applied policy (average score of 11) and its conservative Doha offer (67), remained cautious in the TPP (39).

In comparing TPP commitments with the policy status quo, our measures may underestimate the liberalizing impact of the TPP in two ways. First, the TPP negotiating process could already have induced changes in applied policies before the date at which we measure the policy status quo. Second, some of the TPP commitments specify liberalization several years after the completion of the agreement whereas we focus on changes in policies at the conclusion of the agreement.

# Changes in the “status quo”:  TPP induced?

The TPP was concluded in October 2015 after seven years of negotiations. Could it be the case that important national reforms were induced by the TPP negotiations, became part of applied national policy and therefore are not credited to the TPP when we compare commitments under the agreement with applied policy?

Our applied policy information is from 2008, about the time the TPP negotiations began, and we updated applied policy information for a number of TPP members as of 2015, when the TPP agreement was concluded. We find that between 2008 and 2015, a few countries undertook reforms in their key services sectors. For example, Mexico’s telecommunications policy was reformed in 2013, and Malaysia carried out several services sector reforms between 2009 and 2013 in financial services, telecommunications, and professional services. Both countries removed certain restrictions on foreign ownership in these sectors. These reforms are discussed in more detail in the sectoral discussions below.

Most evidence suggests that the primary impulse in favor of the new laws in both countries was an emerging national consensus in favor of reform not necessarily connected to the TPP. But it is possible that the governments of the two countries were sensitive to demands from TPP negotiating partners, and chose to enact reforms in anticipation of the conclusion of the negotiations. In any case, most reforms in both countries offer improved access on an MFN basis and their benefits were not limited to TPP countries.

# Commitment to future liberalization

Some countries used the TPP to commit to liberalization not immediately but in the future. The rationale may have been to give domestic firms time to prepare for foreign competition. Vietnam’s TPP commitment in retail distribution states that the Economic Needs Test (ENT) currently applied for the establishment of outlets for retail services would be phased out five years after the date of entry into force of the agreement for Viet Nam. In telecommunications services, Vietnam has promised to relax or eliminate foreign equity restrictions over the same time frame. Similar assurances to phase‐in liberalization appear in the financial sector commitments of Malaysia. Cross‐border direct insurance of risks relating to directors’ and officers’ liability is allowed five years after the date of entry into force of the Agreement, and any measures relating to the development of the pension system in Malaysia will cease to be applicable three years after the date of entry into force of this Agreement (Annex III of Malaysia, page 16).

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