- Fabrizio Di Mascio, Alessandro Natalini and Francesco Stolfi (forthcoming). “The implementation of administrative burden reduction policy: Mechanisms and contexts in the study of Europeanization”, Comparative European Politics
Research note by Francesco Stolfi
Two open issues in the European literature are the extent to which EU policies are implemented domestically and how the interaction of causal mechanisms and national contexts shapes implementation. This article has addressed them with regard to the adoption of Administrative Burden Reduction (ABR), a key element of the European Commission’s better regulation agenda, in Germany,France, Italy and Spain.
We address the implementation question by analyzing how causal mechanisms interact with national contexts and what this interaction implies for actual implementation and for policy outputs. Specifically, using an institutional processualist approach we show how ABR has been implemented differently depending on the concatenation of mechanisms activated by a mix of ‘process design features’ and ‘process context factors.’
Process design features refer to the elements of the reform which are shaped by actors’ choice such as guiding ideas and governance arrangements for the implementation of the policy under examination. As a core element of the ABR is the Standard Cost Model (SCM), we identify eight features affecting the ABR policy implementation which map onto the eight core aspects of the original Dutch SMC template. These include:
- Scope of the measurement, ranging from a full baseline measurement of regulations in place focused on all areas of regulation to no baseline measurement with the measurement of selected areas as the halfway point;
- Ex ante measurement, ensuring that new legislation do not impose excessive burdens and ranging from all to no areas of regulation along the line of the baseline measurement;
- Scope of the reduction target, ranging from all to no areas of regulation along the lines of the baseline measurement;
- Type of regulatory costs addressed, ranging from only information obligations to more substantive compliance costs;
- Type of addressees, which can include businesses, citizens, and public authorities;
- Oversight mechanism, required to manage the implementation of the policy across departments and embodied in an external watchdog or a dedicated ministerial unit
- Consultation practices, which can be centralized on established stakeholders or decentralized via perception surveys and crowdsourcing exercises;
- Guiding ideas concerning the administrative burden reduction policy, which can be framed as a technocratic exercise ensuring rigorous quantitative measurement and reduction of costs or as a populist campaign against the most irritating regulations aimed at making the simplification effort noticeable by regulatees.
Process context factors are the political, institutional and policy factors that present opportunities and constraints for making use of design features. In this paper they include the European program for burden reduction, participation in international horizontal networks, the implementation of previous administration simplification policies and the broader public management reform agenda, as well as factors of the political stream (for example, government alternation) and institutional factors (such as the coordination capacities of the executive and the distribution of power across levels of government).
We find that the four national cases exemplify four different patterns of implementation. France is an example of what we call the populist approach. Government alternation and the involvement of the top political leadership turned ABR away from the early experimentation with cost estimation and quantitative reduction targets and towards the practical implementation of more selective reduction measures. The new qualitative approach relied on professionally conducted opinion surveys and standing stakeholder panels complemented by open consultation via the Internet to identify the most irritating administrative formalities for four categories of users (businesses, citizens, local authorities and associations) as well as their expectations regarding burden reduction. In sum, in France ABR has been turned into a policy essentially aimed at meeting the favor of the regulatees, rather than at reducing the heaviest bureaucratic obligations according to objective measures.
Germany has conversely followed a technocratic approach, based on the introduction of an independent external watchdog (the Regulatory Control Council) and the involvement of the Federal Statistics Office. Its guiding idea has been to provide decision makers and stakeholders with maximum and rigorous transparency of costs rather than communicating the simplification efforts to regulates.
In Italy, the introduction of the ABR policy has exhibited a mix of technocracy and populism. The domestic context has been unfavourable, marked as it has been by the executive’s low capacity for interdepartmental steering and by the traditional fragmentation of coalition governments. However, some process design features of the Italian policy proved to be effective in counteracting the fragmentation of the institutional setup: the involvement of the National Statistics Institute and of stakeholders (complemented, as in France, by an online consultation tool), and a selective approach to measurement focusing on the most critical areas rather than mapping all information obligations.
Finally, Spain has been the national case where implementation has been least effective. Like Italy, Spain has adopted a selective approach. However, little political commitment to administrative simplification, and limited experience with it, have meant that the Spanish government failed to meets is quantitative targets of administrative burden reduction, and indeed eventually to the wholesale abandonment of any measurement effort, whether quantitative or qualitative.
Francesco Stolfi is Assistant Professor, Faculty of Social Sciences of the University of Nottingham, Malaysia Campus.
He has a cum Laude degree in Economics from the University of Rome and received my Ph.D. in Political Science from the University of Pittsburgh. Before coming to UNMC he has taught at the University of Exeter, University College Dublin and Allegheny College.
He has been funded by the Fulbright Program, the Nippon Foundation and the British Academy