The broad rationale for socioeconomic RIAs is laid down in the government/coalition agreement of the Balkenende IV administration. The Standard Cost Model specifies all the elements that positively or negatively affect administrative costs of government regulations/subsidies for target groups. It also provides a standard against which monetized administrative cost reductions per bill revoked or per new regulation introduced may be expressed. There are overall reduction targets per department, which may have to compensate for the introduction of new legislation/regulation by abolishing the implementation of older ones. ACTAL justifies its existence by pointing out that administrative cost reduction for firms, citizens and professionals means a 1.7% increase in (macroeconomic) labor productivity and a 1.5% gain in GDP. ACTAL guards against the routine call for more and stricter regulation after incidents or calamities; its activities have also reached subnational, local governments.
The Standard Cost Model method was only recently pilot-tested on administrative burdens falling on individual citizens. ACTAL follows a step-by-step target group approach, prioritizing citizens that suffer in particular from high administrative burdens like the chronically ill, the physically challenged, elderly social benefit recipients and volunteer workers. In sum, only particular types of burdens for some social groups are measured, not all. The most conspicuously absent item from ACTAL’s and the government’s ex ante evaluation’s claims regarding comprehensiveness is that burden reduction is just assumed to be beneficial, on average, for the short- and the long-term. Like other forms of cost-benefit analysis, non-economic, less tangible, non-quantifiable costs and benefits are blended out of the consideration. There is no Standard Benefit Model to logically complement the Standard Cost Model.
R. Hoppe, (2009), Ex ante Evaluation of Legislation: Between Puzzling and Powering, in J. Verschuuren (ed.), The Impact of Legislation. A Critical Analysis of Ex ante Evaluation, Martinus Nijhof, Leiden/Boston, 81-104.