Annexes to COM(2015)90 - Implementation of Regulation 177/2008 establishing a common framework for business registers for statistical purposes

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annex to the BR Regulation).

It was foreseen that the important improvements in quality, which are the main objectives of the BR Regulation, would increase the costs for National Statistical Institutes and the administrative burden on respondents. It was expected that this effect would be very different from one country to another, given the different stage of development of each national business register.

In 2013, additional ad hoc questions on costs for the statistical system and burden on businesses related to the implementation of the BR Regulation were included in the questionnaire.

Unless indicated otherwise, the content of the following sections results from the annual inquiries (responses of the 2 EFTA countries included) as well as from some administrative records on grants that were awarded by Eurostat to Member States.

4.1. Costs for the statistical system

4.1.1. Costs incurred by the National Statistical Institutes of responding countries

The costs for the European Statistical System to operate their business registers for one year, and the supplementary costs resulting from the changes of the BR Regulation can only be roughly estimated and most countries either provided only partial information or were not able to provide any figures at all.

This is explained i.a. by the fact that the harmonisation of the statistical business registers is a long and gradual process that was started by the repealed BR Regulation and it is still ongoing.

For many countries (18) it was not possible to precisely isolate the costs associated to the implementation of the BR Regulation from a larger pool of general costs (e.g. overall redesign of the IT system, shared personnel between multiple domains etc.). Some countries performed individually developments of the national business registers so they were already compliant with the BR Regulation at the moment of its entering into force.

According to the National Statistical Institutes, the main expenses refer to the IT developments needed in order to comply with the BR Regulation as well as additional staff costs.

A better indication was obtained in qualitative terms. All 30 countries replied and the overall results showed that in about 75% of the cases the cost of implementing the BR Regulation was estimated none, negligible or moderate, and that only in about a quarter of the cases the impact was described as substantial. Some Member States indicated that the implementation of the BR Regulation did not result in any additional costs as they had already met the requirements prior to this implementation.

Table 1: Cost estimates by National Statistical Institutes

Cost estimate || Number of countries || Percentage of legal units covered (2013 survey)

None or negligible || 16 || 54.0%

Moderate || 7 || 18.8%

Substantial || 7 || 27.2%

Most countries felt that the implementation of the BR Regulation did neither reduce the costs for launching surveys (28 over 30 countries) nor the time required for these surveys (29 countries).

4.1.2. Financial support granted by Eurostat

Taking into consideration the different stages of development of statistical business registers in the Member States and the costs implied by the implementation of the BR Regulation, the Commission provided funds to support the Member States. These have to be taken into account when evaluating the overall cost of the statistical system.

Most of the projects were targeted at the set-up or redesign of the business register, and/or the improvement of its coverage.

The focus of the 2008 – 2013 grants was on the development of national business registers in order to improve their communication with the EGR. The general objectives of these grants were as follows:

· Development and testing the matching of the EGR data with the national business registers;

· Definition of national preference and priority rules for the EGR;

· Interaction between the central EGR register and the national statistical business register environments;

· Development and implementation of methods and tools for the EGR at national level.

Total amounts of the grants awarded to Member States[6]:

Year || Amount paid (EUR) || Main area of support

2008 || 352 850 || Quality, system development (source and processes)

2009 || 370 793 || Quality, system development (processes)

2010 || 440 579 || System development (processes)

2011 || 354 765 || Coverage, system development (source and processes)

2012 || 66 937 || System development (processes)

2013 || 606 366 || System development (source and processes)

Total amount paid || 2 192 290

The above mentioned amounts contributed to improve the capacity of national business registers to provide information on multinational enterprise groups to the EGR.

Member States also received support for the implementation of a more efficient way of using the data already existing in the economy by simplifying data collection in order to avoid double burden on businesses and improving quality of statistical information. This was done by the means of: on-line data collection, automated integration of data from different registers, automatic export of the statistical data from companies' accounts into electronic questionnaires etc.

4.2. Burden on businesses

The expected initial increase in the burden on businesses proved to be very different from one country to another and quite difficult to measure. The most important and encouraging finding was that the burden did not reach in any case a level generating major problems to the respondents.

The great majority of the answering National Statistical Institutes were only able to provide qualitative assessments.

For roughly 70% of the legal units covered by the inquiry, National Statistical Institutes reported no increase of the burden on businesses. For 2 countries the BR Regulation meant even a reduction of burden.

For roughly 30% of the legal units the National Statistical Institutes felt that the implementation of the BR Regulation increased moderately the burden on businesses.

There were cases of countries where the burden increased in the first years of implementing the Regulation, related to the fact the sectorial coverage was extended, as well as to the need to cover additional variables at enterprise group level.

Table 2: Assessment by National Statistical Institutes of the change in burden:

Overall assessment by National Statistical Institutes of the change in burden on businesses || Change in burden on businesses || Number of countries || Percentage of legal units covered

- (burden reduced) || 2 || 5.7%

0 (no change) || 18 || 63.5%

+ (burden increased moderately) || 10 || 30.7%

++ (burden increased substantially) || 0 || -

In almost all countries (29) the BR Regulation had no impact on the number of surveys addressed to businesses and on the simplification of the existing ones. 23 countries responded that no additional questions had to be included in the existing surveys.

4.3. Benefits of the BR Regulation (national and ESS level)

The implementation of the BR Regulation proved to be beneficial for the quality of statistical business registers and allowed moving forward important steps towards the statistical measurement of globalisation.

The main benefits at national level reported by National Statistical Institutes can be summarised as follows:

· increased data accuracy in individual statistical domains (9 countries)

· coordination among different statistical domains (13 countries)

· a more complete picture on public enterprises (7 countries)

· input for the national enterprise group register (19 countries)

· harmonisation in the area of enterprise groups (15 countries)

· improved tools for analytical purposes (7 countries)

· improved tools for data dissemination (2 countries)

Moreover, the implementation of the BR Regulation implied a more efficient use of administrative sources for 15 countries, led to a more extensive use of commercial sources for 7 countries, and meant the use of additional administrative resources for 13 countries.

Some countries underlined the fact that with the information on enterprise groups it was possible to compile inward foreign affiliates’ trade statistics on the basis of already available data, so that no survey/additional questions were necessary.

The most relevant benefit of the BR Regulation was at the level of the whole European Statistical System. The development of the EGR is a crucial step for the development of accurate and comparable European enterprise statistics and for the production of statistics on globalisation.

The BR Regulation and the inclusion of information about the control of legal units in business registers have permitted to achieve a situation where the structure of multinational enterprise groups operating in the EU and their national parts are currently mapped either in the national business registers or in the EuroGroups Registers, and Member States have established procedures to cooperate for improving data quality.

Other benefits arose from increasing coherence and harmonisation at the level of the European Statistical System. Based on the BR Regulation, important development steps comprise project work on micro data linking and data warehousing, and the launching of the European Profiling of large and complex enterprise groups.

Additional issues

When defining an enterprise (the statistical unit most business statistics refer to), most Member States focus on the legal unit only. This practice has a negative impact on the relevance, accuracy and comparability of European business statistics as it is translated into an increasing gap between the economic reality and its statistical description (e.g. the number of enterprises is overestimated).

The BR Regulation initiated a collaborative process, which extended beyond the usual interaction 'Commission (Eurostat) - Member States’; it also required a strong coordination and cooperation among Member States in the fields of communication, sharing of experiences and working practices. In addition it paved the way for a more efficient and extensive use of administrative sources and the exploitation of additional administrative and commercial sources.

Another result of the implementation of the BR Regulation was the publication of the 'BR Recommendations Manual' as a tool to encourage improvement in quality, consistency and comparability of the principles and contents of business registers in the Member States. The manual was updated in close cooperation with the Member States.

Further developments

Work is underway in the European Statistical System to promote a consistent implementation of the Statistical Units Regulation across Member States. This includes work on a common approach for the treatment of multinational enterprise groups.

The BR Regulation laid the basis for a more accurate and comparable system of statistical business registers, contributing to the increase in consistency and quality of the information provided. This work has not finished but continues with strengthening the backbone functions of business registers in the envisaged Framework Regulation Integrating Business Statistics. The aim is to provide the pre-requisites for the horizontal and vertical integration of statistical data on businesses and pave the way to the reduction of burden for businesses and costs for the National Statistical Institutes.

5. Conclusions

The balance between relevant benefits on one hand and moderate costs for the system and burden on business on the other hand leads in general to a positive assessment of the implementation of the BR Regulation, even if the difficulties encountered with regard to the implementation of the definition of the enterprise according to the Statistical Units Regulation affect the implementation of the BR Regulation.

[1]               Regulation (EC) No 177/2008 of the European Parliament and of the  Council of 20 February 2008 establishing a common framework for business registers for statistical purposes and repealing Council Regulation (EEC) No 2186/93. OJ L 61, 5.3.2008, p. 6

[2]               Council Regulation (EEC) No 2186/93 of 22 July 1993 on Community co-ordination in drawing up business registers for statistical purposes. OJ L 196, 5.8.1993, p.1

[3]               OJ L 76, 30.3.1993, p.1.

[4]               OJ L 67, 12.3.2009, p. 14.

[5]               OJ L 312, 27.11.2010, p. 1.

[6]               For more detailed information on the Member States having received financial support from Eurostat and on the exact amounts paid, please refer to the Annex to this report

ANNEX

Overview of financial support to Member States 2008-2013

Country || Year || Amount (EUR) || Main area of support

Belgium || 2009 || 30,950 || system development (processes)

|| 2010 || 118,803 || system development (processes)

|| 2011 || 52,849 || system development (processes)

|| total || 202,602 ||

Bulgaria || 2008 || 6,379 || quality

|| 2009 || 7,142 || quality and system development (processes)

|| 2011 || 42,244 || coverage and system development (processes)

|| total || 55,765 ||

Cyprus || 2008 || 6,166 || system development (processes)

Czech Republic || 2008 || 12,948 || quality and system development (processes)

Denmark || 2008 || 14,962 || quality and system development (source and processes)

|| 2009 || 25,460 || quality and system development (processes)

|| 2010 || 28,847 || system development (processes)

|| 2011 || 57,740 || system development (processes)

|| total || 127,009 ||

Estonia || 2008 || 3,840 || quality and system development (processes)

Finland || 2008 || 25,542 || system development (processes)

|| 2009 || 38,118 || quality and system development (processes)

|| 2010 || 36,470 || system development (processes)

|| 2011 || 43,164 || system development (processes)

|| total || 143,295 ||

France || 2008 || 18,762 || system development (processes)

|| 2009 || 5,883 || system development (processes)

|| 2010 || 18,247 || system development (processes)

|| 2013 || 209,271 || system development (source and processes)

|| total || 252,163 ||

Germany || 2008 || 101,182 || quality and system development (source and processes)

|| 2009 || 47,317 || system development (processes)

|| 2010 || 46,467 || system development (processes)

|| 2012 || 66,937 || system development (processes)

|| 2013 || 90,309 || system development (source and processes)

|| total || 352,212 ||

Hungary || 2009 || 18,794 || system development (processes)

|| 2011 || 49,298 || system development (source and processes)

|| total || 68,092 ||

Ireland || 2009 || 12,996 || system development (processes)

Latvia || 2008 || 5,941 || system development (processes)

|| 2009 || 6,962 || system development (processes)

|| total || 12,903 ||

Lithuania || 2008 || 2,686 || system development (processes)

|| 2009 || 8,843 || system development (processes)

|| total || 11,529 ||

Malta || 2008 || 3,134 || system development (processes)

Netherlands || 2008 || 20,411 || quality and system development (source and processes)

|| 2009 || 43,283 || system development (processes)

|| total || 63,695 ||

Poland || 2008 || 14,366 || quality and system development (processes)

|| 2010 || 24,126 || system development (processes)

|| 2013 || 25,070 || system development (processes)

|| total || 63,561 ||

Portugal || 2008 || 32,501 || quality and system development (source and processes)

|| 2009 || 36,724 || system development (processes)

|| 2010 || 102,814 || system development (processes)

|| 2013 || 69,861 || system development (processes)

|| total || 241,900 ||

Romania || 2008 || 8,723 || system development (processes)

|| 2009 || 6,062 || system development (processes)

|| 2011 || 33,491 || system development (processes)

|| total || 48,276 ||

Slovakia || 2008 || 7,687 || system development (processes)

|| 2009 || 20,712 || system development (processes)

|| 2013 || 151,242 || system development (processes)

|| total || 179,641 ||

Slovenia || 2011 || 59,511 || system development (source and processes)

|| 2013 || 22,017 || system development (processes)

|| total || 81,528 ||

Spain || 2008 || 5,851 || quality and system development (processes)

|| 2013 || 38,597 || system development (processes)

|| total || 44,448 ||

Sweden || 2008 || 25,179 || system development (processes)

|| 2009 || 45,311 || system development (processes)

|| 2010 || 64,805 || system development (processes)

|| total || 135,295 ||

United Kingdom || 2008 || 36,590 || quality and system development (source and processes)

|| 2009 || 16,235 || system development (processes)

|| 2011 || 16,468 || system development (processes)

|| total || 69,293 ||

EU total || 2008 || 352,850 ||

|| 2009 || 370,793 ||

|| 2010 || 440,579 ||

|| 2011 || 354,765 ||

|| 2012 || 66,937 ||

|| 2013 || 606,366 ||

|| total || 2,192,290 ||