I am a member of the Finnish Council of Regulatory Impact. We are an independent body - but in the Prime Minister’s office. Similar organisations have been established also for example in Germany, the UK and Sweden.

Our task is to evaluate how the evaluation of primarily the economic impact of new legislation has been performed. It is of course clear that environmental and democracy-strengthening aspects are even more important – but here I will focus on the economy.

The approach should be that legislative work starts out with evaluating in broad terms (exact figures are not really possible) of the costs and benefits of the package in question – separately and summed for enterprises, the public sector and households (who are the final stakeholders after all – and should have a €/hour element for time saving). Projects with the best net impact should be given the highest priority. 

In many cases it is clear that dynamic effects can be seen as important (learning 3.0, health, Single Market, innovation, data driven economy, tax evasion etc). These are difficult to include in a more traditional cost-benefit analysis. To keep clarity it may be advisable to include a separate table of these impacts.

One important aspect in our work is to check if best practises in other countries have been evaluated (f course we hope that other countries look at our solutions – the best… as well). Another aspect is that at least the second best solution has been evaluated. On this note I keep in mind the Ministry of Finance principle nbr 7 – that existing private or public solutions (ready habit, economy of reuse) should be used before any new investments are made. The prime victory in this field is of course the use of bank-e-id also in public sector services. Over 100 million times used this 100year anniversary Finland (would be over 7 billion times on EU-level).

From this – avoiding doubled investments I came to the now ready real time Single Market payment infrastructure:https://www.ebaclearing.eu/services/instant-payments/introduction/

Evaluation of this: strongly standardized, country neutral, PAN-EU by-design, good for domestic and SEPA-wide payments, user driven, PSP-including, euro-in and euro-out solutions should for all reasons be given very high priority.

My question is how much should then be spent on possibly competing – possibly not-very-much-adding public sector driven alternatives.