REGULATORY SCRUTINY BOARD OPINION Revision of the Directive on driving licences

EUROPEAN COMMISSION
18.11.2023
SEC(2023) 350
REGULATORY SCRUTINY BOARD OPINION
{COM(2023) 127-128}
{SWD(2023) 128-129}
Revision of the Directive on driving licences
Offentligt
KOM (2023) 0127 - SEK-dokument
Europaudvalget 2023
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This opinion concerns a draft impact assessment which may differ from the final version.
Commission européenne, B-1049 Bruxelles - Belgium. Office: BERL 02/352. E-mail: regulatory-scrutiny-board@ec.europa.eu
EUROPEAN COMMISSION
Regulatory Scrutiny Board
Brussels,
RSB/
Opinion
Title: Impact assessment / Revision of the Directive on driving licences
Overall opinion: POSITIVE
(A) Policy context
The EU has a common framework for driving licences that aims to facilitate free
movement of EU citizens and improve road safety. The evaluation of Directive (EU)
2006/126 establishing these rules pointed to certain areas for improvement.
This initiative aims to strengthen the contribution of the EU rules to reducing fatalities and
serious accidents and to ensure sufficient alignment with the EU’s current policy ambitions
and the technological and market developments.
(B) Summary of findings
The Board notes the additional information provided and commitments to make
changes to the report.
The Board gives a positive opinion. The Board also considers that the report should
further improve with respect to the following aspects:
(1) The report does not provide sufficient explanation on the content and
implications of certain measures.
(2) The report does not sufficiently explain the feasibility of certain measures, in
particular in respect of subsidiarity.
(3) The report does not sufficiently justify the choice of the preferred option.
(C) What to improve
(1) The presentation of the measures and their implications should be improved. The
option description should be detailed enough to allow a better understanding of the
functionality of the measures and any trade-offs between different objectives.
(2) The report should better explain the feasibility of certain options as regards
subsidiarity, for instance, on the mutual recognition of driving disqualification. It should
explicitly present any subsidiarity issues and refer to the views of Member States on the
measures considered.
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(3) The report should better justify the choice of the preferred option. It should provide a
more transparent comparison of options, in particular in terms of effectiveness and
efficiency.
(4) The report should further clarify the impact analysis. It should be more explicit about
the costs related to medical screening and explain whether these are (partially) covered by
medical insurance schemes in the Member States. It should also more clearly distinguish
between the administrative and adjustment costs, in particular in case of the costs for
citizens.
The Board notes the estimated costs and benefits of the preferred option(s) in this
initiative, as summarised in the attached quantification tables.
Some more technical comments have been sent directly to the author DG.
(D) Conclusion
The DG may proceed with the initiative.
The DG must take these recommendations into account before launching the
interservice consultation.
Full title Revision of Directive 2006/126/EC of the European Parliament
and of the Council of 20 December 2006 on driving licences
Reference number PLAN/2021/10346
Submitted to RSB on 12 October 2022
Date of RSB meeting Written procedure
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ANNEX – Quantification tables extracted from the draft impact assessment report
The following tables contain information on the costs and benefits of the initiative on
which the Board has given its opinion, as presented above.
If the draft report has been revised in line with the Board’s recommendations, the content
of these tables may be different from those in the final version of the impact assessment
report, as published by the Commission.
I. Overview of Benefits (total for all provisions) – Preferred Option (Policy option B)
Description Amount Comments
Direct benefits
Enforcement costs savings
for Member States
administrations, expressed
as present value over 2025-
2050, relative to the
baseline
EUR 2.8 billion Enforcement costs savings for Member
States administrations are mainly driven by
measures related to the mutual recognition
of mobile driving licences, the possible
introduction of a QR code on the physical
licence in the areas reserved for microchips,
and improvements and simplification of
rules on administrative validity. In terms of
present value over 2025-2050, the
enforcement costs savings are estimated at
EUR 2.8 billion.
Administrative costs
savings for Member States
administrations, expressed
as present value over 2025-
2050, relative to the
baseline
EUR 2 billion The introduction of the EU mobile driving
licence expected to lead to administrative
costs savings for Member States
administrations estimated at EUR 2 million,
expressed as present value over 2025-2050
relative to the baseline. These costs are
related to the time spent to ensure that the
physical licences are issued to the right
person, and thus the time spent to validate
the identity of the person to which a new
licence is provided. When procedures are
digitised, the time spent on such procedures
and the associated costs are overcome.
Administrative costs
savings for citizens,
expressed as present value
over 2025-2050, relative to
the baseline
EUR 2.3 million Administrative costs savings for citizens
due to the introduction of rules to remove
restrictions associated to automatic gear
transmission, estimated at EUR 2.3 million
expressed as present value over 2025-2050
relative to the baseline.
Adjustment costs savings
for citizens, expressed as
present value over 2025-
2050, relative to the
baseline
EUR 4.9 billion Adjustment costs savings for citizens due to
less frequent medical checks for drivers
suffering of diabetes (every 10 years
instead of 5) and changes in the rules for
the consultation of the general practitioners
for elderly people (above 70 years old),
estimated at EUR 4.9 billion relative to the
baseline (expressed as present value over
2025-2050).
Hassle costs savings for
citizens, expressed as
present value over 2025-
2050, relative to the
baseline
EUR 1.7 billion Hassle costs savings for citizens due to the
introduction of the EU mobile driving
licence, estimated at EUR 1.7 billion
relative to the baseline (expressed as
present value over 2025-2050).
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Administrative costs
savings for businesses,
expressed as present value
over 2025-2050, relative to
the baseline
EUR 0.9 billion The removal of the requirement to hold a
licence of category C or D to obtain a
licence of category CE or DE is expected to
lead to administrative costs savings for
professional drivers that benefit road
transport operators. The administrative
costs savings are estimated at EUR 0.9
billion relative to the baseline, expressed as
present value over the 2025-2050 horizon.
Hassle costs savings for
businesses, expressed as
present value over 2025-
2050, relative to the
baseline
EUR 0.6 billion The introduction of the EU mobile driving
licences is estimated to lead to a reduction
in hassle costs for the renewal of the
category C and D licences. The C and D
licences are mainly used by professional
drivers and the costs savings, estimated at
EUR 0.6 billion relative to the baseline
(expressed as present value over 2025-
2050), are thus expected to benefit transport
operators, mainly SMEs in the road
transport sector.
Improvement in the
functioning of the internal
market
Positive impact on the functioning of the
internal market is expected due to the
removal of unneccesary barriers for
applicants and holders of driving licences
and facilitating free movement of people,
the main measure being an introduction of
mobile driving licences. The common
ISO/IEC 18013-5 standard will ensure
interoperability of the mobile driving
licences issued by each EU Member State
and their recognition in the EU and abroad.
Preferred option will also introduce
measures allowing faster access to licences
of category CE or DE for professional
drivers across the EU which will reduce
barriers for the access to driver profession.
The rules related to the concept of normal
residence will also help persons transferring
their normal residence to another Member
State.
Improvements related to the
free movement of people
Preferred option is expected to contribute
positively to the freedom of movement, and
even if the number of persons facing
unnecessary or unjustified procedures is
rather low, consequences for an individual
can be significant. Clarification of the
concept of normal residence should solve
the problem of determining the issuing
authority just after the transfer of residence.
Simplification of rules on administrative
validity will put the holders of the EU
driving licences on equal footing,
regardless in which country they apply for
or extent the licence. Mutual recognition of
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optional equivalences will allow holders of
driving licences to enjoy rights granted by
an optional equivalence also in other
Member States applying the same rules.
Contribution to the
fundamental rights and
equal treatment of EU
citizens
Preferred option will align DL Directive to
the latest legislation on the protection of
personal data through improvement of the
network for exchange of information on
driving licences RESPER and establishing
the EU digital driving licence (PMc9). The
use of the eIDAS features for the EU
driving licence and EU Wallet for the
storage and exchange of data will ensure a
high level of security and privacy of the
information handled. Mutual recognition of
driving disqualifications will give
procedural safeguards to non-resident
drivers who commit road safety traffic
offences and ensure that their fundamental
rights are respected. It will also have a
positive impact on the right of non-
discrimination, given it will provide
flexibility for the first issuance of driving
licences in case of restrictions related to
languages which will allow applicants to
choose where to take the tests.
Indirect benefits
Reduction in the number of
fatalities and serious injuries
relative to the baseline
(cumulative over
2025-2050)
1,153 lives saved and 11,020 injuries avoided Indirect benefit to society at large.
Significant positive effects on road safety
are expected, in particular due to the
updated standards on skills and knowledge,
the introduction of rules on training and
probation period, with a probation period
for novice drivers, the mutual recognition
of driving disqualifications and the rules on
medical screening and assessment. The
impacts are estimated at 1,153 lives saved
and 11,020 serious injuries avoided over
the 2025-2050, relative to the baseline.
Reduction in external costs
of accidents (fatalities and
serious injuries), expressed
as present value over
2025-2050, relative to the
baseline
EUR 7.1 billion Indirect benefit to society at large, due to
the lives saved and injuries avoided. The
reduction in the external costs of accidents
is estimated at EUR 7.1 billion, expressed
as present value over the 2025-2050
horizon (in 2021 prices) relative to the
baseline.
Reduction in the use of
plastic (polycarbonate),
relative to the baseline
130 tonnes of plastic (polycarbonate) saved
annually
Indirect benefit to society at large, from the
introduction of digital driving licence by
default from 2028 onwards that would
result in approximatively 130 tonnes of
plastic (polycarbonate) saved annually.
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Administrative cost savings related to the ‘one in, one out’ approach
Administrative costs
savings for citizens, relative
to the baseline (annual
average)
EUR 0.1 million per year on average Administrative costs savings for citizens
are due to the introduction of rules to
remove restrictions associated to automatic
gear transmission. The annual average
reduction in the number of practical driving
tests is estimated at 1,184 relative to the
baseline. The administrative costs savings
are estimated at EUR 0.1 million on
average per year, relative to the baseline.
Administrative costs
savings for businesses,
relative to the baseline
(annual average)
EUR 48.5 million per year on average Administrative costs savings for road
transport operators, mainly SMEs, are due
to the removal of the requirement to hold a
licence of category C or D to obtain a
licence of category CE or DE. The measure
would lead to a reduction in the number of
theoretical and practical driving tests,
estimated at 510,474 on average per year
relative to the baseline. The administrative
costs savings are estimated at EUR 48.5
million per year on average, relative to the
baseline.
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II. Overview of costs – Preferred option (Policy option B)
Citizens/Consumers Businesses Administrations
One-
off
Recurrent One-off Recurrent One-off Recurrent
Direct adjustment
costs, expressed
as present value
over 2025-2050,
relative to the
baseline
- For citizens: EUR
663.6 to 1,106.6
million, due to
screening of fitness
to drive for drivers
renewing their
driving licence and
vision test for
applicants.
- For general
practitioners:
EUR 57.7
million, for
(online) training
on physical and
mental fitness.
For Member
States
administrations:
EUR 14.3
million, for the
development of
an IT system
for the mobile
driving licences
and the
improvement of
RESPER for
the purpose of
enforcement.
For Member
States
administrations:
EUR 48.9
million, for
maintenance of
an IT system for
the mobile
driving licences
and the
development of
(animated)
videos for the
driver hazard
perception test.
For the
European
Commission:
EUR 0.7 to 1.1
million, for the
establishment of
an information
platform for
authorities to
exchange on
physical and
mental fitness to
drive and the
development of
an (online)
training
programme for
general
practitioners.
Direct
administrative
costs, expressed
as present value
over 2025-2050,
relative to the
baseline
-
For applicants for a
B category licence:
EUR 52.5 million,
related to the
update of standards
on skills and
knowledge for the
first issuance of a
driving licence.
- - - -
Direct
enforcement
costs, expressed
as present value
over 2025-2050,
relative to the
baseline
- - - - -
For Member
States
administrations:
EUR 26.3
million, for the
investigation and
notification of
driving
disqualifications.
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Costs related to the ‘one in, one out’ approach
Total
Direct adjustment
costs, expressed
as present value
over 2025-2050,
relative to the
baseline
- For citizens: EUR
663.6 to 1,106.6
million, due to
screening of fitness
to drive for drivers
renewing their
driving licence and
vision test for
applicants.
- For general
practitioners:
EUR 57.7
million, for
(online) training
on physical and
mental fitness.
Indirect
adjustment costs
- - - -
Administrative
costs (for
offsetting),
expressed as
present value
over 2025-2050,
relative to the
baseline
- For applicants for a
B category licence:
EUR 52.5 million
expressed as
present value over
2025-2050, or EUR
2.8 million on
average per year
related to the
update of standards
on skills and
knowledge for the
first issuance of a
driving licence.
- -
Electronically signed on 18/11/2022 11:56 (UTC+01) in accordance with Article 11 of Commission Decision (EU) 2021/2121