Evidence-based Instruments


Does the government conduct effective sustainability checks within the framework of RIA?

Sustainability checks are an integral part of every RIA; they draw on an exhaustive set of indicators (including social, economic, and environmental aspects of sustainability) and track impacts from the short- to long-term.
The RIAs have to cover all consequences, whether they be positive or negative, of an economic, administrative and environmental nature, affecting the state, municipalities, regions, business, citizens and relations to the European Union. This includes questions of sustainability. Sustainability is a central concern in government policy and includes economic, fiscal as well as environmental sustainability.
Cirkulære om bemærkninger til lovforslag og andre regeringsforslag og om fremganhsmåden ved udarbejdelse af lovforslag, redegørelser, administrative forskrifter m.v. https://www.retsinformation.dk/Forms/R0710.aspx?id=20940 (accessed 3 May 2013).
The Finnish government understands that regular and complete assessments of regulations are fundamental to the governing of complex and open societies and economies. In consequence, the country has a comprehensive regulatory impact assessment program in place. Also, Finland has formally adopted a regulatory impact assessment strategy that contains instructions to be carried out when drafting legislative proposals, complemented by separate instructions issued by ministries. Assessments involve the use of multiple indicator sets, various interests are consulted and different techniques used. Generally speaking, aspects of sustainability form an integral part of the assessment process. Variations between forecasts and actual outcomes are monitored over time.
New Zealand
Without using the term “sustainability” explicitly, the regulatory impact assessment (RIA) process includes major aspects of this concept. Part of the quality-assurance monitoring process is to check whether all substantive economic, social and environmental impacts have been identified (and quantified where feasible). In addition, it is an integral part of RIAs to plan for regulatory instrument reviews that consider, among others, whether problems persist and if objectives are being met.
Regulatory Impact Analysis Handbook (Wellington: The Treasury 2013).
Sustainability checks lack one of the three criteria.
The potential environmental effects of legislative proposals have to be evaluated as a part of regulatory impact assessments, as do effects on employment. Various decrees require that financial and other issues be assessed. Analysis may focus on the short, medium or long term according to specific RIA legal requirements, but is commonly focused on a period of five years.

The country does feature an overarching sustainability strategy, but this is still relatively underdeveloped. The government tends to give much lip service to the ideas behind sustainability but violates its rhetoric in practice by giving in to special interests. This reflects the dominant tendency in public debate to promote sustainability as long as it does not contradict special interests.

Until 2019, nothing seems to have changed between the symbolic policy of “lip service” and the tendency to follow short-term interests focused on electoral data, although this contradicts official declarations. This may change should the ÖVP form a coalition with the Greens at the beginning of 2020, which appears quite realistic at the time of writing. In order to remain credible, the Greens, who have consistently emphasized environmental sustainability, must ensure that sustainability becomes a core principle of environmental policymaking.
In October 2016, Chancellor Merkel appointed six new members to the German Council for Sustainable Development (RNE), and reappointed the remaining nine members. This body is tasked with contributing to the implementation of the National Sustainability Strategy by identifying areas for action, developing specific project proposals and increasing awareness of the importance of sustainability issues. The RNE independently chooses its array of topics and actions.

In addition, the parliamentary Council for Sustainable Development (Parlamentarische Beirat für nachhaltige Entwicklung, PBnE) supervises the government’s sustainability strategy. Its political influence appears moderate, and its primary task is to act as an advocate for long-term responsibility in the business of government. The PBnE was established in 2004 and must be reconstituted after every parliamentary election. On the whole, neither the RNE nor the PBnE are well integrated into the RIA framework.

In 2019 Sustainable Development Goals (SDG) Index, which was jointly developed by the Bertelsmann Stiftung and the Sustainable Development Solutions Network (SDSN), Germany is well positioned at sixth place out of 157 countries. Its ranking declined by one position compared to 2018.
Sustainable Development Goals Index 2019:



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 mandated since 1987. Anyone who needs a government license for initiating substantial spatial or land-use projects with potentially harmful environmental impacts is obliged to research and disclose potential project impacts. 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. However, environmental impact assessments are sometimes subordinated to economic impact assessments. There are no systematic social – or, for example, health – impact assessments. In 2017, the DNB (Dutch National Bank) announced checks on whether firms in the financial sector have sufficiently explored the risks of climate change in their policies. In the water sector, similar stress tests of policies by water management boards, and municipal and local water management/emergency plans are being prepared. In 2018, the results of recent climate-change platform debates, and negotiations between government, business and other stakeholders were elaborately scrutinized and re-calculated by the Planning Bureau for the Living Environment.

Nevertheless, as reported elsewhere (see “Environment”), the Dutch government has regularly helped economic sectors (farmers, fishermen, civil aviation) delay necessary action and downplay the urgency of sustainability problems.
NRC.next, “DNB waarschuwt financiële sector voor risico’s klimaatverandering, 4 October 2017”

Kennisportaal Ruimtelijke Adaptatie, “Verpliche stresstest wateroverlast voor waterschappen en gemeenten,” consulted 12 October 2017

PBL, Analyse van het voorstel voor hoofdlijnen van het klimaatakkoord, 27 September 2018 (www.pbl.nl>publicaties, accessed 31 October 2018)

M. Chavannes, 19 July, 2019. De net-niet-politiek van Nederland: zwoegen aan het Klimaatakkoord om draagvlak te creëeren voor rustig aan doen. (decorrespondent.nl, accessed 8 November 2019)
In the United Kingdom, the whole RIA process aims to provide support for sustainable policymaking. The assessment is based on a wide range of different indicators, including social, environmental and ecological. However, economic indicators seem to be the most important. The assessments analyze the impact of regulation over several time periods (i.e., short, medium and long-term), and they attempt to take into account external shocks and irregular developments. There is a sustainable development impact test to complete for all relevant policy proposals.
Canada does not have a formally adopted sustainability strategy. In a sense, this is not surprising, as there are different types of sustainability (environmental, economic, social). There is also no consensus as to what sustainability means or to how it should be measured. To be sure, many RIAs address sustainability issues, but the methodologies used differ widely.
The government’s Instructions for Official Studies and Reports require that a sensitivity analysis must be made if any appreciable uncertainty exists, and that alternative instruments should be assessed, including instruments not of a regulatory nature (e.g., economic instruments). In practice, the extent to which alternative options are given careful consideration and submitted to a systematic cost-benefit analysis varies from case to case. Quantification of the costs and benefits of different alternatives is relatively rare.
Environmental sustainability is one of several mainstreamed goals in the policy process. In theory at least, all government bills, procurements and directives to royal commissions are supposed to be assessed to determine their impact on environmental sustainability. As for other types of sustainability criteria, there is little evidence available about the degree to which they are considered in the RIA process.
The government conducts effective sustainability checks within the framework of RIA. Given the decentralized political and administrative system of Switzerland, however, they are only used in few departments.

The Federal Office for Spatial Development uses the Sustainability Impact Assessment (Nachhaltigkeitsbeurteilung, NHB) and the Federal Office for the Environment uses the Economic Impact Assessment (Volkswirtschaftliche Beurteilung, VOBU). There is no social impact assessment at the federal level.
Sustainability checks are an integral part of every RIA assessment but are not very comprehensive. The checklist requires a response to the question of whether there are effects on social, economic and environmental issues and for an indication of what those effects are. A set of 2016 amendments to the RIA guidelines specified how to assess or quantify these effects. Criteria are refined by the relevant ministries on an ongoing basis. The process of assessing the impact of regulation does not replace political decision-making; rather, it creates the preconditions for better decision-making.
The dimension of sustainability is included in the methodological guidelines for RIA. The guidelines demand an assessment of the reviewed policy’s impact over the short, medium and long term. However, sustainability concerns are given a marginal role in the impact-assessment process overall. The existing set of indicators is not explicitly linked to the sustainability check.

Estonia’s next long-term strategy, Eesti 2035, which is currently being prepared, will guide the country’s development from 2021. The strategy will define an integrated vision for the country’s balanced and sustainable development. Nine national priorities, which have been presented in a draft of the strategy, explicitly reference the 17 SDGs.
Summary of the Analysis of the Estonian Sustainable Development Strategy “Sustainable Estonia 21.” https://riigikantselei.ee/sites/default/files/content-editors/Failid/SA_eesti/summary_of_se21_analysis_eng.pdf (accessed 17 December 2017).
In 2015, Israel adopted a long-term plan (2015 – 2030) to improve and advance a number of SDGs, as part of the U.N. Agenda 2030 Plan for Sustainable Development. The plan details 168 objectives and 230 indices, which cover a wide variety of fields, including reduction of poverty, hunger and inequality; improvement of health outcomes, life quality and educational quality; promotion of gender equality, smart consumption and innovation; and the development of infrastructure, energy and sustainable production.

Together with other members of the United Nations, Israel began reporting in 2016 on its efforts to realize the SDGs. In 2017, the United Nations lauded Israel for its quickly and effectively implemented measures in a broad range of areas including clean water and sanitation (Goal 6), quality education (Goal 5), good health and well-being (Goal 3), and industry, innovation and infrastructure (Goal 9). According to the United Nations, the fact that both Israeli companies and ministries are on board with the quick and effective realization of SDGs explains in part the rapid progress made in the country.

In addition, since 2011, the government has published “workbooks” every year, detailing the quantitative measures used to compare policies and policy goals over time. In 2016, another quantitative measure was included examining government performance and goal achievement. In 2019, Israel published its first voluntary national review as part of a joint work conducted by the Ministry of Foreign Affairs, the Ministry of Environmental Protection and various other bodies. The report reviews the things Israel has done to advance Agenda 2030. The report presents Israeli’s many accomplishments in fields such as education, water, healthcare and the economy. However, the report also highlights areas that require further attention.
Adopting SDG goals – sustainable development goals“, Committee meeting of the 20th Knesset, Open Knesset Website, 2017 (Hebrew):

“Agenda 2030 – Sustainable Development Goals of the United Nations“. Ministry of the Environment Website

Arlozorov, Meirav. “The Professionalist Revolution of the Government of Israel.” The Marker website. 2018 (Hebrew): https://www.themarker.com/allnews/1.5846420.

Corporate Responsibility and Sustainable Development, Netivei Israel Company Website (Hebrew):

“Israel earns UN praise at MFA-IDC conference on UN Sustainable Development,” Israel Ministry of Foreign Affairs Website, 2017

Ministry of Foreign Affairs, Implementation of the Sustainable Development Goals – National Review, 2019 (Hebrew):

“Vision of Sustainability for Israel in 2030.” Ministry of the Environment Website 2019: http://kayamut2030.org/index.php?option=com_content&view=article&id=181%3Aindicators&catid=59&Itemid=149
In 2003, the government adopted the National Sustainable Development Strategy. The Ministry of Environment is responsible for coordinating projects related to this document. Lithuanian policymakers are supposed to conduct sustainability checks within the existing framework for regulatory impact assessment. The 2012 impact-assessment guidelines provide for the assessment of economic, social and environmental impacts, among other factors. Both short-term and long-term impacts should be assessed under the new guidelines. However, the guidelines do not provide an exhaustive set of impact indicators addressing these impact dimensions. Producing high-quality environmental reviews remains a challenge under the new system, which focuses on impacts within the business environment and remains a largely formal exercise. The ex ante evaluation of the 2014 to 2020 operational program supported by EU structural funds included strategic environmental assessment that considered the likely effects of EU investments on the environment (in line with EU and national legislation).
So far, RIAs have often highlighted international benchmarking to reinforce their investigations. As one example, in a recent development, the Mexican government signaled its intention to become a world leader in sustainable tourism. Here, sustainability relates to energy efficiency, improved environmental performance and the protection of cultural heritage. The government partnered with the private firm EC3 Global to support the adoption of their trademark EarthCheck science and solutions for tourism operators and companies committed to sustainable practices and to align their performance with global benchmarks, endorsed by the World Tourism Organization. EarthCheck is an internationally recognized environmental management and certification program with more than 1,300 members in 70 countries. The program improves the operational performance of member organizations and reduces costs. However, like in most other OECD countries, RIAs in Mexico have up to now not fully embraced a multidimensional sustainability perspective as is foreseen by the Agenda 2030 for Sustainable Development. This is a particular challenge against the backdrop of the United Nation’s Global Goals (Sustainable Development Goals), which were supported by Mexico and require a multidimensional perspective – including social, economic and ecological dimensions – in public policymaking. However, Mexican government elites at the national level often still appear more likely to be aware of the SDGs than government elites in other OECD countries, which might lead to an improvement in the coming years.
South Korea
The assessment of policy-implementation sustainability in South Korea is regulated by the 2007 Sustainable Development Act and overseen by the Presidential Commission on Sustainable Development, which reports to the Ministry of Environment. This body’s task is to implement, promote, share, educate, network, monitor and make policy proposals on sustainable development. The act addresses environmental quality, vulnerability to environmental degradation, environmental degradation level, the social and institutional capacities to respond, and responsibility sharing with the international community. The Moon administration has promised to focus more strongly on sustainability-related issues, including reductions in youth unemployment rates, air pollution and greenhouse-gas emissions. For example, the Moon administration has promised to build no new nuclear power plants and has temporarily closed 10 coal-fired power plants (although only during months with low electricity demand). At the same time, the government appears to be considering a continuation of previous governments’ problematic practice of prioritizing economic growth, for example by issuing waivers for regulations governing economic development or apartment construction within green-belt areas. While President Moon has promised to highlight environmental sustainability, the actual effects on the RIA process remain to be seen.
Ministry of Government Legislation, http://www.moleg.go.kr/english/korL awEng?pstSeq=57720
Presidential Commission on Sustainable Development (PCSD), http://ncsd.go.kr:2020/index.asp
There has been no standard, separate check required for “sustainability” as such. Assessments have been expected to consider the important costs and benefits relevant to a particular project or policy. While environmental considerations figured prominently in some cases prior to 2016, environmental issues have been aggressively dismissed by the Trump administration. Sustainability checks are either manipulated, ignored or simply do not take place. There are undoubtedly some areas of government – below the radar of Trump, his thin cadre of political appointees, and the business lobbyists that have his attention – in which serious sustainability checks are taking place and guiding decisions.
Sustainability checks lack two of the three criteria.
Most of the regulatory impact assessments in Bulgaria are merely formal, with the exception of budgetary and environmental issues. Bulgaria has a Fiscal Council, which assesses the fiscal sustainability of proposed regulations and policies. Environmental checks focus mostly on issues of pollution and wilderness protection, and less on greenhouse gas emissions. Other economic and social impacts are generally addressed superficially, and the input of non-government actors in the public-consultation process, although formally sought, has little visible impact.
RIAs do not necessarily analyze a regulation’s impact on sustainability in the broad sense. Short-, medium- and long-term analysis tends to focus exclusively on economic rather than ecological or social issues. Some exploratory efforts have been made to include wider and standardized sustainability checks within the RIA framework in the future.
OECD (2016), Regulatory Policy in Chile: Government Capacity to Ensure High-Quality Regulation, OECD
Reviews of Regulatory Reform, OECD Publishing, Paris.

OECD (2017), Reviews of Regulatory Reform
Evaluation Report: Regulatory Impact
Assessment (Chile)
Sustainability checks within the framework of RIA are still underdeveloped but are gradually improving. The reports of the Prime Minister’s Office to the parliament show that they are not yet systematically integrated within RIA and they are not exhaustive from the point of view of the indicators included (economic indicators play a greater role than social and environmental ones). With a decision taken in 2017, the PMO together with the Ministry of Environment will exercise tighter control over the adoption of sustainability criteria in regulation. The second Conte government has indicated its willingness to pay greater attention to sustainability criteria in its policies. It remains to be seen whether this decision will be implemented.
RIA analyses were only timidly introduced in Spain in 2009, and the process as implemented up to this point has not included systematic sustainability checks using an exhaustive set of indicators considering the short- to long-term effects of regulatory change. However, the legal reform of the general administrative procedure in 2015 included new sustainability-related improvements. Under the terms of Law 39/2015, the executive has the centralized task of reviewing whether new bills prepared by the rest of ministries and agencies fulfill various criteria from a procedural point of view. Articles 129 and 130 of the law mandate a systematic process ensuring the substantive congruence of all policy proposals being prepared. This would basically ensure that sufficient planning and effective RIA had been carried out by the sectoral ministry proposing the new legislation, and that an evaluation procedure was included. Royal Decree 931/2017, which came into force in December 2017, aims to improve regulatory impact analyses concentrating on the economic, social and environmental consequences of new legislation. Despite these recent improvements, Spain lacks a formal sustainability strategy other than the National Reform Plan and the Stability Program associated with European economic-governance obligations.
Real Decreto 931/2017.
Croatia adopted a sustainability strategy in 2009. However, neither this strategy nor the RIA Strategy or subsequent RIA action plans provide for comprehensive sustainability checks. RIAs are supposed to consider a broad range of impacts, including fiscal, economic, social and environmental, but the actual quality of assessments is low. There is no systematic differentiation between the short, medium and long term.
The assessment questionnaires inquire on positive and negative impacts of a policy proposal across various aspects of the economy, society, and environment as well as on the processes and work of the government. They also include questions on methods and processes followed, such as interactions with other ministries’ services and consultations with the public and other stakeholders.

There are three questionnaires: for new legislation or amendments, for legislation transposing EU directives into national law and for legislation ratifying international treaties.

Questions on sustainability remain exclusively economic, focusing on budgetary impacts and macroeconomic effects. A new dimension will be introduced: an assessment of the possible impacts on human rights.
Some of the suggested sustainability checks are included in the RIA Guidelines published in 2009 (a 97-page document), but there is no explicit mention of “sustainability” in that document and it does not seem that such checks are integrated into the RIA process. There is explicit provision for the inclusion of poverty impact assessments.
Though regulatory impact assessments are a compulsory regulatory tool in Malta, the government is only gradually learning to use this tool. Until recently, sustainability checks were common mostly in areas involving planning and the environment; however, these have now successfully been extended to the economic sphere, as EU and credit-rating reports indicate. Yet generally speaking, the effectiveness of key regulations and policy initiatives is assessed mainly through Malta’s National Reform Program, and the associated annual report that Malta (like all other EU member states) submits to the European Commission. This report is like a progress check, where Malta provides detailed updates relating to its Europe 2020 targets as a result of its policies. These reports include quantitative impact indicators that can illustrate the effectiveness (or failure) of regulatory projects that touch on social, environmental and economic issues. Overall, Malta has made progress in many areas, reaching many targets but lagging behind in others. Some indicators of progress include an increased level of subsidy provided to public transport programs, improved efficiency with the power-generation sector, and a plan for sustainable water use backed by actual budgetary allocations. More importantly, the PMO is currently directing an ambitious ICT project aimed at ensuring that policies and programs can be better assessed for sustainability, and at ensuring more coordination.
http://ec.europa.eu/europe2020/maki ng-it-happen/index_en.htm
There is no real systematic sustainability strategy except in those cases where EU regulations require such an examination. In most instances, political jockeying tends to prevail over policy analysis. In many instances, decisions are mainly based on political arguments regardless of social, financial or environmental costs. The sustainability argument is mainly used by opponents of a policy or envisaged equipment (the Nantes airport is a clear example of this). Given that every government attempts to pass as many measures in as short a period of time as possible, any preliminary evaluation tends to be regarded as a loss of time, since the crucial variable is the ability to respond swiftly to the pressure of public opinion. This strategy often appears to be misguided. Indeed, since opponents are unable to make their voice heard, they tend to rely either on judicial remedies (potentially delaying projects for many years) or on violent protest. Radical environmental activists, for instance, have become a major impediment to many public and private projects.
No systematic sustainability assessment process exists in Luxembourg. The government plans to introduce effective sustainability checks and systematic monitoring of relevant administrative and legislative acts. In general, the impact of policies and policy side effects at all levels (economic, social and environmental), needs to be evaluated with reference to principles of sustainable development and sustainable decision-making. It is essential to agree on regulatory impact assessment (RIA) procedures to “benefit from improved coherence and coordination between ministries, civil society and stakeholders.” Sustainability checks at all levels should be made transparent by establishing harmonized legislation with binding RIA standards.
Romania is formally committed to SDG implementation. It participated in the 2018 voluntary national review of the U.N.’s High-Level Political Forum on Sustainable Development and has initiated a review of the country’s 2008 National Sustainable Development Strategy with a view to incorporating the 2030 Agenda for Sustainable Development. The RIA methodology manual requires that sustainability concerns be incorporated in assessment reports. In practice, however, sustainability checks do not feature very prominently, are not done in a comprehensive manner, and draw on minimal sets of impact indicators.
Ministry of the Environment (2018): Transformation Toward a Sustainable and Resilient Romania: Romania’s Voluntary National Review 2018. Bucharest (https://sustainabledevelopment.un.org/memberstates/romania).
The RIA methodology manual requires that sustainability concerns be incorporated in assessment reports. In practice, however, sustainability checks do not feature very prominently and are not undertaken in a comprehensive manner. This might change as a result of the ongoing revision of the country’s sustainable development strategy. Slovakia took part in the 2018 voluntary national review of the U.N. High Level Political Forum on Sustainable Development and has initiated a review of the country’s national sustainable development strategy with a view to incorporating the 2030 Agenda for sustainable development. Coordinated by Deputy Prime Minister for Investments and Information Richard Raši, the review process has included broad stakeholder participation and the creation of the Government Council for Agenda 2030, involving key line ministers, as well as representatives of NGOs, academia, the private sector, and associations of cities and regions of the Slovak Republic.
Deputy Prime Minister’s Office for Investments and Informatization of the Slovak Republic (2018): Voluntary National Review of the Slovak Republic on the Implementation of the 2030 Agenda for Sustainable Development. Bratislava (https://sustainabledevelopment.un.org/content/documents/20131Agenda2030_VNR_Slovakia.pdf).
Slovenia’s RIA guidelines provide for relatively far-reaching sustainability checks. However, the specification of assessment criteria and the set of indicators to be used suffer from gaps, and the actual quality of RIA is very uneven. In some cases, there are only vague assessments; in others, comprehensive analytical work is done. During the period under review, the quality of assessments has somewhat improved.
The government has conducted several sustainability checks within its regulatory impact assessment (RIA) framework, for instance for the Waste Electrical and Electronic Equipment Directive, the Habitat Directive and the Discharge Directive.

Within the scope of U.N. Sustainable Development Goals 2030, a project to assess the current state of sustainability in Turkey was launched. However, the project has since been postponed indefinitely.

On the other hand, these examples refer to internationally sponsored projects and are not an indication of a general administrative practice. Politicians and experts widely use the term “sustainability” in policy slogans, but there is no formally adopted sustainability strategy in Turkey.

In 2016, The Coordination Board of Internal Audit published Performance Audit Guidelines for Public Sector Internal Auditors, which includes sustainability checks as a component in performance auditing. However, there is no information about RIA sustainability checks.

While making reference to sustainable growth and development, the Annual Presidential Program of 2019 does not mention sustainable policy or policymaking, with the exception of a reference to financial sustainability.
TC Cumhurbaşkanlığı, 2019 Yılı Cumhurbaşkanlığı Yıllık Programı, https://www.sbb.gov.tr/wp-content/uploads/2018/11/2019_Yili_Cumhurbaskanligi_Yil lik_Programi.pdf (accessed 1 November 2019)

Başbakanlık, Bürokrasinin Azaltılması ve Kamu Hizmet Sunum Esaslarının Geliştirilmesi, Düzenleyici Etki Analizi Raporu, Temmuz 2009, www.pirigroup.com/RIA/doc/Burokrasinin_azaltilmasi.doc (accessed 1 November 2018)

Yavuz Gazibey, Ahmet Keser, Yunus Gökmen, Türkiye’de İllerin Sürdürülebilirlik Boyutları Açısından Değerlendirilmesi, Ankara Üniversitesi SBF Dergisi, 2014, 69(3): 511-544. (accessed 1 November 2018)

İç Denetim Koordinasyon Kurulu, Kamu iç Denetçileri İçin Performans Denetimi Rehberi, 2016, http://www.idkk.gov.tr/SiteDokumanlari/Mevzuat/Ucuncul%20Duzey%20Mevzuat/PerformansDenetimiRehberi.pdf (accessed 1 November 2018)
Sustainability checks do not exist or lack all three criteria.
Regulatory impact assessments are compulsory, but seem to be treated as a formality for many important government decisions. There are however interesting and valuable exceptions, such as for the possibility of adding a fourth mobile phone operator in Belgium.
The Hungarian parliament passed a National Sustainability Strategy in March 2013 and afterwards the parliament’s environmental committee was transformed into the Committee of Sustainable Development (consisting of parliamentarians) and supported by the National Sustainability Council. It remains to be seen how the government will react to the greater significance given to climate change in the European Union. However, the National Sustainability Strategy and RIA processes have not yet been coordinated because sustainability checks are not an integral part of RIA.
The new regulations on cabinet procedures, enacted in March 2016, do not include anything about sustainability checks as parts of the impact assessment. However, financial impact is mentioned.
Reglur um starfshætti ríkisstjórnar. Nr. 292/2016 18. mars 2016.
According to the 2001 Government Policy Evaluation Act, policy effects have to be evaluated in terms of the three criteria of necessity, efficiency and effectiveness. These terms are somewhat flexible and do not necessarily encompass sustainability concerns. Indeed, actual evaluations apply the three guiding principles in a somewhat loose way, with few rigorous quantitative assessments. Reviews cover both pre-project as well as post-project evaluations.
MIC (Ministry of Internal Affairs and Communication, Japan), Website on evaluation results, http://www.soumu.go.jp/menu_seisakuhyouka/kekka.html (accessed in October 2018)
Annotations have no specific sustainability checks. For example, the issue of sustainability is not integrated into the annotations, impact indicators are not consistently used and there is no requirement to perform short-, medium- or long-term analyses. Some annotations do provide such information, but this is discretionary. New regulations on annotations, introduced in 2014, include a regulatory impact assessment that requires a calculation of the administrative burden, such as the cost to business.

Latvia has not adopted a specific sustainability strategy. However, sustainability is integrated into the Latvia 2030 strategy. As draft policies are assessed for compatibility with this strategy, sustainability issues may be taken into consideration. The Cross-Sectoral Coordination Centre (PKC) provides input to the drafting of policies, highlighting sustainability issues. The PKC also conducts an annual assessment of Latvia’s strategic goals, which includes sustainability assessments.
Sustainable Development Strategy of Latvia until 2030, Available at: http://www.pkc.gov.lv/sites/default/files/images-legacy/LV2030/LIAS_2030_en.pdf Last assessed: 05.11.2019.
Although Article 5 of Poland’s constitution enshrines the principle of sustainable development and the state’s responsibility to ensure the protection of the environment, sustainability checks are not an integral part of regulatory impact assessments. The PiS government has been less concerned with issues of sustainability than were its predecessors. Moreover, the PiS government has been involved in several infringement-procedure disputes with the European Commission and the European Court of Justice related to its failure to carry out environmental impact assessments for natural-gas drilling projects, and its disregard for sustainability and environmental-protection principles when approving logging activities in the Białowieża old-growth forest in 2016 and 2017.
Sustainability checks are not integrated systematically into impact assessments. They may take place in some assessment processes but not in others, in a rather ad hoc fashion that depends on who is carrying out the impact assessment. The same is true with regard to the use of sustainability-focused indicators, as well as the temporal dimension of the analyses.
Sustainability checks are not an explicitly integrated component of RIAs in Australia. Australia has not formally adopted a sustainability strategy.
Sustainability checks are not performed; this was the case under the preceding and remains the case under the incumbent government.
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