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The evaluation of German federal laws in theory and praxis Dipl.-Vw. Hanna Willwacher, M.A. Contents 1) InGFA 2) Background - What is RIA? 3) Ex-ante RIA in Germany 4) Ex-post RIA in Germany 5) An international comparison of RIA 6) What happens

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The evaluation of German federal laws in theory and praxis

Dipl.-Vw. Hanna Willwacher, M.A.

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Contents 1) InGFA 2) Background - What is RIA? 3) Ex-ante RIA in Germany 4) Ex-post RIA in Germany 5) An international comparison of RIA 6) What happens with the RIA results?

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  • 1. InGFA

» Unit of the German Research Institute for Public Administration

(FÖV), Speyer

» InGFA was founded in 2009 by Prof. Ziekow and Prof. Böhret » Research-based consultancy solutions for all levels of government

and public administration

» Jointly funded by the German states and the federal government,

additional funds through external sources

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  • 2. Background – What is RIA?

» Governments build the foundations on which people build their lives:

security, education, infrastructure, health services etc.

» Governance occurs mainly through legislation, designed based on

educated guesses of how people will respond

» But often governments have to return to problems they thought had

already been solved or to correct perverse outcomes that were not anticipated (see BIT 2016) How can the design of legislation be improved?

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  • 2. Background – What is RIA?

» Regulatory Impact Analysis (RIA) is a systematic approach to

critically assessing the positive and negative effects of proposed and existing regulations and non-regulatory alternatives (OECD)

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  • 2. Types of RIA (OECD)

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Legislative Process

  • Examination whether and how to regulate to achieve public

policy goals

  • Improve the design of regulations by identifying and

considering the most efficient and effective regulatory approaches, including the non-regulatory alternatives, before a decision is made

  • Objective: Identification of the best regulatory approach
  • Scrutiny of regulations that already

entered into force

  • Examination of target achievement,

positive and negative outcomes

  • Objective: Ensure that regulations are

effective and efficient regulatory intent draft regulation regulation

Regulatory Impact Assessment Evaluation ex-ante ex-post

Source: own representation based on OECD 2012/2015.

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  • 2. Types of RIA (German Approach)

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Legislative Process

  • Development of

regulatory options

  • Assessment whether

and how to regulate

  • Objective:

Identification of the best (regulatory) approach

  • Assessment of a

draft regulation or parts of it

  • Objective:

Optimization of a given draft

  • Scrutiny of

regulations that already entered into force

  • Objective: Ensure

that regulations are effective and efficient regulatory intent draft regulation regulation

Regulatory Impact Assessment (prospective) Regulatory Impact Assessment (concomitant) Evaluation (retrospective) ex-ante ex-post

Source: own representation based on Böhret/Konzendorf 2001.

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  • 3. Ex-ante RIA

» According to § 42 (1) GGO bills consists of: › the draft text of the law (bill) › the explanatory memorandum for the bill (explanatory

memorandum)

› an introductory summary (cover sheet) » According to § 43 (1) V GGO the memorandum must explain the

regulatory impacts in accordance with § 44 GGO

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Requirements according to the joint rules of procedure of the Federal ministries (GGO)

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  • 3. Ex-ante RIA

» “Regulatory impacts mean the main impacts of a law: This covers its

intended effects and unintended side-effects.”

» “The account of the foreseeable regulatory impacts must be drawn

up in consultation with the respective competent Federal Ministries (…) Whether the impacts of the proposal correspond to a long-term development, and in particular which long-term impacts the proposal has shall be indicated.”

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§ 44 (1) GGO

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  • 3. Ex-ante RIA

» The impacts on the public budgetary income and expenditure as

well as on the budgets of the Länder and local authorities

» The compliance costs to the public, industry, and public

administration as defined in § 2 of the Act on Establishing the National Regulatory Control Council (NKRG)

» The costs to industry, and to small and medium-sized

enterprises in particular

» The impacts of the law on unit prices and price levels in general » The impacts of the law on the consumer » Further impacts upon request

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§ 44 (2-6) GGO

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  • 3. Ex-ante RIA

» Equality between men and women should be promoted by all

political, legislative and administrative actions of the Federal Ministries in their respective areas (gender mainstreaming) (§ 2 GGO)

» The language used in bills must be correct and understandable to

everyone as far as possible (§ 42 (5) S.1 GGO)

» Before a bill is submitted to the Federal Government for adoption, it

must be sent to the Federal Ministry of Justice to be examined in accordance with systematic and legal scrutiny (§ 46 (1) GGO)

» RIA for legislative projects of the European Union (§ 74 (3) GGO)

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Further Requirements GGO

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  • 3. Ex-ante RIA

» In addition, there are further criteria that can be derived from other

documents such as the “Demography-check” (letter of the Federal Ministry of the Interior); One-in, one-out rule (cabinet resolution); etc.

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Additional Requirements

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  • 3. Ex-ante RIA

» As “none” was normally entered in the cost column of draft laws, the

National Regulatory Control Council (NKR) was established as an independent supervisory body in 2006 (see NKR 2015b)

» The NKR examines in particular the description of the compliance

costs of new regulations for citizens, the business sector and public administration in terms of comprehensibility and correct methodology, as well as the description of the other costs to businesses, especially for small and medium-sized enterprises (§ 1 (3) NKRG)

» Initially, only the bureaucracy costs of laws were examined

(information and documentation responsibilities); since 2011 expanded to include “compliance costs” (determined via SCM)

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The National Regulatory Control Council

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  • 3. Ex-ante RIA

» Term compliance costs embraces the total measurable time and

costs incurred by the citizens, the business sector and administration through a provision under Federal law

» A differentiation is made between the one-off adjustment costs and

the annual costs

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Compliance Costs

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  • 3. Ex-ante RIA

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Exkursus: Compliance Costs – Standard Cost Model (SCM)

Source: Federal Statistical Office 2012.

costs x number of cases = annual compliance costs of an obligation/ a process costs (per case) number of cases (per year) material costs (if necessary pro rata) number of addressees2 frequency per year2 if necessary: cluster obligations to form processes/ form case groups

  • bligation 1 (individual regulation)

legislative provision/proposal (statutory law, ordinance, administrative regulation) time

  • bligation 3 to n

etc.

 Compliance costs of obligations/a process 1 to n = compliance costs of the provision/proposal

(per year) etc. etc. etc. wage rate1

  • bligation 2

Identification pattern

1 does not apply to citizens 2 if required to identify the number of cases

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  • 3. Ex-ante RIA

» The examination by the NKR can extend beyond the examination

pursuant to § 1 (3) NKRG to include the methodologically appropriate implementation and comprehensible presentation of the following aspects (§ 4 (1) NKRG):

  • 1. comprehensible presentation of the intention of and need for the

regulation,

  • 2. consideration of other possible solutions,
  • 3. consideration regarding the time of entry into force, time limits, and

evaluation,

  • 4. considerations of simplifications of law and administration,
  • 5. the extent to which, in the case of the implementation of a directive or
  • ther statutory instrument of the European Union, further-reaching

regulations are put in place.

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The National Regulatory Control Council

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  • 3. Ex-ante RIA

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The National Regulatory Control Council

Draft regulation

Source: based on NKR 2015b.

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  • 3. Ex-ante RIA

» The National Regulatory Control Council examines the draft

regulations of the Federal Ministries before their submission to the Federal Cabinet (§ 4 (3) NKRG)

» The National Regulatory Control Council examines draft regulations

  • f the Bundesrat if they are transmitted to it by the Bundesrat. It

examines draft acts from the floor of the Bundestag when requested so to do by the parliamentary group or member of the Bundestag proposing the legislation (§ 4 (3) NKRG)

» If the National Regulatory Control Council comments on the bill

(§ 45 (2) GGO), its comments shall be attached to the bill; the same applies to comments by the Federal Government (§ 42 (1) S. 2 GGO)

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The National Regulatory Control Council

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  • 3. Ex-ante RIA

» At the federal level exist different types of guidelines, manuals, and

tools for the various criteria to help legislators scrutinize the impacts

  • f their drafts and to sensitize them to possible outcomes

» Additionally there are aspirations to integrate further criteria/manuals

into the law-making process

» Examples: “Youth Check“; additional compliance costs

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Manuals

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  • 3. Ex-ante RIA

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Manuals (extract)

Assessment Criteria Provision Manual, Guideline, Handbook Gender mainstreaming-Check § 2 GGO Manual: Gender Mainstreaming in the Conduct of Legislation Compliance costs § 44 (4) GGO; § 2 NKRG (1) Erbex-Tool (2) Guidelines on the Identification and Presentation of Compliance Costs in Legislative Proposals by the Federal Government (3) Manual for Participation of Municipalities Other costs to businesses, especially for small and medium-sized enterprises § 44 (5) No. 1 GGO (1) SME Test (2) Guideline Economic Costs and Impacts on Price Levels Legal scrutiny § 42 (4 )GGO; § 46 GGO Manual for Drafting Legislation One In, One-Out criterion Cabinet Decision (2014) Concept of an One-in, One-out Rule Demography-Check Letter of the Federal Ministry of the Interior (2014) Manual: Conduction of Regulatory Impact Assessments (Appendix) Language Scrutiny § 42 (5) GGO Manual for Drafting Legislation Source: own representation.

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  • 3. Ex-ante RIA

» Digitalisation of the legislative procedure (“eGesetzgebung“) » Transformation of the current RIA criteria into a standardized

assessment procedure

» On behalf of the Federal Ministry of the Interior InGFA carries out: › Elicitation of all inspection requirements in legislative procedure › Documentation of all manuals, guidelines, tools at the federal level › Design of a concept for a test cascade › Development of a proposal for a unitary testing procedure for RIA

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Current Challenges

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  • 3. Ex-ante RIA

» Consolidation and digitalisation of manuals, guidelines and

handbooks concerning the legislative procedure

» Development of a “Youth Check” to systematically identify the

consequences of federal measures on young people

» Development of a tool for the assessment of further compliance costs

for businesses

» Dialogue with experts on legal act for environmental inspection –

exchange on possible transformations in the enforcement of EU environmental law

» Development of a tool for RIA in the Evangelical Church in the

Rhineland (EKiR)

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Our projects

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  • 4. Ex-post RIA

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Source: based on NKR 2015b.

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  • 4. Ex-post RIA

» Reassessment by the Federal Statistical Office two years after the

legislative act has entered into force – compliance costs only

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Reassessment

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  • 4. Ex-post RIA

» Provision in the explanatory memorandum of the draft regulation

according to § 44 (7) GGO

» Systematic evaluation of laws with high compliance costs

(since 2013)

» Inclusion of evaluation clauses in a regulation › by the lead federal ministry › by the German Bundestag » (Constitutional evaluation duties)

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In what cases is an evaluation carried out?

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  • 4. Ex-post RIA

» “In the explanatory memorandum for the bill, the lead Federal

Ministry must state whether and, if so, after what period of time, a review is to be held to verify whether the intended effects have been achieved, whether the costs incurred are reasonably proportionate to the results, and what side-effects have arisen.”

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§ 44 (7) GGO

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  • 4. Ex-post RIA

» Significance of legislative proposal/regulation:

Annual compliance costs of at least (threshold)

› €1 million or 100,000 hours for citizens, or › €1 million for businesses, or › €1 million for public authorities » Based on reassessment (evaluation may be prompted by the

reassessment of compliance costs concluding that the actual costs exceed one of the thresholds/ if reassessment finds the actual costs also fall short of the threshold, the ministry may review the evaluation considerations in its draft)

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Systematic evaluation (Decision of State Secretaries 2013)

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  • 4. Ex-post RIA

» Evaluation should take place between three and five years after a

legislative proposal has come into force.

» The final time of the evaluation is at the discretion of the lead

ministry.

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Systematic evaluation (Decision of State Secretaries 2013)

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  • 4. Ex-post RIA

Evaluation criteria:

» Progress made in achieving the objectives (main criterion) » Side-effects of a regulation (positive or negative) » Take-up of a regulation » Practicality of a regulation » Considerations of whether the costs are proportionate to the results

(not necessarily monetary; advantages/disadvantages)

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Systematic evaluation (Decision of State Secretaries 2013)

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  • 4. Ex-post RIA

» BUT: “An evaluation is not predetermined in terms of its depth (e.g.

legislative proposals as a whole, parts of a framework law, some areas of an original act, enforcement), methodology (ranging from an internal to a scientific evaluation) or size (from a two-page report to a detailed report, also depending on the available resources). These decisions are up to the lead department.”

» The evaluation reports are to be submitted to the ministries

concerned as well as the Federal Government Coordinator for Bureaucracy Reduction and Better Regulation and the National Regulatory Control Council

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Systematic evaluation (Decision of State Secretaries 2013)

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  • 4. Ex-post RIA

» Federal Government had conducted seven pilot projects by the end

  • f 2014

» Conclusions (see NKR 2015a): › Objectives were not specified in sufficiently concrete terms -> NKR

will request the specification of criteria

› A major challenge was empirical acquisition of concrete information

  • > involvement of The Federal Statistical Office

› Evaluation results are an added value for the responsible specialist

branches (particularly insights into execution and practicability)

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Systematic evaluation (Decision of State Secretaries 2013)

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  • 4. Ex-post RIA

» Sunset provisions, continuation of the regulation often indexed to

evaluation results

» Besides criteria as target achievement, practicality, acceptance of a

law, sometimes specific criteria (e.g. interference with basic rights)

» Evaluations that were conducted by InGFA mostly based on evaluation

clauses

» Specificity: legal analysis based on empirical data (combination of

legal and social science approaches)

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Evaluation clauses

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  • 4. Ex-post RIA

» In reaction to the NSU murders, the File on Right-Wing Extremism

(RED) was launched in September 2012

» Obliges 36 German security agencies to save relevant information on

violent right-wing extremists, so that each participating agency has immediate access to the data. This aims at improving the exchange

  • f information between agencies and ensuring a more effective fight

against violent right-wing extremism

» Article 3 section 2 of the Act on Improving the Fight against Right-Wing

Extremism from 20 August 2012 provided for an evaluation of the RED-G before 31 January 2016, with the involvement of scientific experts

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Example: Evaluation of the Database on Right-Wing Extremism

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  • 4. Ex-post RIA

» According to the evaluation clause, the intensity of interference with

basic rights that comes along with data collection and use shall be weighed against the effectiveness of the database in fighting violence- related right-wing extremism

» Difficulty: operationalisation of the effectiveness in fighting violence-

related right-wing extremism

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Example: Evaluation of the Database on Right-Wing Extremism

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  • 4. Ex-post RIA

» Approximation: analysis of what changes RED has had on the

exchange of information (interviews, standardized surveys, log data)

» Measuring the interference with basic rights through an assessment of

the amount of data saved in the database, the number of accesses to the data (analysis of log data), avoidance of data collection by security agencies

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Example: Evaluation of the Database on Right-Wing Extremism

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  • 4. Ex-post RIA

» Evaluation of Counter-Terrorism Laws » Evaluation of the Hamburg Transparency Act (HmbTG) » Evaluation of the Act on a File on Right-Wing Extremism (RED-G) » Evaluation of the Police Authority Act (POG) Rhineland-Palatinate » Evaluation of the Act on Regulating Access to Federal Information

(IFG)

» Evaluation of the Mediation Act

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Our projects

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  • 4. Ex-post RIA

» Coherent implementation of the Decision of State Secretaries –

concomitant collection of data, building of evaluation capacities in the ministries

» Evaluation of behaviorally informed approaches (Cabinet Decision of 4

June 2014); RCTs

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Current Challenges in Germany

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  • 5. An international comparison of RIA – ex ante

0,00 0,50 1,00 1,50 2,00 2,50 3,00 3,50 4,00 Methodology of RIA Systematic adoption of RIA Transparency of RIA Oversight and quality control of RIA

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The results apply exclusively to processes for developing primary laws initiated by the

  • executive. The vertical

axis represents the total aggregate score across the four separate categories of the composite indicators. The maximum score for each category is one, and the maximum aggregate score for the composite indicator is four. This figure excludes the United States where all primary laws are initiated by Congress. Source: OECD 2015.

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  • 5. An international comparison of RIA – ex post

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0,5 1 1,5 2 2,5 3 3,5 4 Methodology of ex post analysis Systematic adoption of ex post analysis Transparency of ex post analysis Oversight and quality control of ex post analysis OECD average Source: OECD 2015. The vertical axis represents the total aggregate score across the four separate categories

  • f the composite
  • indicators. The

maximum score for each category is one, and the maximum aggregate score for the composite indicator is four.

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  • 6. What happens with the RIA results?

» Ex-ante: › RIA results are attached to the regulatory draft; pass through the

legislative procedure

» Ex-post: › Evaluation reports are submitted to the lead ministry › Evaluation reports based on decision of State Secretaries are to be

submitted to the ministries concerned, Federal Government Coordinator for Better Regulation and the NKR

› If the evaluation is based on an evaluation clause, results are also

submitted to the German Bundestag

› Publication of evaluation reports

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  • 6. What happens with the RIA results?

» “..RIA’s most important contribution to the quality of decisions is not

the precision of the calculations used, but the action of analyzing – questioning, understanding real-world impacts and exploring assumptions.”

(OECD 2008)

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Thank you very much!

Contact: willwacher@ingfa-speyer.de

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References

Act on the Establishment of a National Regulatory Control Council (NKR-G), available at http://ec.europa.eu/smart- regulation/impact/best_practices_examples/docs/de/act_on_regulatory_conctrol_council.pdf Behavioural Insights Team (BIT) (2016): Update Report 2015-16, Foreword, available at http://38r8om2xjhhl25mw24492dir.wpengine.netdna-cdn.com/wp- content/uploads/2016/09/BIT_Update_Report_2015-16-.pdf Böhret, Carl und Götz Konzendorf (2001): Handbuch Gesetzesfolgenabschätzung (GFA) – Gesetze, Verordnungen, Verwaltungsvorschriften, Baden-Baden: Nomos. Cabinet decision of 4 June 2014, Arbeitsprogramm Bessere Rechtsetzung 2014, available at https://www.amtlich- einfach.de/SharedDocs/Downloads/Arbeitsprogramm.pdf?__blob=publicationFile&v=10 18.5.2017 Evaluation of German Federal Laws in Theory and Praxis 43

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References

Decision of State Secretaries (2013): Strategy for the evaluation of new legislative proposals, in: The Federal Government, Better Regulation 2012: Reducing Regulatory Burden – Cutting Red Tape – Securing Dynamic Growth, Federal Government Report pursuant to Section 7 of the Act on the Establishment of a National Regulatory Control Council, Appendix, available at https://www.bundesregierung.de/Content/EN/Artikel/Buerokratieabbau_en/Anlagen_en/2013-06-05- jahresbericht-2012_en.pdf?__blob=publicationFile&v=4 Federal Statistical Office (2012): Guidelines on the Identification and Presentation of Compliance Costs in Legislative Proposals by the Federal Government, available at: https://www.bundesregierung.de/Content/DE/_Anlagen/Buerokratieabbau/2013-01-02- erfuellungsaufwand.pdf?__blob=publicationFile Joint Rules of Procedure of the Federal Ministries (GGO), available at http://www.bmi.bund.de/SharedDocs/Downloads/DE/Veroeffentlichungen/ggo_en.html Nationaler Normenkontrollrat (2015a): Opportunities for Cost Containment Improved. Seize Digital Opportunities now! 2015 Annual Report of the National Regulatory Control Council, available at https://www.normenkontrollrat.bund.de/Webs/NKR/Content/EN/Publikationen/2015_12_22_annual_repor t_2015.pdf;jsessionid=A1641E63A817471B0DC063CDB365D3E6.s2t2?__blob=publicationFile&v=1 18.5.2017 Evaluation of German Federal Laws in Theory and Praxis 44

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References

Nationaler Normenkontrollrat (2015b): The National Regulatory Control Council, available at https://www.normenkontrollrat.bund.de/Webs/NKR/Content/EN/Publikationen/2016_12_25_infobroschue re_en.pdf?__blob=publicationFile&v=1 OECD: http://www.oecd.org/gov/regulatory-policy/ria.htm OECD (2015): Regulatory Policy Outlook, available at: http://www.oecd.org/publications/oecd-regulatory- policy-outlook-2015-9789264238770-en.htm OECD (2012): Recommendation of the Council on Regulatory Policy and Governance, available at http://www.oecd.org/governance/regulatory-policy/49990817.pdf OECD (2008): Introductory Handbook for Undertaking Regulatory Impact Analysis (RIA), available at https://www.oecd.org/gov/regulatory-policy/44789472.pdf Ziekow, Jan, Axel Piesker, Dieter Katz und Hanna Willwacher (2015): Evaluierung des Rechtsextremismus-Datei-Gesetzes nach Artikel 3 Absatz 2 des Gesetzes zur Verbesserung der Bekämpfung des Rechtsextremismus vom 20. August 2012, German Bundestag paper 18/8060, available at http://dip21.bundestag.de/dip21/btd/18/080/1808060.pdf 18.5.2017 Evaluation of German Federal Laws in Theory and Praxis 45