1. Position Paper of the 4 independent watchdogs Dr. Philipp Birkenmaier Secretariat of Nationaler Normenkontrollrat Nicosia, 2 April 2012

2. 2 The FIVE Independent regulatory watchdogs Nationaler Normenkontrollrat (Germany)ACTAL (The Netherlands)Regelradet (Sweden)Regulatory Policy Committee (United Kingdom) Regulatory Impact Assessment Board (Czech Republic)

3. 3 Task and Composition of NKR Established by a formal federal law (August 2006) Independent advisory body Appointment of 10 members for a term of office of 5 years Start of second term: 20 September 2011 NKR Task Model: The Netherlands Support and Advice to the Federal Government in the reduction of bureaucracy and better regulation I. Avoid the creation of new compliance costs including administrative burdens II. Perceivable reduction of existing administrative burdens

4. 4 Position Paper “The End of the Commission‘s Action Programme for Reducing AB in the EU – What comes next?“ Adopted 10 November 2011Sent out to MS, Commission, EP, StakeholdersPositive Feedback from various MSDiscussed with MEPs 29 February 2012

5. 5 General Conclusions and Recommendations for the next steps In the last five years, there has been a growing awareness in the EU of the need to reduce administrative burdens and to adhere to smarter regulation principles As the Action Programme to reduce AB is coming to an end 2012, the Commission should present an ambitious work programme by summer 2012 on how to continue the work to ensure smart regulation and achieve the necessary change in culture. Such a programme should focus primarily on actions to be taken by the Commission, but should be able to be used as a basis for a common approach by the Parliament and the Council

6. 6 Action Programme for Reducing AB Lessons LearnedRecommendations No full baseline measurementFurther areas should be assessed 25% target is a GROSS targetMechanism to ensure that the total burden decreases Limited on ABOverall regulatory burden

7. 7 Impact Assessments (IA) Lessons LearnedRecommendations Not for all proposals an IA is carried out IA for all legislative or regulatory proposals No stakeholder consultation on draft proposals and draft IAs Stakeholder consultation on draft proposals and draft IAs No independent scrutiny of IAs Enlarge the IAB by independent experts or closer link to the Stoiber-Group No IAs in EP and Council IAs should be carried out for major amendments in EP and Council

8. 8 Institutional Setup Lessons LearnedRecommendations Stoiber-Group plays an important role Prolong and reinforce the mandate No common independent institution to assess IAs Independent body to scrutinise IAs across all institutions