RIA

Following its restrictive policy regarding regulation, the National-led government has introduced a guideline in late 2009 with the effect that RIAs are systematically undertaken for any policy activity involving options that may result in a paper being submitted to cabinet and, accordingly, may lead to draft legislation. This aims at restricting new regulations to those that the government sees as necessary, sensible and robust and to avoid regulations which are ineffective and costly.

The U.S. government provides for extensive analysis of major decisions, within both the legislative and executive branches, and for administrative or regulatory decisions as well as legislation. Regulatory impact assessment is performed by the Office of Management and Budget (OMB) on the executive side and by the Government Accountability Office, the Congressional Budget Office (CBO) and the Congressional Research Service on the legislative side. RIA activities are centrally registered. Under an executive order from the early 1980s, the OMB has a mandate to assess all regulations that executive agencies seek to promulgate. Regulations cannot take effect before a cost-benefit analysis has been performed by the agency and approved by the OMB; the OMB may reject a regulation either because the benefits are insufficient or the costs excessive or because the agencies’ analysis is inadequate. This is a highly political process. Under Republican presidents, it was frequently directed towards containing or curtailing the issuing of environmental and work safety regulations by the Environmental Protection Agency and Occupational Health and Safety Agency. Under Obama (as in the Clinton administration) the disposition toward new regulations is far more supportive, as the administration’s attitude to the regulation of greenhouse gases by the EPA has shown.
The most ambitious projects in policy analysis were the studies by the CBO on health care reform and climate change. These were not limited to the budgetary impact, but addressed the wider policy consequences, including distributional and employment effects of climate change legislation as well as a study on the regional impact of global warming in the United States. The Congressional Research Service also conducted several notable studies on climate change. The CBO study on health care focused primarily on issues of budgetary impact, but it did touch on many other issues, including coverage.

The government-adopted bill in 2004 drafted instructions wherein impact assessment was set to be part of the Finnish legislative drafting process. The RIA process is described in several guidelines. In the preparatory drafting stage, different impact areas are identified. The assessment looks at economic impacts, impacts on public administration as well as environmental and social impacts. A follow-up of the effects of the implemented reform is too part of the impact assessment procedure. The results of the impact assessment are written down in the statement of reasons in the government bill.
The present government has decided in 2009 to retain the system of program management that has been used since 2007. The system encompasses three inter-sectoral policy programs: the Policy Program for Employment, Entrepreneurship and Worklife, the Policy Program for Health Promotion and the Policy Program for the Wellbeing of Children.
The policy programs and the strategy document provide information on issues under intensive monitoring, a draft for legislative projects, a list of statements to be submitted to parliament, a plan for government resolutions and the main themes and priorities for sector research. The issues under special monitoring include climate and energy policy; skills and innovations; administrative reform; structural reform of municipal and service sectors; social protection; exclusion and the reform of social protection systems; preparing for population ageing; broad-based security and Finland’s international status. The Prime Minister’s Office produces in collaboration with other ministries an impact assessment and a follow-up report on the aforementioned issues and policy programs for the use of an end-of-term government policy-review session.

The basic framework for policy evaluation in Japan is the Government Policy Evaluations Act of 2001. According to the OECD, this was only used sporadically until 2004. The Regulatory Reform Program of 2004 ordered that regulatory impact assessments (RIAs) were to be administered in a more systematic way. By the time of a review and revision of the system by Japan’s government in 2005, it was considered to have taken root. In fiscal year 2008, some 7,088 policy evaluations were undertaken by the various ministries, compared to 3,709 in 2007. With regard to the “challenges” formulated by the OECD in its 2004 report on regulatory reform in Japan (p. 2), Japan has now fulfilled most of the points mentioned, at least in a formal sense. The new DPJ-led government has pledged to make a careful examination of existing policies, aiming to cut costly measures that lack obvious social merit; it hopes thus to create the budgetary flexibility to pursue its own priorities. As a new body attached to the Cabinet Office, the Government Revitalization Unit conducted a number of televised interviews with project leaders in late 2009, which some characterized as similar to an “inquisition,” and which were noteworthy for the lack of professionalism of some of the questions and arguably of some of the decisions reached.

Regulatory impact assessment (RIA) was introduced in Mexico in 1997. In 2000, RIA was implemented broadly through reform of the Federal Administrative Procedure Law. Thus, RIA in Mexico is established by law, and not by presidential or prime ministerial degree as in some other OECD countries. There is a government agency belonging to the Ministry of Economy, the Federal Commission for Regulatory Improvement (Comisión Federal de Mejora Regulatoria, COFEMER), which is responsible for performing impact assessments on new proposals if these generate compliance costs. COFEMER does spot-check existing regulations, but does not assess them systematically. Nevertheless, despite some limitations, it has been quite active since it was established at the beginning of Fox’s term in 2000, and its reputation in Mexico is good. However, opinions issued by COFEMER are not binding on other agencies and ministries. More then 10 Mexican states have also adopted RIAs for subnational regulatory projects. Moreover, evidence-based evaluations of several Mexican public policies in the social sector have gained international recognition, and have had significant spillover effects to the international evaluation community. This is especially true for social policies, where rigorous impact assessments based on randomized control-based trials of the Education, Health, and Nutrition Program (Programa de Educación, Salud y Alimentación, PROGRESA) can be perceived as an international showcase on how to evaluate large-scale social programs. In this area, the National Council for the Evaluation of Social Development Policy (CONEVAL) is responsible for carrying out rigorous impact evaluations in large social-sector programs. CONEVAL is an autonomous and independent agency created by the Ley General de Desarrollo Social in 2007.

In the Netherlands, RIAs are broadly and effectively applied in two fields: Environmental Impact Assessments (EIMs) and Administrative Burden Reduction Assessments (ABRAs).
EIMs have been legally prescribed since 1987. Everybody who needs a government license for initiating substantial spatial or land-use projects (e.g., when building a chemical factory, expanding an airport) with possible harmful environmental impacts is obliged to show these impacts through research. The EIM report mentions one or several alternative options, whose environmental impacts will also be described and analyzed. Meanwhile , more than 1,000 EIM reports have been administratively and politically processed. They guarantee that environmental and sustainability considerations play a considerable role in government decision-making.
The development of a Standard Cost Model (CBA) method for evaluating ex ante legislation regarding compliance costs to business deriving from government regulations was entrusted, in 1998, to an ad-hoc but independent advisory commission, the Advisory Board on Administrative Burden Reduction (ACTAL). Since then, ACTAL’s competency has evolved beyond the think tank function of a policy and organizational infrastructure systematically aiming at the reduction of administrative burdens. Under the Balkenende IV administration, ACTAL served as the government’s watchdog, with two deputy ministers (Finance and Economic Affairs) overseeing its activities and a special-purpose interdepartmental project unit providing support. ACTAL reviews all ministerial ex ante evaluations for administrative burden reduction, assists ministerial units in its analytic tasks, and advises the cabinet and parliament about the quality and effectiveness of ministerial regulatory proposals prior to formal decision-making or policy adoption. ACTAL’s findings are always reported in the explanatory memorandums attached to bills. The cabinet also responds to ACTAL’s annual progress reports. For example, when the Balkenende IV government was compelled to renegotiate its coalition agreement as a consequence of the banking and financial crisis, ACTAL was used to identify the risks (administrative burden increases) involved with new regulations and oversight activities.

The federal government and the state and territory governments require the preparation of Regulation Impact Statements (RIS) for significant regulatory proposals. An RIS provides a formal assessment of the costs and benefits of a regulatory proposal and alternative options for that proposal, followed by a recommendation supporting the most effective and efficient option. Regulation Impact Statements are thus not assessments of socioeconomic impacts of regulatory proposals, although implicitly such impacts are taken into account as part of the process. Moreover, RIS do not apply to draft laws that are not of a regulatory nature - for example, changes to tax and transfer policies. Indeed, they are generally only applicable to proposed regulations affecting businesses.

Since many government functions and responsibilities are shared between the federal government and the states, these shared activities are coordinated through the Council of Australian Governments, which is the body that brings the federal and state governments together to decide policy. The procedures for the preparation of RIS proposals differ between the federal government and the Council of Australian Governments. Most states and territories have their own requirements for RISs that apply where a regulation will have effect in only a single state or territory. At the federal level, RISs are managed by the Office of Best Practice Regulation, which is part of the Department of Finance and Deregulation.

All new law proposals must be accompanied by a report summarizing the expected fiscal impact and the financial implications for the government budget. This report is always prepared by the fiscal department of the corresponding ministry. Chile also has a constitutional restriction on policy proposals that imply budget changes. Economic and social-impact assessments are provided by ad hoc commissions that prepare draft policy reform proposals in specific policy areas, and which are appointed by the president or by line ministers. Environmental impact assessments are performed for most large public investment programs (as well as private investment programs).

In 2005, regulatory impact assessment (RIA) was introduced as an integral part of public administration reform. Application has rested with a department of the Ministry of the Interior, making use of advice and guidelines from the European Union. By 2008, all draft laws were to be subjected to RIA. Some exceptions were allowed, largely for legislation already in process. There are two forms of RIA, a short and a comprehensive one. The latter is applied when broad policy consequences are envisaged or when a strategic government policy is being examined. In some cases, the assignment has been controversial.

An instruction (cirkulære) from the PMO in 1998 to all ministries and agencies established the requirement of evaluating various consequences of proposed legislation and administrative regulations. Subsequently, a number of ministries developed texts advising the civil servants on how to do this. In May 2005 a common guide was worked out with the Ministry of Finance as lead ministry.
The rules require impact assessments dealing with economic consequences for state and local governments, administrative consequences, business economic consequences and environmental consequences. The relation to EU legislation must also be assessed.
Thinking about consequences starts during the initial consideration of a new law or regulation (screening stage), continues while the content and degree of new measures are considered (scoping stage) and a detailed RIA is worked out during the final stage (assessment stage).
So RIAs have become a required part of Danish policy formulation.
The extent to which existing regulations are regularly assessed depends on the regulation in question and the feedback the administrative agency gets.

In 2000, the federal ministries revised rules of procedures came into effect, demanding that an impact assessment be performed for every draft law. Thus, the regulatory impact assessment (RIA) process is institutionally anchored in Germany. The RIA is designed to restrain the amount of state regulation to the degree possible, examining alternative regulation possibilities and improving the quality of regulations. The RIA analyses the intended effects and the unintended side effects of draft laws as well as of alternatives.
The Federal Ministry of the Interior has developed guidelines for the application of these impact assessments. The evaluation of the actual effects and therefore a retrospective RIA of existing laws and regulations is part of the assessment process.
There is a separate program for environmental impact assessment.
The budgetary and bureaucratic consequences of a draft law are also required to be assessed.

In Norway, a system of regulatory impact assessment (RIA) was introduced in 1985 and revised in 1995. The ministers and the government are responsible for providing comprehensive assessments of the budgetary, environmental, health and human-rights effects of their proposals. Consequences should be quantified as far as possible, including by means of a thorough, realistic socioeconomic analysis. A set of codified guidelines (the Instructions for Official Studies and Reports) regulates RIAs. However, the ministry in charge has some discretion to decide when an RIA should be produced. There is no formal rule on when a full RIA must be conducted, or when a less detailed assessment is sufficient.
The RIA is included as a separate section in the ad-hoc reports commissioned from experts or broader committees, as well as in white papers and final bills. There is no central body in the government administration that conducts quality control on RIAs, although each department has issued guidelines on how RIA should be conducted. An interministerial panel on economic impact assessments was established in 2005, which brought together RIA experts from various ministries, and has an advisory function in improving the quality of RIAs. The parliament may send back a proposal if it regards the RIA as unsatisfactory. This has actually occurred in a number of cases.

There were no changes in regulatory impact assessment (RIA) policy in the period under review. RIA has been mandatory for all new regulations since 2005, and for older regulations should they be strengthened in any way. RIAs assess proposals’ socioeconomic impacts and provide cost-benefit analyses.

There is no formal institution responsible for ex ante impact assessment. Article 170 of the constitution states that “(t)he federal parliament shall ensure that the efficacy of measures taken by the confederation is evaluated.” In some ministries, there may be cases in which units (such as the economics ministry) do ex ante impact assessment. Furthermore, ex ante evaluations by the administration always include checks for consistency with existing law (performed by the Ministry of Justice), compatibility with EU regulations, and if necessary, analyze budget implications, administrative costs and personnel requirements. Ex post evaluations have also been strongly developed, yet as elsewhere, one cannot take for granted that the results of these analyses have any effect on implementation.
Beyond these processes, functional equivalents of impact assessments do exist. First, expert commissions that draft or suggest laws evaluate alternatives to, potential impacts of, benefits of and problems associated with proposed solutions. Second, and probably more important, is the so-called consultation procedure derived from Article 147 of the constitution. This article stipulates that “[t]he cantons, the political parties and the interested circles shall be heard in the course of the preparation of important legislation and other projects of substantial impact, and on important international treaties.” As a consequence, all those who are affected by a planned law may give their opinion as to its pros and cons.

The Better Regulation Executive (BRE), originally part of the Cabinet Office, has now moved to the Department for Business Innovation and Skills (BIS), previously known as the Department for Business, Enterprise and Regulatory Reform (BERR). Seemingly somewhat downgraded in importance, the group’s key goal is now to improve regulation, mainly by reference to a set of principles: All regulations should be transparent, accountable, proportionate, consistent and targeted. The department’s goal is to reduce the costs of regulation to businesses in Britain by 25% by 2010. There is no longer any mention of regulatory impact assessments (RIAs) in their annual report.
While many RIAs are still being produced in Britain (as the Treasury website shows, for example), academic research suggests that their results are not systematically integrated into civil service decision-making procedures, and may just be a sign of the “hypermodernism” characteristic of the British regulatory state – a discursive element rather than an instrument for steering change. The degree to which RIA shapes the final legislation is probably impossible to estimate with any precision.

Regulatory impact analysis (RIA) is used by all government departments and offices. It applies to:
• proposals for primary legislation involving changes to the regulatory framework;
• significant statutory instruments;
• proposals for EU directives and significant EU regulations when they are
published by the European Commission; and
• proposals for legislation by policy review groups.
Prior to the discussion of legislative proposals by cabinet committees, RIAs are prepared by departments for consideration by relevant senior officials.
An independent review of the operation of RIAs was completed in 2008 and published as “Regulatory Impact Analysis: An Operational Review by the Department of the Taoiseach (Prime Minister’s Office).” The review indicated that good progress had been made in relation to the implementation of regulatory impact analysis across departments. It made a range of recommendations in relation to how the RIA model could be amended and improved.
A new set of guidelines drawing on the experience of the RIA pilot process was published in June 2009. This document listed 45 RIAs that had been published since 2006. However, the range of topics covered is not wide, and many important topics are not included. The new guidelines pointed to the need for a more detailed consideration of methodological issues, particularly where qualitative data is involved, as well as the importance of including advice on public service implementation and administrative costs. It is claimed that all these issues have now been addressed in the process.
Despite this apparently high level of commitment to appraisals and assessments, it is far from clear that the process works to ensure meaningful analysis of major legislation. Analytical skills have not been built up within ministries over the years. There is excessive reliance on external consultants for project appraisal and impact analysis.

RIA aims at improving the quality of regulation and legislation. The EU Commission has been promoting RIA for several years as an instrument to reduce paperwork for private business. The Swedish experience with RIA appears to be mixed. The results were recently described as “rather modest.”

According to paragraph 14/1 of the federal budget law (Bundeshaushaltsgesetz, BHG), the government (i.e., ministries) must assess the financial impact of legislative proposals in terms of the public budget, the employment of civil servants and the financial resources of (financially) autonomous institutions.
Legislative proposals also have to be evaluated with regard to their impact on financial, economic, environmental, consumer-protection and employment issues(Deregulation law 2001). In addition, in order to avoid over-regulation, government’s legislative proposals have to be assessed regarding their regulative impact.
Since 2007 every legislative proposal has to be assessed regarding its effects on business originating from transparency requirements (Par. 14a BHG).
RIA outcomes are then published in the preface to the legislative proposal. In Austria, RIA is a very recently established, but nonetheless a rapidly evolving tool for legislators and parliamentarians.

Canada’s assessment of the potential socioeconomic impact of draft laws is somewhat irregular, as regulatory impact assessments (RIA) applied randomly, except in areas such as environmental projects where they are required by statute.

Carrying out impact assessments has been mandatory for all government bills and regulation since 2001. New RIA guidelines were adopted in 2006 under the previous government. While assessments are undertaken by the ministries, supervision and quality control rest with the Chancellery of the Prime Minister. However, the quality of assessments is often poor, and the RIA requirements are often met only on paper. One major reason is the lack of well-trained staff. In 2009, the government launched a number of measures in order to improve the quality of RIA (Ministry of the Economy 2010). It introduced a new training system, created an electronic platform for widening access to analytical tools and good practices, and set up RIA audits in order to strengthen ex post quality control.

The practice of RIA has been developed since 1995, notably under the supervision of the Prime Minister’s Office. Furthermore, the minister of finance systematically assesses the impact of draft proposals under discussion, usually acting as a brake on many proposals. Line ministries do the same but in the opposite direction, playing the advocates of the bill under discussion. A further assessment is provided by the Council of State (Conseil d’Etat) whose advice is required by the constitution for all government draft bills and decrees. This assessment is supposed to be purely legalistic but the council might also consider other dimensions such as the social, financial or international impact of a proposed measure.
Existing studies analyzing the impact of RIA nonetheless indicate some problems. Although the initial skepticism of administrative bodies toward RIA has been overcome, the content of assessments has been too general and often tended to justify the need for action rather than try a critical, and well-grounded, assessment; in addition, there are few international comparisons when examining possible alternatives.
The assessments are conducted by stakeholders with a perspective of fighting for or against the policy measure. Thus, in general it has little to do with a rational exercise.

Regulatory impact assessments (RIAs) are in principle required from all ministries and local authorities (under laws 50/1999 and 246/2005). RIAs at the national level fall under the responsibility of the PMO. The PMO is responsible for the review and quality control of RIAs produced by ministries, as well as for the coordination of activities associated with an RIA. The Presidency of the Council of Ministers, with its department for juridical and legislative affairs, is the body responsible for the elaboration of RIA methodology. However, it is questionable whether sufficient resources are available within the Presidency to seriously further RIA efforts. Implementation has in fact been far from systematic since the beginning of the RIA program. As a consequence, a new plan adopted in July 2007 by the Prodi II government created new, simpler RIA forms that were implemented starting November 2007. Further implementation rules were approved in 2008 – 2009 by the Berlusconi IV government (DPCM 170/2008 and Directive 26 February 2009). According to this framework, the performance of RIAs at the ministerial level is intended to be enforced by a prohibition on cabinet discussion of any proposal lacking this assessment. However, in February 2010, the parliamentary committee (“Comitato per la legislazione”) responsible for monitoring the quality of legislation at the national and regional levels discovered that in a sample of 20 regulations approved by the government in the previous 10 months (March 2009 – January 2010), only eight laws had been accompanied by the requested RIA.

There remains a need for greater assessment of the socioeconomic impact of legislation. The first Sócrates government took measures to rectify this situation by means of its “Simplex Test” (an estimation of the bureaucratic footprint associated with legislation) and its “Legislating Better” Council of Ministers resolution of 2006. This drive was developed further in the 2008 – 2010 period. A Council of Ministers resolution in December 2008 (Resolução do Conselho de Ministros No. 196/2008) sought to incorporate the Simplex Test into the EU’s action program for reducing administrative burdens, and to standardize its implementation. Moreover, another Council of Ministers resolution (Resolução do Conselho de Ministros No. 198/2008) changed that body’s own rules of procedures, making the Simplex Test mandatory for all proposed legislation with its results submitted along with the proposal to the council. This is a positive step in terms of the implementation of ex ante assessment. However, it is not clear how effectively this has been implemented. The Council of Ministers’ rules of procedures stipulate that these assessments are for the government’s eyes only. Moreover, while Council of Ministers Resolution No. 196/2008 ordered that annual reports be prepared be made evaluating the Simplex Test assessments, “in order to facilitate its public scrutiny” (No. 18, iii), no such reports assessing the use of the Simplex Test in draft legislation were found for either 2008 or 2009.

Hungary has seen various attempts at improving impact assessment ever since 1987. In 2006, the Ministry of Justice and Public Order published new guidelines, modeled on EU approaches. However, these guidelines have not been adopted as an official government document yet. RIA suffers from unclear and fragmented competencies. Both the Prime Minister’s Office and the Ministry of Justice and Public Order have been active in the field. In practice, there is no systematic application of RIA. In a number of cases, no RIA is undertaken; in other cases, draft bills come with in-depth assessments of more than 100 pages.

The provisions on RIA are still in flux. RIA application suffers from a number of weaknesses (Chren 2009). First, RIA are not obligatory and can be circumvented relatively easily. Second, the supervision of RIA is divided among different agencies, and the supervising agencies can only check the formal correctness of the assessments, but not their substantial quality Third, as RIA is strongly integrated in the normal process of interministerial coordination, it is often reduced to an instrument for improving coordination within government.

In July 2009, general regulatory impact assessments (RIAs) were established for the first time in Spain by Royal Decree 1083/2009. Previously, Law 30/2003 had already introduced a gender impact assessment (GIA). The new law facilitated the RIA process by specifying a general procedure to be applied across content area. The decree emphasized the contents of RIAs performed on draft legislation must address economic and budgetary considerations as well as any other relevant aspects, such as environmental impact, gender equality concerns, and any possible effect for disabled people.
Because this is a relatively new obligation, it is difficult to determine precisely how effectively impact assessments have been performed thus far. With respect to gender impact assessments, longer application does not necessarily reflect satisfactory results. In some occasions, the GIA has been efficiently used; in others, it seems to have been a formal requirement fulfilled by the public administration by simply asserting the legislation would not produce any differential impact from the perspective of gender.

Regulatory impact assessments (RIAs) are known in Greece, but are not systematically applied. Efforts to introduce RIAs in the previous reporting period were never implemented. Under the Karamanlis government, all ministries were requested to accompany new bills with a RIA beginning in February 2009. However, the elections of 2009 and the financial crisis of 2009 – 2010 have served as considerable distractions, and the RIA process was quickly dropped. In theory, RIAs in Greece are supposed to assess the impact that new bill would have on already existing legislation, estimate the economic impact of the bill, and evaluate whether the new law would overlap with other legislation. But impact assessments (and policy evaluation more generally) has in fact remained very underdeveloped.
In the Papandreou government, a new attempt to start applying RIA was made in various ministries in April 2010, but it is too early to evaluate this attempt. A separate unit for RIAs within the PMO was also apparently under discussion.

Regulatory impact analysis, in the true sense of the concept, does not exist in Luxembourg. Nevertheless, as of 10 years ago, every new law or regulation has to be accompanied by a financial fact sheet listing direct expenses and revenues and an impact assessment form specifying administrative costs. The administrative costs are all the formalities and administrative obligations incumbent on businesses, citizens, administrations and ministries, directly or indirectly related to the legislation.
In late 2009, the impact assessment form was redesigned by the Committee for Administrative Simplification (Comité à la Simplification Administrative, CSA) to give new life to a poorly used tool.

Since 2007, regulatory impact assessment (RIA) has been required for all legislation (laws, decrees and other regulatory procedures) having a financial impact of at least TRY 10 million, excluding issues relating to national security, the draft budget, or final accounts, (under Article 24 of Regulation No. 4821 on the Procedure and Principles of Preparing Legislation, dated December 12, 2005, followed by a resolution of the Council of Ministers published in the Official Gazette on February 17, 2006 (No. 26083)). The prime minister’s office also issued a circular on practices of regulatory impact assessment on April 3, 2007, providing a guide on preparation of the assessments. However, it is hard to say that RIA is systematically applied in Turkey.

Before making a decision, the government will typically query stakeholders and attempt to prevent unexpected policy outcomes. But there are no formal regulatory impact assessments as part of this process, and unexpected policy outcomes are not exceptional. Two examples help to illustrate this fact. There is the case of tax reforms introduced in 2002 that were meant to attract foreign direct investment and promote the creation of jobs by lowering corporate tax rates. There was no proper assessment of the potential costs of these reforms, nor any fact-based assessment of their potential impact on job creation. As the government deficit has increased, the reforms are perceived by many as too costly for the number of jobs they have created.
Another case relates to a reform introduced by the French Community in Belgium (Communauté Française de Belgique), responsible for education in the French-speaking part of Belgium. A complex mechanism was put in place to address discriminatory school selection practices that, in some schools, work against children who come from economically disadvantaged backgrounds. The mechanism centralized secondary school registration and relied on a mechanism of random selection, perceived as fair by the government. The mechanism was so inefficient however that it did not select any school for scores of children, whereas other children got selected in several schools. This outcome was predictable and many academics and other interested parties (mainly parents’ organizations) had actually warned the government of these risks. Yet, the community government turned a blind eye on these warnings and only admitted the failure of its actions in the summer of 2009, when classes were about to start and the system had left hundreds of children without a school to attend. The government then relied on additional measures to resolve the situation after the fact.

Regulatory impact assessment (RIA) is not and has never been applied in Iceland.