Gold-plating in the European Structural and Investments Funds Dr Kai Böhme Spatial Foresight 1
Structure of the Presentation 1. 2. 3. 4. 5. 6. 7. Objective & methodology Definition of gold-plating in ESIF Gold-plating in the programme cycle Reasons for gold-plating Effects of gold-plating Conclusions Recommendations 2
Aim & methodology Aim: Contribute to the debate and policy dialogue on goldplating related to cohesion policy Clarifying gold-plating in ESIF, its reasons and effects Providing pointers for actions to reduce gold plating Methodology: Desktop analysis of literature and documents In-depth interviews with selected stakeholder Focus group with selected stakeholders Coverage 28 MS, 9 of which in-depth 3
Definition of gold-plating in ESIF Active gold-plating: additional administrative procedures and regulatory obligations that go beyond the ESIF requirements set out at EU level. Passive gold-plating: national, regional or local players fail to apply simplification measures proposed in the ESIF regulations. Administrative costs: costs for an administrative task carried by bodies responsible for managing a policy. Administrative burden: costs funds beneficiaries and final recipients have for complying with the information obligations. 4
Definition of gold-plating in ESIF other EU regulatory frameworks ESIF EU regulatory framework national frameworks sub-national frameworks Gold plating adding to the minimum requirements of the ESIF regulatory framework Interpretations of regulatory frameworks Programme management and implementation obligatory administrative workload and costs + additional administrative workload and costs + additional administrative workload and costs Beneficiaries management and implementation of funded actions obligatory administrative burden + additional administrative burden + additional administrative burden 5
Gold-plating in the programme cycle Gold-plating most prominent in: - Eligibility - Reporting - Payment - Financial controls Programme evaluations Financial controls Payment. claims & reimbursements Programme development and accreditation Funding applications & eligibility checks Reporting & monitoring 6
Reasons for gold-plating Inconsistencies & additional policy objectives Changing regulations Interpretation uncertainties Back seat driving by auditors Delayed regulations Bad experience Risk aversion and fear Administrative traditions and cultures Complexity of the system Vested interests Bureaucratic power Lack of communication and cooperation more rules = higher error risks = more uncertainty 7
Effects of gold-plating Gold-plating ADMIN COSTS (programme bodies) - More work Increased admin costs and burden Higher error risks - ADMIN BURDEN (Beneficiaries) More work (in particular for small entities) Disincentive to apply Reduced effectiveness Focus on how to implement rather on what to achieve (doing it the right way prevails over doing the right thing) More gold plating 8
Gold-plating in the case of ESIF Inconsistencies & additional policy objectives Gold plating in ESIF Changing regulations Interpretation uncertainties Increased admin costs and burden Back seat driving by auditors Delayed regulations Bad experience ADMIN COSTS (programme bodies) - More work Risk aversion and fear Higher error risks - ADMIN BURDEN (Beneficiaries) More work (in particular for small entities) Disincentive to apply Reduced effectiveness Administrative traditions and cultures Focus on how to implement rather on what to achieve (doing it the right way prevails over doing the right thing) Complexity of the system Vested interests More gold plating Bureaucratic power Lack of communication and cooperation more rules = more errors = more uncertainty 9
Conclusions on gold-plating in ESIF Gold-plating increases administrative costs and burden Both active and passive gold-plating play a role Gold-plating happens irrespective of the administrative level and time of ESIF management processes Differences mainly between Member States Gold-plating mainly driven by audit fear and uncertainties Complexity of the system leads to vicious circles In some cases gold-plating might be justifiable Reducing or avoiding gold-plating is a task for all players in the ESIF shared management system 10
Recommendations All players need to reduce gold-plating in the 2014-2020 period: EU legislators: increase transparency and promote clarity, simplicity and continuity of rules. National level: e-governance should be further promoted, national administrative changes can be launched. Programme level: focus on providing clarity to beneficiaries and to make more use of SCO. Potential actions across levels include Capacity building, open dialogue, better focus on a balance between compliance and performance. Encouraged use of simplification measures. 11
Recommendations beyond 2020 At least 3 paths how to reduce gold-plating: Current system increased shift from compliance to performance More & tighter rules main focus on input control and compliance More flexibility & trust main focus on achievements and performance It is up to the legislators to choose the path 12
Thank you! Dr Kai Böhme Spatial Foresight GmbH +352 691 87 32 49 kai.boehme@spatialforesight.eu www.spatialforesight.eu 13
Current system
More & tighter rules
More flexibility & trust