respect the principle of subsidiarity as framed by Article 5 
of the TFEU. 

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? 

Figure 7 sets out the main objective and specific objectives. There are no clear trade-offs between 
specific  objectives.  Each  of  them  is  quite  distinct  on  a  specific  strand  of  actions  to  achieve 
the general objective.  

21 

 
 
Figure 7.  Objective tree 

4.1.  General objectives 

The general objective of the action is to produce labour market and business statistics that are up-
to-date,  relevant,  comprehensive  in  coverage  of  important  economic  actors,  comparable  across 
Member States and consistent with related statistical domains. It answers in the LMB domain the 
requirements  of  Article  338  TFEU  for  the  production  of  statistics  where  necessary  for  the 
performance  of  the  activities  of  the  Union,  in  line  with  its  principles  of  high  quality  and  non-
excessive burden. 

Source: ICF 

4.2. 

Specific objectives 

The general objective is made of 3 specific objectives: 

  Adapting  the  regulatory  framework  to  allow  flexibility  in  meeting  emerging  needs,  to 
release more timely statistics and to promote the use of innovative sources and  methods of 
duly assessed quality 

 

 

Improving the coverage of statistics to the whole economy and ensure exhaustive GPG data  

Improving the consistency with related statistical domains  

Table  3  shows  the  connection  between  problem  drivers  and  specific  objectives.  In  other  words, 
each  driver  could  be  seen  as  an  obstacle  to  achieve  the  objectives.  To  the  extent  policy  options 
would address drivers and problems, these would be helping to achieve the objectives. 

22 

 
 
 
Table 3.  The problems and its drivers are obstacles to achieve the strategic and general objectives 

Problem drivers 

Specific objectives 

General objectives 

[D1] LMB statistics do not 
cover emerging needs 

[D2] The quality framework 
of LMB statistics is not fit for 
the use of administrative data 
and innovative sources 

[D3] Some LMB statistics are 
not timely or frequently 
enough 

[D4] The public sector and 
micro enterprises are not 
captured by LMB statistics 

[D5] GPG data are provided 
by MS on a voluntary basis 

Adapting the regulatory 
framework to allow 
flexibility in meeting 
emerging needs, to release 
more timely statistics and to 
promote the use of 
innovative sources 
and methods of duly 
assessed quality. 

Improving the coverage of 
statistics to whole economy 
and ensure exhaustive GPG 
data 

[D6] Lack of alignments with 
concepts and approaches in 
related statistical domains 

Improving the consistency 
with related statistical 
domains 

To produce labour market and 
business statistics that are up-to-
date, relevant, comprehensive in 
coverage of important economic 
actors, comparable across Member 
States and consistent with related 
statistical domains 

Consistency with other EU policy objectives 

As  highlighted  in  the  effectiveness  part  of  the  evaluation,  the  objectives  of  this  intervention 
contribute to different European flagships: 

  European Employment Strategy (2005/600/EC); 
  Principle 6 of the European Pillar of Social Rights.  
  Directive  on  equal  opportunities  and  equal  treatment  between  men  and  women  in 

employment and occupation (2006/54/EC) 

  Directive on adequate minimum wages (EU) 2022/2041,  
  Commission proposal for EP and Council Directive on pay transparency; 

The policy options will also be assessed on these criteria. 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? 

5.1.  What is the baseline from which options are assessed? 

In the baseline scenario, no action is taken. The current legal framework of LMB statistics divided 
into 3 different basic acts would continue to exist with the shortcomings described in the previous 
sections. In the baseline scenario there is no EU policy change and it does not require any particular 
measure or action. Hence, this is an extrapolation within the next 10 years of what would happen in 
a ‘no-change’  scenario.  This  scenario  implies  consequences  for  stakeholders  as  described  in  the 
problem definition, that is, economic, social and any other relevant impacts.  

23 

 
 
 
5.2.  Description of the policy options 

In  order  to  set  up  policy  options,  an  exhaustive  list  of  all  possible  measures  identified  during 
preparatory work with NSIs, the Public Consultation and stakeholders’ consultation was set up for 
each data collection. In a second step, measures are bundled into regulatory frameworks or policy 
options and clustered by related policy drivers. 

Policy measures 

The policy measures are structured around the data collections to be regulated, amended or updated.  

Job vacancies (JVS); 

Labour cost index (LCI); 

Labour cost survey (LCS); 

Structure of earnings survey (SES); and 

Gender pay gap (GPG). 

The list of measures is presented in the table 4. 

Table 4.  List of measures by data collection 

Code 
SES 1 
SES 2 
SES 3 
SES 4 
SES 5 

SES 6 

SES 7 

SES 8 
LCS 1 
LCS 2 
LCS 3 
LCS 4 
LCS 5 
LCI 1 

LCI 2 

LCI 3 

Description 
NACE Rev. 2 section O mandatory in SES 
Extending SES to micro firms (1-9) for main information only  
Timeliness = T+16 months (instead of T+18 months), for SES  
Extending SES to micro firms (1-9) collecting all SES information  
Frequency of SES = bi-annual (instead of 4-yearly), between LCS years 
Timeliness = T+11 months (instead of T + 18 months) with reference month changed 
from October to February or April, for SES 
Collecting in SES set of new variables identified at the preparatory work stage and 
emerging from the evaluation26 
Improved quality reporting of SES to cover elements assessing new data sources 
NACE Rev. 2 section O mandatory in LCS27 
Extending LCS to micro firms (1-9)  
Timeliness = T+15 months (instead of T + 18 months), for SES 
Frequency of LCS = bi-annual (instead of 4-yearly), between SES years 
Improved quality reporting of LCS to cover elements assessing new data sources 
Flash LCI at T+45 days for large (‘flash’) countries 
Timeliness = T+65 days (instead of T+70) for small (‘non-flash’) countries; 
Full NACE breakdown at t+65 days for all countries, for LCI 
Indices of hours worked/labour costs for NACE aggregates: B to E, F, G to N, B to N, O 
to S and B to S, for LCI 

26 Possible variables to consider at the level of secondary legislation:  occupation at ISCO-3 digits, net earnings, gross 
earnings in kind, disability status of employees, career breaks of employees, number of employee’s dependent children, 
institutional sector of the enterprise.  
27 In addition  limiting  the collection of  labour  cost  survey data  on apprentices to countries  where they represent less 
than 1% of the total number of employees will serve as a simplification measure. 

24 

 
 
                                                 
Code 
LCI 4 

JVS 1 

JVS 2 
JVS 3 
GPG 1 
GPG 2 
All 1 

Description 
Improved quality reporting of LCI to cover elements assessing new data sources 
Full coverage of the economy in JVS including micro firms (1-9), public institutions and 
the non-business economy (NACE Rev. 2 O to S) 
JVS data available by region and occupation  
Improved quality reporting of JVS to cover elements assessing new data sources 
Create a legal basis for the mandatory transmission of annual unadjusted GPG data 
Improved quality reporting of GPG to cover elements assessing new data sources 
Improved harmonisation and  synchronisation of planning 

Policy options 

We present in the following a list of options that correspond to different level of ambitions, but also 
costs and burden, for the LMB review subject to this impact assessment. 

Options are defined as a set of individual measures, from those described in the previous part of the 
document, that would meet the user requirements identified in the evaluation and in the ‘problem 
definition’ part of this document.  

In order to make grouping of the various measures into policy options, a first feasibility assessment 
of  each  individual  topic  and  measure  was  carried  out.  This  process  involved  assessing  how  the 
topics  and  measures  relate  to  one  another  (mutually  exclusive  or  complementary),  and  an  initial 
screening  of  their  likely  effectiveness,  as  well  as  their  technical,  operational,  economic  and  legal 
feasibility.  Based  on  this  assessment  and  in  order  to  integrate  the  various  policy  measures  in 
a meaningful set of policy options that would offer a choice to the policymaker, a realistic selection 
based on the hard or soft nature of the requirement was carried out. This builds on the distinction 
between  required  measures  and  voluntary  measures  on  the  one  hand,  and  the  extent  to  which 
measures were included at all in the option. Two categories of policy measures shall be tackled at 
the  level  of  secondary  legislation,  namely  those  on  improved  quality  reporting  and  on  emerging 
needs for variables and breakdowns. Hence, in the description of policy options, they are grouped 
in only two sets of combined measures on quality and emerging needs respectively.   

The policy options range from the least ambitious ('option 1’)  – implementing most improvement 
measures but without legal enforcement (“soft” non-mandatory / voluntary measures) except for the 
annual GPG - to the most ambitious and costly (‘option 3’)  - whereby all improvement measures 
identified  in  the  evaluation  would  be  implemented  through  legally  binding  provisions.  Option  2 
would enforce only a selected set of improvement measures. Options 1 to 3 are defined under one 
legislative  act  that  will  be  an  umbrella  bringing  together  all  current  three  LMB  related  primary 
legislations. 

Finally,  option  4  is  the  “conservative”  option  offering  changes  in  every  relevant  framework 
regulation.  It  keeps  the  three  exiting  framework  regulations  and  accommodates  changes  in  their 
context when possible. It is further presented under part 5.2.4 but was discarded at an early stage as 
explained under part 5.3. 

The  baseline  (option  0)  and  policy  options  1  to  3  are  detailed  in  Table  5  and  in  the  following 
paragraphs. In this table the selection of measures is indicated according the following labels:  

- Full regulatory approach with binding measures set in EU legislation are marked as “Full” 

25 

 
 
- Soft regulatory approach with non-binding measures set in EU legislation resulting with MS data 
transmitted on a voluntary basis is marked as “Soft”. 

- Measures not included under this policy option are marked as “Not included”. 

26 

 
 
Table 5.  Proposed policy options 0 to 3 clustered by drivers they address 

27 

Option 0: no further EU actionOption 1: Reliance on the voluntary nature of contributionsOption 2: High coverage, better timeliness and other measuresOption 3: Highest coverage and increased frequencyImproving consistency with related statistical domains (synchronised planning and flexibility)/D6Single new framework regulation Single new framework regulation Single new framework regulation Single new framework regulation All 1New framework regulation (Improved harmonisation and synchronisation of planning )Not includedFullFullFullMaking GPG data collection compulsory/D5GPG regulatedGPG regulatedGPG regulatedGPG 1 Create a legal basis for the mandatory transmission of annual unadjusted GPG dataNot includedFullFullFullExtension of the coverage of LMB/D4VoluntaryVery high coverageFull coverage and detailsSES 1NACE Rev. 2 section O mandatory in SESSoftSoftFullFullLCS 1NACE Rev. 2 section O mandatory in LCSSoftSoftFullFullSES 2Extending SES to small firms (1-9) for main information onlySoftSoftFullNot applicableSES4Extending SES to small firms (1-9) collecting all SES information SoftSoftNot applicableFullLCS 2Extending LCS to small firms (1-9)SoftSoftNot includedFullJVS 1Including small firms (1-9) and public institutions and the non-business economy (O to S) in the JVSSoftSoftFullFullImproving timeliness and frequency of LMB/D3Better timeliness  High timeliness, frequency unchangedBest timeliness and frequencySES 3Timeliness of SES = T+16 months (instead of T+18 months)Not includedSoftFullNot applicableSES 6Timeliness of SES = T+11 months (instead of T + 18 months) with reference month changed from October to February or AprilNot includedSoftNot applicableFullLCS 3Timeliness of LCS= T+15 months (instead of T + 18 months)Not includedSoftNot includedFullLCI 1Timeliness of flash= LCI at T+45 days  for large (‘flash’) countries, total economySoftSoftFullFullLCI 2Timeliness of LCI= T+65 days (instead of T+70) for small (‘non-flash’) countries. Full NACE breakdown at t+65 days for all countriesSoftSoftFullFullSES 5Frequency of SES = bi-annual (instead of 4-yearly), between LCS yearsNot includedNot includedNot includedFullLCS 4Frequency of LCS = bi-annual (instead of 4-yearly), between SES yearsNot includedNot includedNot includedFull Adapting quality reporting framework for use of administrative data and innovative sources/D2VoluntaryQuality reporting for all sources Quality reporting for all sourcesSES 8, LCS 5, LCI 4, JVS 3, GPG 2Quality reporting covering elements needed for assessing new data sources in all data collectionsNot includedSoftFullFullAdressing emerging needs /D1VoluntaryEmerging needs for variables and breakdowns Emerging needs for variables and breakdowns SES 7, LCI 3, JVS 2Emerging needs related to new variables in SES, indicies for hours wokred and labour costs in LCI and more detailed breakdowns of the JVS.Not includedSoftFullFull 
 
 
 
5.2.1.  Option 1: Reliance on the voluntary nature of contributions 

In  this  option,  the  existing  data  collections  and  their  legal  obligations  as  foreseen  in  the  three 
existing  regulations  are  implemented  under  a  new  framework  regulation.  Moreover,  the  GPG, 
which is not covered by and does not fit in the scope of any of the 3 current framework regulations, 
is encompassed in this new framework regulation. The reason is the need of  making GPG annual 
data collection compulsory (addressing driver five), aligning definitions, concepts and approaches 
as  well  as  synchronising  planning  as  set  up  by  the  sixth  problem  driver.  Strong  methodological 
links  are  necessary  between  SES  and  GPG  (both  dealing  with  earnings)  and  LCS  and  LCI  (both 
dealing with labour costs).   

However,  selected  new  policy  measures  for  improvement  of  the  data  collections  requested  by 
stakeholders  will  be  implemented  by  voluntary  data  collections.  This  could  be  done  using 
agreement  between  the  NSIs  or  other  national  authorities  and  the  Commission  (Eurostat)  as 
foreseen in the article 14 of the Regulation No 223/200928 by which members of the ESS agree to 
implementing  new  statistical  developments  /  collections  on  a  voluntary  basis.  It  should  be  noted 
that  increasing  the  frequency  of  the  SES  and  LCS  data  collection  on  a  voluntary  basis  was 
discarded  as  its  high  costs  limit  its  implementation  on  a  voluntary  basis.  Moreover,  different 
periodicities of data collections (LCS and SES) among member states would lead to fragmentation 
of  the  statistical  processing  and  dissemination.  Only  some  policy  measures  (GPG  1  and  All  1) 
would be enforced, in line with the approach of the new framework legal basis.  

5.2.2.  Option 2: High coverage, better timeliness and other measures 

In  this  option  all  data  collections  and  the  annual  GPG  are  implemented  under  a  new  framework 
regulation. The measures implemented will be compulsory. However, this option does not include 
the policy measures that have the highest impact in terms of burden and costs for businesses and 
NSIs.  In particular the higher frequency  for SES and  LCS (every two-year instead of every four-
year as currently) that would double the burden of these two surveys for businesses. Similarly, the 
coverage of micro businesses in LCS and some very ambitious improvements of timeliness are not 
implemented.  

Namely,  in  this  option  the  coverage  will  be  extended  to  micro  businesses  for  SES  for  the  main 
information collected in the survey (SES 2) - while LCS will not be extended to these enterprises - 
measures  associated  to  the  fourth  problem  driver.  Both,  SES  and  LCS  will  be  extended  to  cover 
NACE  Rev.  2  section  O  (SES  1  and  LCS  1)  and  JVS  will  cover  full  economy  (including  micro 
firms,  public  institutions  and  non-business  economy,  NACE  Rev.  2  sections  O  to  S)-  JVS  1. 
Moreover,  timeliness  will  be  improved  for  the  LCI  for  all  countries  (LCI  1)  and  larger  countries 
will  provide  quick  estimates  allowing  calculation  the  EU  and  euro  area  flash  labour  costs  index 
twenty  days  earlier  than  the  current  date  of  T+70  days  (LCI  2).  For  the  SES,  the  timeliness  will 
improve  by  two  months  (SES  3)  and  no  improvement  will  take  place  for  LCS  (LCS  3  not 
implemented). Frequency of SES and LCS will not increase (SES 5 and LCS 4 not implemented) – 
measures associated to the third problem driver. All measures associated to the other policy drivers 
will be taken into account, including developing a legal basis for the GPG as under option 1 and 
covering  emerging  needs.  Improved  quality  reporting  will  be  assured  for  all  data  collections  and 

28 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32009R0223&from=EN  

28 

 
 
 
                                                 
better  harmonisation  and  planning  will  be  assured  via  one  framework  regulation.  The  objectives 
would be partially achieved: four out of six drivers would be fully answered and two only partially. 

5.2.3.  Option 3: Highest coverage and increased frequency 

This  option  intends  to  implement,  under  a  new  framework  regulation  encompassing  all  data 
collections  and  the  annual  GPG,  all  and  best  policy  measures  listed  above,  including  the  high 
frequency measures for SES and LCS (every two-year data collection for each). This option would 
answer  exhaustively  the  needs  for  improvement  and  harmonisation  of  all  LMB  statistics  as 
expressed by stakeholders. 

Namely, it includes all policy measures identified, for all actions answering all the 6 policy drivers, 
either  in  terms  of  coverage,  timeliness  and  high  frequency,  quality  reporting  and  use  of 
administrative  data  and  innovative  sources,  alignment  of  concepts  across  LMB  domains,  making 
GPG data collection compulsory and covering emerging needs. That means, the coverage of SES 
and LCS would be extended to micro firms and NACE  Rev. 2 section O (SES 1, LCS 1, SES 4, 
LCS  2)  and  JVS  to  micro  firms  and  NACE  sections  O  to  S  (JVS  1).  Timeliness  of  SES  would 
improve to T+11 (SES 6) and LCS to T+15 (LCS 3).  All measures associated to the other policy 
drivers will be taken into account, including developing a legal basis for the GPG as under option 1 
and 2 and emerging needs. Improved quality reporting will be assured for all data collections. And 
better harmonisation and planning will be assured via one framework regulation.  

Framing options 2 and 3 in the secondary legislation 

The  framework  regulation  will  define  domains  and  topics  for  the  data  collections.  The  technical 
elements  including  the  list  and  description  of  variables  and  breakdowns  will  be  specified  in  the 
secondary legislation. 

The detailed variables (preliminarily identified in the evaluation) or breakdowns will be a subject 
for secondary legislation due to high level of details and granularity as well as their very technical 
character.  Similarly,  the  framework  regulation  in  options  2  and  3  will  require  Member  States  to 
provide quality reports on the sources and data collection methods, while their technical elements 
including the content of the quality report will be defined in secondary legislation. This approach 
allows for updating the contents of quality reports should new specific quality dimensions become 
relevant. 

In  addition,  to  assure  flexibility  in  addressing  future  needs,  some  aspects  (detailed  topics,  their 
corresponding periodicity and reference periods as well as transmission deadlines) will be set out in 
the annex of the framework regulation with delegated powers for the Commission to adapt them. 
This is the usual approach for statistical legislation, and it allows for updating technical elements to 
cater for future emerging needs. 

5.2.4.  Option 4: Implement actions in the existing legal frameworks 

This  option  would  implement  policy  measures  by  amending  the  existing  three  framework 
regulations. While it is possible to implement a large series of measures by amending Regulation 
(EC) 530/1999 for SES and LCS measures, Regulation (EC) 450/2003 for LCI and Regulation (EC) 

29 

 
 
 
453/2008  for  JVS,  there  will  be  no  legal  framework  for  regulating  the  annual  GPG  nor  better 
harmonisation and planning. 

5.3.  Options discarded at an early stage 

The  data  collections  covered  in  the  LMB  statistics  are  interlinked.  They  should  use  the  same 
statistical definitions and be coordinated in timing to be fully effective. For example, indicators on 
labour cost  levels  are collected every four  years  (direct  measurement)  and updated every  year by 
using the annual labour costs index as an auxiliary variable. As another case, the yearly gender pay 
gap is benchmarked every four years on the results of the structure of earnings survey. This requires 
definitions used for wages and other labour cost components to be identical in all these datasets in 
order to obtain unbiased yearly estimates. Updating each framework regulation separately would be 
a missed opportunity to best align the common concepts used in labour market statistics. Moreover, 
if  the  legal  framework  remains  scattered,  introducing  any  future  new  concepts  into  one  existing 
regulation in future would require potential reopening of the other.  

Moreover, the legal basis for the mandatory transmission of the annual unadjusted GPG data does 
not  exist  so  far:  this  indicator  and  does  not  fit  in  the  scope  of  any  of  the  three  existing  legal 
frameworks.  Hence,  option  4  would  not  allow  developing  this  legal  basis  that  is  an  important 
request of stakeholders and is high in the policy agenda of the EU with the proposal of Directive on 
pay transparency, the EPSR and the SDG.   

In  addition,  while  a  large  set  of  policy  measures  could  be  implemented  in  each  domain,  e.g.,  the 
extension of coverage requested by stakeholders, high consistency and consolidation would not be 
ensured  across  the  different  domains  and  risks  of  divergences  in  national  implementations  would 
also increase. Indeed, the legal fragmentation of the 3 existing framework regulations makes it very 
difficult to achieve a coordinated and consistent approach when it comes to modifications. 

In  addition,  there  is  a  need  for  better  coordination  of  the  planning.  While  Regulation  530/1999 
ensures  an  alternation  of  SES  and  LCS,  and  LCI  and  JVS  regulations  foresee  quarterly 
transmissions  to  Eurostat,  a  full  synchronised  planning  including  GPG  is  needed.  Links  between 
LCI and LCS for providing annual estimates of labour costs based on indexes  as well as between 
the LCS and SES (and SES and GPG) for coherence of statistical concepts and quality reports for 
all data collections allowing a smooth repartition of the burden for NSIs would not be ensured. 

Finally,  the  undertaken  initiative  to  modernise  and  streamline  LMB  statistics  necessitates 
substantive  amendments  to  the  provisions  of  the  legislative  acts  currently  in  force  and  granular 
approach dealing with every regulation separately will be administratively highly inefficient.  

On  the  opposite,  merging  regulations  into  one  integrated  framework  would  foster  clarity  and 
consistency  for  all  stakeholders,  in  particular  the  national  statistical  institutes,  data  providers, 
institutional and policy users, researchers, students and EU citizens in general. It is the best way to 
ensure that data producers use the same concepts in the same manner across all LMB datasets. It is 
also the simplest and most transparent way to align LMB concepts on the related definitions from 
European Business Statistics or National Accounts.  

30 

 
 
 
Moreover,  the  flexibility  for  introducing  requirements  that  will  be  proved  to  be  feasible  (by  for 
instance  conducting  pilot  studies)  will  also  be  easier  to  manage  if  LMB  statistics  are  all 
consolidated in one single basic act. 

Finally,  as  LMB  data  collections  are  usually  collected  by  the  same  bodies  in  the  member  states, 
the integrated  framework  would  allow  a  better  balancing  and  controlling  of  the  burden  on 
respondents over time, including for future new needs to be implemented in the context of the new 
flexibility. 

Taking into account all these elements, option 4 has been discarded. 

The  features  and  differences  of  the  options  considered  for  the  analysis  of  their  impacts  are 
summarised in Table 6. 

Table 6.  Options 0 (baseline) as well as 1, 2 and 3 under a single new framework regulation  

main features and differences 

Cluster of measures  Option 0 
(baseline) 

GPG annual data 
collection 
Coverage 

No 

No 

No 

No 

Timeliness and 
Frequency 

Quality reporting, 
use of administrative 
data and innovative 
sources 
Emerging needs 

Option 1 

Option 2 

Option 3 

Compulsory 

Full implementation 

Full implementation 

Micro enterprises covered in 
SES (for main information)  
NACE Rev. 2 section O 
covered in SES and LCS. 
Full coverage for JVS. 

Timeliness improved but 
limited to LCI and slightly 
for SES. 
No increase of frequency of 
SES and LCS 
Full implementation 

Micro enterprises covered 
in SES (for all information) 
and LCS.  
NACE Rev. 2 section O 
covered in SES and LCS. 
Full coverage for JVS. 
Timeliness improved for 
LCI, significantly for SES 
and moderately for LCS.  
The frequency of SES and 
LCS is doubled 
Full implementation 

Voluntary 

Voluntary 
(timeliness 
only 

Voluntary  
(compulsory 
for GPG) 

No 

Voluntary 

Yes  

Yes 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? 

The  three  policy  options  are  assessed  using  a  partial  quantitative  assessment  of  the  efficiency  of 
the policy  options,  with  impacts  monetised  to  the  greatest  extent  possible,  based  on  the  available 
evidence. 

Moreover,  a  qualitative  assessment  is  carried  out  for  each  of  the  policy  options  covering 
the following criteria: 

  Effectiveness; 
  Coherence  with  the  overarching  objectives  of  EU  policy  and  consistency  with 

the proportionality principle; 

31 

 
 
 
  Efficiency; 
 

Impacts including on fundamental rights and wider social, environmental, digitalisation 
and on administrative burden of enterprises; 

o  By  its  nature,  statistics  can  only  indirectly  impact  fundamental  rights  and 
contribute to social, economic developments by allowing monitoring them.  
o  As  the  LMB  statistics  collects  information  on  businesses  it  contributes  to  an 

administrative burden on them related to data reporting although limited.  
o  Statistical processing is a beneficiary and contributor to digital development. 

For the qualitative assessment, a scoring approach is defined as indicated below. 

Scoring approaches used in the report 

The consistency of each policy option with the principle of proportionality is rated as 
‘Pass’, ‘Uncertain’ or ‘Fail’. 

The options have also been qualitatively scored against the criteria of effectiveness, 
coherence and efficiency Each option was scored against these three criteria using the 
following scoring system:  

Scoring system 

Level of impact 
Strong negative impact 

Slight negative impact 

No impact compared to baseline 

Slight positive impact 

Strong positive impact 

Score 
-- 

- 

0 

+ 

++ 

The baseline has been scored as ‘0’ against all three criteria (effectiveness, coherence and 
efficiency).  All other options have been scored relative to this baseline using the above 
scoring system. The options have also been scored relative to one another.  Thus, two or 
more options with a similar strength of impact against the same criterion have been given 
a tied score.    

The scores and the breakpoints between them are, to the extent possible, grounded in the 
evidence gathered from the consultation and desk research.  

Quantitative analysis of the options 

Policy  option  0  is  the  baseline  scenario.  The  costs  associated  with  this  option  are  therefore  an 
estimate  of  current  costs,  assuming  these  costs  would  remain  constant  over  10  years.  The  cost 
assessment  of  the  baseline  scenario  has  been  carried  out  based  on  the  evaluation  results.  It  is 
important to note that the baseline costs estimated as part of this Impact Assessment are the costs 
associated with the current legal framework. The baseline costs estimated include all costs currently 
incurred  to  produce  the  various  LMB  datasets  that  could  potentially  be  affected  by  the  policy 

32 

 
 
 
 
measures  and  options  proposed.  Datasets  not  regulated  and  voluntary  are  not  included  in 
the baseline costs. 

The  costs  assessed  for  policy  options  1,  2  and  3  are  expressed  in  comparison  with  the  baseline 
(policy  option  0).  These  only  estimate  the  additional  costs  associated  with  the  implementation  of 
each of the measures/actions required under each option, over and above the baseline situation, i.e. 
costs  that  would  be  incurred  in  any  option.  As  such,  total  costs  for  each  option  are  equal  to 
the costs reported for policy option 0 plus those reported for each other relevant option. 

The study supporting this impact assessment has been able to assess the  minimum costs expected 
for a number of cost items, in particular: 

  EC (Eurostat):  

-  one-off costs for amending the framework regulation and implementing regulations 
-  Recurring costs for monitoring compliance by MS. 

  MSs/NSIs 

-  One-off costs for adapting the existing data collections to the new requirements under the 

revised LMB framework regulation 
-  Recurring costs for data collections 
-  One-off cost to communicate the change 
-  Recurring costs for reporting to the EU 

There are other cost items and cost savings involved that the study could not ascertain, which 
include: 

  The costs of adapting IT systems to new regulations 
 

Indirect cost savings due to improved policymaking as a result of the changed framework 
regulation. 

The assessment of the costs for businesses is based on a detailed study conducted by Eurostat in 
cooperation with the compilers (NSIs and other national authorities in charge of LMB).  

Table 7 provides a high-level overview of the approximate costs. The assumptions are shown in 
Annex IV and V. 

33 

 
 
 
 
 
 
 
 
Table 7.  Overview of costs, in Euro 

Type of 
costs 

PO0 
Baseline 

PO1 Reliance 
on the 
voluntary 
nature of 
contributions 

PO2 High 
coverage, 
better 
timeliness and 
other measures 

PO3 Highest 
coverage and 
increased 
frequency 

EC/ESTAT 

Developing the 
framework regulation 
and amending 
implementing 
regulations 
Monitoring 
compliance 

MS/NSIs 
Adaptation and 
preparation for using 
the revised text of the 
LMB framework 
regulation 
Data collections 
Communicate the 
change 
Issuing guidance and 
training 
Reporting to the EU 

Businesses 

One-off 

Recurring 

One-off 

Recurring 

One-off 

One-off 

Recurring 

Costs for participating 
in surveys 

Recurring 

Totals 

0 

0 

0 

0 

0 

0 

0 

0 

0 

28,545 

35,682 

42,818 

8,182 

12,273 

13,909 

45,537 

91,075 

106,254 

66,814 

88,315 

7,081 

6,900 

3,259,423 

19,021,716 

88,315 

88,315 

110,394 

10,349 

110,394 

11,729 

92,365 

4,618,254 

38,002,583 

343,739 

8,225,765 

57,397,718 

34 

 
 
 
 
  
 
 
 
Benefits  such as potential  cost  savings or reductions  in  the administrative burden  associated with 
each policy option could generally not be quantified. This depends in particular on future progress 
in  IT  and  data  collection  techniques  (such  as  ‘web-scraping’)  which  have  not  been  implemented 
yet. These techniques are expected to decrease the LMB burden in the long run so that the estimates 
provided in this study should be taken as maximum amounts (caps). Estimates for the expected cost 
savings  would  be  severely  limited  and  hence  add  little  value.  In  order  to  enable  a  choice  to 
the policymaker  between  policy  options  0  to  3,  the  available  cost  estimates  and  the  qualitative 
assessments of the options are considered to be sufficient.  

Many benefits on the availability, accessibility and use of LMB data sets have different effects on 
stakeholder groups (data users), making them challenging to define, quantify or monetise.  

Analysis of the policy options 

An overview of the qualitative assessment for the four options retained for the  impact assessment 
has  been  carried  out.  It  starts  by  an  assessment  of  proportionality,  followed  by  assessments  of 
effectiveness,  efficiency  and  coherence.  A  detailed  scoring  of  the  policy  options  is  provided  in 
the Section 2 of Annex 3.  

6.1. 

Policy option 0 (baseline): No targeted EU action 

The  baseline  passes  the  criterion  on  consistency  with  the  proportionality  principle,  however  on 
form  of  action  (choice  of  instrument)  it  is  uncertain  whether  this  option  can  deliver  satisfactory 
achievement of the objective and effective enforcement.  

All  effectiveness,  efficiency  and  coherence  criteria  under  policy  option  0  score  ‘0’  to  enable 
meaningful comparisons with options 1, 2 and 3. For the baseline scenario there is no further EU 
action.  

35 

 
 
 
6.2. 

Policy option 1: Reliance on the voluntary nature of contributions 

Figure 8.  Intervention logic for option 1 

Under policy option 1, there will be limited mandatory changes at the EU level and a larger number 
of voluntary changes. The measures, however, generally represent a continuation of the status quo 
under the baseline.  

Policy  option  1  passes  the  criterion  on  consistency  with  the  proportionality  principle,  including 
choice of an instrument. This option scores “+” on effectiveness in all specific objectives. It scores 
“+” on impact on fundamental rights and social impact and is neutral “0” on impact on Sustainable 
Development Goals.  

The results of the consultation on cost and burden with the NSIs and the  further qualitative study 
showed that the introduction of a compulsory data collection on GPG would lead to an increase of 
costs of 34 % (+ 215 000 Euro) for this data collection. For the whole LMB, however, this means 
an increase of less than 1 % in total. The estimated increase in costs related to burden on enterprises 
would be negligible (less than 100 000 Euro). This is mainly linked to the fact  that the GPG data 
collection is based on the existing sources and the burden is mainly on the statistical authorities to 
compile the data and prepare quality report.  

This option would have limited effectiveness in addressing the problems identified with the current 
EU legal framework as, relying on national willingness, it would not ensure that improvements are 
implemented  Union-wide.  While  it  passes  the  proportionality  principle  simply  because  it  is 
a simplification  compared  to  the  existing  framework,  its  effects  are  modest  and  do  not  meet 
the expectations  for  a  general  review  of  LMB  legislation.  While  there  are  some  positive  social 
impacts,  the  overall  coherence  with  EU  policies  is  not  deemed  well-served  by  this  option,  thus 
making it sub-optimal.  

36 

 
 
 
 
In summary, this option would be somewhat more effective in addressing the problems identified 
with  the  LMB  framework  compared  to  the  baseline,  although  it  still  falls  short  from  users 
expectations identified through the LMB evaluation exercise. 

6.3. 

Policy option 2:  High coverage, better timeliness and other measures 

Figure 9.  Intervention logic for option 2 

As highlighted in the intervention logic, most of the drivers are addressed in option 2. It is therefore 
highly effective in achieving most of the policy objectives. In terms of coverage, option 2 does not 
foresee the extension of LCS to cover micro firms but extends SES to micro firms although only for 
main  information  (SES  2).  Option  2  also  offers  better  timeliness  but  the  frequency  remains 
unchanged  –  as  with  the  baseline  scenario  (4-yearly).  The  option  leaves  limited  gaps  with 
the identified set of problems and drivers. While it is anticipated that the increase in timeliness will 
allow for better research and evidence from SES and LCI, the frequency of LMB statistics would 
not increase although this issue was often mentioned by stakeholders. Whereas cyclical indicators 
(JVS  for  labour  shortages,  LCI  for  hourly  labour  costs)  are  provided  with  sufficient  frequency 
(quarterly), some users  would appreciate a shorter periodicity  for structural  data such as the  LCS 
and  the  SES.  Nevertheless,  option  2  would  also  cover  important  actors  and  segments  of 
the population  to  allow  for  better  research  and  policy  analysis.  This  option  also  introduces  new 
templates for the collection and quality reporting for the use of administrative data and innovative 
sources  as  well  as  more  alignment  in  terms  of  concepts  and  definitions  of  relevant  data  domains 
including national accounts and the European business statistics. 

The policy option 2 passes the criterion on consistency with the proportionality principle, including 
choice of an instrument. This option scores “++” on effectiveness related to specific objective 1.1 
“Adapting the regulatory framework to allow flexibility in meeting emerging needs” and 1.3 “To 
promote the use of innovative sources and methods of duly assessed quality”. It scores however “+” 
on specific objective 1.2 “To release more timely statistics”. On specific objective 2 “Improving the 
coverage of statistics to the whole economy and ensure exhaustive GPG data” option 2 scores “+” 

37 

 
 
 
 
and  on  objective  3  “Improving  the  consistency  with  related  statistical  domains”  it  is  assessed  to 
be“++”.  

Impact  on  fundamental  rights  and  on  Sustainable  Development  Goals  is  positive  “+”  and  social 
impact  “++”.  Indeed,  in  addition  to  the  improvements  related  to  the  gender  pay  gap  data,  the 
extension of the SES coverage to the micro firms and NACE Rev. 2 section O would allow better 
assessment of the low–wage earners and contribute to the monitoring of the directive on minimum 
wages adequacy. Option 2 scores “+” on coherence as it would address most of the shortcomings of 
the  baseline  in  terms  of  coverage  of  the  economy  and  answering  emerging  needs  and  further 
harmonisation of standards (definitions, concepts, templates for quality reports). A clear effort  on 
collecting these types of data would better ensure meeting overarching EU objectives. 

The  costs  for  compilers  and  time  burden  on  businesses  on  statistical  reporting  related  to  data 
collections  were  assessed  based  on  a  quantitative  survey  of  NSIs  and  Other  National  Agencies 
(ONAs) in charge of LMB statistics. This was complemented by a qualitative survey of the LAbour 
MArket  Statistics  (LAMAS)  working  group  carried  out  in  the  July-August  2022  and  the  study 
conducted for the purpose of evaluation and impact assessment. 

The  Table  8  provides  an  overview  of  the  increase  in  costs  for  NSIs  across  datasets  for  NSIs,  for 
policy option 2 

Table 8. 

Increase in costs of NSIs for policy option 2 

Total annual costs of 
baseline for NSIs (in 
EUR) 

Increase of NSI´s cost (in 
EUR) 

% Increase of total 
NSIs´costs  

JVS 
LCI 
LCS 
SES 
GPG 
Total LMB 

5,659,238 
9,318,641 
7,185,434 
7,386,671 
628,709 
30,178,693 

586,191 
865,516 
529,808 
1,511,227 
214,647 
3,707,389 

10% 
9% 
7% 
20% 
34% 
12% 

Overall, the increase of costs for NSIs is approximately. 12 % (EUR 3.7 million) of which SES is 
the  costliest  with  1.5  million  (20 %)  followed  by  LCI  with  close  to  0.9  million  (9 %).  Costs  for 
mandatory data collection on GPG are marginal. 

38 

 
 
 
 
 
 
 
The table below provides an overview of the increase in costs for businesses across datasets. 

Table 9. 

Increase in costs for businesses for policy option 2 

Total annual costs of 
baseline for businesses (in 
EUR) 

Increase of businesses cost 
(in EUR) 

% Increase of total 
costs of business  

JVS 
LCI 
LCS 
SES 
GPG 
Total LMB 

4,472,272 
12,001,564 
10,703,029 
16,079,802 
0 
43,256,667 

723,594 
11,935 
456,720 
3,426,005 
92,365 
4,710,619 

16% 
0.1% 
4% 
21% 
na 
11% 

Overall, the increase on  businesses amounts to  approximately EUR 4.7 million  (11 %), of which 
EUR 724,000 (16 %) for JVS, EUR 12,000 (0.10 %) for LCI, EUR 457,000 (4 %) for LCS, EUR 
3.43 million (21 %) for SES and EUR 92,000 for GPG. 

To summarize, option 2 would create a limited increase in burden, mainly due to the extending SES 
to  micro-firms.  The  costs  implied  (8.2  million)  represent  a  negligible  part  (less  than  1%)  of  the 
costs European Business Statistics (annual  total costs of around 980 million Euro in 2017)29. The 
real amounts will be even smaller as ten NSIs have already extended SES to micro-firms. Therefore 
option 2 scores “++” on efficiency.  

https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1342-European-business-statistics-FRIBS-

29 
_en  

39 

 
 
 
 
 
                                                 
6.4. 

Policy option 3: Highest coverage and increased frequency 

Figure 10.  Intervention logic for policy option 3  

Option  3  fully  captures  all  important  business  actors  and  allows  for  the  monitoring  of  socio-
economic  phenomena  across  the  whole  EU  economy.  It  leaves  no  meaningful  gaps  with  the 
identified set of problems and drivers. 

The extension of both the SES and LCS scope to micro-firms would also fill in  the existing data 
gaps for this part of the economy. The addition of new data, improvements in timeliness, increased 
frequency of SES and LCS and alignment of definitions would result in more complete full filling 
users’ needs leading to better evidence-based policy making with issues such as discrimination and 
inequalities  being  better  covered  by  European  official  statistics.  All  these  improvements  would 
significantly enhance the scope and depth of policy research on earnings, labour costs and labour 
shortages. 

The policy option 3 passes the criterion on consistency with the proportionality principle, including 
choice of an instrument. However, the increased frequency and timeliness entail sustained further 
efforts  that  may,  strictly  speaking,  not  all  be  necessary  to  meet  objectives  of  the  initiative. 
Therefore  the  option  is  uncertain  to  pass  on  the  criterion  of  costs  being  commensurate  with  the 
objective of the initiative.  

This option scores “++” on effectiveness related to specific objective 1.1 “Adapting the regulatory 
framework to allow flexibility in meeting emerging needs”, objective 1.2 “To release more timely 
statistics”  and  1.3  “To  promote  the  use  of  innovative  sources  and methods  of  duly  assessed 
quality”. 

40 

 
 
 
 
On  specific  objective  2  “Improving  the  coverage  of  statistics  to  whole  economy  and  ensure 
exhaustive  GPG  data”  option  3  scores  “++”  and  on  objective  3  “Improving  the  consistency  with 
related statistical domains” it is assessed to be“++”.  

Impact  on  fundamental  rights,  social  impact  and  on  Sustainable  Development  Goals  is  highly 
positive “++”.  

Option 3 scores “+” on coherence as it would address most of the shortcomings of the baseline in 
terms  of  coverage  of  the  economy  and  answering  emerging  needs  and  further  harmonisation  of 
standards  (definitions,  concepts,  templates  for  quality  reports).  A  clear  effort  at  collecting  these 
types of data would better ensure meeting overarching EU objectives. 

The table below provides an overview of the increase in costs for NSI’s across datasets, for policy 
option 3 

Table 10.  Increase in costs for NSIs for policy option 3 

Total costs of baseline for 
NSIs (in EUR) 

Increase of NSI´s cost (in 
EUR) 

% Increase of Total 
costs  

JVS 
LCI 
LCS 
SES 
GPG 
Total LMB 

5,659,238 
9,318,641 
7,185,434 
7,386,671 
628,709 
30,178,693 

2,198,958 
1,379,390 
8,348,942 
7,409,460 
1,658 
19,338,408 

39% 
15% 
116% 
100% 
0% 
64% 

The  total  cost  of  NSIs  as  reported  in  the  Eurostat’s  costs  and  burdens  study  suggests  an  overall 
increase of around + €19 million (+64%) of LMB statistics for policy option 3 as compared to the 
baseline. The higher increase would be for LCS 8.3 million (116 %), followed by SES (100%, +7.4. 
million).  

The table below provides an overview of the increase in costs for businesses across datasets. 

Table 11.  Increase in costs for businesses for policy option 3 

Total costs of baseline 
for businesses (in EUR) 
4,472,272 
12,001,564 
10,703,029 
16,079,802 
0 
43,256,667 

JVS 
LCI 
LCS 
SES 
GPG 
Total LMB 

Increase of businesses cost (in 
EUR) 

% Increase of total 
costs of businesses  

2,715,790 
11,935 
15,187,811 
20,087,048 
0 
38,002,583 

61% 
0% 
142% 
125% 
0% 
88% 

Similarly to NSIs, businesses would also face a significant increase in costs, In monetary terms, 
policy option 3 would increase costs for businesses of an estimated EUR 38 million, of which EUR 
12,000 for LCI, EUR 2.7 million (61%) for JVS, EUR 15.2 million (142%) for LCS and EUR 20 

41 

 
 
 
 
 
 
million (125%) for SES. Overall this would mean 88% increase in costs for businesses compared to 
the baseline.  

Option  3  would  create  much  higher  costs  for  NSIs  and  a  significant  increase  in  the  burden  for 
respondents. Therefore it scores “+” on efficiency. 

Options 1, 2 and 3 are to the same extent likely to have a rather neutral indirect  environmental 
impact when considering the European Green Deal and is not different from the baseline. There are 
no  to  negligible  impacts  on  competitiveness,  research  and  innovation  and  all  three  options  are 
fully in line with the principle of “Do No Significant Harm”. All those options are also fully in 
line  with  the  principle  of  digital-ready  policymaking:  digitalization  is  at  the  core  of  statistical 
processes within the European Statistical System (‘digital by default’). The specific measures will 
be  implemented  through  digital  techniques  (web-forms,  digital  processes,  IT  programmes)  with 
a view to minimize the costs for NSIs and burden on respondents for all options.  

42 

 
 
 
 
 
7.  HOW DO THE OPTIONS COMPARE? 

Table12 below summarises scoring for all options assessed.  

Table 12.  Summary assessment table 

Consistency with the 
proportionality 
principle  (Pass / 
uncertain / fail) 

Assessment 

Does the option go beyond what is necessary to satisfactorily 
achieve the objectives? 

Is the scope of the option limited to aspects that Member States 
cannot achieve satisfactorily on their own, and where the Union 
can do better? 

Are costs for the Union, national governments, regional or local 
authorities, economic operators or citizens commensurate with 
the objectives of the initiative? 

Is the form of action (choice of instrument) as simple as possible 
and coherent with a satisfactory achievement of the objective and 
effective enforcement? 

SO1.1: Adapting the regulatory framework to allow flexibility in 
meeting emerging needs 

SO1.2: To release more timely statistics 

SO1.3: To promote the use of innovative sources and methods of 
duly assessed quality 

Effectiveness (-- to 
++) 

SO2: Improving the coverage of statistics to whole economy and 
ensure exhaustive gender pay gap data  

SO3: Improving the consistency with related statistical domains  

Impacts on fundamental rights including the promotion of 
equality 

Social impacts 

Sustainable Development Goals 

Coherence 

Coherence with 
overarching 
objectives of EU 
policy (-- to ++) 

Efficiency 

Efficiency 

Score 
Option 
2 
Pass 

Option 
3 
Pass 

Option 1 

Pass 

Pass 

Pass 

Pass 

Pass 

Pass  Uncertain 

Pass 

Pass 

Pass 

+ 

+ 

+ 

+ 

+ 

+ 

+ 

0 

- 

0 

++ 

+ 

++ 

+ 

++ 

+ 

++ 

+ 

+ 

++ 

++ 

++ 

++ 

++ 

++ 

++ 

++ 

+ 

++ 

+ 

All options presented in the impact assessment are largely in line with the first judgement criteria 
on whether the option go beyond what is necessary to satisfactorily achieve the objectives because 
they are limited to what is necessary to satisfactorily achieve the objectives. They do not attempt to 
address any additional problems beyond those defined in the problem definition.  

Moreover, policy options 1, 2 and 3 clearly pass the criterion the extent to which each policy option 
is  limited  to  aspects  that  cannot  be  achieved  satisfactorily  by  the  Member  States  on  their  own. 
Ensuring consistency in the geographic, temporal and thematic breakdowns of LMB statistics at EU 

43 

 
 
 
 
level  requires  EU  intervention  and  cannot  be  left  solely  to  the  Member  States  (necessity  and 
subsidiarity tests are passed).  

The  third  criteria  concerns  the  extent  to  which  the  costs  (for  the  Union,  national  governments, 
regional or local authorities, economic operators or citizens) are commensurate with the objectives 
of the initiative. Based on the above assessment on cost and burden, all policy options are judged as 
having costs that are commensurate with the objectives of the initiative and passing the test. Even 
policy option 3, which would be the costliest option to implement, is judged as passing this test.  

On  the  fourth  criterion,  as  to  whether  the  form  of  action  (choice  of  instrument)  is  as  simple  as 
possible all options pass the test for the simple reason that a new framework regulation – required 
for all options  –  would be a clear simplification compared to  the baseline. While the benefits  for 
option 1 are cancelled out by its inherent inefficiencies, the form of action is still the simplest one 
possible. 

Effectiveness 

Option  1  would  aim  to  increase  effectiveness  of  the  existing  framework  by  considering  elements 
that were not part of the existing regime. While these are voluntary in nature the mere consideration 
of these needs, and in responding to problems, this option compares favourably with the baseline. 
Consistency  with  related  statistical  domains  would  be  improved  somewhat,  though  the  voluntary 
nature of the regime would greatly mitigate these potential benefits.  

The impact  on fundamental rights  is  not  fully neutral.  Given  on the  compulsory collection of the 
gender pay gap in particular the impact on fundamental rights of collecting these types of data will 
be partially served through this option.  

Both option 2 and 3 would help to significantly improve the depth of statistics by further adapting 
the framework to evolving needs, sources and methods by considering numerous elements that are 
not part of the existing regime.  

The  coverage  of  statistics  will  be  improved  in  particular  for  GPG  data,  extending  SES  to  micro 
firms, better coverage of the economy through including NACE Rev. 2 section O “administration”, 
new  elements  of  quality  reporting  allowing  assessment  of  quality  of  innovative  or  administrative 
data sources, aligned definitions and concepts, and addressing emerging needs. 

This together with improvements in LCI timeliness would further contribute to modernising social 
statistics. 

In  terms  of  social  impacts  there  are  positive  effects  in  both  option  2  and  3,  with  the  mandatory 
collection  of  data  on  gender  pay  gap  and  on  additional  variables  and  breakdowns  to  be  further 
detailed in the secondary legislation. The mandatory collection of information on employees  (e.g. 
carer  breaks)  would  expand  the  range  of  possible  analyses  on  segregation,  subject  to  legal 
constraints on privacy and data protection. 

All  three  options  have  a  rather  neutral  indirect  environmental  impact  when  considering  the 
European Green Deal and not different from the baseline. 

44 

 
 
 
Overall  option  3  compares  favourably  to  option  1,  and  is  more  ambitious  than  option  2  when  it 
comes to the frequency of SES and LCS. The timeliness and frequency improvements do match an 
expressed need of some users and thereby it makes the LMB more effective than under option 2. 

Coherence 

In terms of coherence both option 2 and 3 are expected to provide strong positive impact. On the 
other hand, option 1 would not address all the shortcomings of the baseline (option 0) in terms of 
the  somewhat  more  complex  nature  of  the  various  existing  datasets,  the  divergence  of  outcomes 
due to the voluntary nature of many of the measures and thereby the rendering of coherence in EU 
policies somewhat less favourable than possible.  

Both option 2 and 3 would address most of the shortcomings of the baseline in terms of coverage, 
answering emerging needs and further harmonisation of standards (definitions, concepts, templates 
for  quality  reporting).  It  is  anticipated  that  these  policy  options  would  align  LMB  statistics  with 
other  EU  flagship  initiatives  such  as  the  EP  and  Council  Directive  on  minimum  wages, 
Commission proposal for a Directive on pay transparency and the principle 6 of the European Pillar 
of Social Rights. 

Efficiency 

All  options  would  incur  higher  costs  compared  with  the  current  LMB  framework  taken  as  the 
baseline. Costs in policy option 1 are mainly for NSIs and related to the GPG. Costs of option 2 (for 
Eurostat, NSIs and enterprises) are mainly driven by the costs of producing the statistics on wages 
and job vacancies on the extended population of enterprises, to a lesser extent on labour costs and 
the gender pay gap. In terms of impacts for respondents, option 2 would be far less burdensome (+ 
11% increase in costs for businesses) than Option 3 (+88%). 

Therefore,  although  option  3  presents  the  highest  effectiveness,  this  comes  at  a  high  price  and 
option 2 scores far better in terms of efficiency.  

Potential obstacles that might be encountered for an effective implementation 

The problem  of the  LMB statistics currently  lies in  non-legally binding collections (at  EU level), 
particularly  for  micro  firms.  For  instance,  12  member  states  (and  2  EFTA  countries)  transmitted 
those data in the latest SES 2018. Section O is covered in the SES by 24 member states and by 22 
member states in LCS. Hence, the main impact in terms of extension of the coverage will be for the 
data  collection  of  the  SES  on  micro-firms,  i.e.,  the  effort  will  be  for  Belgium,  Denmark  Greece, 
France  Croatia,  Italy,  Luxembourg,  Hungary  Malta,  Austria,  Poland,  Portugal,  Romania,  Finland 
and  Sweden.  In  job  vacancy  statistics,  most  member  states  already  achieve  a  full  coverage  of 
economy. However, data for three of them (Denmark, France  and  Italy)  are not  fully  comparable 
with those of the rest of the EU. In both France and Italy, public institutions are not covered within 
the sectors of public administration, education and human health (NACE Rev. 2, sections O, P and 
Q).  Furthermore,  France  only  includes  units  with  10  employees  or  more  whereas  Denmark  only 
covers units within the business economy (NACE Rev. 2, sections B-N). 

45 

 
 
 
8.  PREFERRED OPTION 

8.1. 

PREFERRED OPTION 

Policy option 2 has been identified as the most effective option, which addresses the needs of data 
users and providers in  the most cost-efficient  way.  In the online  workshop with  stakeholders this 
option was the preferred option. Although data users would like to  see more ambitious proposals 
such as option 3, participants in the online workshop insisted that the selected option be realistic in 
terms  of  what  can  be  achieved  with  Member  States  in  the  current  context  of  cost  and  burden 
limitation  and  what  could  be  possibly  accepted  for  implementation  by  the  EU  statistical 
community. All options ensure proportionality. Although option 3 is the best performing option in 
terms of effectiveness, it is also the most expensive and causes the highest burden on enterprises. 
According to data providers, the implementation of option 3 would also raise serious difficulties on 
the field. The preferred option is therefore option 2. 

8.2.  REFIT (simplification and improved efficiency) 

REFIT: Simplification and improved efficiency 

Options  1,  2  and  3  would  require  a  new  framework  regulation.  This  entails  integrating  the  3 
existing framework regulations for LMB into one single basic act.  

The favoured option (option 2), will lead to simplifications and improved efficiency through three 
main channels: 

a)  Merging  the  existing  three  framework  regulations  into  one  single  legal  act.  A  single 
framework  regulation  will  clearly  set  the  scope  of  LMB  statistics  and  underline  their  common 
nature  (collected  from  businesses)  and  purpose  (to  inform  about  developments  in  EU  labour 
markets).  Each  concept  will  be  defined  only  once  and  thus  fostering  consistency  (also  in  future 
updates)  and  sparing  users  cumbersome  cross-references.  Moreover,  at  the  member  states  level, 
a single  and  coherent  framework  regulation  will  facilitate  use  of  the  same  tools  for  different 
purposes and limit consequently data collections and burden. Similarly, it will facilitate the use of 
administrative  or  innovative  sources  as  the  discussions  with  data  owners  will  focus  on  the  same 
concepts  and  finding the best  source for them instead of having to repeat  the same exercise with 
different  concepts,  building  on  different  sources  and  delaying  the  decrease  of  the  burden  on 
businesses by using other / new sources. 

b)  Fostering  the  use  of  alternative  administrative  sources  and  modern  digital  techniques, 
including  automatically  transferring  payroll  data  and  web  scrapping,  which  will  play  a  role  in 
mitigating the burden on enterprises in  general  and SMEs in particular. This may be achieved by 
extracting data on earnings and labour costs from payrolls and job advertisements from the internet. 
It  is  expected  that  new  administrative  or  innovative  data  collections  will  also  help  covering 
emerging needs.  

c) Limiting collection of variables on apprentices in the LCS only from those countries where 
they represent a sizeable share (more than 1%) of all employees; 

46 

 
 
 
The legislation will empower the Commission to adapt statistical requirements with implementing 
or  delegated  acts.  Secondary  legislation  will  cover  technical  details  related  to  periodicities, 
reference  periods,  description  of  variables,  modalities,  statistical  classifications  and  data 
breakdowns,  precision  targets,  the  metadata  to  be  transmitted  as  well  as  on  the  content  and  the 
deadlines  for  transmission  of  the  quality  reports.  These  instruments  are  expected  to  be  used  for 
covering also future emerging needs. 

Option 3 also entails the above simplifications but would extend the SES data collection to micro-
enterprises for all variables. This is not the case for option 2 that limits this future data collection on 
micro-enterprises  to  a  core  set  of  key  variables,  most  of  which  are  available  from  administrative 
sources therefore simplifying as much as possible the extension of scope.  

By  contrast,  option  1  may  not  lead  to  simplification  and  efficiency  gains  if  different  choices  are 
made across LMB datasets, a clear risk due to the non-harmonised and uncoordinated nature of this 
option. 

For the above reasons, only options 2 and 3 would pass the REFIT test as they would both improve 
the  efficiency  of  evidence-based  policymaking,  including  through  enhanced  possibilities  for 
comparative research across member states. Nevertheless, option 2 would come first (++ against + 
for option 3) as it refrains  from  increasing the frequency  of labour cost  and structure of earnings 
surveys, thus bringing lower costs and larger efficiency gains. 

At the same time, the additional measures added under the options, in particular options 2 and 3, 
can  also  require  a  slight  additional  need  for  follow-up,  reporting  (more  frequent  and  timely  data 
collection) and enforcement. Nevertheless, it is expected that some  cost saving could be made by 
reducing the current administrative burdens borne by both the Commission (Eurostat) and NSIs.  

The table below sets out a qualitative analysis of the possible simplifications brought about by this 
initiative. The stakeholder group benefiting from these savings is specified in the final column of 
the table.   

REFIT Simplification and improved efficiency 
Option  Description  

1 

2 

3 

Improved efficiency in evidence-based policymaking, 
alignments of concepts and definitions 
As for 1, with the addition of: 
Marginally reduced costs associated with new templates for 
quality reporting, possibility of using innovative data sources.  
Improved efficiency of comparative research 
As for 2, with the addition of: 
Further improvements in the efficiency of evidence-based 
policymaking (Due to higher frequency for LCS and SES and 
new variables on wage determinants)  
Even further improvement of efficiency in comparative 
research (same reasons) 

Impacts by 
group  
MS, COM 

Eurostat, 
enterprises 
Data users 

COM, MS 
Data users 

47 

 
 
 
 
 
 
8.3.  Application of the ‘one in, one out’ approach  

No  burdens  on  citizens  will  be  caused  by  the  initiative  as  it  concern  statistical  collections  on 
businesses.  

For  businesses  as  explained  in  the  SME  test,  only  a  small  subset  of  businesses  are  required  to 
produce the datasets under LMB (sample surveys, i.e. only the very limited number of businesses 
selected in the sample), even under options 2 and 3.  
While  the  specific  information  demands  are  higher  for  option  3,  the  total  burden  on  enterprises 
remains negligible for option 1 and 2, higher for option 3. 

8.4. 

SME test  

SMEs represent around 85% of new jobs in Europe and are hugely important to the EU economy.  

The  four  steps  of  the  SME  Test  are  set  out  below,  explaining  the  assessment  carried  out  and 
estimated impacts on SMEs of the policy option 2. 

8.4.1.  SME Test: four steps 

Step 

IA approach taken, outputs and 
mitigation 

Estimated outcome/results 

Identification 
of affected 
businesses 

The initiative is proposing to extend the 
scope of the four-yearly structure of 
earnings survey (SES) to a subsample 
of microenterprises. Those are the 
Small and Medium Sized Enterprises 
with less than ten employees. 
Enterprises employing 10 persons or 
more are already in the SES sample.  
This extension does not concern 
Bulgaria, Czechia, Germany, Estonia, 
Ireland, Spain, Cyprus, Latvia, 
Lithuania, Netherlands, Slovenia, and 
Slovakia that already provide data for 
firms employing one to 9 persons. 
Hungary and Finland cover firms with 
more than 5 employees. 
In the preferred option, the SES would 
still take place with a four-yearly 
frequency. 

Only the sampled microenterprises will 
be affected. For countries collecting 
SES data on enterprises with 1 to 9 
employees, the number of enterprises 
in this category in the sample represent 
1.5% of the whole population of 
SMEs.  
If all countries had to start transmitting 
data for the enterprises with 1 to 9 
employees the EU sample would need 
to be extended by the same rate.  
However, if we account for the fact 
that 10 countries already cover micro-
firms (+ 2 partly), which represent 
together 32% of the EU population of 
SMEs, the increase would be 1% 
(1.5% × 68%), every four years. 
Moreover, in most cases, the micro-
firms concerned by the extension of the 
SES scope would not have any 
response burden as only core SES 
variables will be requested, which are 
normally available from administrative 
registers. 

48 

 
 
 
 
Following no replies from the direct 
consultation of the SME, information 
coming from the NSIs is used for 
assess the impact of the proposal on 
the SMEs.  

Consultation 
of 
stakeholders 

SME 

To ensure that the direct views of SMEs 
are captured and information is collected 
on the cost and burden on SMEs, 
particularly micro-enterprises for the 
different policy options, the consultant 
(ICF) has tried to collect information 
from different sources: 
SME Europe was contacted and the 
organisation circulated request for data 
collection among their members 
Local network contact points of 
Enterprise Europe were contacted in the 
following Member States: BE, BG, HR, 
IT, ES, NL, RO, FR, DE, SK, LV 
The ICF used a sample from the Orbis 
database to reach out to ten micro-
enterprises from: CZ, EL, ES, IT,  PL, 
SK 
In addition during workshops two 
organisations expressed interest to help 
facilitate data collection from micro-
enterprises: Confederation of Danish 
Employer and the Austrian Federal 
Economic Chamber. 
The Confederation of Danish Employer 
liaised with its members and provided 
four contact details to SMEs from which 
one organisation responded to 
questionnaire. All other sources resulted 
in no responses from SMEs. 
The study team received one reply from 
a representative industry association, but 
they declined carrying out an 
assessment.   

Measurement 
of the impact 
on SMEs 

Information on the burden on enterprises 
was also assessed by the NSIs in the cost 
and burden study.  
This showed that the effects are limited 
due to the low number of businesses 
selected in the sample and the 
simplification of the questionnaire 
addressed to micro-enterprises. In 
particular, only core variables will be 
collected most of which are available 
from administrative registers. 

The results of the study done with the 
NSIs showed that the initiative will 
cause a median increase in the time 
spent by all responding units 
(enterprises with one and more 
employees) of around 16%, every 
four years.  
Considering that SMEs represent 86% 
of the SES sample, on average, this 
means that the total time spent by all 
responding SMEs will increase by 

49 

 
 
 
16% × 86% = 14 %.  
This does not account for the fact that 
10 Member States already provide 
SES data for micro-enterprises and 2 
(Hungary and Finland) do it partly. 
Altogether, these countries account 
for almost one third (32%) of the SES 
sample of SMEs, EU wide. 
With an average sampling rate of 
2.5% for SMEs, we estimate that the 
burden increase for SMEs caused 
by the extension of SES to micro-
firms amounts to 0.24% (2.5% × 
14% × 68%) of the current average 
burden, for the whole population of 
SMEs, every four years.  

Thanks to the simplification of the 
LCS data collection on apprentices, 
the total time spent by the sampled 
SMEs in filling LCS questionnaires 
will be reduced by 27% (6/22) for all 
EU Member States except Germany, 
Denmark, France, Italy and Austria. 
The latter countries represented 34% 
of the population of EU SMEs, in the 
LCS 2016 sample. 
Estimating the LCS burden from the 
number of variables collected, we 
conclude that the LCS simplification 
would reduce the burden by 18% 
(27% × 66%), every four years for the 
sampled enterprises. 
Taking 4% as a lower bound for the 
LCS sampling rate, the burden 
reduction for the whole population of 
SMEs would be at least 0.7% (18% × 
4%), every four years. 
This compares with the burden 
increase on SMEs caused by the SES 
extension to micro-firms (+0.24%). 
Under the favoured option (option 2), 
the LMB review would therefore have 
no net impact on the burden for 
SMEs. 
The additional decreases in the SME 

Assessment 
of alternative 
mechanisms 
and 
mitigating 
measures 

The SES questionnaire for 
microenterprises will be limited to the 
main information (core variables) most 
of which are already available from 
administrative sources. 
Another simplification proposed under 
the LMB review consists in limiting the 
collection of labour cost survey data on 
apprentices to countries where they 
represent less than 1% of the total 
number of employees. This would 
simplify the LCS questionnaire where 
6 out of 22 variables (excluding the 
derived totals) would become 
voluntary, for all EU Member States 
except Germany, Denmark, France, 
Italy and Austria.  
Following the subsidiarity principle, 
countries are free to use data collection 
method chosen nationally and being the 
most effective in terms of costs and 
burden. In addition, the extension of 
the population could also take place by 
reallocation of the total SES sample. 
That means, given the precision of 
information collected is of the same 
quality, NSIs will be free to decrease 
the number of SMEs employing 10 and 
more persons to compensate the 
extension to micro enterprises. 

50 

 
 
 
burden obtained through a 
reallocation of the sample (between 
SMEs and larger firms) was 
impossible to estimate due to different 
sampling schemes and various data 
collection methods used in the 
countries, according to the 
subsidiarity principle. 

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? 

Monitoring and evaluation form an integral part of the policy cycle and must be undertaken through 
the implementation,  application and review stages of the  LMB initiative. The performance of the 
new  LMB  framework  should  be  monitored  and  evaluated  in  relation  to  its  operational  objectives 
(shown  in  the  table  below).  The  next  sections  briefly  describe  the  main  considerations  for 
monitoring and evaluation at each stage of the policy cycle.  

Implementation stage 

The  choice  of  approach  remains  open,  whether  largely  voluntary  data  collection  under  the  LMB 
framework or different forms of mandatory changes to the LMB framework.   

During  the  implementation  phase  of  the  new  legal  framework,  the  Commission  (Eurostat)  will 
continue  organising  regular  expert  group  meetings  with  partner  NSIs  in  the  ESS  to  discuss  and 
clarify any issues that may arise, continuing a long-standing history of good and close cooperation 
between  Eurostat  and  its  ESS  partners  on  technical  and  statistical  matters.  This  includes  diligent 
joint preparation of key implementing acts regulating the detailed new statistical data and metadata 
requirement,  which will  be of central  interest  to  both  statistics users and  producers.  For instance, 
Eurostat can establish topical task forces to address specific technical challenges in achieving the 
objectives  of  the  new  legislation.  The  implementation  stage  is  planned  to  conclude  with  a  first 
evaluation  focussing  on  the  implementation,  functioning  and  initial  impacts  of  the  new  legal 
framework. To obtain sufficient information on the performance, this evaluation is planned within 
three  to  five  years  after  the  entry  into  force  of  the  new  legal  framework,  in  line  with  better 
regulation advice that evaluations should have access to at least three full years of data. 

A monitoring and evaluation clause is normally included in any new, or amended, legislative act to 
facilitate the collection of the necessary information.  

Application stage 

During  the  application  stage,  the  Commission  (Eurostat)  plans  to  undertake  an  evaluation  of  the 
functioning  and  impact  of  the  legislation  every  three  to  five  years.  The  following  table  provides 
some  suggestions  on  potential  indicators  for  monitoring  the  effectiveness  of  the  LMB  initiative 
against its objectives. It also indicates some of the data sources that might be used.   

It will be important to ensure that the indicators can be measured through methods and sources that 
are easily available and credible. Eurostat’s user satisfaction survey and more targeted surveys (e.g. 

51 

 
 
 
among NSIs) could be relevant sources of evidence. Quality reports, annual compliance assessment 
exercises  are  also  important  tools  for  this  purpose  in  the  European  Statistical  System.

52 

 
 
 
9.1.1.  Possible key performance indicators, targets and data sources for operational objectives  

Operational 
objectives 
1.1. LMB addresses 
emerging needs 
(depending on the 
option) 

1.2. Datasets are 
provided in a timely 
and frequent manner 

Specific 
objective 
1. Adapting 
the regulatory 
framework to 
allow 
flexibility in 
meeting 
emerging 
needs, to 
release more 
timely 
statistics and 
to promote the 
use of 
innovative 
sources and 
methods of 
duly assessed 
quality 

Monitoring indicators 

MI 1.1.1 Number of Member States providing 
new voluntary/mandatory variables in SES 
MI 1.1.2 Number of Member States providing 
new voluntary/mandatory breakdowns in JVS 
MI 1.1.3 Number of Member States providing 
new voluntary/mandatory variables in LCI 
MI 1.2.1 Number of Member States providing 
SES data) in T+16 months / T+11 months 

MI 1.2.2 Number of Member States providing 
LCS data in T+15 months  

MI 1.2.3 Number of Member States providing 
LCI at T+45 days for large ‘flash’ countries (no 
NACE breakdown) 
MI 1.2.4 Number of Member States complying 
with the increased frequency of SES (bi-annual) 
between the (bi-annual) LCS years 
MI 1.2.5 Number of Member States complying 
with the increased frequency of LCS (bi-annual) 
between the (bi-annual) SES years 

Current 
benchmarks 
N/A 

7 

N/A 

1 

N/A 

8 (pilot 
data) 

N/A 

N/A 

Data sources  

Targets 

Data received via Edamis 

All MS 

Data received via Edamis 

All MS 

Data received via Edamis 

All MS 

Data received via Edamis  
Eurostat annual compliance 
assessment 
Data received via Edamis  
Eurostat annual compliance 
assessment 
Data received via Edamis  
Eurostat annual compliance 
assessment 
Data received via Edamis  
Eurostat annual compliance 
assessment 
Data received via Edamis  
Eurostat annual compliance 
assessment 

All MS 

All MS 

9 MS 

All MS 

All MS 

53 

 
 
 
1.3. The legal 
framework is 
sufficiently flexible to 
adapt as users’ needs 
evolve 

MI 1.3.1. Proportion of users who agree that, 
overall, Eurostat’s LMB data meet their needs 
(broken down by type of user, e.g. policymaker, 
academic, media, commercial) 

65 % (value 
for all users 
coming 
from the 
PC) 

MI 1.3.2. Extent to which Eurostat and 
Commission officials agree that it is possible to 
adjust the legal framework to meet users’ evolving 
needs 
MI 1.4.1 Number of Member States providing 
information about the use of administrative and 
innovative data sources 

N/A 

N/A 

Eurostat User Satisfaction 
Survey, 
Targeted surveys with 
representatives from Eurostat 
and Commission statistical 
correspondents 
Targeted surveys with 
representatives from Eurostat 
and Commission statistical 
correspondents 
Quality reports received in 
the metadata handler 

80 % 

80 % of 
satisfied 
policy users 

All MS 

MI 2.1.1 Number of MS providing annual GPG 
data  
MI 2.2.1 Number of MS providing SES data for 
microenterprises 
MI 2.2.2 Number of MS providing SES data for 
NACE Rev. 2 section O 
MI 2.2.3 Information on earnings for all economy 
published for EU/EA aggregates 

25 

12 

24 

Data received via Edamis 

All MS 

Data received via Edamis 

All MS 

Data received via Edamis 

All MS 

N/A 

Eurobase 

All tables 
provide 
aggregates 
for EU and 
EA  

54 

1.4. Quality reports 
are provided and 
administrative and 
innovative data 
sources are 
documented 
2.1. GPG data made 
compulsory 
2.2. SES coverage 
extended to micro 
enterprises and NACE 
Rev. 2 section O 

2. Improving 
the coverage 
of statistics to 
the whole 
economy and 
ensure 
exhaustive 
GPG data 

 
 
 
2.3. LCS coverage 
extended to micro 
enterprises and NACE 
Rev. 2 section O 

2.4. JVS coverage 
extended to micro 
enterprises and NACE 
sections B to S 
3.1. Concepts are 
further aligned and 
definitions match 
relevant domains  

MI 2.3.1 Number of MS providing LCS data for 
microenterprises 

MI 2.3.2 Number of MS providing LCS data for 
NACE Rev. 2 section O 
MI 2.4.1 Number of MS providing JVS data for 
microenterprises 
MI 2.4.2 Number of MS providing JVS data 
covering NACE sections B to S 
MI 3.1.1 Extent to which concepts and definitions 
are applied in practice 
MI 3.1.2 Users’ views on the consistency of 
concepts and definitions across datasets 

3. Improving 
the 
consistency 
with related 
statistical 
domains 

11 

22 

26 

24 

Data received via Edamis 

All MS 

Data received via Edamis  

All MS 

Data received via Edamis  

All MS 

Data received via Edamis  

All MS 

N/A 

Quality reports 

Targeted surveys with 
representatives from Eurostat 
and Commission statistical 
correspondents. 

31 % (value 
for all 
stakeholders 
coming 
from the 
PC) 

All MS 

70 % 

55 

 
 
 
 
ANNEX 1: PROCEDURAL INFORMATION 

1.  LEAD DG, DECIDE PLANNING/CWP REFERENCES 

Lead DG 

Eurostat 

PLAN/2021/1202430 

Decide 
Planning 

CWP reference 

2.  ORGANISATION AND TIMING 

After political validation of the LMB initiative in November 2021, an interservices steering group 
(ISG)  chaired  by  Eurostat  and  composed  of  representatives  of Commission  DGs31  was  set  up  to 
supervise  the  progress  on  the  combined  evaluation  and  impact  assessment  including  stakeholder 
consultations. The ISG met 5 times to discuss this evaluation SWD: 

Meeting date 

Topics discussed 

11/11/2021 

Background information on LMB statistics and need for review 

Call for evidence 

Draft consultation strategy 

Draft  terms  of  reference  of  a  tender  for  a  study  supporting  the 
evaluation and impact assessment  

Draft  Public  Consultation  (PC)  questionnaire  (launch  of  written 
consultation) 

28/04/2022 

Presentation of the progress on PC 

Presentation of the work plan and consultant 

Intervention logic 

Draft evaluation matrix 

13/07/2022 

Presentation of the results of the public consultation 

Presentation of the interim report from the consultant 

Proposed measures for the impact assessment 

21/10/2022 

Presentation of the draft SWD on consultation synopsis  

30 https://intragate.ec.europa.eu/decide/sep/?view-dossier-details-id=DORSALE-DOSSIER-2021-24018 

31 ECFIN, EMPL, JUST, JRC, RTD, SG and SJ 

56 

 
 
 
 
                                                 
Presentation 
the 
comments/endorsement  

of 

draft 

SWD 

on 

evaluation 

for 

Problem definitions and drivers for the assessment 

2/12/2022 

Presentation of the main changes in the draft SWD on evaluation for 
approval  

Presentation  of  the  draft  SWD  on  impact  assessment  for  comments 
and forthcoming endorsement 

13/03/2023 

Revised draft SWD on impact assessment for endorsement of changes 
addressing the RSB opinion 

3.  CONSULTATION OF THE RSB 

The RSB was consulted on this impact assessment on 18 January 2023.  

The  Board  findings  and  recommendations  were  addressed  in  the  impact  assessment  report  as 
follows (text in italics):  

Summary of findings  

The Board notes the additional information provided and commitments to make changes to the draft 
report.  

However, the report still contains significant shortcomings. The Board gives a positive opinion with 
reservations because it expects the DG to rectify the following aspects:  

(1)  The  report  does  not  clearly  analyse  the  scale  of  the  problem  as  well  as  its  consequences  for 
policy making. It does not adequately explain the rationale for intervention.  

(2)  The  report  does  not  sufficiently  address  the  simplification  potential  of  the  preferred  policy 
option. 2  

What to improve  

(1)  The  report  should  clarify  the  size  of  the  problem.  It  should  better  explain  the  rationale  for 
intervention,  given  that  the  evidence  shows  that  most  of  the  contacted  stakeholders  in  the  public 
consultation  seem  to  be  satisfied  with  the  current  situation.  It  should  bring  out  more  clearly  any 
public interest case for new and more frequent data for EU policy areas.  

Specific section discussing on size of the problem (section 2.3) was added to the report. 

The rationale for intervention was reinforced by refocusing the narrative from the analysis 
of satisfaction with the current LMB statistics to reflection of users related to the possible 
improvements. This is described mainly in the analysis of the problems drivers (section 2.2). 

(2)  The  simplification  potential  of  the  preferred  policy  option  should  be  better  explained  and 
elaborated. The report should explain how the replacement of the three existing Regulations  with 

57 

 
 
 
 
 
a single  framework  will  foster  simplification.  It  should  identify  and  analyse  any  additional 
simplification aspects such as reducing the data requirements to the strict minimum and using data 
sources other than surveys.  

Advantages of using a single legal act on LMB are discussed in sections 5.3 (in relation to 
the discarded option) and section 8.2 related to simplifications. Further simplifications are 
also described there. Details on using alternative data sources are provided in analysis of 
driver D2 in section 2.2 on problem drivers.  

(3) The report should discuss potential problems with compliance and enforcement, where relevant. 
It  should  provide  further  information  on  the  possible  implementing  or  delegated  acts  of  key 
importance for the impact or the success of the initiative.  

Potential obstacles that might be encountered for an effective implementation are discussed 
in section 7 on comparison of the options. 

Framing  of  options  2  and  3  in  the  secondary  legislation  is  described  in  section  5.2  on 
description of policy options. 

(4)  The  report  should  better  explain  the  scale  of  provision  of  statistics  on  a  voluntary  basis  by 
Member States and its consequences. In addition, it should provide further detail on how the sub-
objectives on quality reporting, the use of administrative data and innovative sources by Member 
States and the response to emergent needs will be achieved. 

The situation related to provision of data on voluntary basis is described in the description 
of  current  issues  with  LMB  statistics.  Biases  in  the  data  have  been  illustrated  as  some 
countries  provide  the  data  covering  full  economy  voluntarily.  More  information  about 
countries providing the data voluntarily was added in the analysis of the problem driver D4. 
The  consequences  and  compilers  opinion  on  voluntary  character  of  GPG  collection  are 
described in the analysis of problem driver D5.  

Use of administrative data and innovative sources as well as related quality reporting are 
described in the analysis of problem driver D2.  

(5)  The  report  should  improve  the  presentation  of  stakeholder  views.  The  consultation  activities 
findings  should  be  provided  with  the  necessary  granularity  and  should  not  be  presented  as 
aggregate  percentages.  The  report  should  clarify  to  which  consultation  activities  the  results  are 
referring  to.  The  reader  should  also  be  able  to  understand  what  stakeholder  category  expressed  a 
certain concern or opinion and to what extent this evidence is significant and robust.  

Relevant  graphical  presentation  and  comments  on  stakeholder  consultation  was  changed 
across the document, to cover more granular information on type of stakeholder and to add 
absolute figures.  

(6) The report should better explain the problems with the evidence-base and data availability, its 
methodological choices as well as the limitations and the uncertainties of the consultation activities. 
It  should explain how limited use of the public  consultation  results to  assess possible impacts,  in 
particular on respondents to the LMB statistics (enterprises), has been mitigated.  

58 

 
 
 
Issues  related  to  data  availability  and  mitigation  of  problems  related  to  low  coverage  of 
enterprises in the results of consultation are further complemented in section 4 (Evidence, 
sources and quality) of Annex 1 on procedural information.  

The  Board  notes  the  estimated  costs  and  benefits  of  the  preferred  option  in  this  initiative,  as 
summarised in the attached quantification tables.  

Some more technical comments have been sent directly to the author DG.  

In order to limit the number of pages in the main text of impact assessment, the section on 
policy relevance of the LMB data was shortened; the detailed scoring of the policy options 
was  moved  to  the  Section  2  of  the  Annex  3.  Scoring  and  narrative  in  the  assessment  of 
options were aligned. 

4.  EVIDENCE, SOURCES AND QUALITY 

Evidence 

Sources 

Desk research 

  Statistical data and metadata published during the evaluation period, 

and partially before as available (baseline)  

  Legal acts related to the intervention 
  Commission reports on implementation of legislation  
  Methodological guidelines and papers  
  Policy documents establishing statistical needs 

The  fact  that  the  existing  legal  framework  evaluated  here  was 
adopted before Better Regulation guidelines were in place presented 
a  major  obstacle,  as  the  available  documentation  does  not  provide 
information  typically  required  for  evaluation.  The  stakeholder 
consultations  attempted  to  balance  resulting  gaps  to  the  extent 
possible.  
In-depth interviews with selected organisational statistics users 

 
  Bilateral exchanges to pinpoint specific needs 
  PC survey 
 
Interviews 

In-depth interviews with selected organisational statistics users 

 
  PC survey 
  Workshop 

  Regular consultations of Labour Market Statistics/LMB  
  Directors  of  Social  Statistics  and  The  European  Statistical  System 

Committee was also informed about the progress  

  PC survey 

Opinion 
of 
statistics  users: 
Commission 
services  

of 
Opinion 
other  statistics 
users  

of 

Opinion 
statistics 
producers 

The  LMB statistics  are  specific as for the type of information  they provide and users they target, 
meaning  a  highly  specialised  domain  with  relatively  scarce  sources  for  evaluation.  The 

59 

 
 
 
 
stakeholders’  consultation  (public  consultation  and  targeted  interviews  as  well  as  workshop  with 
data  users  validating  the  policy  options)  was  therefore  extensively  used  to  complement  the  first 
findings  of  the  evaluation.  To  ensure  the  highest  coverage  of  most  important  stakeholders,  the 
public  consultation  was  advertised  through  correspondence  with  most  important  data  user 
(Including  European  Statistical  Advisory  Committee,  Directors  of  Social  Statistics,  Business 
Statistics Directors Group, Labour Market Statistics Working Group, EUROFOUND, EIGE, ECB, 
DG  EMPL  CIVIC  DIALOGUE,  Employment  Committee  Indicators  Group  (EMCO  IG)  and 
Indicators' Sub-Group of the Social Protection Committee (ISG SPC) of the Council, SME Envoy 
Network,  LMB  data  collection  correspondents,  SES  microdata  users,  European  Economic  and 
Social  Committee  labour  market  observatory,  Business  Europe,  SMEunited,  ETUC  (European 
Trade  Union  Confederation),  Platform  of  European  Social  NGOs  and  international  organisations 
such as ILO, OECD and UNECE). In addition, different social media channels were used to catch 
general  public.  Unfortunately,  very  few  replies  from  the  general  public  were  received.  However, 
while  not  constituting  a  real  survey  outcome  in  the  statistical  sense  (small  number  of  replies,  no 
probabilistic selection of the sample or respondents), the public consultation  confirmed the needs 
accumulated  over  the  years  (for  instance  during  the  regular  hearings  between  Eurostat  and  the 
Commission policy DGs). They were complemented by the targeted interviews and technical level 
correspondence  between  Eurostat  and  for  instance  the  ECB.  In  addition,  a  careful  analysis  of 
Commission reports to the European Parliament and the Council on implementation of the labour 
costs index and job vacancy statistics, allowed to observe the developments in the implementation 
and compliance improvements of those data collections (evaluation SWD section 3.1). For its part, 
the systematic review of the quality reports that is a daily work in Eurostat allowed identification of 
main  issues  with  the  data.  This  way  the  information  existing  and/or  collected  in  the  consultation 
exercise together with the desk research analysing the legal LMB was triangulated to best evaluate 
the current initiative.  

The  limited  use  of  the  public  consultation  results  to  assess  possible  impacts  in  particular  on 
respondents  to  the  LMB  statistics  (enterprises)  was  planned  to  be  mitigated  by  ensuring  that  the 
direct views of SMEs are captured and information is collected on  the cost and burden on SMEs, 
particularly micro-enterprises for the different policy options. The consultant (ICF) made effort of 
contacting  SME  Europe  to  circulate  a  request  for  data  collection  among  their  members.  Local 
network contact points of Enterprise Europe were also contacted in the following Member States: 
BE, BG, HR, IT, ES, NL, RO, FR, DE, SK, LV. In addition, the ICF used a sample from the Orbis 
database to reach out to ten micro-enterprises from: CZ, EL, ES, IT, PL, SK. Moreover, during the 
workshop  two  organisations  expressed  interest  to  help  facilitate  data  collection  from  micro-
enterprises:  the Confederation of Danish  Employer and the Austrian Federal  Economic Chamber. 
The Confederation of Danish Employer liaised with its members and provided four contact details 
to  SMEs  from  which  one  enterprise  responded  to  questionnaire.  All  other  sources  resulted  in  no 
responses  from  SMEs.  This  situation  was  further  mitigated  by  assessing  the  burden  of  possible 
options  on  businesses  via  assessments  of  national  statistical  institutes.  Indeed,  they  provided,  in 
specific  on-line  consultation  and  costs  assessment  consultation,  qualitative  (on  the  descriptive 
levels  of  burden)  and  quantitative  (on  the  time  estimated  to  provide  additional  information  as 
foreseen in the options) information related to the response burden.  

Moreover,  at  the  workshop  that  gathered  main  LMB  data  users  (institutional  policy  users,  trade 
unions,  business  associations  and  international  organisations)  draft  findings  of  the  impact 
assessment  and  results  regarding  the  problem  definition,  feasibility,  effectiveness,  efficiency,  and 

60 

 
 
 
wider impacts of the policy options were validated. In particular, the trade unions representative at 
the  workshop  highlighted  the  importance  of  structure  of  earnings  survey  data  on  collective  pay 
agreements (which is also a data requirement under the minimum wage directive). 

USE OF EXTERNAL EXPERTISE 

Eurostat carried out this evaluation with topical support from a contractor study contributed by ICF 
SA, Belgium.  In particular,  the evaluation  and  the impact analysis, as  well as  public consultation 
analysis,  organisation  and  analysis  of  stakeholders  consultations  activities  (excluding  public 
consultation  prepared  by  Eurostat),  were  provided  through  the  support  study.  Parts  of  this 
evaluation  SWD  are  therefore  based  on  the  final  report  on  evaluation  support  and  other  analysis 
documents prepared by the contractor. 

Eurostat has also monitored the work of the external support contractor regularly (at least every two 
weeks) and assessed the quality of the final report on evaluation from the external support study. 
The overall work quality and deliverables were found to be in line with the contract and generally 
sufficient to be used for this impact assessment. 

61 

 
 
 
 
 
 
ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) 

1.  CONSULTATION STRATEGY 

In  line  with  the  European  Commission’s  Better  Regulation  guidelines,  the  consultation  strategy 
aimed to gather input on whether population statistics continue to provide the necessary evidence 
base  for  EU  policies  and  other  relevant  use  cases;  if  there  are  new  and  emerging  data  needs  and 
potential  obsolete  data  requirements;  the  cost  and  burden  of  statistics,  as  well  as  the  potential  to 
improve the efficiency and for regulatory simplification. This represented both backward looking 
elements  (explore  what  works  well  and  what  works  less  well  in  the  current  legal  base)  and 
forward-looking  elements  (the  impacts  of  improvement  options  on  all  relevant  stakeholder 
groups) to meet the needs of the back-to-back evaluation and impact assessment. 

There  were  three  main  stakeholders  groups.  Data  providers  represented  administrative  data 
providers  that  are  public  administrations  providing  source  data  to  statistical  authorities  for 
producing  European  statistics,  and  respondents  (enterprise  level  data  providers)who  are 
participating  directly  in  the  data  collection  (sample  surveys).  Statistics  producers  were  the 
national  statistical  institutes  (NSIs)  and  other  national  authorities  collecting,  treating  and 
transmitting to Eurostat statistics on earnings, labour costs structure, job vacancies and gender pay 
gap.  Statistics  users  were  a  diverse  group.  They  included  institutional  users  that  are  directly 
involved in EU policymaking. At EU level, they were the actual policy makers, and at international 
and national levels, they support policymaking and contribute to it. Institutional users include EU 
bodies,  international  organisations,  national  ministries  and  government  research  institutes. 
Furthermore, there were other professional users who contribute occasionally and indirectly to the 
policymaking  process  at  EU  level.  These  were  universities,  research  institutes,  professional 
organisations,  advisory  councils,  NGOs,  individual  private  companies  and  business  associations. 
The media and the general public were also part of the users’ group. 

The strategy envisaged the use of different consultation activities per stakeholder as shown in Table 
1.Table 1 

Consultation activities per user group 

Stakeholder Group/Activity 

Public consultation 

Expert 
consultations 

Interviews 

Institutional data providers 
Individual data providers 
Data producers 
Institutional users 
Other professional users 
Media 
General public 

X 
X 
X 
X 
X 
X 
X 

X32 

X 
X 
X33 
X 
X 

32 Working Group on labour market statistics (LAMAS WG). 

33 ECB; Commission DGs: ECFIN, EMPL, GROW, JUST, REGIO, agencies: EIGE, EUROFOUND 

62 

 
 
 
 
 
 
 
 
 
 
 
 
                                                 
In addition, a specific cost and burden survey related to assessment of current and possibly future 
costs  and  burden  of  data  collections  that  are  in  the  scope  of  the  LMB  (and  GPG  collected 
voluntarily) took place in the framework of the technical discussions with data producers (National 
Statistical Authorities). This survey was launched on the 17 December 2020 to LAMAS delegates 
who were invited to fill the questionnaire and send it back to Eurostat by 30 April 2021. Apart from 
the assessment of cost, information on time spent annually per respondent in minutes and of time 
spent annually by all respondents for each LMB domain was collected. The exercise was tentatively 
concluded before launching of the evaluation and impact assessment procedure (LAMAS WG on 
19-20.10.2021)  as  further  on,  in  July  –  August  2022  the  countries  were  consulted  to  provide 
additional  (qualitative  information)  on  the  policy  options  and  needs  that  emerged  from  the 
evaluation study.  

2.  METHODOLOGY AND TOOLS USED TO PROCESS THE RESULTS 

A mixed-methods approach was chosen for the consultation and included the following activities: 
public and targeted consultations, targeted workshop, interviews with  key stakeholders as well as 
desk research. 

Public  consultation,  targeted  consultation  with  national  statistics  institutes  took  place  through 
online tools, including EUSurvey questionnaires. Workshop and interviews took  place as  virtual 
meetings due to health considerations and specific working arrangements related to the COVID-19 
pandemic. 

The call for evidence and the public consultation34 were run via the Have Your Say website of the 
European Commission35. No feedback was received by the Commission (Eurostat) on the call for 
evidence. The public consultation  was available  in  all official  EU languages. These consultations 
aimed at  gathering information and feedback from the general public and all relevant stakeholder 
groups  as  input  into  the  evaluation  and  impact  assessment  as  a  step  towards  the  preparation  of 
a legislative proposal. 

The  public  consultation  was  promoted  via  different  channels:  Have  Your  Say,  Eurostat  website 
a dedicated  news  item  on  23  February  2022,  social  media  campaign  and  Eurostat  email  banners, 
emails to stakeholders as well as nationally by several NSIs. Public Consultation (PC) questionnaire 
had a section assessing the LMB statistics in general and specific sections on each data collection 
that  are  a  part  of  the  LMB.  The  latter  covered  questions  on  satisfaction  and  attitude  towards 
possible improvements or simplifications. 

As NSI have been consulted by Eurostat several times throughout the review process it was agreed 
that  their  contributions  would  be  most  beneficial  in  an  online  survey  format  instead  of  semi-
structure interviews. The questionnaire sent for the purpose of the targeted consultation with NSIs 
asked for more detailed opinions of statistics producers. The survey contained qualitative questions 
on  costs  and  burden  related  to  introduction  of  possible  improvements  per  data  collection.  In 

34See  the  Factual  summary  report  on  the  public  consultation  of  LMB:  https://ec.europa.eu/info/law/better-
regulation/have-your-say/initiatives/13266-European-labour-market-statistics-on-businesses-LMB-/public-
consultation_en 
35https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13266-European-labour-market-statistics-on-
businesses-LMB-_en 

63 

 
 
 
                                                 
addition,  open  questions  on  anticipated  difficulties  other  than  those  related  to  cost  or  burden  and 
identification  of  elements  that  were  listed  as  potential  improvement  but  are  not  needed  in  the 
opinion of the NSI.  

Interviews were run, first for scoping purposes then in-depth. They had a semi-structured format 
and  were  addressing  LMB  users.  No  interviews  with  the  NSIs  were  conducted  due  to  the  time 
contains.  The  most  important  element  of  them  were  integrated  into  the  targeted  on-line 
questionnaire.  

One workshop was scheduled to present the draft findings of the impact assessment and to validate 
the results regarding the problem definition, feasibility, effectiveness, efficiency, and wider impacts 
of  the  policy  options.  Participants  were  given  the  opportunity  to  discuss  their  views  and  provide 
feedback on the research findings.  

Consultation  with  SMEs  was  foreseen  by  the  study  accompanying  supporting  the  impact 
assessment work to test directly the burden of the new proposals. Although several attempts were 
made  to  receive  the  information  no  replies  were  provided  directly  by  the  SMEs.  Instead, 
information provided by the statistical institutes was used as a proxy assess the burden.  

The  responses  to  all  consultation  activities  were  carefully  analysed.  To  analyse  the  public 
consultation results, all replies were first mapped onto the key stakeholder groups and then assessed 
by each group. Where relevant, the synopsis report presents the diverging views of various groups 
of stakeholders on the same issue. 

3.  STAKEHOLDER PARTICIPATION  

The  consultation  activities  mentioned  above  were  implemented  by  Eurostat  and/or  the  contractor 
supporting  Eurostat  during  the  evaluation  and  impact  assessment  -  ICF  S.A.,  Belgium.  Table  2 
presents the timeline of key consultation actions. 

Table 2 

Timeline of key consultation actions 

Consultation action 
Call for evidence 
Public consultation  
Targeted interviews 
Targeted consultation with NSIs 
Workshop 

Timeline 
03 December 2021 - 31 December 2021 
09 February 2022 - 13 May 2022 
April- September 2022 
22 July - 26 August 2022 
14 September 2022 

In terms of level of participation, no replies were received during the 4-weeks consultation on call 
for  evidence  while  the  public  consultation  resulted  in  79  replies  from  21  Member  States, 
Montenegro,  and  the  United  Kingdom.  Most  responses  were  received  from  Italy,  followed  by 
Latvia, Sweden and Belgium. Almost half of the respondent (46 %) represented public authorities, 
followed  by  academic  and  research  institutions  (19 %).  Trade  unions  and  companies  represented 
each  4 %  of  the  respondents.  In  terms  of  size,  the  majority  of  respondents  came  from  large 
organisations  with  250  or  more  employees  (71 %),  while  only  6 %  of  respondents  represented 
micro and small organisations. 

64 

 
 
 
 
In total 63 stakeholders were invited for interviews. Out of this number, 28 interviews were carried 
out  with  data  users  representing  institutional  policy  users,  trade  unions,  business  associations, 
research organisations and international organisations.  

A  total  of  27  responses  were  received  during  the  on-line  consultation  with  the  NSI´s  from  the 
following  countries:  Austria,  Belgium,  Bulgaria,  Czechia,  Cyprus,  Denmark,  Finland,  France, 
Germany,  Greece,  Hungary,  Iceland,  Ireland,  Italy,  Latvia,  Lithuania,  Luxembourg,  Malta, 
Netherlands,  Poland,  Portugal,  Romania,  Slovakia,  Slovenia,  Spain,  Sweden,  and  Switzerland. 
Contributions were high quality and adequate and were used to feed into the impact assessment. 

The workshop was attended by 9 participants. 

No response from the media were received during the consultation. This was not considered to be 
problematic as the LMB statistics does not normally attract much of the media attention.  

The  consultation  ensured  appropriate  stakeholder  coverage  for  statistics  producers  and  several 
types of statistics users. All NSIs of EU Member States and EFTA countries in charge of compiling 
LMB statistics and transmitting it to Eurostat were involved in the various consultation activities. 
Limited  feedback  was  obtained  from  administrative  data  providers  (three  replies  to  the  public 
consultation). 

To ensure that the views of SMEs are capture and information is collected on the cost and burden 
on SMEs, particularly micro-enterprises for the different policy options, the study team has tried to 
collect information from different sources: 

  SME Europe was contacted and the organisation circulated request for data collection 

among their members 

  Local network contact points of Enterprise Europe were contacted in the following Member 

States: BE, BG, HR, IT, ES, NL, RO, FR, DE, SK, LV 

  The study team used a sample from the Orbis database to reach out to ten micro-enterprises 

from: CZ, EL, ES, IT, PL, SK 

In  addition  during  the  workshop  two  organisations  expressed  interest  to  help  facilitate  data 
collection  from  micro-enterprises:  Confederation  of  Danish  Employer  and  the  Austrian  Federal 
Economic Chamber. 

The Confederation of Danish Employer liaised with its members and provided four contact details 
to SMEs from which one organisation responded the questionnaire. All other sources resulted in no 
responses from SMEs. 

Furthermore, LMB review was presented and discussed with Commission informal expert groups. 
These were mostly meetings of Eurostat-led expert groups with the participation of Member State 
experts,  namely  a  LAMAS  Working  Group,  the  Directors  of  Social  Statistics  as  well  as  the 
European Statistical System Committee (2 meetings in total).  

65 

 
 
 
4.  MAIN RESULTS FROM THE STAKEHOLDER CONSULTATION 

4.1.  General feedback on current statistics 

Results of the public consultation show that overall stakeholders are satisfied with the quality of 
European labour market statistics on businesses. The main quality elements that were highly rated 
by stakeholders include: 

  Overall high quality 

  Relevance 

  Sufficiently reliable and accurate 

  Contribute to the public good and 

  Are impartial and objective. 

Results  of  the  semi-structured  interviews  confirm  the  findings  of  the  public  consultation  and 
showed  an  overall  positive  outlook  on  the  quality  of  LMB  statistics  while  some  areas  for 
improvement were identified.  

4.2.  Areas for improvements 

The elements of LMB that were found important to be further improved in the public consultation 
were:  

  extending the coverage of the survey to micro firms and for NACE Rev. 2 section O for the 

SES, LCS and for the missing countries in the JVS; 

 

improving timeliness of the SES and LCS as well as LCI, in particular for the EU and euro 
area for the latter; 

Collecting  and  publishing  the  numerator  (labour  costs)  and  the  denominator  (index  of  hours 
worked)  of  the  LCI  ratio  for  several  NACE  aggregates  or  quarterly  data  on  the  ‘total  number  of 
hours worked’ was found as needed by stakeholders. 

Moreover,  the  consultation  results  showed  that  increasing  the  frequency  to  every  2  years  for  the 
SES  was  supported  by  55 %  of  data  users  but  only  39 %  of  producers  of  LMB  statistics.  The 
increase  of  frequency  of  the  LCS  was  supported  by  45 %  of  data  users  compared  to  23 % 
producers. 

During  interviews,  the  users  manifested  a  growing  interest  in  new  topics  such  as  the  impact  of 
economic  crises  on  the  labour  market,  the  inflation  factor  from  the  labour  costs,  mismatches  of 
skills of the work force, types of pay schedules and possible discrimination in the labour market.  

One of the most pressing problems highlighted by data users was in relation to data on gender pay 
gap, which is currently provided by Member States only on voluntary basis. For users this means 
that  evidence  is  not  comprehensive  and  suitable  for  cross-country  comparison.  In  this  regard, 
stakeholders  offered  detailed  examples.  Data  users  expressed  also  their  need  for  detail  on  certain 
datasets including adding work history to study gender pay gap, data and availability of information 
by  NUTS  regions.  Furthermore,  with  regards  to  the  need  of  additional  breakdown  and  variables, 

66 

 
 
 
stakeholders  expressed  the  need  for  additional  detail,  including  more  detailed  level  of 
disaggregation of information on occupation in the SES, adding work history to study GPG, (and 
data by NUTS region), which is not currently included in the SES. Moreover, further information 
on e.g. net earnings and annual earnings in kind would be appreciated by some GPG users as a way 
to analyse other aspects of gender segregation and/or discrimination in pay.  

Stakeholders shared the view that it would be beneficial to include more innovative data collection 
method as  it has  the potential  to  decrease burden on data providers. The ESS is  also  working on 
new  techniques  such  as  web  scraping.  However,  some  stakeholders  noted  that  one  should  ensure 
that data from innovative sources are of high quality and comparable with other data sources. 

4.3.  Qualitative assessment of areas needing improvements.  

The  quantitative  evaluation  of  costs  and  burden  related  to  the  improvements  took  place  at  the 
technical level prior the start of evaluation and impact assessment of the LMB review. Following 
problem  definition  of  the  LMB  and  identification  of  preliminary  policy  options,  the  NSI´s  where 
addressed  with  the  targeted  consultation  to  assess  the  possible  improvements.  This  assessment 
covered qualitative questions on improvements related to coverage, frequency and timeliness of the 
particular data collections constituting the LMB statistics and monetary and qualitative assessment 
addressing  some  punctual  needs  related  to  for  instance  missing  variables  in  one  data  collection 
(SES).  

Coverage of the LMB 

Extending the coverage of the SES to micro firms (1-9 employees) for  main information would 
cause significant  increase in  costs for 53% of the NSI´s (for 15% it will be one off cost  for 38% 
regular every time the survey takes place). For 46% of NSI´s the increase will be no significant or 
zero. Extending the coverage of the SES to micro firms (1-9 employees) for whole set of variables 
would cause significant increase in costs for 62% of the NSI´s (for 4% it will be one off cost for 
58%  regular  every  time  the  survey  takes  place).  For  38%  of  NSI´s  the  increase  will  be  no 
significant or zero.  

Extending the coverage of the LCS to micro firms (1-9 employees) would cause significant increase 
in  costs regular every time the survey takes place for 62% of NSI´s. No increase or insignificant 
would be according to 38% of NSI´s.  

Naturally, the extension of the coverage for JVS (both for the micro enterprises and for the NACE 
Rev. 2 section O) will affect only the 3 countries that do not do it yet.  

For costs relating to extending the  coverage to  NACE Rev. 2 section O, over half of respondents 
(69%) noted no increase in costs for SES datasets. 19% noted an increase compared to the baseline 
every time the survey takes place. The remaining 12% noted costs when starting-up. For LCS, most 
respondents  (81%)  indicated  no  increases  in  cost.  15%  of  respondents  indicated  significant  cost 
every  time  the  survey  takes  place  and  the  remaining  4%  indicated  a significant  increase  when 
starting up. 

67 

 
 
 
 
Frequency and timeliness 

Transmitting all LCI results earlier, 65 days instead of 70 days after the end of the reference quarter 
would, according to NSI, not lead to significant increases in cost compared to the baseline (64%). 
Likewise, improving timeliness of the SES by two months is not likely to result in increases in cost 
compared to the baseline (58% of NSI´s). 

Costs associated with collecting SES data every two years instead of every four years may be high 
as a large majority of respondents (84%) noted a significant increase compared to the baseline in 
cost every time the survey takes place. The remaining 16% noted no increase in costs.  

For  the  LCS  survey,  most  NSI´s  (76%)  reported  an  increase  in  cost  every  time  the  survey  takes 
place every two years instead of four. The 20% of respondents indicated no increase in costs. 

Additional variables  

Replies  to  the  NSI´s  consultation  showed  that  introduction  of  variables  needed  for  deep  policy 
analysis  (e.g.  disability  status  of  employees  according  to  the  administrative  concept  in  the  SES, 
career  brakes)  would  be  problematic.  The  reason  being  the  differences  in  the  definitions  at  the 
national level, lack of this information to the employer, issues related to confidentiality and ethics 
as well as a high burden they cause on the employers. 

At the same time other variables (e.g. occupation to be collected at more disaggregated level in the 
SES) seem to be relatively easier to be collected.  

Other 

Comments  made  by  participants  during  the  online  showed  that,  while  participants  welcomed  the 
additional  measures  and  the  full  regulatory  approach  it  was  noted  that  there  should  be  a balance 
between ambition and realism. It was emphasized that assessing the burden on enterprises for the 
proposed new measures would be crucial before making any final decisions. 

5.  CONCLUSIONS 

The  stakeholder  consultation  was  implemented  in  line  with  Commission’s  Better  Regulation 
Guidelines.  It  reached  successfully  the  intended  stakeholder  groups  except  for  the  administrative 
data  providers  and  media  organisations.  Given  the  technical  nature  of  the  subject,  the  overall 
engagement  of  respondents  was  considered  sufficient  to  support  the  back-to-back  evaluation  and 
impact assessment of the LMB.   

The  consultation  supported 
initiative  on  LMB  statistics  and 
acknowledged importance of the data that constitute it. It also pointed out the existence of statistical 
gaps  and  the  emergence  of  new  statistical  needs  that  cannot  be  satisfied  within  the  current  legal 
framework. 

the  ongoing  Commission 

All stakeholders confirmed the need to plan statistical improvements although they did not always 
agree on the level of ambition of such improvements and statistics producers were somehow more 
prudent to changes than statistics users. 

68 

 
 
 
Statistical topics that gathered support across all stakeholder groups as priority topics were increase 
of  the  coverage  in  particular  to  the  NACE  Rev.  2  section  O  for  all  data  collections  and  to 
microenterprises for the SES and better timeliness of the LMB data. 

The main statistical topics where producer and users had different views concerned the increase of 
frequency of the SES or LCS. Producers and users also had different views regarding the addition 
of specific variables in SES.  

69 

 
 
 
ANNEX 3: WHO IS AFFECTED AND HOW? 

1.  PRACTICAL IMPLICATIONS OF THE INITIATIVE 

The preferred option (option 2) would require the following changes in the LMB data collections.  

Labour cost index 

It is proposed to develop a flash LCI, to be transmitted by all countries representing more than 3% 
of the total number of employees at EU level (currently: Belgium, Germany, Spain, France, Italy, 
the Netherlands, Poland, Portugal and Romania). The flash LCI should be transmitted at t+45 days 
(in  addition  to  the  final  data  transmitted  at  t+70  days  as  is  already  the  case)  and  published  three 
working days later (i.e. at t+50 days at the latest).  

Job vacancy statistics 

For  JVS,  the  main  proposal  consists  in  eliminating  possible  biases  by  covering  all  economic 
activities  and  enterprise  sizes,  which  is  not  yet  the  case  for  three  Member  States.  In  France  and 
Italy, public institutions are not covered within the sectors of public administration, education and 
human health (NACE Rev. 2 sections O, P and Q). In France, only units with 10 employees or more 
are included. Denmark only covers units within the business economy (NACE Rev. 2 sections B-
N). 

Gender pay gap 

Annual (unadjusted) on gender pay gap data are currently collected under a gentlemen’s agreement. 
Under  the  LMB  review,  it  is  proposed  to  introduce  a  legal  basis  for  the  transmission  of  this 
important  indicator.  This  will  also  serve  the  needs  of  the  proposed  directive  on  pay  transparency 
whose monitoring will require annual on gender pay gap data. 

Structure of earnings survey 

It is proposed to extend the scope of the four-yearly Structure of Earnings Survey to  micro firms 
(with 1 to 9 employees) and to public administration (NACE Rev.2 section O). The SES extension 
aims to correct the existing biases in the mean and median earnings which are used in a number of 
policy-relevant policies including the newly adopted directive on adequate minimum wages and for 
the on gender pay gap. 

It is also proposed to shorten the deadline for transmitting SES data to Eurostat.  

Labour cost survey 

It  is  proposed  to  extend  the  scope  of  the  four-yearly  labour  cost  survey  to  public  administration 
(NACE Rev.2 section O) and to shorten the deadline of transmission of data to Eurostat.  

Moreover, the proposal will limit the data collection on apprentices to Member States where they 
represent  more  than  3%  of  the  total  number  of  employees  at  EU  level  (currently:  Germany, 
Denmark, France, Italy and Austria).  

70 

 
 
 
 
 
General 

To compensate for the resulting increase in the response burden, the LMB review will foster the use 
of  administrative  and  innovative  (e.g.  web-scraping)  sources  for  the  compilation  of  LMB  data. 
Quality  reporting  templates  will  be  adapted  to  fit  administrative  data  and  multiple  sources.  In 
addition the emerging needs related to new variables in SES, indices for hours worked and labour 
costs in LCI and more detailed breakdowns of the JVS will be implemented These will be done in 
the secondary legislations. 

The data are collected by the Members States based on the sample survey, based on the extraction 
of the information already available in the administrative registers, as a combination of the methods 
described above. National Statistical Institutes or Other National Authorities are free to choose the 
method that is the most efficient in terms of burden and the statistical quality.  

2.  DETAILED SCORING BY POLICY OPTION 

Table 13.  Policy Option 0: No targeted EU action (baseline) 

Under the baseline, no further EU action would be taken and 
therefore does not go beyond what is necessary. 

Under the baseline, no further EU action would be taken.  Current 
EU action is limited to those aspects that Member States cannot 
achieve satisfactorily on their own, such as EU-wide comparative 
data that follow harmonised standards in areas such as labour 
costs, earnings and job vacancies. Results from the evaluation 
show that current EU action provides clear added value. 

Under the current LMB legal basis, compilers were already called 
upon minimizing the costs subject to the objectives set by the EU 
legislation. Under the subsidiarity principle, compilers were free 
to choose the most efficient sources and methods given the 
national context, provided they meet the objectives fixed at the 
time with the high level of quality expected for official statistics. 

Pass 

Brief description 

Policy Option 0 (baseline, no targeted EU action) 
Assessment criterion  Score 
(Pass / 
Consistency with 
uncertain 
proportionality 
/ fail) 
principle 
Pass 
Does the option go 
beyond what is 
necessary to 
satisfactorily achieve 
the objectives? 
Is the scope of the 
option limited to those 
aspects that Member 
States cannot achieve 
satisfactorily on their 
own and where the 
Union can do better? 
Are costs for the 
Union, national 
governments, regional 
or local authorities, 
economic operators or 
citizens commensurate 
with the objectives of 
the initiative? 
Is the form of action 
(choice of instrument) 
as simple as possible 
and coherent with a 
satisfactory 

Pass 

71 

Uncertain Under the baseline, no further EU action would be taken. Each 

statistical domain would continue to be implemented as a separate 
statistical process based on its own EU legislation. Thus, all 
existing pieces of legislation would remain which does not favour 
easy enforcement and achievements of the objectives, in 

 
 
 
 
achievement of the 
objective and effective 
enforcement? 

Effectiveness in 
achieving policy 
objectives: 
SO1.1: Adapting the 
regulatory framework 
to allow flexibility in 
meeting emerging 
needs 

0 

0 

0 

0 

0 

0 

SO1.2: To release 
more timely statistics  
SO1.3: To promote the 
use of innovative 
sources and methods 
of duly assessed 
quality 
SO2: Improving the 
coverage of statistics 
to whole economy and 
ensure exhaustive GPG 
data  
SO3: Improving the 
consistency with 
related statistical 
domains  
Impacts on 
fundamental rights and 
the promotion of 
equality 

Social impacts  

0 

Environmental impacts 0 

Competitiveness 

0 

particular the coherence and clarity of EU legislation.  
Nonetheless, the various stakeholders are accustomed to the 
current regime which has been in place since several years and it 
cannot be considered as ‘failing’ on this part of the 
proportionality assessment. 

 (-- to ++)  

Under the baseline, no further EU action would be taken to 
further adapt the framework to evolving needs, sources and 
methods.  
Maintaining the current system would mean that LMB statistics 
would not fully satisfy emerging user needs, as the current 
problems would remain unaddressed.  
The deadlines of release of the LMB statistics will stay the same 
as currently 
No reporting on quality of administrative and innovative data 
sources will take place and assessment of their quality will not be 
assured therefore use of innovative sources will not be promoted. 

Under the baseline, no further EU action would be taken to 
change the coverage of statistics in terms of topics and actors.  

Under the baseline, no further EU action would be taken to 
improve consistency with related statistical domains.  

The impact on fundamental rights is not, however, entirely 
neutral. As policymakers and other stakeholders are involved in 
protecting population sub-groups at risk of inequality (in terms of 
pay discrimination based on gender or disability, there may be 
impacts). 
This option has no impacts on the promotion of equality. 
Under the baseline scenario, no further EU action would be taken, 
hence no social impact.  
Policy option 0 is likely to have a rather neutral indirect 
environmental impact when considering the European Green 
Deal. 
Under policy option 0 there are no impacts on competitiveness, 
research & innovation. 

72 

 
 
 
Do no significant 
harm, including 
climate consistency 
check  

Digital by default  
Sustainable 
Development Goals 
Coherence with 
overarching objectives 
of EU policy 
Coherence 

Efficiency 

0 

0 
0 

This option has no impact on the principle of “Do no significant 
harm”. 

The option has no impacts on digital-ready policymaking. 
Under this option there is no impacts on the SDG. 

 (-- to ++)  

0 

 0 

Maintaining the status quo would mean that some shortcomings 
of the current framework would not be resolved (i.e. partial 
coverage of the economy causing biases in key indicators). 
Considering that most of the drivers would remain unaddressed in 
the baseline scenario, it is highly likely that the misalignment 
between LMB statistics and other relevant EU flagships and 
initiatives will remain. For instance, the findings from evaluation 
identified a need for a more coherent and harmonised approach to 
data on equality.  
Hence, with option 0, LMB statistics will not be aligned with 
initiatives such as the recently adopted Directive on adequate 
minimum wages, the Commission proposal for a directive on pay 
transparency, and Principle 6 of the European Pillar of Social 
Rights. 

Under Policy option 0, stakeholders will incur the same level of 
ongoing costs as under the current LMB framework of legal acts.  
Costs in Policy option 0 (for Eurostat, NSIs and enterprises) are 
mainly driven by the costs of regularly producing the various 
types of LMB statistics on wages, labour costs, and job vacancies.   
Benefits remain unchanged. 
Overall, NSIs are permanently optimizing their sources and 
methods, given the national contexts, so that the efficiency is high 
as also confirmed by the  evaluation 

73 

 
 
 
 
 
 
 
 
 
2.1. 

Policy option 1: Reliance on the voluntary nature of contributions 

Table 14.  Policy Option 1: Reliance on the voluntary nature of contributions 

Policy Option 1 Reliance on the voluntary nature of contributions 
Assessment criterion  Score 
 (Pass / 
Consistency with 
uncertain 
proportionality principle 
/ fail) 
Pass 

Brief description 
Assessment 

Does the option go 
beyond what is 
necessary to 
satisfactorily achieve the 
objectives? 

Pass 

Is the scope of the 
option limited to aspects 
that Member States 
cannot achieve 
satisfactorily on their 
own, and where the 
Union can do better? 

Pass 

Pass 

Are costs for the Union, 
national governments, 
regional or local 
authorities, economic 
operators or citizens 
commensurate with the 
objectives of the 
initiative? 
Is the form of action 
(choice of instrument) as 
simple as possible and 
coherent with a 
satisfactory achievement 
of the objective and 
effective enforcement? 

As part of policy option 1, most measures are voluntary in nature, 
with only GPG data being mandatory. The nature of other 
measures being voluntary ensures that the option does not go 
beyond what is necessary to satisfactorily achieve the initial 
objectives. 
A new regulation would be created for regulating GPG. This 
satisfies the criterion in that the only avenue for addressing the 
specific issue of gender pay gap information is through specific 
legislation and cannot be achieved in a voluntary manner. This is 
therefore consistent with the proportionality principle. 
Under option 1, some but restricted mandatory further EU action 
would be taken. Current EU action is limited to those aspects that 
Member States cannot achieve satisfactorily on their own, such as 
EU-wide comparative data that follow harmonised standards in 
areas such as labour costs, earnings, and job vacancies. The 
indicators added and the improvements to timeliness are 
comparatively minor in nature, rendering option 1 limited to 
aspects that Member States cannot achieve on their own.  
As part of option 1, limited further mandatory EU action is taken 
when compared to the baseline. The costs for additional data 
collection (on GPG) are limited. In particular, the future 
mandatory transmission of GPG data would be strictly limited to 
the current (voluntary) data collection transmission. It thereby 
passes the test of the costs being commensurate with the 
objectives of the initiative.  

Under option 1, one framework regulation is proposed with a 
limited degree of mandatory legal changes required -inclusion of 
GPG. All statistical domains would be covered under one EU 
legislation, allowing for better harmonisation and planning.   
In a certain way, the voluntary nature of the collection of some 
data would render the overall framework opaquer. It would not be 
as simple as possible as it creates divergence across Member 
States. 

74 

 
 
 
 
 
 
Effectiveness in 
achieving policy 
objectives: 
SO1.1:  Adapting the 
regulatory framework to 
allow flexibility in 
meeting emerging needs 
SO1.2: To release more 
timely statistics  
SO1.3: To promote the 
use of innovative 
sources and methods of 
duly assessed quality 
SO2: Improving the 
coverage of statistics to 
whole economy and 
ensure exhaustive GPG 
data  
SO3: Improving the 
consistency with related 
statistical domains  

+ 

+ 

+ 

+ 

+ 

Impacts on fundamental 
rights including the 
promotion of equality 

+ 

Social impacts  

+ 

Nonetheless, given the limited impact of the current regime on the 
various stakeholders, it is unlikely that this would be considered a 
‘fail’ on this part of the proportionality assessment. 

 (-- to ++)  

As part of option 1, the framework would be slightly more 
adapted (due to its voluntary character) to constantly evolving 
needs (in particular the new needs on GPG), sources and methods 
by considering elements that were not part of the existing regime. 
Improvements to timeliness would be minor as the early data 
transmission will take place voluntarily 
Quality reporting on use of administrative and/or innovative 
sources will be voluntary.  

The coverage of statistics will be improved in particular for GPG 
data. Moreover, with the voluntary nature of the extension of 
coverage of other LMB data -, adapting quality reporting 
frameworks, aligning concepts and definitions - there are a 
number of improvements to be made compared to the baseline.   
Consistency with related statistical domains would be improved, 
in particular through the single basic act with updated references 
to the related statistical domains (National Accounts, European 
Business Statistics) but voluntary nature of extension to public 
administration may still leave not full resolved issue related to 
definition of an employee.  
Making GPG data collection compulsory would have a positive 
impact on the monitoring of fundamental rights as regards gender 
issues. 
A mandatory legal basis for the data collection of GPG data 
would also be in line with the proposal for a Directive on pay 
transparency. 
However, further information on the GPG collected in the 
underlying source (SES) would be collected voluntarily, posing a 
risk of low compliance and hence limited data availability. This 
would limit future developments in GPG analyses (adjustments 
based on detailed occupations, impact of social contributions on 
the GPG etc.) 
Therefore, the impact on fundamental rights is slightly positive. 
The modernisation of social statistics began with Regulation (EU) 
2019/1700 on European social surveys. This regulation 
constituted the first milestone of the modernisation of social 
statistics, setting up a specific framework for European statistics 
on people and households based on data at an individual level, 
and collected from samples. 
Some of the proposed measures, such as on regularisation of 

75 

 
 
 
Sustainable 
Development Goals 

 0 

gender pay gap, would further contribute to the promotion of 
social inclusion and the monitoring of social cohesion at national 
and regional levels. The European Pillar of Social Rights is about 
better delivering the rights for citizens towards a strong social 
Europe that is fair and inclusive.  
In terms of social impacts, there are positive effects in regard to 
the mandatory collection of data on the gender pay gap. This 
would nonetheless be a net positive result for this criterion.  
For LMB statistics, SDG 5 on gender equality and SDG 10 on 
reduced inequalities are relevant. The mandatory collection of 
GPG data will provide policy makers with more complete 
information to support policies in the area of gender equality and 
contribute to both SDG objectives. However, the voluntary data 
collection on microenterprises would lead to limited data 
availability on enterprises employing less than 10 persons 
preventing Eurostat from correcting the existing bias in the global 
SDG indicator on gender pay equality (the GPG). 

Coherence with 
overarching objectives 
of EU policy 
Coherence 

Efficiency 

 (-- to ++)  

- 

0 

Option 1 would not address all the shortcomings of the baseline in 
terms of the somewhat more complex nature of the various 
existing datasets, the divergence of outcomes due to the voluntary 
nature of many of the measures, and thereby the rendering of the 
coherence in EU policies being somewhat less favourable than 
expected. It can also be questioned whether a voluntary approach 
would bring overarching EU objectives any closer. It is likely 
therefore that the effect is slightly negative compared to the 
baseline. 
However, as a new sole framework regulation is used, the risk of 
discrepancies between the domains will be lower, providing for 
better coherence of the LMB package in terms of definitions, 
concepts, approaches and planning.  

Under policy option 1, stakeholders will incur slightly higher 
ongoing costs than under the current LMB framework of legal 
acts.  
Costs in policy option 1 are mainly driven by the costs of 
regularly producing GPG. Those costs however are negligible for 
the enterprises as the data collection will be done by the NSI 
mainly based on the existing sources.  
There would, however, be a positive impact on benefits given the 
voluntary nature of most of the measures and thus the benefits are 
also comparatively modest. 
Overall efficiency may still be relatively high based on findings 
from the evaluation.  

76 

 
 
 
 
 
 
Results of the consultation on cost and burden with the NSIs and the study estimation combined, 
provided that introduction of the compulsory data collection on GPG would lead to increase of costs 
for this data collection by 34 % (+ 215 000 Euro). For the whole LMB, this means an increase of less 
than 1 % in total. Estimated, increase in costs related to burden on enterprises would be negligible 
(less than 100 000 Euro). This is mainly linked to the fact that GPG data collection is based on the 
existing sources and the burden is mainly on the statistical authorities to compile the data and prepare 
quality report.  

In relation to burdens associated with creating a legal basis for the mandatory transmission of annual 
unadjusted GPG data, 54% of respondents (14 NSIs) indicated no increases in response burden and 
an additional 35% (9 NSIs) noted that data was already collected or available. Nevertheless, 12% of 
respondents indicated an increase in response burden 4% (1 NSI) medium and 8% (2 NSIs) high. 
When asked about the possible increase in burden associated with collecting and publishing quality 
reports for the yearly GPG, most respondents (62%, 16 NSIs) noted no increases in response 
burdens. 27% (7 NSIs) also noted that data was already available or collected. Increases are however 
noted by the remaining 12% of respondents with 8% (2 NSIs) indicating a high increase and 4% (1 
NSI) indicating no increases in response burdens. Negligible increase in total burden on the 
enterprises is expected, coming mainly from the country that either do not provide data already (e.g. 
IE). 

Overall assessment 

Under policy option 1, there will be limited mandatory changes at the EU level and a larger number 
of voluntary changes. The measures, however, generally represent a continuation of the status quo 
under the baseline.  

This option would have limited effectiveness in addressing the problems identified with the current 
EU legal framework and while it passes the proportionality principle simply because it is a 
simplification compared to the existing framework, its effects are modest and do not meet the 
expectations for a general review of LMB legislation. While there are some positive social impacts, 
the overall coherence with EU policies is not deemed well-served by this option, thus making it sub-
optimal.  

In summary, this option would be somewhat more effective in addressing the problems identified 
with the LMB framework compared to the baseline, although it still falls short from users 
expectations identified through the LMB evaluation exercise. 

77 

 
 
 
 
 
 
2.2. 

Policy option 2:  High coverage, better timeliness and other measures 

Table 15.  Policy Option 2: High coverage and timeliness; GPG regulated 

Brief description 
Assessment 

Policy Option 2: High coverage and timeliness; GPG regulated 
Assessment criterion  Score 
 (Pass 
/ 
Consistency with 
uncertain 
proportionality 
/ fail) 
principle 
Pass 
Does the option go 
beyond what is 
necessary to 
satisfactorily achieve 
the objectives? 

The new mandatory additions under option 2 relate to an 
extension of the coverage in certain areas, including of micro 
firms and NACE Rev. 2 section O for the SES,  improved 
timeliness, adapting templates for quality reports, aligning 
concepts and definitions, making GPG data compulsory and 
addressing emerging needs.  
To ensure compliance with the principle of proportionality, the 
intervention of the EU in the field of European statistics must 
ensure a higher level of comparability of the relevant LMB 
datasets.  
The option is not deemed to go beyond what is necessary to 
satisfactorily achieve the objectives because it covers areas where 
data users have expressed a need and addressed emerging needs 
that the evaluation found are currently missing. It also updates 
concepts, definitions and templates to ensure alignment. 
Timeliness increases considerably in some respects.   
Under option 2, further mandatory EU action is taken in the range 
of areas described above. It is reasonable to assess that Member 
States would not be able to cover alone those areas that the 
evaluation has found are gaps and limitations of the current 
regime. Several of the proposed measures concern coordination 
efforts (on definitions, templates for quality reports, concepts) 
and addressing needs in any case already expressed in EU 
strategies (such as extension of the coverage). It is clear the 
Union can do better than the totality of the Member States.  
As part of option 2, considerable EU action is taken compared to 
baseline. There would be higher costs for measures that are 
currently not in place, though these are assessed as reasonable 
compared to the wider EU policies, strategies and objectives, and 
the needs for rendering the framework future-proof.  
It thereby passes the test of the costs being commensurate with 
the objectives of the initiative.  

Under option 2, mandatory action is taken, and this is done by 
merging the existing 3 framework regulations into a single 
integrated legal act. It can be considered comparatively simpler 

78 

Pass 

Is the scope of the 
option limited to those 
aspects that Member 
States cannot achieve 
satisfactorily on their 
own, and where the 
Union can do better? 

Are costs for the 
Union, national 
governments, regional 
or local authorities, 
economic operators or 
citizens commensurate 
with the objectives of 
the initiative? 
Is  the  form  of  action 
(choice  of  instrument) 
as  simple  as  possible 

Pass 

Pass 

 
 
 
 
and  coherent  with  a 
satisfactory 
achievement  of 
the 
objective and effective 
enforcement? 

 (-- 
++) 

 ++ 

+ 

++ 

 + 

in 
policy 

Effectiveness 
achieving 
objectives: 
SO1.1:  Adapting  the 
regulatory  framework 
to  allow  flexibility  in 
meeting 
emerging 
needs 
SO1.2:  To 
release 
more timely statistics  
SO1.3:  To  promote 
the  use  of  innovative 
and methods 
sources 
of 
assessed 
quality 
SO2: Improving the 
coverage of statistics 
to whole economy and 
ensure exhaustive 
GPG data  

duly 

  ++ 

 + 

the 
with 
statistical 

SO3:  Improving 
consistency 
related 
domains  
on 
Impacts 
rights 
fundamental 
including 
the 
promotion of equality 

than discrete regulations for each type of data. 
The mandatory nature of the collection of data, expansion of the 
coverage and addressing of emerging needs, as well as the 
updating of concepts, definitions and templates for quality reports 
would render the overall framework more future-proof. It helps to 
achieve the objectives more satisfactorily than is currently the 
case. It expands the scope of LMB statistics while reducing the 
complexity of the current legal framework. 
Option 2 therefore passes this test. 

to 

As part of option 2, the framework would clearly help in further 
adapting to meet constantly evolving needs (including the needs 
identified in the evaluation), sources and methods by considering 
numerous elements that were not part of the existing regime.  

The timeliness of the statistics will be improved, in particular for 
the LCI and to a lesser extent for the SES.  
The use of administrative and innovative sources will be 
promoted by better reporting of their quality 

The coverage of statistics will be improved in particular for GPG 
data, extending SES to micro firms, providing better coverage of 
the economy through including administration in the SES and 
also in the LCS, full coverage of the economy including micro 
firms, public institutions and the non-business economy (O to S) 
in the JVS, new templates for quality reports, definitions and 
concepts, and addressing emerging needs. 
This helps to significantly to improve the coverage to whole 
economy.  
Consistency with related statistical domains would be improved, 
in particular through the single basic act with updated references 
to the related statistical domains (National Accounts, European 
Business Statistics). 
Compared with the baseline, option 2 will regulate GPG 
transmissions thus increasing coherence with the current legal 
framework, specifically with Article 23 of the EU Charter, the 
European Pillar of Social Rights, Directive 2006/54 on the 
implementation of the principle of equal opportunities and equal 
treatment of men and women in matters of employment and 
occupation as well as the Gender Equality Strategy 2020-2025. 
With extension of the SES to NACE Rev. 2 section O and 
microenterprises coverage, users will get unbiased results on 
wages allowing better analysis of the gender differences.  

79 

 
 
 
 
Social impacts  

 ++ 

Sustainable 
Development Goals 

 + 

Coherence 
with 
overarching  objectives 
of EU policy 
Coherence 

 (-- 
++) 

 + 

Some of the proposed measures, such as extension of the SES 
coverage to the micro firms and NACE Rev. 2 section O would 
allow better assessment of the low–wage earners and contribute 
to monitoring of the directive on minimum wages adequacy. 
They will also further contribute to modernising social statistics. 
Modernisation of this kind may be needed to support various 
Union actions, such as the promotion of social inclusion and the 
monitoring of social cohesion at national and regional levels. The 
European Pillar of Social Rights is about better delivering the 
rights for citizens towards a strong social Europe that is fair and 
inclusive. 
There are positive effects with the mandatory collection of data 
on the gender pay gap, indices of hours worked and labour costs, 
variables identified as emerging need in SES. There would 
clearly be a net positive result for this criterion. 
SDG 5 on gender equality and SDG 10 on reduced inequalities 
were assessed under this option. Regulated data collection for 
GPG, has the potential to increase data accessibility on GPG data 
and provide policy makers with more up to date information to 
support policies in the area of gender equality and contribute to 
SDG 5 on gender equality. In addition, under this option SES data 
collection is extended to micro-enterprises, this increases the 
coverage of economy and provides more detailed and accurate 
information on gender pay gap and contributes to an unbiased 
calculation of SDG indicator on gender equality.  

to 

Option 2 would address most of the shortcomings of the baseline 
in terms of coverage, covering emerging needs and further 
harmonisation of standards (definitions, concepts, templates for 
quality reports). A clear effort at collecting these types of data 
would better ensure meeting overarching EU objectives.  
The impact of policy option 2 would be further aligned with the 
aforementioned EU flagship initiatives such as the Equality 
Employment Directive (2000/78/EC), EP and Council directive 
on minimum wages, Commission proposal for a directive on pay 
transparency and Principle 6 of the European Pillar of Social 
Rights.  
Last but not least, a unified legal framework (single legal act) will 
improve the clarity and coherence of the whole LMB legislation. 

Efficiency 

 ++ 

 (see assessment below) 

The costs for compilers related to data collections were assessed based on a quantitative survey of 
NSIs and Other National Agencies (ONAs) in charge of LMB statistics. This was complemented by 
a qualitative survey of the LAbour MArket Statistics (LAMAS) working group carried out in the 
July-August 2022 and the study conducted for the purpose of evaluation and impact assessment 

80 

 
 
 
 
 
 
 
The table below provides an overview of the increase in costs for NSIs across datasets for NSIs, for 
policy option 2 Increase in costs of NSIs for policy 

Table 16.  Increase in costs of NSIs for policy option 2 

Total annual costs of 
baseline for NSIs (in 
EUR) 

Increase of NSI´s cost (in 
EUR) 

% Increase of total 
NSIs´costs  

586,191 
865,516 
529,808 
1,511,227 
214,647 
3,707,389 

5,659,238 
9,318,641 
7,185,434 
7,386,671 
628,709 
30,178,693 

JVS 
LCI 
LCS 
SES 
GPG 
Total LMB 
In the qualitative survey among the MSI´s most respondents (64%, 16 NSIs) noted insignificant 
costs for transmitting all LCI results earlier, 65 days instead of 70 days after the end of the 
reference quarter. 24% (6 NSIs) reported a significant increase every time the survey takes place 
and 13% (Malta, Belgium, Greece, France and Bulgaria) when starting up. NSI respondents from 
BE, DE, ES, FR, IT, NL, PT, and PL were asked to evaluate the level of costs in terms of providing 
the data for a flash LCI at 45 days after the end of the reference quarter. Half of them respondents 
noted a significant increase in costs every time the survey takes place. 

10% 
9% 
7% 
20% 
34% 
12% 

Most NSIs respondents (58%, 15 NSIs) also noted an absence of increase in costs for transmitting 
all SES results earlier (T+16 months instead of T+18 months). 19% (5 NSIs) noted an increase 
when starting up and the remaining 23% (6 NSIs) noted one every time the survey took place.  

In a nutshell, option 2 would trigger limited costs for NSIs whose main part could be financed 
through by EU grants. 

Costs for respondents 

The costs for respondents was assessed in a survey of compilers complemented with a qualitative 
study. The costs for enterprises were calculated based on the median time spent by enterprises to 
comply with the data collection request multiplied by hourly labour costs in Member States. The 
sum of costs of the available countries, plus the EU median value for the missing countries not 
reporting any cost were added to calculate the total costs. 

The table below provides an overview of the increase in costs for businesses across datasets. 

Table 17.  Increase in costs for businesses for policy option 2 

Total annual costs of 
baseline for businesses (in 
EUR) 

Increase of businesses cost 
(in EUR) 

% Increase of total 
costs of business  

JVS 
LCI 
LCS 
SES 
GPG 
Total LMB 

4,472,272 
12,001,564 
10,703,029 
16,079,802 
0 
43,256,667 

81 

723,594 
11,935 
456,720 
3,426,005 
92,365 
4,710,619 

16% 
0.1% 
4% 
21% 
na 
11% 

 
 
 
 
 
In relation to the burden associated with extending the coverage of LMB datasets, 42% of the NSIs 
(11 NSIs) noted a high increase in response burden in extending coverage of SES datasets to micro-
firms for main information. The remaining respondents either noted that data was already collected 
(38%, 10 NSIs), Finland, Belgium, Luxembourg and France (16%) recorded no increase and only 
Latvia (4%) reported a low increase in response burden. 

Responses regarding extending the coverage of the SES survey to NACE Rev. 2 section O (‘public 
administration and defence, compulsory social security’) suggest data is either already collected or 
available (73%, 19 NSIs). Impacts of response burdens for the remaining countries are either 
medium (15%, 4 NSIs) or high (12%, 3 NSIs). For LCS datasets, most respondents (77%, 20 NSIs) 
noted data availability. 

Only three respondents noted high increases in response burdens for transmitting all SES results 
earlier, at T+16 months instead of at T+18 months (T being the end of the reference year). 19% (5 
NSIs) indicated data availability and 42% (11 NSIs) of respondents noted no increases in response 
burdens. 

To summarize, option 2 would create a limited increase in burden, mainly due to the extension of 
the SES scope to micro-firms. The costs implied (8.2 million) represent a negligible part (less than 
1%) of the costs European Business Statistics (annual total costs of around 980 million Euro)36. The 
real amounts will be even smaller as ten NSIs have already extended SES to micro-firms. 

Overall assessment 

The overall assessment of option 2 is that it passes the proportionality test, ensures enhanced 
coherence with EU policies, goes a significant way in meeting policy objectives and has positive 
social impacts. The option leaves limited gaps with the identified set of problems and drivers.  

Most of the drivers are addressed. Option 2 is highly effective in achieving most of the policy 
objectives. In terms of coverage, option 2 does not foresee the extension of LCS to cover micro 
firms but extends SES to micro firms although only for main information (SES 2). Option 2 also 
offers high timeliness but the frequency remains unchanged – as with the baseline scenario (4-
yearly).  

While it is anticipated that the increase in timeliness will allow for better research and evidence 
from SES and LCI, the frequency of LMB statistics would not improve. Whereas cyclical indicators 
(JVS for labour shortages, LCI for hourly labour costs) are provided with sufficient frequency 
(quarterly), some users would appreciate a shorter periodicity for structural surveys such as the 
LCS and the SES.   

Nevertheless, option 2 would also cover important actors and segments of the population to allow 
for better research and policy analysis. This option also introduces new templates for the collection 
and quality reporting for the use of administrative data and innovative sources as well as more 
alignment in terms of concepts and definitions of relevant data domains including national accounts 
and the EBS. 

https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1342-European-business-statistics-FRIBS-

36 
_en  

82 

 
 
 
                                                 
2.3.  Policy option 3: Highest coverage and increased frequency 

Table 18.  Policy Option 3: Highest coverage and increased frequency 

Policy Option 3: Highest coverage and increased frequency 
Assessment criterion  Score 

Brief description 

Consistency with 
proportionality 
principle 

Assessment 
/ 
 (Pass 
uncertain 
/ fail) 

Pass 

Does the option go 
beyond what is 
necessary to 
satisfactorily achieve 
the objectives? 

The full set of mandatory aspects under option 3 relate to an 
extension of the coverage in certain areas, including of micro 
firms, improved timeliness, adapting templates for quality reports, 
aligning concepts and definitions, making GPG data compulsory 
and addressing emerging needs.  

To ensure compliance with the principle of proportionality, the 
intervention of the EU in the field of European statistics must 
ensure a higher level of coherence and comparability of the 
relevant LMB datasets.  

The option goes further than option 2 in particular in improving 
both timeliness and frequency of the publication of datasets. The 
frequency and timeliness were cited as key points of 
improvements by data users. Overall, the set of measures is not 
deemed to go beyond what is necessary to satisfactorily achieve 
the objectives because it covers areas where data users have 
expressed a need and addressed emerging needs that the 
evaluation found are currently missing. It also updates concepts, 
definitions and templates to ensure alignment. Such alignment 
can be considered reasonable. 

Under option 3, significant mandatory EU action is taken in a 
wide range of areas. It is reasonable to assess that Member States 
would not be able to cover those areas that the evaluation has 
found are gaps and limitations of the current regime. Several of 
the proposed measures concern coordination efforts (on 
definitions, templates, concepts) and addressing needs in any case 
already expressed in EU strategies. It is clear the Union would do 
better than the totality of Member States in this policy area. 

The most far-reaching option adopts an overhaul of the entire 
legal framework but the scope of the option is limited to what is 
necessarily required. The new legislation would rationalise the 
legal basis and hence be a simplification. 

Pass 

Is the scope of the 
option limited to those 
aspects that Member 
States cannot achieve 
satisfactorily on their 
own, and where the 
Union can do better? 

Are costs for the 
Union, national 
governments, regional 

Uncertain As part of option 3, considerable EU action is taken to cover 

significantly the shortcomings identified in the evaluation. There 
would be higher costs for measures that are currently not in place, 

83 

 
 
 
or local authorities, 
economic operators or 
citizens commensurate 
with the objectives of 
the initiative? 

Is the form of action 
(choice of instrument) 
as simple as possible 
and coherent with a 
satisfactory 
achievement of the 
objective and effective 
enforcement? 

increasing frequency and timeliness. These are generally 
commensurate to objectives: LCS and SES frequency cannot 
double without increasing the burden by a similar proportion. 
However, the increased frequency and timeliness entail sustained 
further efforts that may, strictly speaking, not all be necessary to 
meet objectives of the initiative.  

It is therefore somewhat uncertain if it passes the test of the costs 
being commensurate with the objectives of the initiative.  

Pass 

Under option 3, mandatory action is taken and this is done by 
producing a single new framework regulation.  

The mandatory nature of the collection of data, expansion of the 
coverage and addressing of emerging needs, as well as updating 
of concepts, definitions and templates for quality reports would 
render the overall framework more future-proof. It helps to 
achieve the objectives more satisfactorily than is currently the 
case through its legal streamlining (1 instead of multiple 
regulations). It expands the scope of LMB statistics but does not 
expand its current level of complexity.  

Option 3 therefore passes this test. 

Effectiveness 
achieving 
objectives: 

 (-- to ++)  

in 
policy 

++ 

SO1.1: Adapting the 
regulatory framework 
to allow flexibility in 
meeting emerging 
needs 

As part of option 3, the framework would clearly help in further 
adapting the framework to constantly evolving needs, sources and 
methods by considering extensively elements that were not part of 
the existing regime. 

SO1.2: To release 
more timely statistics  

++ 

The timeliness of the statistics will be significantly improved, in 
particular for the SES, LCI and LCS.   

++ 

SO1.3: To promote the 
use of innovative 
sources and methods of 
duly assessed quality 

++ 

SO2: Improving the 
coverage of statistics to 
whole economy and 
ensure exhaustive GPG 
data 

The  use  of  administrative  and  innovative  sources  will  be 
promoted by better reporting of their quality 

The coverage of statistics will be improved in particular for GPG 
data, creating better coverage of the economy through extending 
the LCS and SES to micro firms for all variables as well as to 
administration, new templates for quality reports, definitions. 

This helps to significantly improve the coverage and depth of 
statistics.  

84 

 
 
 
++ 

Consistency with related statistical domains would be improved.  

SO3: Improving the 
consistency with 
related statistical 
domains 

++ 

Impacts on 
fundamental rights 
including the 
promotion of equality 

Social impacts  

++ 

Sustainable 
Development Goals 

 ++ 

Considering EU strategies on equality, and the gender pay gap in 
particular, the impact on fundamental rights through collecting 
these types of data would be aided positively by this option.  

With any fundamental right drawbacks being limited, the overall 
assessment is positive. 

This option has the potential to increase the impact of LMB 
statistics and creating a stronger legal basis for collecting such 
data and increasing coherence with the current legal framework, 
specifically with Article 23 of the EU Charter, the European Pillar 
of Social Rights, Directive 2006/54 on the implementation of the 
principle of equal opportunities and equal treatment of men and 
women in matters of employment and occupation, the Gender 
Equality Strategy 2020-2025. The increased frequency of SES 
data collection would allow for more frequent provision of 
benchmarked GPG and better monitoring of the equality policies.  

Some of the proposed measures, such as mandatory collecting of 
data on gender pay would further contribute to modernising social 
statistics. Modernisation of this kind may be needed to support 
various Union actions, such as the promotion of social inclusion 
and the monitoring of social cohesion at national and regional 
levels. The European Pillar of Social Rights is about better 
delivering on rights for citizens towards a strong social Europe 
that is fair and inclusive. The increase of frequency of SES and 
LCS is an additional element with a social impact. 

In addition, there are positive effects with the mandatory 
collection of data on the gender pay gap, data, indices of hours 
worked and labour costs, pay schedules and additional variables 
in SES data. There would be a clearly net positive result for this 
criterion.   

SDG 5 on gender equality and SDG 10 on reduced inequalities 
were assessed under this option. Regulated data collection for 
GPG, has the potential to increase data accessibility on GPG data 
and provide policy makers with more up to date information to 
support policies in the area of gender equality and contribute to 
SDG 5 on gender equality. In addition, under this option SES data 
collection is extended to micro-enterprises and provided more 
frequently. This increases the coverage of economy and provides 
more frequent and accurate information on benchmarked gender 
pay gap and contributes to an unbiased calculation of SDG 

85 

 
 
 
indicator on gender equality.  

Under this policy option additional variables in SES identified as 
emerging need SES would be collected on a mandatory basis. 
This information could be used to support the calculation of 
SDGs scoreboard in relation to reduced inequalities.  

Coherence 
with 
overarching  objectives 
of EU policy 

 (-- to ++)  

Coherence 

 + 

Option 3 would address most of the shortcomings of the baseline 
in terms of coverage, covering emerging needs and further 
harmonisation of standards (definitions, concepts, templates for 
quality reports). A clear effort in collecting these types of data 
would better ensure meeting overarching EU objectives.  

It is expected that with the introduction of new variables (for 
instance, covering ‘pay schedule’) and mandatory collection of 
GPG data, LMB statistics will be fully aligned with flagship 
initiatives such as the EP and Council directive on minimum 
wages, the Commission proposal for the directive on pay 
transparency and Principle 6 of the European Pillar of Social 
Rights. 

Efficiency 

 + 

 See assessment below 

Option 3 offers the highest effectiveness but also comes at a high price. This is the most costly and 
burdensome option.  

The table below provides an overview of the increase in costs for NSI’s across datasets for NSI’s, 
for policy option 3 

Table 19.  Increase in costs for NSIs for policy option 3 

Total costs of baseline 
for NSIs (in EUR) 

Increase of NSI´s cost (in 
EUR) 

% Increase of Total 
costs  

JVS 
LCI 
LCS 
SES 
GPG 
Total LMB 

5,659,238 
9,318,641 
7,185,434 
7,386,671 
628,709 

30,178,693 

2,198,958 
1,379,390 
8,348,942 
7,409,460 
1,658 

19,338,408 

39% 
15% 
116% 
100% 
0% 

64% 

Participant responses in qualitative survey among NSI´s were balanced in relation to transmitting all 
LCS results earlier, at T+15 months instead of at T+18 months. Although 46% of respondents (12 
NSIs) noted a significant increase in cost every time the survey takes place, and 15% (4 NSIs) 
indicating cost increases when starting-up, 38% of responses (10 NSIs) also suggest no significant 
increase in cost would take place. 

86 

 
 
 
 
 
 
 
Costs associated with collecting SES data every two years instead of every four years will be high 
as a large majority of respondents (84%, 21 NSIs) noted a significant increase in cost every time the 
survey takes place. The remaining 16% (Iceland, Hungary, Denmark and Switzerland) noted no 
increase in costs. In terms of collecting LCS data every two years instead of every four years, a 
large majority of respondents (76%, 19 NSIs) indicated significant increases in costs every time the 
survey takes place. Portugal indicated significant costs when starting up and respondents from 
Ireland, Iceland, Denmark, Switzerland and Romania (20%) also noted no increase.  

Most respondents (60%, 15 NSIs) also noted an increase in costs associated with transmitting all 
SES results much earlier, at T+11 months (instead of T + 16 months) with a reference month 
change. 20% noted increases in costs when starting up (5 countries) and 20% noted no increases in 
cost.  

The table below provides an overview of the increase in costs for businesses across datasets 

Table 20.  Increase in costs for businesses for policy option 3 

Total costs of baseline 
for businesses (in 
EUR) 

Increase of businesses cost (in 
EUR) 

% Increase of total 
costs of businesses  

JVS 
LCI 
LCS 
SES 
GPG 
Total LMB 

4,472,272 
12,001,564 
10,703,029 
16,079,802 
0 
43,256,667 

2,715,790 
11,935 
15,187,811 
20,087,048 
0 
38,002,583 

61% 
0% 
142% 
125% 
0% 
88% 

Turning to the qualitative study, most respondents (64%, 16 NSIs) indicated a high increase in 
response burden due to doubling the SES frequency (every two years instead of every four years). 
Only five respondents (20%) indicated that SES data were already available with a bi-annual 
frequency.  

A similar response was provided as regards the impact of doubling the LCS frequency: 60% of the 
respondents (15 NSIs) noted high increases in response burdens while only 20% (5 NSIs) indicated 
that LCS was already collected every two years.  

As concerns collecting JVS data by occupation, it will cause high increase in burden according to 
67% of NSIs (16 replies), in 5 countries data by ISCO is collected already. Regional data (at NUTS 
1 level) for JVS is collected already in 11 countries (46% of NSIs). 4 of NSIs report possible high 
increase in burden.  

Results of the qualitative survey were more balanced as regards improving the timeliness of SES 
from T+16 months to T+11 months (T being the end of the reference year): 32% of respondents (8 
NSIs) indicated high increases in response burdens and similarly another 8 NSIs indicated no 
increase in response burden. Only 12% (3 NSIs) noted that the data were already available within 
the shorter deadline of T+11 months.  

For LCS datasets, responses suggest mixed impacts in terms of burdens associated with transmitting 
all LCS results earlier, at T+15 months instead of at T+18 months (T being the end of the reference 

87 

 
 
 
 
 
year). Two respondents (8%) noted a high increase in burden, 27% (7 NSIs) noted a medium 
increase in response burden and another two a low increase. The remaining 40% of respondents (10 
NSIs) noted no increases in response burdens. 

To summarize, option 3 would create a large increase (+88%) in the LMB response burden, This 
increase would be notably higher for LCS (+ 142%) and SES (+ 125%), mainly due to doubling the 
frequency of those costly data collections (+ the extension to micro-firms for LCS). Collecting job 
vacancy data by occupation and region would also have a large impact on the response burden. 

Overall assessment 

The overall assessment of option 3 is that it may pass the proportionality test, though its high level 
of ambition in frequency of publication may not necessarily be the least costly approach needed to 
meet objectives. The option ensures enhanced coherence with EU policies, ensures policy 
objectives are met and has positive social impacts. The option leaves no meaningful gaps with the 
identified set of problems and drivers.  

Option 3 is the most ambitious and effective among the policy options. It is also the most impactful 
option as it addresses all drivers, and the achievement of policy objectives is maximised even if 
implying a higher burden on data compilers as well as respondents The foreseen legislative changes 
under policy option 3 are likely to significantly impact all stakeholders. 

Indeed, the findings from the evaluation and stakeholder consultation have stressed the need for 
LMB statistics to adapt to new and emerging user needs, data sources, and methods. Option 3 offers 
an extension of the coverage of LMB statistics and the best timeliness and frequency in the richest 
(and most costly) sets of LMB data (SES and LCS). It also provides for detailed information on 
labour shortages by occupation and region.  

Option 3 fully captures the important actors and allows for the observation of socio-economic 
phenomena across the EU economy.  

The extension of both the SES and LCS scope to micro-firms would also fill the existing data gaps 
for this part of the economy. 

All these improvements would significantly enhance the scope and depth of policy research on 
earnings, labour costs and labour shortages. 

The addition of new data, improvements in timeliness, frequency and alignment of definitions 
would result in an increased satisfaction for data users leading to better evidence-based policy 
making with issues such as discrimination and inequalities being better covered by European 
official statistics.  

On the downside, this would create much higher costs for NSIs and a significant increase in the 
burden for respondents.  

88 

 
 
 
 
 
 
I. Overview of Benefits (total for all provisions) – Preferred Option 

Description 

Amount 

Comments 

Direct benefits 

Better EU level timeliness and completeness of  statistics across all 
Member States 

Not quantified  EU level institutional users 

Better EU level comparability and coherence of statistics across all 
Member States 

Not quantified 

Underlying data on earnings and related indicators not biased 

Not quantified 

Better data evidence for monitoring and policy making 

Not quantified 

Better EU level timeliness and completeness of  statistics across all 
Member States 

Not quantified  Other  institutional  users  (national 

and sub-national levels) 

Improved comparability of statistics with other Member States 

Not quantified 

Underlying data on earnings and related indicators not biased 

Not quantified 

Improved comparability of statistics with other Member States 

Not quantified  Statistics producers (NSIs) 

Underlying data on earnings and related indicators not biased 

Not quantified 

Reduced  administrative  burden 
administrative and/or other data sources) 

(through 

improved  use  of 

Not quantified 

Reduced administrative burden  (trough limitation of the    LCS data 
collection on apprentices to all EU Member States except Germany, 
Denmark, France, Italy and Austria)  

Not quantified 

Reduced  administrative  burden  (relating  to  regulatory  changes  to 
adapt to evolving policy needs) 

Not quantified 

Better EU level timeliness and completeness of  statistics across all 
Member States 

Not quantified  General public 

Better EU level comparability and coherence of statistics across all 
Member States 

Not quantified 

Underlying data on earnings and related indicators not biased 

Not quantified 

Reduced  administrative  burden  (relating  to  regulatory  changes  to 
adapt to evolving policy needs) 

Not quantified  Eurostat 

Reduced administrative burden (related to quality assurance) 

Not quantified 

Indirect benefits 

Reputational gains from improved policy-making and EU decision-
making in general Not quantified EU level institutional users 

Not quantified  EU level institutional users 

Reputational  gains  from  improved  visibility  and  transparency  in 
a European context  

Not quantified  Other  institutional  users  (national 

and sub-national levels) 

Increased ability to meet legal requirements 

Not quantified  Statistics producers (NSIs) 

Increased staff skills  

Not quantified 

Benefits from improved policy-making 

Not quantified  General public 

Advancement of Eurostat mission ‘to provide high quality statistics 
and data on Europe’ 

Not quantified  Eurostat 

Improved collaboration with EU level policy users 

Not quantified 

89 

 
 
 
 
 
Reputational  gains  from  enhanced 
European statistics free for all 

international  standing  of 

Not quantified 

Administrative cost savings related to the ‘one in, one out’ approach* 

The  simplification  of  the  LCS  data  collection  on  apprentices  will 
lead to reduction of the total time spent by the  sampled enterprises 
in filling LCS questionnaires. 

Not quantified  The  time  spent  be  the  enterprises 
will  be  will  be  reduced  by  27% 
(6/22)  for  all  EU  Member  States 
except  Germany,  Denmark,  France, 
Italy and Austria. 

(1) Estimates are gross values relative to the baseline for the preferred option as a whole (i.e. the impact of individual 
actions/obligations of the preferred option are aggregated together); (2) Please indicate which stakeholder group is the 
main recipient of the benefit in the comment section;(3) For reductions in regulatory costs, please describe details as to 
how the saving arises (e.g. reductions in adjustment costs, administrative costs, regulatory charges, enforcement costs, 
etc.;);  (4)  Cost  savings  related  to  the  ’one  in,  one  out’  approach  are  detailed  in  Tool  #58  and  #59  of  the  ‘better 
regulation’ toolbox. * if relevant 

II. Overview of costs – Preferred option 

Citizens/Consumers 

Businesses 

Administrations 

One-off 

Recurrent 

One-off 

Recurrent 

One-off 

Recurrent 

N/A 

N/A 

N/A 

N/A 

234,391 

N/A 

N/A 

N/A 

N/A 

N/A 

91,075 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

4,618,254 

N/A 

N/A 

N/A 

N/A 

N/A 

3,282,045 

N/A 

Costs related to the ‘one in, one out’ approach 

Action (a)   

Direct adjustment 
costs 

Direct 
administrative 
costs 

Direct regulatory 
fees and charges 

Direct 
enforcement costs 

Indirect costs 

Direct adjustment 
costs  

Total   

Indirect 
adjustment costs 

Administrative 
costs (for 
offsetting) 

(1)  Estimates  (gross  values)  to  be  provided  with  respect  to  the  baseline;  (2)  costs  are  provided  for  each 
identifiable  action/obligation  of  the  preferred  option  otherwise  for  all  retained  options  when  no  preferred 
option  is  specified;  (3)  If  relevant  and  available,  please  present  information  on  costs  according  to  the 
standard  typology  of  costs  (adjustment  costs,  administrative  costs,  regulatory  charges,  enforcement  costs, 
indirect  costs;).  (4)  Administrative  costs  for  offsetting  as  explained  in  Tool  #58  and  #59  of  the  ‘better 
regulation’ toolbox. The total adjustment costs should equal the sum of the adjustment costs presented in the 
upper part of the table (whenever they are quantifiable and/or can be monetised). Measures taken with a view 
to  compensate  adjustment  costs  to  the  greatest  extent  possible  are  presented  in  the  section  of  the  impact 
assessment report presenting the preferred option. 

90 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
3.  RELEVANT SUSTAINABLE DEVELOPMENT GOALS 

III. Overview of relevant Sustainable Development Goals – Preferred Option(s) 
Relevant SDG 

Expected progress towards the Goal 

Comments 

SDG 5 – Gender equality 

Assured  data  evidence  for  monitoring  and 
relevant policies 

Gender pay gap data delivered based on the 
legal  requirements  (measures  GPG1  and 
GPG2) 

91 

 
 
 
 
 
 
ANNEX 4: ANALYTICAL METHODS 

Detailed approach to the quantification of costs (efficiency) 

The  costs  estimated  as  part  of  this  evaluation  were  those  associated  with  the  current  LMB 
framework specifically focusing on data collections defined by:  

  Council Regulation (EC) No 530/1999 of 9 March 1999 concerning structural statistics on 

earnings and labour costs, (applicable for SES and LCS),  

  Regulation  (EC)  No  450/2003  of  the  European  Parliament  and  of  the  Council  of  27 

February 2003 concerning the labour cost index (LCI) 

  Regulation  (EC) No 453/2008  of the European Parliament and of the Council of 23 April 

2008 on quarterly statistics on Community job vacancies (JVS) 

In addition the costs of voluntary gender pay gap data collection were assessed. 

In order to get information on the current costs and the burden of the data collections, a survey was 
launched by Eurostat for National Statistical Authorities.  

The questionnaire was structured along three parts, covering respectively:  

(1) the costs for compilers (direct and indirect, both including FTE), 

(2) the time per respondent (in most of the cases the respondent in LMB statistics is an enterprise, 
few  countries  however  collect  data  for  SES  directly  from  the  employees).  For  the  sake  of 
simplification, all costs for respondents are treated as costs of businesses. 

(3) the time for all responding units. For the sake of simplification, all respondent related costs are 
treated as businesses costs. 

Countries  were  asked  to  report  the  whole  costs  and  burden  for  scenario  of  no  changes  in  the 
legislation, and for the possible policy options,  both the direct and indirect costs, after converting 
occupied posts in Full Time Equivalents (FTEs37) Costs had to be reported in national currency and 
were converted into euros according to the latest exchange rates38 available. The survey aimed to 
cover the whole production cycle - from the preparation of collecting the information via a survey 
or  administrative  sources,  applying  the  corresponding  legislation,  the  methodological  work,  the 
verification  of  the  data  in  the  country,  all  work  related  to  dissemination  -  until  the  moment  of 
sending the data to Eurostat. 

37  FTE:  Full  Time  Equivalents  varies  (in  respect  of  working  days  and  working  hours  per  day)  across  countries,  it  is 
proposed to use the following standards: one year corresponds to 215 working days (used as well in Commission’s unit 
cost  methodology), and one  working day equals 8 hours  worked. However, NSIs are  free to decide to use their  own 
(country  wise)  definition  of  ‘FTE’.  In  that  case,  the  NSI  was  invited  to  communicate  (for  each  survey)  how  many 
working days and hours one ‘FTE’ corresponded in the reporting country. 

38 https://appsso.eurostat.ec.europa.eu/nui/show.do?dataset=ert_bil_eur_m&lang=en 

Euro/ECU exchange rates - monthly data [ert_bil_eur_m] extracted on 05 May 2021. 

92 

 
 
 
                                                 
On burden, countries were asked to report on time spent annually per respondent in minutes and of 
time  spent  annually  by  all  respondents.  The  results  were  requested  to  be  annual  to  account  for 
differences  in  frequencies  of  LMB  data  collections  (quarterly,  yearly,  4  yearly).  The  burden  was 
requested to be provided only in relation to scope required by the EU.  

Eurostat has estimated the cost and burden for enterprises to provide data for LMB data collection.  

For  costs  of  compliers,  (NSI),  EU  totals  were  derived  as  a  simple  sum.  When  a  country  did  not 
report any  costs or when the results  had not  been  confirmed in  the validation process,  the values 
were imputed using the results from a country with a similar number of employees. 

Given the low country coverage of the survey on burden by median time spend by all responding 
units, the values for missing countries were imputed by the EU median value calculated based on 
the  available  countries  information.  To  monetise  burden  of  respondents,  time  for  all  responding 
units in hours was multiplied by the mean hourly labour costs for the country concerned. It should 
also be noted that in some cases authorities extract data from administrative resources or data are 
derived from other surveys. 

The  data  from  compilers  were  complemented  by  results  of  study  from  the  ICF  as  no  clear 
distinction  of  one-off  costs  and  recurrent  costs  were  available  from  the  compilers  survey.  The 
assumptions used for this assessment are provided in the Annex IV 

93 

 
 
 
 
 
ANNEX 5: ASSUMPTIONS USED FOR THE DISTRIBUTION OF COSTS 
TO THE BR TYPOLOGY 

The  contract  support  study  on  this  impact  assessment  has  assessed  a  total  of  three 
options:  

Option 1: Reliance on the voluntary nature of contributions 

Option 2: High coverage, better timeliness and other measure 

Option 3: Highest coverage and increased frequency 

Costs have been considered for three main stakeholder groups, namely 1) Member States 
and  their  National  Statistical  Institutes  (NSIs),  2)  the  European  Commission,  including 
Eurostat  specifically  and  3)  data  producers/businesses.  The  cost  of  businesses 
participating  in  the  data  collection  for  all  three  policy  options  were  assessed  in  the 
Eurostat  study  conducted  with  the  NSIs  (as  described  in  the  Annex  IV).  Similarly,  the 
baseline  costs  of  LMB  were  assessed  for  NSIs  and  businesses  in  the  same  study.  The 
results  collected  as  annual  to  account  for  differences  in  frequencies  of  LMB  data 
collections  (quarterly,  yearly,  4  yearly).  And  in  the  consolidation  of  results,  they  were 
considered  as  recurrent  and  related  to  the  data  collections  for  the  NSIs  and  costs  for 
participating in surveys for the businesses.  

Assumptions related to other types of costs (not related to data collection or participation 
of businesses in the LMB surveys) are summarised in the Table 1.  

Further assumptions used (e.g. the hourly costs rates for the one-off costs in the NSIs) are 
annexed to the ICF study report.   

Benefits  were  generally  not  appropriate  for  quantification.  For  example,  the  benefits  to 
non-institutional data users from increased access to high quality labour market statistics 
on  businesses  would  be  challenging  to  quantify  since  this  would  depend  on  several 
additional  factors,  such  as  how  this  data  would  be  used  or  the  cost  of  accessing  data 
through alternative sources. Therefore, estimates for benefits are not available. 

94 

 
 
1.  DETAILED OVERVIEW OF ESTIMATE COSTS 

EC/MS/ 

Cost category  Cost item 

Stakeholder
s affected 

Type 

Value 
(EUR) 

Description of assumption 

Comments/not
es 

 Policy Option 1 

EC 

Administrative 
costs 

EC 

Compliance 
costs 

a 
and 

Developing 
Regulation 
implementing 
particular for GPG) 

Framework 
amending 
(in 

legislation 

Eurostat 

One-off cost  

 28,545   2 EU officials (AD10) * 20 days 

value in EUR  

Monthly salary for AD10 is 9,000 

22  days  worked  per  month  (based  on  Eurostat 
2019: average of 36.2 hours worked per week) 

Monitoring compliance by MS 

Eurostat 

Recurrent cost  

 8,182   2 EU officials (AD10) * 10 days 

value in EUR  

MS 

MS 

MS 

Administrative 
costs 

Adaptation  and  preparation 
revised text of the LMB FR 

One-off cost  

for 

The 27 MS 
bound by the 
FR 

Monthly salary for AD10 is 9,000 

22 days worked per month (based on Eurostat 
2019: average of 36.2 hours worked per week) 

 45,537   220 days worked per year (based on Eurostat 

value in EUR  

2019: average of 36.2 hours worked per week)" 

Administrative 
costs 

Compliance 
costs 

Issuing guidance and training. 

Communicate the change. 

27 MS 
affected 

27 MS 
affected 

One-off cost  

 7,081   2 MS officials for 10 days 

value in EUR  

One-off cost  

 88,315   4 MS officials for 8 days  

value in EUR  

95 

 
 
EC/MS/ 

Cost category  Cost item 

Stakeholder
s affected 

Type 

Value 
(EUR) 

Description of assumption 

Comments/not
es 

MS 

MS 

Compliance 
costs 

Data collections 

This would 
affect all MS 
bound by 
legislation 

Ongoing cost 

66,814   Value based on Eurostat survey 

value in EUR  

Administrative 
costs 

Reporting to EU 

This would 
affect all MS 

Ongoing cost 

6,900  Derived from the baseline assumption re FTE 
for reporting (i.e. 1 official per MS 2.5 days per 
year) 

value in EUR  

Businesse
s 

Costs for 
participating in 
the surveys 

 Policy Option 2 

EC 

EC 

Administrative 
costs 

Compliance 
costs 

This would 
affect the 
businesses 
selected 

Recurring 

 92,365  Estimated at 2% the cost of PO 2 considering 

value in EUR  

that GPG data (the only mandatory element) is 
roughly 2% of the baseline costs for NSIs. 

a 
and 

Developing 
Regulation 
implementing 
particular for GPG) 

Framework 
amending 
(in 

legislation 

Eurostat 

One-off cost  

 35,682  2 EU officials (AD10) * 25 days 

Monthly salary for AD10 is 9,000 
22 days worked per month (based on Eurostat 
2019: average of 36.2 hours worked per week)  value in EUR  

Monitoring compliance by MS 

Eurostat 

One-off cost  

 12,273  2 EU officials (AD10) * 15 days 

value in EUR  

MS 

Administrative 
costs 

Adaptation  and  preparation 
revised text of the LMB FR 

One-off cost  

for 

The 27 MS 
bound by the 
FR 

Monthly salary for AD10 is 9,000 
22 days worked per month (based on Eurostat 
2019: average of 36.2 hours worked per week) 

 91,075  Derived from the baseline assumption re FTE 
for the transposition of the LMB into national 
law per MS (i.e.  2 official per MS, 5 to 10 days of 
their time on this activity per month, 6 months 

value in EUR  

 
 
 
 
EC/MS/ 

Cost category  Cost item 

Stakeholder
s affected 

Type 

Value 
(EUR) 

Description of assumption 

Comments/not
es 

Here we assume that transposition of 
amendments will take 30% of the total time 
required to transpose the whole LMB initially. 

One-off cost  

 110,394  2MS officials for 20 days 

One-off cost  

 88,315  4 MS official for 8 days 

value in EUR  

value in EUR  

Recurring 

3,259,423 Value based on Eurostat survey 

value in EUR  

Recurring 

 10,349  Derived  from  the  baseline  assumption  re  FTE 
for reporting (i.e. 1.5 official per MS 2.5 days per 
year) 

value in EUR  

Recurring 

 4,618,254  Value based on Eurostat survey 

value in EUR  

"27 MS 
affected 

"27 MS 
affected 

"27 MS 
affected 

"27 MS 
affected 

This would 
affect the 
businesses 
selected 

MS 

MS 

MS 

MS 

Administrative 
costs 

Issuing guidance and training. 

Compliance 
costs 

Compliance 
costs 

Communicate the change. 

Data collections 

Administrative 
costs 

Reporting to EU 

Businesse
s 

Costs for 
participating in 
the surveys 

 Policy Option 3 

EC 

Administrative 
costs 

a 
and 

Developing 
Regulation 
implementing 
particular for GPG) 

Framework 
amending 
(in 

legislation 

Eurostat 

One-off cost  

 42,818  2 EU officials (AD10) * 30 days 

value in EUR  

Monthly salary for AD10 is 9,000 
22 days worked per month (based on Eurostat 
2019: average of 36.2 hours worked per week) 

 
 
 
EC/MS/ 

Cost category  Cost item 

Stakeholder
s affected 

Type 

Value 
(EUR) 

Description of assumption 

Comments/not
es 

Compliance 
costs 

Monitoring compliance by MS 

Eurostat 

Recurring costs  

 13,909  2 EU officials (AD10) * 17 days 

value in EUR  

EC 

MS 

MS 

MS 

MS 

MS 

Administrative 
costs 

Adaptation  and  preparation 
revised text of the LMB FR 

Administrative 
costs 

Issuing guidance and training. 

Compliance 
costs 

Compliance 
costs 

Communicate the change. 

Data collections 

Administrative 
costs 

Reporting to EU 

Businesse
s 

Costs for 
participating in 
the surveys 

One-off cost  

for 

The 27 MS 
bound by the 
FR 

Monthly salary for AD10 is 9,000 
22 days worked per month (based on Eurostat 
2019: average of 36.2 hours worked per week) 

 106,254  Derived from the baseline assumption re FTE 
for the transposition of the LMB into national 
law per MS (i.e.  2 official per MS, 7.5 days of 
their time on this activity per month, 6 months 
Here we assume that transposition of 
amendments will take 35% of the total time 
required to transpose the whole LMB initially. 

value in EUR  

One-off cost  

 110,394  2 MS officials for 20 days 

value in EUR  

One-off cost  

 88,315  4 MS official for 8 days 

value in EUR  

Recurring 

19,021,716 Value based on Eurostat survey 

value in EUR  

Recurring 

 11,729  Derived  from  the  baseline  assumption  re  FTE 
for reporting (i.e. 1.7 official per MS 2.5 days per 
year) 

value in EUR  

Recurring 

38,002,583  Value based on Eurostat survey 

value in EUR  

"27 MS 
affected 

"27 MS 
affected 

"27 MS 
affected 

"27 MS 
affected 

This would 
affect the 
businesses 
selected 

 
 
 
 
1.1.1.  Mapping of the costs categories to typology used in the Annex II 

Commission  

NSIs 

Businesses 

One-off 

Recurrent 

One-off 

Recurrent 

One-off 

Recurrent 

Direct  adjustment 
costs 

Amending the 
Framework 
Regulation and 
Implementing 
Regulations 

Direct 
administrative 
costs 

Direct  regulatory 
fees and charges 

Direct 
enforcement costs 

Indirect costs 

Communicate the 
change + Issuing 
guidance and 
training 

Adaptation and 
preparation for 
revised text of the 
LMB framework 
regulation 

Monitoring 
compliance 

Data collections + 
Reporting to the EU 

Costs of for 
participation in surveys