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Study to Support the Review of Environmental Monitoring and Reporting Obligations Evaluating Monitoring and Reporting Arrangements - Discussion Document
9 September 2016
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Study to Support the Review of Environmental Monitoring and Reporting Obligations Evaluating Monitoring and Reporting Arrangements - Discussion Document
A report submitted by ICF Consulting Services
in association with
IEEP and Denkstatt
Date: 9 September 2016
Job Number J30300747
ICF Consulting Services Limited Watling House 33 Cannon Street London EC4M 5SB
T +44 (0)20 3096 4800 F +44 (0)20 3368 6960
www.icfi.com
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Document Control
Document Title Evaluating Monitoring and Reporting Arrangements – Discussion Document
Job No. J30300747
Prepared by Rupert Haines, Matt Rayment
Checked by Matt Rayment
Date 9 September 2016
This report is the copyright of European Commission and has been prepared by ICF Consulting
Services Ltd under contract to European Commission. The contents of this report may not be
reproduced in whole or in part, nor passed to any other organisation or person without the specific
prior written permission of European Commission.
ICF has used reasonable skill and care in checking the accuracy and completeness of information
supplied by the client or third parties in the course of this project under which the report was produced.
ICF is however unable to warrant either the accuracy or completeness of such information supplied by
the client or third parties, nor that it is fit for any purpose. ICF does not accept responsibility for any
legal, commercial or other consequences that may arise directly or indirectly as a result of the use by
ICF of inaccurate or incomplete information supplied by the client or third parties in the course of this
project or its inclusion in this project or its inclusion in this report.
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Contents
1 Introduction 3 1.1 This paper ................................................................................................................................ 3 1.2 The structure of the paper ........................................................................................................ 3
2 Environmental Monitoring and Reporting – Objectives and Principles 4 2.1 Objectives ................................................................................................................................ 4 2.2 Principles .................................................................................................................................. 5 2.3 Criteria for Evaluation ............................................................................................................... 6
3 Relevance 7 3.1 Are environmental reporting requirements relevant for assessing progress with Key
Performance Indicators (building on the indicators system introduced by the Better
Regulation Guidelines)? ........................................................................................................... 7 3.2 Has the process of reporting taken advantage of technology: including advances in IT,
increasing provision of data through Copernicus, etc? ............................................................ 7 3.3 Does the process of reporting remain relevant (compared to alternative methods of
sharing information i.e. harvesting of data)? ............................................................................ 7
4 Effectiveness 9 4.1 Does environmental reporting provide sufficient information on the state and the
effectiveness of implementation of the environmental acquis? i.e. does it satisfy the
objectives of reporting? ............................................................................................................ 9 4.2 Are reporting obligations satisfied? Is the quality and timeliness of data good? ..................... 9 4.3 Does environmental reporting allow for evidence based decision making including
evaluations of regulatory fitness and impact assessments?.................................................... 9 4.4 Does environmental monitoring and reporting allow for the public to be properly informed
about the state of the environment? Is the information received publically accessible? ....... 10
5 Efficiency 11 5.1 What are the costs of reporting? Are they justified and proportionate compared to the
benefits? ................................................................................................................................. 11 5.2 What factors influence the costs of reporting and the efficiency of reporting processes? ..... 11 5.3 Are there national or regional best practices examples that can reduce costs? ................... 11 5.4 Could improvements be made to the reporting process that reduce costs? ......................... 11 5.5 Could the timing of reporting be better synchronized to reduce costs? ................................. 12 5.6 Could the costs of reporting be reduced through promotion of active dissemination of
information (in the context of Directives 2003/4/EC and 2007/2/EC), whilst improving
access for public authorities, businesses and citizens? ........................................................ 12
6 Coherence 13 6.1 Is some data reported multiple times, when it could be reported once and then used for
multiple purposes? ................................................................................................................. 13 6.2 Is data reported (including to other parts of the Commission) but then full use not made of
it? 13 6.3 Is there coherence between reporting to the EU level and to other international levels? ..... 13
7 EU added value 14 7.1 What are the benefits of reporting at the EU level, compared to local or national levels? .... 14 7.2 What would be the consequence of a cessation of EU level reporting and replacing them
by increased transparency and active dissemination? .......................................................... 14
8 Possible options for change 15
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1 Introduction
1.1 This paper
The European Commission is undertaking a Fitness Check of monitoring and reporting
obligations arising from EU environmental legislation. The purpose of the Fitness Check is to
“to ensure that environmental reporting is fit-for-purpose and to allow for the identification of
concrete actions towards a streamlined, low burden, high effects monitoring and reporting in
the context of environmental legislation”1.
The review is supported by a study contract being undertaken for the Commission by ICF,
IEEP and Denkstatt. The contract involves developing an inventory of reporting obligations,
assessing the costs and benefits of these obligations, examining how well current
arrangements are working and identifying and appraising options for change.
To inform the Fitness Check, the European Commission is keen to hear the views and
experiences of Member States and stakeholders on current arrangements for monitoring and
reporting, and to discuss potential changes that could be made to improve these
arrangements. With this in mind, a public consultation took place between November 2015
and February 2016, and progress is being discussed through a series of stakeholder
workshops.
The 3rd Stakeholder Workshop will take place on 26-27 September 2016 in Barcelona, and
will discuss among other things how well the current system of monitoring and reporting is
working, and the potential opportunities for change. This discussion paper is intended to
guide that discussion.
In addition, Member State authorities, experts and stakeholders are invited to submit written
comments and supporting information. Please address these to [email protected]
by 14 October 2016 at the latest.
1.2 The structure of the paper
The Fitness Check is examining 18 evaluation questions, organised under each of the
standard EU evaluation criteria: relevance, effectiveness, efficiency, coherence and EU
added value.
This paper begins by outlining the key principles and objectives of the monitoring and
reporting system (Section 2).
It then sets out the critical evidence needs associated with each of the evaluation questions
being addressed by the Fitness Check, for each of the five evaluation criteria (Sections 3-7).
Each question is presented in turn, with a short explanation of the pertinent aspects of each
and a small number of key discussion points focussed on the primary evidence needs and/or
gaps.
Finally, the paper introduces questions about potential changes that could be made to the
current environmental monitoring and reporting system, in order to enhance its effectiveness
and efficiency (Section 8).
1 European Commission (2016). Fitness Check (FC) Roadmap. Fitness check of environmental monitoring and
reporting obligations in environmental policy. http://ec.europa.eu/smart-regulation/roadmaps/index_en.htm
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2 Environmental Monitoring and Reporting – Objectives and Principles
2.1 Objectives
The role of environmental reporting is to enable the collation of data that provides evidence
on the implementation and impacts of EU environmental policy. This is a critical part of
Better Regulation and ensures that evidence-based actions can be taken to ensure that
policy is amended where necessary to ensure that it remains fit-for-purpose.
Box 1: Objectives of reporting
A. Demonstrate compliance with legal obligations
B. Determine if the objectives of legislation are being achieved effectively and efficiently,
including, where appropriate, ensuring a level playing field of the internal market
C. Inform the other EU institutions as well as the public and stakeholders at EU level on the
progress of implementation and the identification of gaps:
D. Help inform the understanding of an environmental issue and so help to improve decision
making, e.g. policy evaluations or impact assessments:
E. Identify and spread good practices amongst Member States
Source: Based on Better Regulation Guidelines
Respondents to the public consultation highlighted the importance of monitoring and
reporting in assessing whether legal obligations are being met, improving stakeholder
understanding of the state of the environment, and providing environmental information for
citizens.
Figure 2.1 Stakeholder opinion on the relative importance of the ‘objectives’
Source: Environmental Monitoring and Reporting Fitness Check Public Consultation
0 1 2 3 4 5 6 7 8 9 10
B: It should indicate how well the legislation isworking (i.e. costs and benefits)
E: It should allow comparison between MemberStates as regards their performance when
implementing EU environment law
C: It should generate reliable environmentalinformation and ensure access to environmental
information for citizens
D: It should allow stakeholders to understand thestate of the environment and the actions taken to
maintain and improve it
A: It should allow for an assessment of whether EUlegal obligations are being met
Mean score (10 = high; 0 = low)
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2.2 Principles
There are five governing principles that a monitoring and reporting system should adhere to
in order to ensure that it is fit-for-purpose.
Box 2: Governing principles for reporting
A. Comprehensive:
i. Should provide data that is sufficiently detailed to inform monitoring, evaluation and
decision making.
ii. Must provide data that cover the objectives of the intervention and should provide
evidence on both the costs and benefits of the legislation.
iii. Can include objective (e.g. factual, quantitative) and subjective (e.g. opinion based,
qualitative) evidence.
B. Proportionate:
i. A balance should be struck between the extent of information requested and the
cost of its provision.
ii. The weight of evidence provided should reflect the importance placed on different
aspects of the intervention.
C. Minimise overlap:
i. It should not duplicate requirements already in place. New reporting obligations
should focus on gaps that need to be filled.
ii. Information should be collected once and shared where possible for many
purposes.
D. Timeliness:
i. The timing of reporting should align with the when the evidence will be used.
ii. It should provide data that is up-to-date at the point of use.
E. Accessibility:
i. In principle, all evidence gathered should be made available to the general public
(subject to appropriate aggregation and confidentiality constraints).
Source: Based on Better Regulation Guidelines
Respondents to the public consultation highlighted the importance of the principles that
information should be collected once and used many times, that reported information should
be available to the general public, that monitoring and reporting should be timely and up-to-
date, and that a balance should be struck between the information sought and the cost of
reporting (Figure 2.2).
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Figure 2.2 Stakeholder opinion on the relative importance of the ‘principles’
Source: Environmental Monitoring and Reporting Fitness Check Public Consultation
2.3 Criteria for Evaluation
The Fitness Check is examining current monitoring and reporting arrangements according to
the five standard EU evaluation criteria of effectiveness, efficiency, relevance, coherence
and EU added value.
These objectives and principles are important reference points in assessment of the current
arrangements for environmental monitoring and reporting, and in evaluation against the five
criteria. For example:
■ Effectiveness concerns the degree to which the system addresses the main objectives of
monitoring and reporting, as set out above. Key principles such as the
comprehensiveness, timeliness and accessibility of the information reported influence its
effectiveness;
■ Efficiency concerns the extent to which these objectives are met at least cost, and the
balance of the costs and benefits of reporting. The principle of proportionality is an
important determinant of efficiency;
■ Relevance concerns the extent to which the objectives of the reporting system remain
relevant to the needs they are trying to address, and whether the overall system remains
relevant to the current situation. To be relevant, the information reported needs to be
consistent with the principles of comprehensiveness, timeliness and accessibility;
■ Coherence examines the consistency of reporting obligations with each other and with
wider requirements, including international commitments, and the degree to which there
may be overlapping or possibly conflicting requirements within the system. The principle
of minimisation of overlap is particularly important.
The following sections introduce questions for discussion under each of the five evaluation
criteria.
0 1 2 3 4 5 6 7 8 9 10
A.ii: Monitoring and reporting should cover thecosts and benefits of the action
A.i: Monitoring and reporting should provide a verydetailed picture
B: A balance should be struck between asking formore information, and the cost of that provision
D: Monitoring and reporting should be timely andup to date
E: Reported information should be fully available tothe general public, after due consideration of the…
C: Information should be collected once and sharedwhere possible for many purposes
Mean score (10 = high; 0 = low)
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3 Relevance
These questions are focussed on whether the objectives of the reporting system remain
relevant to the needs they are trying to address, and whether the overall system remains
relevant to the current situation.
3.1 Are environmental reporting requirements relevant for assessing progress with Key Performance Indicators (building on the indicators system introduced by the Better Regulation Guidelines)?
Key Performance Indicators (KPIs) are a type of indicator used to track how effectively
objectives are being met and evaluate success in relation to pre-defined targets. Adoption of
KPIs could foster a more streamlined, coherent and coordinated approach to presenting
information across environmental legislation. KPIs could be employed as ‘level 1’ in a multi-
level approach to reporting, with additional layers providing more detailed information).
Existing scoreboards provide certain KPIs, ranging from a simple view of implementation to a
more detailed quantitative view of environmental state and pressures.
■ Do ROs cover the main issues (i.e. implementation, state/pressures, governance, etc)
and provide the data necessary to construct KPIs (i.e. quantitative data that can be
processed rapidly e.g. within 6 months)?
■ Could KPIs reduce the amount of data that would need to be reported? Can you provide
examples?
■ Is there scope for streamlining indicators through sectoral / horizontal sharing of KPIs
across legislation?
3.2 Has the process of reporting taken advantage of technology: including advances in IT, increasing provision of data through Copernicus, etc?
Technological advances provide opportunities for improving the efficiency and robustness of
reporting processes (e.g. greater automation of data transfer and storage), and enhancing
the nature of data that is reported. IT advances can relate to, for example, processes for
data transfer i.e. the adoption of electronic data manipulation and transfer, as well as data
formats i.e. the use of spatial GIS data. Copernicus is the European Earth observation
programme. It processes data from earth observation satellites and in situ sensors to provide
information across six thematic areas: land, marine, atmosphere, climate change,
emergency management and security.
■ What technological advances have been successfully implemented for reporting
obligations? What benefits have these brought?
■ Are there technologies that could be more widely used in environmental reporting? To
which areas of legislation / datasets could they be applied?
■ What are the costs and challenges of implementing new technologies?
3.3 Does the process of reporting remain relevant (compared to alternative methods of sharing information i.e. harvesting of data)?
The process of reporting involves the collection, collation, quality checking and transfer of
information by data providers (typically MS), and then the collation, quality checking, analysis
and publication of information by data receivers (typically EEA/EC).
With regards EU reporting, data harvesting refers to the process of an EU hub database
collecting data from multiple MS databases, typically via the internet, and subsequently
hosting the data and making it available for use (internally by EU institutions or externally by
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other stakeholders e.g. the public). A common model for the exchange of data needs to be
agreed so that the EU database receives data in a consistent form from all MS databases.
Active dissemination of public sector data typically prescribes certain data which should be
made publically available and often specifies the format. It can therefore provide the
groundwork to enable data harvesting by EU institutions as well as providing information to
other stakeholders and the public.
If such alternative approaches are viable they hold potential for altering the magnitude and
nature of administrative burdens and for enabling access to more up-to-date information.
■ To what extent is data harvesting already occurring? What have been the benefits, costs
and challenges?
■ In what situations is data harvesting appropriate?
■ Are there specific legislation / ROs / data for which implementation of data harvesting
could be considered?
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4 Effectiveness
Effectiveness concerns the performance of the system of monitoring and reporting against its
objectives.
4.1 Does environmental reporting provide sufficient information on the state and the effectiveness of implementation of the environmental acquis? i.e. does it satisfy the objectives of reporting?
The objectives of reporting include the provision of information from which to understand the
state of implementation and progress towards achieving objectives. The evaluation question
seeks to examine whether environmental reporting is providing the information necessary to
achieve this understanding.
■ Are there examples where the available information is insufficient (or at least suboptimal)
to enable a satisfactory evaluation of implementation or impact?
■ What aspects of the required reporting are responsible for deficiencies?
4.2 Are reporting obligations satisfied? Is the quality and timeliness of data good?
Deficiencies in how MS fulfil ROs can have implications for the sufficiency of the received
information and the achievement of the objectives of reporting, with knock on implications for
policy design and implementation and the environment.
Timeliness is principally concerned with whether the reported information is sufficiently up-to-
date to enable the end user to draw robust and relevant conclusions. Timeliness can be
affected by the duration of the reporting cycle, issues and delays occurring with the reporting
processes, and through the alignment of final reporting with end user needs.
■ Are there examples of legislation / ROs where data submission is regularly delayed, or
has an excessively long timeframe? What were/are the causes?
■ Does the submission/publication of data synchronise with end user needs?
■ Are there examples of legislation / ROs where timeliness has been improved? How has
this been achieved?
Quality relates to both the accuracy and completeness of the data provided. Deficiencies in
quality can result in incomparable data, prohibit EU level assessment, generate biased
evidence, make enforcement more challenging and ultimately undermine the effectiveness of
the reporting process.
■ Are there examples of legislation / ROs where inconsistencies and errors commonly
occur? What were/are the causes?
■ Are there examples of legislation / ROs where quality has been improved? How has this
been achieved?
4.3 Does environmental reporting allow for evidence based decision making including evaluations of regulatory fitness and impact assessments?
As indicated by the Better Regulation guidelines, reporting obligations are put in place to
ensure that Member States provide information to the European Commission that can
enable evidence-based regulation. Evaluations and impact assessments are important tools
to support evidence-based regulation, but are only as good as the information that can be
collated and analysed as part of their production.
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■ Are there examples of ROs informing impact assessment and evaluations?
■ Was the information found to be sufficient? If not, why not?
4.4 Does environmental monitoring and reporting allow for the public to be properly informed about the state of the environment? Is the information received publically accessible?
Informing the public at EU level on the progress of implementation, the state of the
environment and actions being taken constitutes one of the objectives of environmental
monitoring and reporting.
■ Is sufficient information on the state of the environment made available to the public?
■ Is the information provided via tools and in formats that are accessible, comprehensible
and meaningful to the public?
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5 Efficiency
Efficiency is concerned with the achievement of monitoring and reporting objectives at
minimum cost and whether the benefits of achieving them outweigh the costs of doing so.
5.1 What are the costs of reporting? Are they justified and proportionate compared to the benefits?
A principle of monitoring and reporting is that this administrative burden should be
proportionate - there should be a balance between the costs of reporting and the benefits
that it provides.
Estimates of the costs of reporting, by legislation, are laid out in the Discussion Document -
Assessing the Costs and Benefits of Current Reporting Obligations. They indicate a range of
zero to multiple millions Euros per annum. Costs of reporting refer to the burden generated
by the obligation, which may fall on businesses, Member State authorities, European
institutions and other stakeholders.
■ Are there examples where the costs are thought to be disproportionate to the benefits?
Why is this?
5.2 What factors influence the costs of reporting and the efficiency of reporting processes?
The Standard Cost Model equation defines the key parameters which influence the costs of
satisfying reporting obligations. These are: The number of entities undertaking actions to
satisfying the reporting obligation; the frequency of these actions; the time taken to deliver
these actions and staff costs; and, other costs such as use of consultants and equipment.
The efficiency of reporting processes can be assessed by examining how these parameters
are affected by reporting requirements/process and changes therein. These may be
influenced by issues specific to the RO (e.g. guidance, complexity, type of information
required), by MS-specific factors (e.g. internal processes, interpretation of requirements), or
interrelated factors (e.g. the processes for transferring information between MS and the
EEA/EC)
■ What are the key factors which drive costs or create inefficiencies in ROs that you are
familiar with?
■ How have they affected costs and efficiencies (positively or negatively)?
5.3 Are there national or regional best practices examples that can reduce costs?
There is scope for MS and groups of MS to implement novel approaches and best practices
which can reduce costs. Examples range from the integration of business information
collection to the use of strategic partnerships to aid data QA.
■ Are you aware of any best practices which have helped to reduce costs?
■ What aspects of reporting have they influenced and what was the effect on costs?
■ Are they likely to be transferable to other MS or other legislation?
5.4 Could improvements be made to the reporting process that reduce costs?
Improvements to reporting processes can reduce costs if they positively affect any of the
previously identified ‘factors’ i.e. number of entities involved, frequency of activity, time
require to fulfil obligations, investment / contractor / other costs. Process improvements may
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occur at a number of different levels e.g. through the specification of the RO and its
supporting guidance; through the mechanisms for data transfer between MS and the
EEA/EC; or through MS internal collation, QA and report production processes.
■ What improvements could be made to reporting processes? How would these affect
costs?
■ Are there specific examples of where such improvements have been made and costs
reduced?
5.5 Could the timing of reporting be better synchronized to reduce costs?
Improving the synchronisation of reporting has two dimensions (1) the synchronisation of
reporting which has interrelated processes, so that these can be carried out by the reporting
bodies once, rather than more than once; (2) where the same data is reported at different
times or frequencies under different reporting obligations – this second dimension relates
specifically to one of the better regulation principles for monitoring and reporting is that
‘information should be collected once and shared where possible for many purposes’.
■ Where synchronisation has occurred, how has this affected costs?
■ Are there specific opportunities where better synchronisation could occur? How might
this affect costs?
5.6 Could the costs of reporting be reduced through promotion of active dissemination of information (in the context of Directives 2003/4/EC and 2007/2/EC), whilst improving access for public authorities, businesses and citizens?
MS have been making increased efforts to deliver active dissemination. The Access to
Environmental Information Directive (2003/4/EC) obliges MS to make publically available
certain information (from environmental policies to environmental data) in certain formats.
Under the INSPIRE Directive (2007/2/EC), Member States must make available in a
consistent format spatial datasets in scope of the Directive and also create network services
for accessing the datasets.
■ How have the costs of reporting been affected by the implementation of active
dissemination initiatives? How has the distribution of costs been affected e.g. between
businesses, public authorities, EEA/EC?
■ Are there specific items of legislation or aspects of ROs where active dissemination
could have a positive effect on costs?
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6 Coherence
Coherence examines the consistency of reporting obligations with each other and with wider
requirements, including international commitments, and the degree to which there may be
overlapping or possibly conflicting requirements within the system.
6.1 Is some data reported multiple times, when it could be reported once and then used for multiple purposes?
Data is often collected based on a single purpose requirement only, without consideration of
other potential users who may have similar needs. One of the principles of environmental
monitoring and reporting is that overlap in reporting requirements should be minimised.
Overlaps can generate unnecessary additional reporting costs, and potentially reduce data
credibility if there is a lack of coherence between two overlapping datasets. Multiple reporting
may occur across legislation within the same sector, or with non-legislative data activities
(e.g. data on natural hazards collected by both public agencies and insurance companies).
■ Are there examples where the same data is reported multiple times?
■ What changes would be required to avoid these overlaps?
6.2 Is data reported (including to other parts of the Commission) but then full use not made of it?
Substantial volumes of data are collected as part of environmental monitoring and reporting
requirements. Such data may have use for organisations / departments beyond that which is
collating it. However it is not clear whether all data is used to the full extent possible.
■ Are there examples where data could have use beyond its immediate purpose / EU
unit/department, but this is not occurring?
■ What are the reasons why full use may not be being made of reported data across
organisations / departments?
6.3 Is there coherence between reporting to the EU level and to other international levels?
The reporting obligations inventory identifies 49 instances where an EU reporting obligation
is directly linked to (in many cases mirrors) an international reporting requirement.
Coherence between EU and international reporting can be considered principally in terms of:
(i) timing of monitoring and reporting; (ii) format of information being reported; (iii) the specific
of the information requested.
■ Are there examples of incoherence between EU and international reporting? In what
ways does this occur?
■ Would it be beneficial to improve coherence in such situations?
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7 EU added value
EU added value examines the benefits of reporting at EU rather than at Member State level,
and considers the consequences of removing EU level reporting obligations.
7.1 What are the benefits of reporting at the EU level, compared to local or national levels?
During the life cycle of legislation, reporting provides information on: implementation,
application and progress towards objectives, compliance and enforcement, and the broader
context.
Environmental reporting obligations, like all requirements linked to EU legislation, should be
subject to the principle of subsidiarity. In this regard, there is a need to demonstrate a clear
case for reporting at the EU level, compared to reporting at the national or local levels.
■ What is the benefit of defining and administering reporting obligations at an EU level?
■ Are there specific situations where EU level reporting does or does not provide clear
benefit?
7.2 What would be the consequence of a cessation of EU level reporting and replacing them by increased transparency and active dissemination?
It is conceivable that the processes of formal reporting of data to the Commission and
subsequent analysis and dissemination in the form of periodic reports, could be replaced by
increased transparency, continuous reporting and active dissemination (e.g. accessible
databases and web pages) at the Member State level.
■ What advantages and disadvantages would this bring?
■ In what situations might this occur? Are there any real examples of these at present?
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8 Possible options for change
The system of monitoring and reporting is changing over time. Changes in reporting
obligations and their implementation offer opportunities to enhance the effectiveness of the
system and to reduce administrative burdens.
Implementation of existing reporting obligations may be improved through developments in
reporting processes, including new technologies, reporting formats and content
requirements.
At the same time, ongoing policy reviews have led to proposals to reform, amend or repeal
certain reporting obligations. For example, the Circular Economy Package proposes to
remove the requirement for implementation reporting for three items of waste legislation and
require only numerical reporting of results. Regulatory Fitness Checks offer opportunities to
review and reform reporting obligations for relevant items of legislation (e.g. EPRTR,
INSPIRE, REACH). For example, the EPRTR REFIT has examined opportunities to
harmonise reporting requirements and formats under IED, EPRTR and LCP. The
Commission has also proposed to repeal the Standardised Reporting Directive, which would
result in the repeal of certain reporting obligations (e.g. VOC-I and asbestos directives).
The Fitness Check of environmental monitoring and reporting is also considering
opportunities to go beyond existing proposals to examine how the overall system of reporting
could be improved in terms of its structure, format, process and timing. Current obligations
are relatively complex and there are variations and overlaps in timing and content between
different items of legislation, which could be reviewed.
Questions that could be considered include:
■ What changes could be implemented to improve the implementation of existing reporting
obligations?
■ What are the most promising opportunities for current policy reviews to enhance the
effectiveness and efficiency of monitoring and reporting arrangements?
■ Is there scope to harmonise and streamline existing reporting obligations, and/or to
reduce overlaps, without reducing the effectiveness of reporting?
■ What further changes could be considered to the timing, content and process of
reporting?
■ How would the above changes enhance the benefits, and/or reduce the costs of
reporting?
