COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT REPORT Accompanying the document Proposal for a Regulation of the European Parliament and of the Council on European labour market statistics on businesses, repealing Council Regulation (EC) No 530/1999 and Regulations (EC) No 450/2003 and (EC) No 453/2008 of the European Parliament and of the Council

EN EN
EUROPEAN
COMMISSION
Brussels, 28.7.2023
SWD(2023) 265 final
COMMISSION STAFF WORKING DOCUMENT
IMPACT ASSESSMENT REPORT
Accompanying the document
Proposal for a Regulation of the European Parliament and of the Council
on European labour market statistics on businesses, repealing Council Regulation (EC)
No 530/1999 and Regulations (EC) No 450/2003 and (EC) No 453/2008 of the European
Parliament and of the Council
{COM(2023) 459 final} - {SEC(2023) 295 final} - {SWD(2023) 266 final}
Offentligt
KOM (2023) 0459 - SWD-dokument
Europaudvalget 2023
Table of contents
1. INTRODUCTION: POLITICAL AND LEGAL CONTEXT............................................................... 2
2. PROBLEM DEFINITION .................................................................................................................... 6
3. WHY SHOULD THE EU ACT? ........................................................................................................ 20
4. OBJECTIVES: WHAT IS TO BE ACHIEVED? ............................................................................... 21
5. WHAT ARE THE AVAILABLE POLICY OPTIONS? .................................................................... 23
6. WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ........................................................... 31
7. HOW DO THE OPTIONS COMPARE?............................................................................................ 42
8. PREFERRED OPTION ...................................................................................................................... 46
9. HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED?.................................. 48
ANNEX 1: PROCEDURAL INFORMATION............................................................................................ 56
1. LEAD DG, DECIDE PLANNING/CWP REFERENCES.................................................................. 56
2. ORGANISATION AND TIMING...................................................................................................... 56
3. CONSULTATION OF THE RSB....................................................................................................... 57
4. EVIDENCE, SOURCES AND QUALITY......................................................................................... 59
ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT)................................................ 62
1. CONSULTATION STRATEGY ........................................................................................................ 62
2. METHODOLOGY AND TOOLS USED TO PROCESS THE RESULTS........................................ 63
3. STAKEHOLDER PARTICIPATION................................................................................................. 64
4. MAIN RESULTS FROM THE STAKEHOLDER CONSULTATION ............................................. 66
5. CONCLUSIONS................................................................................................................................. 68
ANNEX 3: WHO IS AFFECTED AND HOW? .......................................................................................... 70
1. PRACTICAL IMPLICATIONS OF THE INITIATIVE..................................................................... 70
2. RELEVANT SUSTAINABLE DEVELOPMENT GOALS............................................................... 91
ANNEX 4: ANALYTICAL METHODS ..................................................................................................... 92
ANNEX 5: ASSUMPTIONS USED FOR THE DISTRIBUTION OF COSTS (ONE OFF AND
RECURRENT) TO THE BR TYPOLOGY........................................................................................ 94
Glossary
Term or acronym Meaning or definition
ECB European Central Bank
EPSR European Pillar of Social Rights
ESP European statistical programme
ESS European Statistical System
ESSC European Statistical System Committee
EEA European Economic Area
EFTA European Free Trade Association
EU European Union
Eurobase Public database of European statistics disseminated by Eurostat
Eurostat Statistical office of the European Union
FTE Full-time equivalent
GPG Gender pay gap
ISG Inter-service group of the European Commission
JVS Job vacancy statistics
LMB Labour Market Statistics on Businesses
LCI Labour cost index
LCS Labour cost survey
MS Member State(s) of the European Union
NSI National statistical institute
OECD Organisation for Economic Co-operation and Development
PC Public consultation
PEEIs Principal European Economic Indicators
SES Structure of earnings survey
2
1. INTRODUCTION: POLITICAL AND LEGAL CONTEXT
Eurostat and the European Statistical System
Eurostat, the statistical office of the European Union (EU), ensures the production of high quality,
comparable European statistics1
according to the legal framework Regulation (EC) No 223/20092
(the “Statistical law”) and the statistical principles, notably those laid down in the European
statistics Code of Practice3
. These rules and principles aim to ensure, among others, the
independence, impartiality, objectivity and reliability of European statistics, and through those
objectives, public trust in the statistics. The main uses of European statistics are to serve EU policy
design, implementation and monitoring, and their main users are EU Institutions.
The European Statistical System (ESS) is the partnership between Eurostat and the national
statistical institutes (NSIs), as well as other national authorities responsible for the development,
production and publication of European statistics in each Member State. This partnership also
includes the European Economic Area (EEA) and European Free Trade Association (EFTA)
countries, i.e. Iceland, Liechtenstein, Norway and Switzerland. Eurostat issues statistical
regulations and methodological guides, organises expert groups, and assesses the quality of
statistics and Member States’ legal compliance. In accordance with the EU principles of
subsidiarity and proportionality, each ESS member develops a statistical system suitable to their
individual institutional context, while still following the common rules.
Eurostat’s activities are further influenced by overarching policies such as the EU’s Better
Regulation agenda4
, which promotes open and transparent EU decision-making and evidence-based
decisions, and European Commission President Ursula von der Leyen’s six political priorities,
among them “An economy that works for people”. Implementing, monitoring and assessing these
policies and priorities requires impartial and objective data – that is, official statistics.
Labour Market Statistics on Businesses (LMB)
Labour market statistics on businesses (LMB) are official statistics that describe businesses
functioning in relation to labour markets. The areas covered by LMB mostly relate to level and
composition of labour costs, distribution and structure of earnings, labour cost index, and job
vacancy statistics. First statistics related to the level and structure of labour costs had already been
1
Statistics in the ESS context are defined according to Article 3(1) of Regulation (EC) No 223/2009 (see footnote 2) as
“quantitative and qualitative, aggregated and representative information characterising a collective phenomenon in a
considered population.”
2
Regulation (EC) No 223/2009 of the European Parliament and of the Council of 11 March 2009 on European statistics
and repealing Regulation (EC, Euratom) No 1101/2008 of the European Parliament and of the Council on the
transmission of data subject to statistical confidentiality to the Statistical Office of the European Communities, Council
Regulation (EC) No 322/97 on Community Statistics, and Council Decision 89/382/EEC, Euratom establishing
a Committee on the Statistical Programmes of the European Communities (OJ L 87, 31.3.2009, p. 164).
3
European statistics Code of Practice, revised version endorsed by the European Statistical System Committee on 16
November 2017 (KS-02-18-142).
4
https://ec.europa.eu/info/law/law-making-process/planning-and-proposing-law/better-regulation-why-and-how_en.
3
collected since 19595
, with a periodicity of two to four years based on specific legislation for each
data collection and covering different sectors of the economy (industry, wholesale and retail
distribution, road transport, banking and insurance, services). Council Regulation (EC) No
530/1999 introduced systematic data collections on the level and composition of labour costs
(labour cost survey, LCS) for the calendar year 2000 and at four-yearly intervals thereafter. The
same act established the statistics on the structure and distribution of earnings (structure of earnings
survey, SES) for the calendar year 2002 and for a representative month in that year, and at four-
yearly intervals thereafter. Before Regulation (EC) No 450/2003 of the European Parliament and of
the Council of 27 February 2003 on labour cost index (LCI) was adopted, the data had been
collected on a voluntary basis since 1996. Similarly, Regulation (EC) No 453/2008 of the European
Parliament established for the first time and regulated the data collection on job vacancies (JVS).
Earlier on, the job vacancies data used to be collected on a voluntary basis, since 2001.
LMB statistics are relevant to policymaking in various areas including macroeconomic
convergence, social cohesion, price stability and gender equality. They are the reference source for
all key indicators on labour demand (job vacancy statistics), on labour costs structure and levels
across countries and distribution of earnings. The labour cost index supports the assessment of the
inflation/deflation risks within the euro area conducted by the ECB; job vacancy statistics show
labour shortages, structure of earnings survey data offer evidence to analyse wage determinants.
The latter also allows calculating/adjusting the gender pay gap which is an indicator for gender
equality listed under the Sustainable Development Goals scoreboard (SDG 2030) and the European
Pillar of Social Rights (EPSR). Both the labour cost index and the job vacancy are in the list of the
Principal Economic Indicators for the Euro monitoring.
High quality and internationally comparable LMB statistics covering all Member States6
are
essential to support EU evidence-based policy making and a range of other initiatives by the EU
institutions, Member States, and other statistical users (e.g., trade unions, non-governmental
organisations, research institutes, the media, etc.). LMB statistics are used in many publications of
Commission services, for instance the annual and quarterly Employment and Social Developments in
Europe (ESDE) reports or the annual review of Labour Market and Wage Developments in Europe7.
They are also very important for monetary policy and used by the ECB in the preparation of the
Governing Council8 meetings, many Economic Bulletins9 and analyses published occasionally10.
As LMB statistics play a pivotal role in policy-making, the fast-changing social and policy
landscape is demanding further improvements of LMB statistics in terms of flexibility to address
new needs of users and compilers, better data timeliness, comparability, consistency and quality
reporting. Megatrends such as automation and shocks to the economy as those caused by the
5
Council Regulations: No 10/1960, No 14/1961, No 28/1962, No 151/1962, No 101/66/EEC, (EEC) No 1899/68,
(EEC) No 2259/7, (EEC) No 328/75, (EEC) No 494/78, Regulations (EEC) No 2053/69, (EEC) No 3192/73 and (EEC)
No 494/78, (EEC) No 1596/81, (EEC) No 3149/83, (EEC) No 1612/88, (EEC) No 3949/92, No 2744/95, (EC) No
23/97,
6
The study scope covers the 27 EU Member States plus the EEA Member States of Norway, Iceland and Lichtenstein.
7
https://ec.europa.eu/social/main.jsp?catId=113#LMD
8
The Governing Council is the main decision-making body of the ECB. It consists of the six members of the Executive
Board, plus the governors of the national central banks of the 19 euro area countries.
9
For instance: https://www.ecb.europa.eu/pub/economic-bulletin/html/eb201801.en.html#IDofArticle1,
https://www.ecb.europa.eu/pub/economic-bulletin/articles/2021/html/ecb.ebart202008_02~bc749d90e7.en.html#toc7
10
For instance:
https://www.ecb.europa.eu/pub/pdf/scpops/ecb.op232~4b89088255.en.pdf?1ccf533dc92317c07a71721418088bd4
4
financial crisis of 2008 or the COVID-19 pandemic show that researchers and policy makers need
accurate and timely information on the functioning of labour markets, in particular LMB statistics.
The COVID-19 pandemic led to decreases in the number of hours worked and vacant posts and to
changes in the labour cost structure due to labour subsidies. Some groups of workers have
benefitted from improved employment conditions, including increased earnings, while others have
seen their employment prospects and conditions decline. This also had an impact on labour
shortages and the relative earnings levels of employees.
LMB indicators are used to monitor important European policies such as the EPSR11
or the SDG12
.
In particular, the gender pay gap (GPG) is an SDG indicator under Goal 5 “gender equality” and is
part of the EPSR dashboard, under the ‘Fair working conditions’ (Principle 6: “wages”).
Over time, the policy context for LMB has steadily evolved. In 2009, the Commission released
a Communication to the European Parliament and the Council giving its vision for the production
method of EU statistics for the decade (2010-2020)13
. This document has explored the key changes
in the business environment of the European Statistical System, and the implications for
policymaking. It highlighted the importance of having an integrated system that allows countries to
gather data from different sources, increasing the availability and reach of the analysis. It also
highlighted the importance of increasing the quality of the data, considering that many external
sources do not match the expected requirements for European statistics. In 2014, the Commission
(Eurostat) began the process of modernising social statistics. This led to the adoption of the
framework regulation for European statistics relating to persons and households, based on data at
individual level collected from samples of persons and households14
. In parallel, on 27 November
2019, the European Parliament and the Council adopted the Regulation on European Business
Statistics (EBS), repealing 10 legal acts in this field. The LMB is at the intersection between both
domains, belonging to social statistics in terms of topic covered and to business statistics according
to the type of respondents (enterprises). This initiative on LMB should be seen as completing the
modernisation round of social statistics.
Current issues with LMB statistics
As recognised by the evaluation, LMB statistics allow collecting high quality information that are
widely used for the intended purposes. The strengths of LMB statistics lie in their coherence,
efficiency, comparability and the fact that they are well established, reliable and widely used by
organisations and policy makers at all levels. Moreover, no alternative data at the EU or wider
levels exist.
However, some shortcomings that were already identified at the time of adoption of the legal acts
were differently approached (by requiring feasibility studies that lead to amendment of the
legislation, by making available financial support for creating the capabilities needed to give effect
to the legal base), and in the case of some data collections not sufficiently resolved. They mainly
concern the partial coverage of LMB data on earnings which limits their use for policy purposes.
11
https://ec.europa.eu/info/strategy/priorities-2019-2024/economy-works-people/jobs-growth-and-
investment/european-pillar-social-rights_en
12
https://ec.europa.eu/eurostat/web/sdi/overview
13
https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2009:0404:FIN:EN:PDF .
14
Regulation (EU) 2019/1700 of the European Parliament and of the Council of 10 October 2019 establishing a
common framework for European statistics relating to persons and households, based on data at individual level
collected from samples […] (Text with EEA relevance) (OJ L 261I, 14.10.2019, p. 1)
5
For several EU Member States, structure of earnings survey and/or labour cost survey do not cover
enterprises with one to nine employees or part of the public sector (NACE Rev. 2 section O: ‘Public
administration, defence, compulsory social security’). This creates biases in key statistics such as
the average earnings and labour costs and therefore, for the gender pay gap as well (see Table 1).
Table 1. Gender pay gap by size class of the enterprise, 2018
Source: Eurostat, calculation based on the SES 2018
Those limitations became more visible further to the recent policy developments in the areas of
equality, skills, working conditions and monetary union monitoring to which the data at the EU
level is essential and provides clear added value.
For instance, the monitoring of the new directive15
on adequate minimum wages requires unbiased
estimates of the median wages as a (country-specific) benchmark. This requires that Structure of
Earnings data cover all segments of the economy, including enterprises with less than 9 employees
and the public sector, whose importance varies across EU countries.
15
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022L2041
Enterprises employing
10 and more persons
Enterprises employing 1
and more persons
Enterprises employing
from 1 to 9 persons
Belgium 5.8 : :
Bulgaria 14.0 14.4 11.7
Czechia 19.7 18.3 4.0
Denmark 14.6 : :
Germany 20.1 20.6 15.9
Estonia 21.8 18.3 8.1
Ireland 11.3 10.1 6.6
Greece 10.7 : :
Spain 11.9 12.4 13.4
France 16.7 : :
Croatia 11.4 : :
Italy 5.5 : :
Cyprus 10.4 9.6 14.4
Latvia 19.5 17.3 8.8
Lithuania 14.0 11.9 2.0
Luxembourg 1.4 : :
Hungary 14.2 : :
Malta 13.0 : :
Netherlands 14.7 16.4 25.8
Austria 20.4 : :
Poland 8.5 : :
Portugal 8.8 : :
Romania 2.2 : :
Slovenia 9.3 7.2 1.4
Slovakia 19.8 19.3 8.3
Finland 16.9 : :
Sweden 12.1 : :
Iceland 13.8 : :
Norway 13.2 13.0 10.9
Switzerland 18.6 19.1 21.0
6
In other respects, the lack of a legal obligation to provide information on gender pay gap (GPG)
became more problematic as the current data collection is voluntary and does not cover all EU
countries nor all GPG variables. This brings a risk factor for the monitoring of principle 2 (‘Gender
equality’) of the European Pillar of Social Rights.
The frequency of SES and LCS is not sufficient anymore for a number of users and the timeliness
of the LCI, SES and LCS need to be improved.
Moreover, some stakeholders consulted in the public consultation and interviews, expressed needs
for more breakdowns (e.g., ISCO or NUTS) or additional variables, allowing a better analysis of
wage determinants including for the gender pay gap. In the interviews, they shared the view that it
would be beneficial to assess innovative data collection methods (e.g., web scraping for job
vacancies), that have the potential to decrease the burden on data providers, provided they ensure
sufficient quality.
The evaluation has shown that those shortcomings reduce the relevance, effectiveness, coherence
and comparability of statistics across Member States, with negative impacts for decision-making
based on them.
2. PROBLEM DEFINITION
2.1. What is/are the problems?
The evaluation identified issues that could be structured around three main problems.
Problem 1: LMB statistics does not address new needs, sources and methods.
The current legal framework does not cover new and emerging users’ needs. For example, policy
users expressed a growing interest in data on the skills of the employees (the occupation data
collected at the detailed levels of the ISCO classification can be used as a proxy for skills) and their
net earnings (e.g. to monitor the purchasing power of low wage and of minimum wage earners).
LMB also miss a quarterly index of hours worked that would have allowed monitoring the impact
of COVID-19 and other possible crises on the volume of work. Job vacancy statistics by region and
occupation are not available either, except for a few EU countries. These were deemed crucial to
build more comparable vacancy data, estimate needs and assess job shortages at the regional level.
At the moment, the data collection framework is not flexible enough to allow for adjusting new
variables or the timeliness of statistics. There is also growing interest in non-discrimination and
gender equality, but the collection of gender pay gap data is currently collected voluntarily and not
delivered by all Member States. This results in data that are not as precise and comparable as
possible or required by some data users. Moreover, data on the earnings of people with disabilities
are not collected, even those based on a national (non-harmonised) concept of disability. This fails
in supporting users in making evidence-based policies and to follow the requirements of Article 8
TFEU and the UN Convention on the Rights of Persons with Disabilities.
Users are also seeking timelier data, for some LMB statistics, namely more frequent data
collections and releases (note that the frequency of collection and release currently varies by type of
LMB statistics) and/or that statistics become available faster.
Another emerging trend not fully considered in the current LMB framework is the use of
administrative data. Several Member States are making increasing uses of this type of source. This
7
facilitates more frequent data collection (e.g., quarterly). The current legal framework is not,
however, able to accommodate appropriate quality reporting for this type of data across Member
States.
Therefore, some user needs are likely to remain unmet, representing a missed opportunity to
maximise the impact of LMB statistics across stakeholders and especially policy makers and
researchers making use of this data. The provision of data closer to users’ needs, coordinated across
the Member States, would provide policymakers with the opportunity to make more rapid and
reliable assessments and respond quicker to changing issues/needs.
Problem 2: LMB statistics do not capture important actors or phenomena of the EU economy
As the current data collection on the gender pay gap is voluntary, some Member States do not
provide the data, or only partially so that estimates are not fully available for comparisons across
countries and time. This hampers users to have a full overview of gender pay disparities across EU
countries and act in order to promote equality between men and women as requested by article 10
TFEU, SDG 5 and the second principle of the European Pillar of Social Rights.
Interviewed stakeholders representing users stressed that extending the coverage of LMB statistics
to micro enterprises would also be important, at least for the main variables of SES, and to the
public sector as no coverage of these impacts the proportion of minimum wage earners and low-
wage workers. This would also correct the existing biases in key figures such as the mean and
median earnings which are used in many policy indicators such as the minimum wage to median
earnings ratio (‘Kaitz index’). Covering only part of the economy also distorts derived indicators
such as the gender pay gap. It prevents users from analysing the adequacy of wages in the public
sector and assessing the corresponding wage policies of EU governments.
Similarly, adding more variables in structure of earnings survey would enrich the scope and depth
of analysis and modelling based on this data source. This would allow refining further the existing
decompositions of the unadjusted gender pay gap which face limitations in possibility for
disaggregation (not accounting for wage penalties related to family situation, career breaks, etc.).
Problem 3: LMB statistics are not aligned with related statistical domains
The evaluation results show that the current legal framework can be further improved to align with
other EU policies and legislations as those that are new or evolved since the LMB legislation
adoption. For instance, more pressing needs have emerged with the adoption of the new directive
on minimum wage adequacy16
. It becomes even more important than before to collect and publish
mean and median earnings for the whole economy, as a benchmark for minimum wage levels. It is
also useful to develop concepts such as the net wages received by employees after deduction of all
social contributions.
The same applies to recent developments on gender equality, for which the gender pay gap has
become a prominent indicator and should be possibly adjusted for all social contributions and more
precise estimates of the skills levels.
Due to the time elapsed since the adoption of the current LMB legislation, the latter is no longer
aligned on the latest versions of the related legal texts. This concerns in particular the latest edition
16
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32022L2041
8
of the European System of Accounts (ESA 201017
) which defines the main concepts (e.g. notions of
employees, labour costs, wages) used in labour statistics. It is also relevant for European Business
Statistics18
whose general concepts have been updated with the adoption of the revised framework
regulation and implementing acts.
A few stakeholders highlighted some issues of consistency in terminologies used across Member
States. This was mentioned for example about labour costs, namely, the elements included
capturing social security contribution. Similarly, other stakeholders mentioned some
inconsistencies in collective agreement across different countries.
Coherence between different data collections is another dimension of quality as it is fundamental to
address multi-dimensional issues. The fragmented legal framework poses an immediate risk of the
lack of coherence and comparability between data collections.
Stakeholders affected
The persistence of the problems affects users of the LMB statistics who do not have the evidence
that meets their demands and those of policy makers that miss it for an efficient decision-making
process. Ultimately, EU citizens could be considered not to be able to fully capitalise on high
quality research and efficient policies.
The next section explains more in detail these problems and assesses how significant they are in
terms of scale and impact. It also examines the main drivers leading to the problems and reflects on
the expected evolution of the problems in the absence of targeted action.
2.2. What are the problem drivers?
Each of the problems has specific causes, also known as drivers. The main causes of the problems
identified so far are grouped under each problem. That is, each problem has specific drivers.
For each problem, the list of all relevant drivers is detailed in the next paragraphs.
Problem 1: LMB statistics do not address new needs, sources and methods
D1 – LMB statistics do not cover emerging needs
Over the time, policy data users alerted Eurostat that there are particular variables or breakdowns
missing in the LMB that would allow them better analysis and policy monitoring. In that context,
also during the public consultation several improvements needed were confirmed, for instance
collecting and publishing the numerator (labour costs) and the denominator (index of hours
worked) of the LCI ratio for several NACE aggregates was found crucial or highly important by 13
data users out of 35 replying to the public consultation, another 15 considered this improvement of
medium importance and only 7 as low. For 5 out of 18 data producers this was unimportant, other 9
producers gave medium importance and 4 high or crucial importance. Similarly, quarterly data on
the ‘total number of hours worked’ was needed by both types of stakeholders: data users (29 replies
out of 36, of which 13 scored this improvement as crucial or highly important and 16 of medium
17
https://ec.europa.eu/eurostat/documents/3859598/5925693/KS-02-13-269-EN.PDF/44cd9d01-bc64-40e5-bd40-
d17df0c69334
18
https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32019R2152
9
importance) and producers (only 7 out of 18 gave it a low importance). Those needs were
confirmed in the interviews with EU policy makers (e.g. DG EMPL; DG ECFIN). For lack of this
information, it was not possible to monitor the impact of the COVID-19 crisis on the volume of
work. This will also be relevant for future crises.
The results of interviews with main stakeholders (in particular European policy users) confirmed
that there is a set of unmet needs related to missing variables that prevent from fully adequate
analysis. Regarding SES, in the interviews, policy users, in particular DG JUST, DG EMPL,
expressed interest in intersectional analyses that would build on sex, age, possibly disability, etc. as
far as feasible in a harmonised fashion. This would allow a better analysis of wage determinants
and the refining existing adjustment of the gender pay gap. Indeed, the gender pay gap is very
difficult to interpret without adjustment for the structure of the male versus female labour force in
terms of occupations, economic activities, seniority, family situation, etc. Refined adjustments
would therefore contribute to a better benchmarking between Member States and to the monitoring
of the Gender Equality Strategy, European Pillar of Social Rights, the Sustainable Development
Goals (gender pay gap is an indicator for gender equality listed under the EU SDG indicators set
Goal 5: ‘Gender Equality’). Collecting SES information on net earnings and detailed occupation
would allow users to better monitor the promotion of equality enshrined in the Charter of
Fundamental Rights. Getting data on vacancies and occupied posts (JVS) by occupation at the 2nd
digit level of the ISCO classification19
was considered crucial or highly important, in the public
consultation, by 18 data users out of 31 replying the question, other 8 considered it as medium
important and only 5 as unimportant. Out of 17 data producers, 7 put low importance to having JVS
data by occupation. The JVS data by NUTS 2 region were found crucial or highly important by 14
out of 31 data users and 8 found this improvement as medium important. Among data producers
replying to the question only 3 out of 16 found it unimportant. The JVS data by NUTS 2 region
were found crucial in the interviews with DG REGIO. This data would allow identifying regional
mismatches and measuring labour shortages for different skills. They would also be needed to
check the quality of non-official vacancy data (online job vacancies).
Yet, the LMB statistics legal framework does not facilitate incorporating new elements on an ad-
hoc approach. As underlined by the policy users at several occasions (e.g. meeting of the working
groups, hearings), the new legal basis should as much as possible include the variables or
breakdowns identified as ‘emerging needs’ and be open for future updates if the situation requires.
D2 – The quality framework of LMB statistics is not fit for the use of administrative data and
innovative sources
In the past two decades, an increasing number of Member States has switched to administrative
sources for the compilation of some LMB datasets, as least for some variables. In the case of the
LCI, the use of administrative sources is already the standard in most countries; labour cost
variables are generally taken from social security data whereas the number of hours worked is still
collected via surveys. This is also the case for annual gender pay gap data which are compiled from
the four-yearly SES data for the years when survey data are available and which are extrapolated
with social security sources in some countries. In the latest structure of earnings survey (SES 2018),
19
See also:
https://ec.europa.eu/eurostat/ramon/nomenclatures/index.cfm?TargetUrl=LST_NOM_DTL&StrNom=ISCO_88_CO&S
trLanguageCode=EN&IntPcKey=&StrLayoutCode=HIERARCHIC
10
10 out of 27 Member States reported using a combination of survey data and administrative
sources. Administrative sources are less common for job vacancies domain as data from public
employment services tend to overestimate the real levels, some filled vacancies being still recorded
in the register of vacant post.
Without incorporating this type of data into the framework of LMB, there will be an untapped
potential for adding variables and breakdowns as well as reducing the cost and burden. However,
increasing the use of administrative data and potential innovative data sources requires an updated
quality reporting framework for documenting those sources, assessing their quality and
communicating to the users.
Administrative data have not been primarily collected for statistical purposes and they only partly
match the concepts to be measured. In addition, non-statistical sources may have other impacts such
as the lack of timeliness (due to the administrative process before their availability). Hence, using
these sources, requires specific quality assessments (e.g. in quality reports) such as on the biases
introduced by the original purposes for which these data are collected and measuring the extent and
impact of the biases introduced in the quality of the statistics based on them. Specific quality
reporting on administrative or hybrid data sources does not exist yet for LMB statistics. The current
reporting is focused on the survey collection and the quality is mainly measured through the
statistical variance and on possible deviations of the statistical sample from the target population of
enterprises or employees.
Similarly, the experimental work on use of innovative data sources (for instance information on
online job advertisements available on the internet) showed so far that the web-scrapped data (data
extracted from the internet) provide results that differ in levels from the official statistical
information collected by the members states directly from the enterprises but are following roughly
the same time trends. Online job advertisements do not cover all job offers but they can
complement the existing statistics with further comprehensive, detailed, and timely insights into
labour market trends, allowing the early identification of new emerging jobs and skills. Being
a potential important source for the future, the quality of these data collected from the web should
be correctly assessed. Public consultation showed that for 18 users of the data adding a description
of administrative sources/registers to the SES quality report was crucial or highly important, for 13
importance was medium and for 5 low. In total 36 users replied. Only 2 out of 20 data producers
considered it unimportant.
Similarly for LCS, 13 data users out of 35 were stated that adding description of administrative
sources was crucial or highly important, 16 that it was moderately important and only 6 that it was
not important. Only 2 data producers out of 18 who replied considered it unimportant.
In case of LCI, only 3 out of 36 data users and 3 out of 18 data producers were not interested in
information on administrative sources in the quality reporting.
For JVS, 9 data users (out of 31 who replied) and 1 data producers (out of 16) considered adding
information on administrative sources in the quality reporting unimportant. For 11 data producers
this was crucial of highly important and for other 11 moderately important.
11
D3 – Some LMB statistics are not timely or frequent enough
Data that are published with a long lag after the reference period lose their relevance and usability,
in particular when the observed phenomenon quickly varies over time. Expectations are also higher
and, although LMB data generally comply with the deadlines, they are not considered timely or
frequent enough nowadays, at least by some users.
Stakeholders expressed a view that a higher frequency of data and quicker updates of some LMB
datasets are needed. In the public consultation, the timeliness and the collection frequency were two
of the less positively assessed elements of the statistical quality for SES: 30 % of respondents to the
public consultation were not satisfied with the frequency of the survey (18 replies out of 59)
whereas 51 % expressed satisfaction (30 out of 59) and 19 % being neutral (11 replies out of 59).
For LCS dissatisfaction on the frequency reached 24 % (14 replies out of 58), with 48 % expressing
satisfaction (28 replies out of 58), and 28 % being neutral (16 replies). Satisfaction with frequency
was much higher for GPG, JVS and LCI with dissatisfaction only amounting to 2 % for each of
these.
The results of the public consultation also showed that collecting SES data every 2 years instead of
every 4 years, was considered crucial or highly important by 20 out of 36 data users replying this
question against 7 out of 18 producers of LMB statistics. For 10 data users this improvement was of
medium importance and for 10 data producers low.
At the same time, collecting LCS data every 2 years instead of every 4 years was considered crucial
or highly important by 15 data users out of 33 who replied, for 10 of them it has medium and for 8
low importance. 12 out of 18 producers considered doubling frequency of LCS of low importance.
More frequent SES would provide more relevant figures for derived indicators such as the mean
and median earnings. Some users (e.g. trade unions), during the stakeholders workshop, underlined
this need that became crucial in time of quick changes (e.g., high inflation) to see if wages are
adapted to the inflation. In addition increased SES frequency would allow more timely analysis of
pay gap determinants.
Similarly to frequency, the timeliness of the SES and LCS data was also not satisfactory for 32 %
of the respondents to the public consultation (19 replies), 39 % of them were satisfied (23 replies)
and 29 % (17 replies) did not have an opinion.
12
Figure 1. Public consultation respondents’ satisfaction with data timeliness across datasets
Source: Public consultation
Among the data users, almost the same number was satisfied (14) as dissatisfied (13) with SES
timeliness. For the LCS, 10 users were dissatisfied with timeliness against 12 satisfied.
Satisfaction with timeliness was much higher for JVS and LCI with dissatisfaction amounting to
only 6 negative replies for JVS and 1 for LCI.
Improving timeliness was considered one of the three most supported priorities for the SES and
LCS in the public consultation. Improving timeliness of SES (by 5 months) was considered crucial
or highly important by 22 data users out of 36 who replied the question, 10 considered it medium
important and only 4 as not important. Similarly, 15 data producers out of 18 who replied thought
the timeliness improvement is either highly or medium important (9 and 6 replies respectively) and
only 3 that it is low. When it comes to the LCS, shortening the time of data publication by 6 months
was unimportant only to 4 out of 35 data users and 4 out of 18 data producers.
1
2
1
3
7
6
3
6
13
6
11
8
14
9
11
8
1
9
5
1
13
4
1
13
1
1
12
2
1
11
4
8
2
1
1
1
5
2
1
1
2
1
1
1
User of European labour market statistics on
businesses
Producer of European labour market statistics on
businesses
Provider of administrative records as input for
European labour market statistics on businesses
User of European labour market statistics on
businesses
Producer of European labour market statistics on
businesses
Provider of administrative records as input for
European labour market statistics on businesses
User of European labour market statistics on
businesses
Producer of European labour market statistics on
businesses
Provider of administrative records as input for
European labour market statistics on businesses
User of European labour market statistics on
businesses
Producer of European labour market statistics on
businesses
Provider of administrative records as input for
European labour market statistics on businesses
SES
LCS
LCI
JVS
Very satisfied Satisfied Neutral/no opinion Not satisfied Very dissatisfied
13
The interviews with EU policy makers (DG JUST, DG EMPL, DG ECFIN) confirmed those
findings that were further strengthened by the employment organisations and trade unions during
the stakeholders’ workshop. In particular, due to the COVID-19 pandemic and the current rise in
inflation, the timeliness of data has become even more important to stakeholders. With the fast-
paced changes in the labour market, stakeholders highlighted the need for more timely statistics to
inform policy making. No alternative data sources exist at the EU level, therefore not addressing
this issue will put in question correct and timely monitoring of EU policies LMB is used for.
Problem 2: LMB statistics do not capture important actors or phenomena of the EU economy
D4 – The public sector and micro enterprises are not captured by LMB statistics
The coverage of LMB statistics was a shortcoming identified already at the time of adoption of the
legal acts. Those were differently approached (by requiring feasibility studies that lead to
amendment of the legislation, by making available financial support for creating the capabilities
needed to give effect to the legal base) and, in the case of some data collections, not sufficiently
resolved. While there are only three Members States with difficulties in providing JVS data for the
whole economy, more than half of them did not progress over time in gathering information on
labour costs and structure of earnings for enterprises employing less than 10 persons or for NACE
Rev. 2 section O (public administration, defence, compulsory social security), in the SES and LCS.
The economic activities required to be covered by the SES in the legislation are NACE sections B
to S excluding O. Although most of the countries go beyond this requirement and provide
information for section O, the lack of data from some of them prevents from calculating the EU
aggregates. The above-mentioned shortcoming of the coverage of the SES influence also the
comparisons of the earnings of men and women. Moreover, the section O covers enterprises that
are female dominated.
Following the difference described above, the gender pay gap calculated for the whole economy
(sections B to S) differs from the one in the aggregate not covering section O (sections B to S
except O). The lack of the data for section O in some countries does not allow full comparisons
across the EU.
14
Table 2. Gender pay gap by economic activity of enterprise, 2018
Source Eurostat, [earn_gr_gpgr2]
Extension of the coverage of the SES to micro firms was perceived as crucial or highly important
by 22 out of 36 of data users replying the question, for 8 of them this improvement had low
importance and for 6 medium. Out of 18 data producers, only one was considering this change
unimportant.
Extension to NACE Rev. 2 section O was considered unimportant by only 5 data users and one data
producer (out of 36 and 18 of them respectively). For 21 data users this change was crucial or
highly important and for 10 the importance was medium. 10 data producers considered this change
as crucial of highly important and 7 gave it a medium importance.
For the LCS, the level of satisfaction with the coverage was higher for size classes than for
economic activities for both data users and providers.
Industry, construction and
services (except public
administration, defense,
compulsory social security) -
NACE B to S except O
Industry, construction and
services (except activities of
households as employers and
extra-territorial organisations
and bodies) - NACE B to S
Public administration and
defence; compulsory social
security - NACE O
Belgium 5.8 : :
Bulgaria 13.9 13.6 8.3
Czechia 20.1 19.5 15.7
Denmark 14.6 14.3 9.3
Germany 20.1 19.0 6.9
Estonia 21.8 20.7 7.2
Ireland 11.3 11.4 10.8
Greece 10.4 7.4 -16.7
Spain 11.9 11.2 6.3
France 16.7 16.1 9.9
Croatia 11.4 10.9 9.2
Italy 5.5 6.2 8.6
Cyprus 10.4 11.0 13.9
Latvia 19.6 17.6 -2.8
Lithuania 14.0 13.2 5.1
Luxembourg 1.4 1.6 0.4
Hungary 14.2 13.7 6.7
Malta 13.0 11.8 -5.5
Netherlands 14.7 14.2 2.6
Austria 20.4 : :
Poland 8.5 8.8 15.1
Portugal 8.9 : :
Romania 2.2 1.0 2.3
Slovenia 9.3 9.0 10.4
Slovakia 19.8 19.7 19.0
Finland 16.9 16.6 13.8
Sweden 12.1 11.9 7.6
Iceland 13.8 13.6 9.6
Norway 13.2 13.4 15.8
Switzerland 18.6 18.6 17.8
15
Figure 2. Public consultation respondents’ satisfaction with size classes covered by LCS (all
enterprises except those with less than 10 employees)
Source: Public consultation
Figure 3. Public consultation respondents’ satisfaction with economic activities covered by LCS
Source: Public consultation
Few countries provide LCS data for micro enterprises. Not covering all sizes of enterprises leads
to biased results for the average labour costs which are generally lower in microenterprises
compared with enterprises employing 10 persons and more, as illustrated in Figure 4 for the
countries for which this information is available.
3
2
14
11
11
2
1
6
3
1
1
User of European labour market
statistics on businesses
Producer of European labour
market statistics on businesses
Provider of administrative records
as input for European labour
market statistics on businesses
very satisfied satisfied neutral/no opinion not satisfied very dissatisfied
4
2
12
6
10
5
1
7
5
1
2
User of European labour market
statistics on businesses
Producer of European labour
market statistics on businesses
Provider of administrative records
as input for European labour…
very satisfied satisfied neutral/no opinion not satisfied very dissatisfied
16
Figure 4. Total labour costs20 in Euro, per employee in full-time equivalents, per hour, by size of
enterprise, 2016
Source : Eurostat, [lc_ncost_r2]
Since the adoption of the LMB legislation and following the policy developments (e.g. introduction
of the European Pillar of Social Rights), the data became more prominent and widely used,
therefore requiring necessary improvements in quality.
For the structure of earnings survey reference year 2006, 11 Member States provided data on
enterprises employing from 1 to 9 employees21
. The situation did not improve significantly in the
following waves of the survey (2010, 2014) and only 12 Member States (and 2 EFTA countries)
transmitted those data in the latest data collection available for reference year 201822
. Similarly to
the structure of earnings survey, only 11 Member States provided data for enterprises with 1 to 9
employees in the last labour costs survey (2016)23
.
Section O is covered on voluntarily basis in the structure of earning survey by 23 Members States,
in labour cost survey by 22 and by 24 Members States in the JVS24
.
This illustrates that voluntarily extension of the surveys coverage did not provide satisfactory
outcome.
20
Costs of apprentices not included
21
Czechia, Denmark, Estonia, Spain, Cyprus, Latvia, Lithuania, Netherlands, Poland, Slovenia, Slovakia. Additionally,
three MS (Ireland, Hungary and Finland) provided data for enterprises with 3 or 5 and more employees.
22
Bulgaria, Czechia, Germany, Estonia, Ireland, Spain, Cyprus, Latvia, Lithuania, Netherlands, Slovenia, Slovakia.
Additionally, Hungary and Finland provided data for enterprises with 5 and more employees.
23
Bulgaria, Czechia, Estonia, Spain, Latvia, Lithuania, Netherlands, Portugal, Romania, Slovenia, Slovakia.
Additionally, Hungary and Ireland provided data for enterprises with 3 or 5 and more employees.
24
In France and Italy, public institutions are not covered within the sectors of public administration, education and
human health (NACE Rev. 2, sections O, P and Q) Denmark provides data for NACE sections B to N.
2,7 2,8
5,3 5,3 6,5 7,2 7,5 8,0
12,7 13,5
32,3
47,1
4,5 5,4
7,4 7,7
10,3 10,8 10,2
13,7
16,8
21,2
35,1
56,7
0
10
20
30
40
50
60
From 1 to 9 employees
17
D5 – GPG data are provided on a voluntary basis
Data on the gender pay gap are provided by Member States on a voluntary basis leading to a partial
coverage of countries (Ireland and Greece do not transmit) and statistical variables thus hampering
cross-country comparisons.
More than half of LMB data producers responding to the public consultation would find it crucial
or of high importance to create a legal basis for the mandatory transmission of annual adjusted GPG
data. Interestingly, only one data producer found this unimportant. Out of 37 data users replying the
question, only 8 found that a legal basis on GPG is not needed. In the interviews, the data users
(e.g. DG EMPL, DG JUST) offered detailed examples on how the data is used and stressed it´s
importance as well as the problems caused by its voluntary status (e.g. incomplete coverage).
Moreover, some miss certain determinants of the pay gap (e.g. number of children, work spell, total
experience) to conduct research on the gender pay gap based on available statistics. Another
problem they highlighted was that the gender pay gap statistics go through sizeable revisions, when
SES becomes available. Finally, the proposal for directive on pay transparency25
requires
a sustainable production of annual GPG.
Figure 5. For you, how important would it be to add the following measures to the GPG data
collection process: Creating a legal basis for the mandatory transmission of annual
unadjusted GPG data?
Source: Public consultation
Problem 3: LMB statistics are not fully consistent with related statistical domains
D6 – Lack of alignments with definitions, concepts and approaches in related statistical domains
The evaluation found that the current legal framework for LMB statistics is internally coherent
although this could be improved further by simplifying the legal architecture (replacing the three
framework regulations currently in force by a consolidated text). This unified legal framework
would benefit from systematic references to the corresponding concepts used in closely related
domains such as the National Accounts and European Business Statistics. The legislation has been
updated in both domains and their methodology revised (ESA 2010, EBS regulation) since the
LMB legislation has been adopted. Aligning LMB is needed with a view to foster coherence across
domains and clarity to the users of LMB legislation and the statistical offices of the Member States.
25
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52021PC0093&from=EN
2
1
14
9
13
6
8
1
User of European labour market
statistics on businesses
Producer of European labour
market statistics on businesses
crucial (please explain) high importance medium low importance
18
Moreover, the exclusion of “public administrations and defence, compulsory social security”
(NACE Rev. 2 section O) from SES, leads also to a deviation from the scope used in national
accounts. Civil servants and other government employees are covered in national accounts data but
not always in LMB statistics.
The legal framework can also be further improved to align with other EU policies and legislations
as those that are new or evolved since the LMB legislation adoption. This problem has rather
limited impact on stakeholders and would be resolved by the above policy measures related to the
extension of the scope of the LMB and updated referencing. Therefore, no specific policy measures
addressing the alignment with other policies and legislations are needed.
2.3. Size of the problem(s)
Different problems or weaknesses identified in the evaluation of the legislation have different levels
of severity that can be assessed based on the consequences of the identified shortcomings. Those
mainly depend on the importance of the policy concerned and of the type of institutional user. The
most important problems of the current legal framework is that it does not reflect the latest
evolution of user needs and is not flexible enough to address those that will emerge in the future.
This includes the fact that the gender pay gap data collection is provided on voluntary basis and
therefore is not transmitted by all member states.
The timeliness of the data defined in the legislation currently in force is not sufficient anymore for
the most important policy users (Problem 1). For instance, the labour cost index, could be provided
to the Governing Council of the European Central Bank one month earlier than now, allowing
quicker reactions to inflation/deflation risks stemming from by wages. This type of analysis and the
timeliness of the LCI data have become even more crucial since inflation has regained momentum
in EU economies. Timeliness and frequency of data are closely related. The data collected
frequently to monitor phenomena changing quickly in time should be published almost immediately
to be relevant. The data collected with lower frequency usually do not describe phenomena that are
volatile but should be available with short delay to be useful for users who wait for it longer (in
between the data collections). The policy users, in various occasions (expert groups meetings,
hearings between the Commission services) often underlined the need for more timely and frequent
LMB data. For instance, DG JUST, would need SES microdata more frequently than every four
years in order to conduct detailed analyses of gender pay gap determinants.
Additional variables such as for instance career and family situation in the SES would also enhance
the analysis of the gender pay gap. Similarly, information on net earnings would help good
monitoring of the wages adequacy (problem 1). The indicators defined based on the LMB data are
used to monitor policy initiatives that gained importance over time. For instance, the broader use of
median wages data (coming from the structure of earning survey, SES) for policy monitoring, in the
context of the directive on minimum wages, requires comparable data across EU countries
whatever the share of SMEs in the economy or the relative size of the public versus private sectors
(Problem 2). As illustrated in the evaluation report, the mean earning differs depending on the size
of enterprises (Figures 1 and 9, evaluation SWD). Similarly, the current gender pay gap indicator is
not provided for the whole economy as it is based on the same SES source (as illustrated in Table
1).
Moreover, the annual gender pay gap is provided on a voluntary basis only and in consequence not
by all member states (Greece and Ireland do not provide data) and is on a potential risk to being
discontinued.
19
Hence, the implementation and monitoring of the two new and very important directives on
adequate minimum wages and (forthcoming) on pay transparency would not be accurate with the
current LMB statistics.
2.4. How likely is the problem to persist?
LMB statistics are the only data source on the structure of earnings, labour costs and labour demand
at EU level. No alternative data sources exist. Hence, without any changes, over a 10-year horizon,
users’ needs are likely to remain increasingly unmet, missing an opportunity for evidence-based
policy and good quality research. Considering the importance of LMB statistics for policies that
generate impacts (e.g., inflation, gender pay gap, labour market performance, convergence), there is
room for improving the LMB evidence provided for optimal decision-making process.
For instance, the partial coverage of EU economies leads to biases in key figures used for EU
policies such as the job vacancy rate or the mean and median earnings. Without a revision of the
current legislation, this problem will persist as observed in the past years despite Eurostat’s
repetitive warnings (e.g. through the three-yearly report to EP/Council on job vacancy statistics).
Likewise, strategic policies related to equal rights will remain sub-optimal until the annual GPG
data collection is made mandatory and SES data are complemented with additional wage
determinants such as detailed occupations; new variables such as net earnings and (possibly) new
information on discriminated and/or segregated sub-populations such as persons with disabilities.
In economic terms, users will continue to bear additional costs and burdens to search for data that
are not available at the EU level.
The problem tree
Figure 6 below shows the links of the problems and their drivers as well as their main
consequences.
Figure 6. Problem tree
20
3. WHY SHOULD THE EU ACT?
3.1. Legal basis
The legal basis for EU intervention in the area of European statistics is Article 338 of the Treaty on
the Functioning of the European Union (TFEU), which confers on the European Parliament and the
Council the power to adopt measures for the production of statistics where necessary for the
performance of the activities of the Union, in accordance with the ordinary legislative procedure.
Article 338(2) TFEU mentions six general principles that Union statistics must follow, namely
impartiality, reliability, objectivity, scientific independence, cost-effectiveness, and statistical
confidentiality while not entailing excessive burdens on economic operators. These principles are
defined in Article 2(a)–(f) of Regulation (EC) No. 223/2009 on European Statistics and further
detailed in the European statistics Code of Practice adopted according to Article 11 of the
regulation. Article 338(2) TFEU also stipulates that Union statistics shall not entail excessive
burdens on economic operators. This provision, together with that of Article 338(1) TFEU,
according to which statistics shall only be produced where necessary, reflect an expression of the
principle of proportionality.
Article 5 of the Treaty on European Union (TEU) enshrines three principles: conferral,
proportionality and subsidiarity. In line with the principle of conferral, Article 338 TFEU
empowers the Union to establish European statistics, so this is a clear specific objective to be
pursued at EU level.
LMB statistics are part of the European statistics which are framed by Article 338 of the Treaty on
the Functioning of the European Union (TFEU) as the legal basis. This is done following the
ordinary legislative procedure in which case the European Parliament and the Council adopt
measures to produce statistics for the Union to deliver on its role. Hence, according to Article 338,
LMB statistics must conform to standards of impartiality, reliability, objectivity, scientific
independence, cost-effectiveness and statistical confidentiality.
Finally, legislative action on LMB statistics falls under supporting competences, where
the principle of subsidiarity authorises an intervention of the Union only if a specific issue cannot
be addressed by the individual intervention of the Member States and provided the objective can be
better achieved “by reason of the scale and effects of the proposed action” at EU level.
In this context, this section assesses whether a revision of the current legal framework governing
European statistics on labour market on businesses is appropriate and justified, in view of its
purpose to ensure high-quality data on the EU in line with the statistical principles and quality
criteria applicable to European statistics.
3.2. Subsidiarity: Necessity of EU action
Currently, LMB data collections are undertaken under three separate Regulations that do not
sufficiently address new needs; sources and methods neither cover important actors of the EU
economy.
Voluntary data collections are appropriate instruments to pilot the production of new topics or
characteristics, and to foster the incremental capability of national statistical systems to provide
such new data. However, they tend to become inefficient over time as recurrent production costs
21
eventually fail to generate substantial EU value added in terms of completeness and timeliness for
all Member States.
The ESS provides an infrastructure for statistical information needed at the EU level. The system is
designed to meet the needs of multiple users for decision-making in democratic societies.
It complements the national needs assuring harmonised approaches and data comparability without
duplicating the effort. The action does not go beyond the necessary activities of ESS partners while
better ensuring the quality and comparability of statistics. Among the main criteria to be fulfilled by
official statistics are consistency and comparability. Member States cannot achieve those criteria
without a clear European framework, that is to say Union legislation laying down the common
statistical concepts and transmission requirements.
In light of the variety of measures adopted at national level and given that providing a robust legal
framework for the collection of LMB statistics is essential to maintain relevant and comparable
statistics at EU level based on harmonised concepts and approaches to methodology, further action
at EU level is justified. Moreover, while some problems are limited to some countries (e.g.,
coverage of JVS statistics incomplete in DK, FR, IT only), the general problems and requests from
stakeholders apply to all Member States.
Moreover, the legislative action is necessary and proportionate as the problems identified can only
be solved via the appropriate EU legislation and have a genuine EU-wide scope clearly linked to
gaps of the current legislation (section 2). Without further EU legislative action, these problems
will persist.
3.3. Subsidiarity: Added value of EU action
The added value of complete and comparable LMB statistics lies in their important input to feed
into strategic EU policies (monetary and economic policies, Gender Equality Strategy,
the European Pillar of Social Rights, Sustainable Development Goals). LMB statistics are also
designed to meet the needs of multiple users, for the purpose of decision-making at all levels in the
EU, as well as research and informing the general public.
For this purpose, statistics that are consistent and comparable across EU Member States are
required. Coordinated action is essential to deliver coherent, reliable, timely and comparable data
based on harmonised concepts. It is clear that without a European framework, Member States
would not achieve the same results in terms of data, harmonised methodology and comparability of
outputs and consistence, which can only be fully achieved by way of EU action.
Moreover, in order to ensure compliant provision of national data, a regulation is the most adapted
type of EU action
Therefore, actions within this area will respect the principle of subsidiarity as framed by Article 5
of the TFEU.
4. OBJECTIVES: WHAT IS TO BE ACHIEVED?
Figure 7 sets out the main objective and specific objectives. There are no clear trade-offs between
specific objectives. Each of them is quite distinct on a specific strand of actions to achieve
the general objective.
22
Figure 7. Objective tree
Source: ICF
4.1. General objectives
The general objective of the action is to produce labour market and business statistics that are up-
to-date, relevant, comprehensive in coverage of important economic actors, comparable across
Member States and consistent with related statistical domains. It answers in the LMB domain the
requirements of Article 338 TFEU for the production of statistics where necessary for the
performance of the activities of the Union, in line with its principles of high quality and non-
excessive burden.
4.2. Specific objectives
The general objective is made of 3 specific objectives:
 Adapting the regulatory framework to allow flexibility in meeting emerging needs, to
release more timely statistics and to promote the use of innovative sources and methods of
duly assessed quality
 Improving the coverage of statistics to the whole economy and ensure exhaustive GPG data
 Improving the consistency with related statistical domains
Table 3 shows the connection between problem drivers and specific objectives. In other words,
each driver could be seen as an obstacle to achieve the objectives. To the extent policy options
would address drivers and problems, these would be helping to achieve the objectives.
23
Table 3. The problems and its drivers are obstacles to achieve the strategic and general objectives
Problem drivers Specific objectives General objectives
[D1] LMB statistics do not
cover emerging needs
Adapting the regulatory
framework to allow
flexibility in meeting
emerging needs, to release
more timely statistics and to
promote the use of
innovative sources
and methods of duly
assessed quality.
To produce labour market and
business statistics that are up-to-
date, relevant, comprehensive in
coverage of important economic
actors, comparable across Member
States and consistent with related
statistical domains
[D2] The quality framework
of LMB statistics is not fit for
the use of administrative data
and innovative sources
[D3] Some LMB statistics are
not timely or frequently
enough
[D4] The public sector and
micro enterprises are not
captured by LMB statistics
Improving the coverage of
statistics to whole economy
and ensure exhaustive GPG
data
[D5] GPG data are provided
by MS on a voluntary basis
[D6] Lack of alignments with
concepts and approaches in
related statistical domains
Improving the consistency
with related statistical
domains
Consistency with other EU policy objectives
As highlighted in the effectiveness part of the evaluation, the objectives of this intervention
contribute to different European flagships:
 European Employment Strategy (2005/600/EC);
 Principle 6 of the European Pillar of Social Rights.
 Directive on equal opportunities and equal treatment between men and women in
employment and occupation (2006/54/EC)
 Directive on adequate minimum wages (EU) 2022/2041,
 Commission proposal for EP and Council Directive on pay transparency;
The policy options will also be assessed on these criteria.
5. WHAT ARE THE AVAILABLE POLICY OPTIONS?
5.1. What is the baseline from which options are assessed?
In the baseline scenario, no action is taken. The current legal framework of LMB statistics divided
into 3 different basic acts would continue to exist with the shortcomings described in the previous
sections. In the baseline scenario there is no EU policy change and it does not require any particular
measure or action. Hence, this is an extrapolation within the next 10 years of what would happen in
a ‘no-change’ scenario. This scenario implies consequences for stakeholders as described in the
problem definition, that is, economic, social and any other relevant impacts.
24
5.2. Description of the policy options
In order to set up policy options, an exhaustive list of all possible measures identified during
preparatory work with NSIs, the Public Consultation and stakeholders’ consultation was set up for
each data collection. In a second step, measures are bundled into regulatory frameworks or policy
options and clustered by related policy drivers.
Policy measures
The policy measures are structured around the data collections to be regulated, amended or updated.
Job vacancies (JVS);
Labour cost index (LCI);
Labour cost survey (LCS);
Structure of earnings survey (SES); and
Gender pay gap (GPG).
The list of measures is presented in the table 4.
Table 4. List of measures by data collection
Code Description
SES 1 NACE Rev. 2 section O mandatory in SES
SES 2 Extending SES to micro firms (1-9) for main information only
SES 3 Timeliness = T+16 months (instead of T+18 months), for SES
SES 4 Extending SES to micro firms (1-9) collecting all SES information
SES 5 Frequency of SES = bi-annual (instead of 4-yearly), between LCS years
SES 6
Timeliness = T+11 months (instead of T + 18 months) with reference month changed
from October to February or April, for SES
SES 7
Collecting in SES set of new variables identified at the preparatory work stage and
emerging from the evaluation26
SES 8 Improved quality reporting of SES to cover elements assessing new data sources
LCS 1 NACE Rev. 2 section O mandatory in LCS27
LCS 2 Extending LCS to micro firms (1-9)
LCS 3 Timeliness = T+15 months (instead of T + 18 months), for SES
LCS 4 Frequency of LCS = bi-annual (instead of 4-yearly), between SES years
LCS 5 Improved quality reporting of LCS to cover elements assessing new data sources
LCI 1 Flash LCI at T+45 days for large (‘flash’) countries
LCI 2
Timeliness = T+65 days (instead of T+70) for small (‘non-flash’) countries;
Full NACE breakdown at t+65 days for all countries, for LCI
LCI 3
Indices of hours worked/labour costs for NACE aggregates: B to E, F, G to N, B to N, O
to S and B to S, for LCI
26
Possible variables to consider at the level of secondary legislation: occupation at ISCO-3 digits, net earnings, gross
earnings in kind, disability status of employees, career breaks of employees, number of employee’s dependent children,
institutional sector of the enterprise.
27
In addition limiting the collection of labour cost survey data on apprentices to countries where they represent less
than 1% of the total number of employees will serve as a simplification measure.
25
Code Description
LCI 4 Improved quality reporting of LCI to cover elements assessing new data sources
JVS 1
Full coverage of the economy in JVS including micro firms (1-9), public institutions and
the non-business economy (NACE Rev. 2 O to S)
JVS 2 JVS data available by region and occupation
JVS 3 Improved quality reporting of JVS to cover elements assessing new data sources
GPG 1 Create a legal basis for the mandatory transmission of annual unadjusted GPG data
GPG 2 Improved quality reporting of GPG to cover elements assessing new data sources
All 1 Improved harmonisation and synchronisation of planning
Policy options
We present in the following a list of options that correspond to different level of ambitions, but also
costs and burden, for the LMB review subject to this impact assessment.
Options are defined as a set of individual measures, from those described in the previous part of the
document, that would meet the user requirements identified in the evaluation and in the ‘problem
definition’ part of this document.
In order to make grouping of the various measures into policy options, a first feasibility assessment
of each individual topic and measure was carried out. This process involved assessing how the
topics and measures relate to one another (mutually exclusive or complementary), and an initial
screening of their likely effectiveness, as well as their technical, operational, economic and legal
feasibility. Based on this assessment and in order to integrate the various policy measures in
a meaningful set of policy options that would offer a choice to the policymaker, a realistic selection
based on the hard or soft nature of the requirement was carried out. This builds on the distinction
between required measures and voluntary measures on the one hand, and the extent to which
measures were included at all in the option. Two categories of policy measures shall be tackled at
the level of secondary legislation, namely those on improved quality reporting and on emerging
needs for variables and breakdowns. Hence, in the description of policy options, they are grouped
in only two sets of combined measures on quality and emerging needs respectively.
The policy options range from the least ambitious ('option 1’) – implementing most improvement
measures but without legal enforcement (“soft” non-mandatory / voluntary measures) except for the
annual GPG - to the most ambitious and costly (‘option 3’) - whereby all improvement measures
identified in the evaluation would be implemented through legally binding provisions. Option 2
would enforce only a selected set of improvement measures. Options 1 to 3 are defined under one
legislative act that will be an umbrella bringing together all current three LMB related primary
legislations.
Finally, option 4 is the “conservative” option offering changes in every relevant framework
regulation. It keeps the three exiting framework regulations and accommodates changes in their
context when possible. It is further presented under part 5.2.4 but was discarded at an early stage as
explained under part 5.3.
The baseline (option 0) and policy options 1 to 3 are detailed in Table 5 and in the following
paragraphs. In this table the selection of measures is indicated according the following labels:
- Full regulatory approach with binding measures set in EU legislation are marked as “Full”
26
- Soft regulatory approach with non-binding measures set in EU legislation resulting with MS data
transmitted on a voluntary basis is marked as “Soft”.
- Measures not included under this policy option are marked as “Not included”.
27
Table 5. Proposed policy options 0 to 3 clustered by drivers they address
Option 0: no further EU
action
Option 1: Reliance on the
voluntary nature of
contributions
Option 2: High coverage,
better timeliness and other
measures
Option 3: Highest coverage
and increased frequency
Improving consistency with related statistical domains (synchronised planning and flexibility)/D6
Single new framework
regulation
Single new framework
regulation
Single new framework
regulation
Single new framework
regulation
All 1 New framework regulation (Improved harmonisation and synchronisation of planning ) Not included Full Full Full
Making GPG data collection compulsory/D5 GPG regulated GPG regulated GPG regulated
GPG 1 Create a legal basis for the mandatory transmission of annual unadjusted GPG data Not included Full Full Full
Extension of the coverage of LMB/D4 Voluntary Very high coverage Full coverage and details
SES 1 NACE Rev. 2 section O mandatory in SES Soft Soft Full Full
LCS 1 NACE Rev. 2 section O mandatory in LCS Soft Soft Full Full
SES 2 Extending SES to small firms (1-9) for main information only Soft Soft Full Not applicable
SES4 Extending SES to small firms (1-9) collecting all SES information Soft Soft Not applicable Full
LCS 2 Extending LCS to small firms (1-9) Soft Soft Not included Full
JVS 1 Including small firms (1-9) and public institutions and the non-business economy (O to S) in the JVS Soft Soft Full Full
Improving timeliness and frequency of LMB/D3 Better timeliness
High timeliness, frequency
unchanged
Best timeliness and
frequency
SES 3 Timeliness of SES = T+16 months (instead of T+18 months) Not included Soft Full Not applicable
SES 6
Timeliness of SES = T+11 months (instead of T + 18 months) with reference month changed from October to
February or April Not included Soft Not applicable Full
LCS 3 Timeliness of LCS= T+15 months (instead of T + 18 months) Not included Soft Not included Full
LCI 1 Timeliness of flash= LCI at T+45 days for large (‘flash’) countries, total economy Soft Soft Full Full
LCI 2
Timeliness of LCI= T+65 days (instead of T+70) for small (‘non-flash’) countries. Full NACE breakdown at t+65 days
for all countries Soft Soft Full Full
SES 5 Frequency of SES = bi-annual (instead of 4-yearly), between LCS years Not included Not included Not included Full
LCS 4 Frequency of LCS = bi-annual (instead of 4-yearly), between SES years Not included Not included Not included Full
Adapting quality reporting framework for use of administrative data and innovative sources/D2 Voluntary
Quality reporting for all
sources
Quality reporting for all
sources
SES 8, LCS 5,
LCI 4, JVS 3,
GPG 2
Quality reporting covering elements needed for assessing new data sources in all data collections Not included Soft Full Full
Adressing emerging needs /D1 Voluntary
Emerging needs for
variables and breakdowns
Emerging needs for
variables and breakdowns
SES 7, LCI 3,
JVS 2
Emerging needs related to new variables in SES, indicies for hours wokred and labour costs in LCI and more detailed
breakdowns of the JVS. Not included Soft Full Full
28
5.2.1. Option 1: Reliance on the voluntary nature of contributions
In this option, the existing data collections and their legal obligations as foreseen in the three
existing regulations are implemented under a new framework regulation. Moreover, the GPG,
which is not covered by and does not fit in the scope of any of the 3 current framework regulations,
is encompassed in this new framework regulation. The reason is the need of making GPG annual
data collection compulsory (addressing driver five), aligning definitions, concepts and approaches
as well as synchronising planning as set up by the sixth problem driver. Strong methodological
links are necessary between SES and GPG (both dealing with earnings) and LCS and LCI (both
dealing with labour costs).
However, selected new policy measures for improvement of the data collections requested by
stakeholders will be implemented by voluntary data collections. This could be done using
agreement between the NSIs or other national authorities and the Commission (Eurostat) as
foreseen in the article 14 of the Regulation No 223/200928
by which members of the ESS agree to
implementing new statistical developments / collections on a voluntary basis. It should be noted
that increasing the frequency of the SES and LCS data collection on a voluntary basis was
discarded as its high costs limit its implementation on a voluntary basis. Moreover, different
periodicities of data collections (LCS and SES) among member states would lead to fragmentation
of the statistical processing and dissemination. Only some policy measures (GPG 1 and All 1)
would be enforced, in line with the approach of the new framework legal basis.
5.2.2. Option 2: High coverage, better timeliness and other measures
In this option all data collections and the annual GPG are implemented under a new framework
regulation. The measures implemented will be compulsory. However, this option does not include
the policy measures that have the highest impact in terms of burden and costs for businesses and
NSIs. In particular the higher frequency for SES and LCS (every two-year instead of every four-
year as currently) that would double the burden of these two surveys for businesses. Similarly, the
coverage of micro businesses in LCS and some very ambitious improvements of timeliness are not
implemented.
Namely, in this option the coverage will be extended to micro businesses for SES for the main
information collected in the survey (SES 2) - while LCS will not be extended to these enterprises -
measures associated to the fourth problem driver. Both, SES and LCS will be extended to cover
NACE Rev. 2 section O (SES 1 and LCS 1) and JVS will cover full economy (including micro
firms, public institutions and non-business economy, NACE Rev. 2 sections O to S)- JVS 1.
Moreover, timeliness will be improved for the LCI for all countries (LCI 1) and larger countries
will provide quick estimates allowing calculation the EU and euro area flash labour costs index
twenty days earlier than the current date of T+70 days (LCI 2). For the SES, the timeliness will
improve by two months (SES 3) and no improvement will take place for LCS (LCS 3 not
implemented). Frequency of SES and LCS will not increase (SES 5 and LCS 4 not implemented) –
measures associated to the third problem driver. All measures associated to the other policy drivers
will be taken into account, including developing a legal basis for the GPG as under option 1 and
covering emerging needs. Improved quality reporting will be assured for all data collections and
28
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32009R0223&from=EN
29
better harmonisation and planning will be assured via one framework regulation. The objectives
would be partially achieved: four out of six drivers would be fully answered and two only partially.
5.2.3. Option 3: Highest coverage and increased frequency
This option intends to implement, under a new framework regulation encompassing all data
collections and the annual GPG, all and best policy measures listed above, including the high
frequency measures for SES and LCS (every two-year data collection for each). This option would
answer exhaustively the needs for improvement and harmonisation of all LMB statistics as
expressed by stakeholders.
Namely, it includes all policy measures identified, for all actions answering all the 6 policy drivers,
either in terms of coverage, timeliness and high frequency, quality reporting and use of
administrative data and innovative sources, alignment of concepts across LMB domains, making
GPG data collection compulsory and covering emerging needs. That means, the coverage of SES
and LCS would be extended to micro firms and NACE Rev. 2 section O (SES 1, LCS 1, SES 4,
LCS 2) and JVS to micro firms and NACE sections O to S (JVS 1). Timeliness of SES would
improve to T+11 (SES 6) and LCS to T+15 (LCS 3). All measures associated to the other policy
drivers will be taken into account, including developing a legal basis for the GPG as under option 1
and 2 and emerging needs. Improved quality reporting will be assured for all data collections. And
better harmonisation and planning will be assured via one framework regulation.
Framing options 2 and 3 in the secondary legislation
The framework regulation will define domains and topics for the data collections. The technical
elements including the list and description of variables and breakdowns will be specified in the
secondary legislation.
The detailed variables (preliminarily identified in the evaluation) or breakdowns will be a subject
for secondary legislation due to high level of details and granularity as well as their very technical
character. Similarly, the framework regulation in options 2 and 3 will require Member States to
provide quality reports on the sources and data collection methods, while their technical elements
including the content of the quality report will be defined in secondary legislation. This approach
allows for updating the contents of quality reports should new specific quality dimensions become
relevant.
In addition, to assure flexibility in addressing future needs, some aspects (detailed topics, their
corresponding periodicity and reference periods as well as transmission deadlines) will be set out in
the annex of the framework regulation with delegated powers for the Commission to adapt them.
This is the usual approach for statistical legislation, and it allows for updating technical elements to
cater for future emerging needs.
5.2.4. Option 4: Implement actions in the existing legal frameworks
This option would implement policy measures by amending the existing three framework
regulations. While it is possible to implement a large series of measures by amending Regulation
(EC) 530/1999 for SES and LCS measures, Regulation (EC) 450/2003 for LCI and Regulation (EC)
30
453/2008 for JVS, there will be no legal framework for regulating the annual GPG nor better
harmonisation and planning.
5.3. Options discarded at an early stage
The data collections covered in the LMB statistics are interlinked. They should use the same
statistical definitions and be coordinated in timing to be fully effective. For example, indicators on
labour cost levels are collected every four years (direct measurement) and updated every year by
using the annual labour costs index as an auxiliary variable. As another case, the yearly gender pay
gap is benchmarked every four years on the results of the structure of earnings survey. This requires
definitions used for wages and other labour cost components to be identical in all these datasets in
order to obtain unbiased yearly estimates. Updating each framework regulation separately would be
a missed opportunity to best align the common concepts used in labour market statistics. Moreover,
if the legal framework remains scattered, introducing any future new concepts into one existing
regulation in future would require potential reopening of the other.
Moreover, the legal basis for the mandatory transmission of the annual unadjusted GPG data does
not exist so far: this indicator and does not fit in the scope of any of the three existing legal
frameworks. Hence, option 4 would not allow developing this legal basis that is an important
request of stakeholders and is high in the policy agenda of the EU with the proposal of Directive on
pay transparency, the EPSR and the SDG.
In addition, while a large set of policy measures could be implemented in each domain, e.g., the
extension of coverage requested by stakeholders, high consistency and consolidation would not be
ensured across the different domains and risks of divergences in national implementations would
also increase. Indeed, the legal fragmentation of the 3 existing framework regulations makes it very
difficult to achieve a coordinated and consistent approach when it comes to modifications.
In addition, there is a need for better coordination of the planning. While Regulation 530/1999
ensures an alternation of SES and LCS, and LCI and JVS regulations foresee quarterly
transmissions to Eurostat, a full synchronised planning including GPG is needed. Links between
LCI and LCS for providing annual estimates of labour costs based on indexes as well as between
the LCS and SES (and SES and GPG) for coherence of statistical concepts and quality reports for
all data collections allowing a smooth repartition of the burden for NSIs would not be ensured.
Finally, the undertaken initiative to modernise and streamline LMB statistics necessitates
substantive amendments to the provisions of the legislative acts currently in force and granular
approach dealing with every regulation separately will be administratively highly inefficient.
On the opposite, merging regulations into one integrated framework would foster clarity and
consistency for all stakeholders, in particular the national statistical institutes, data providers,
institutional and policy users, researchers, students and EU citizens in general. It is the best way to
ensure that data producers use the same concepts in the same manner across all LMB datasets. It is
also the simplest and most transparent way to align LMB concepts on the related definitions from
European Business Statistics or National Accounts.
31
Moreover, the flexibility for introducing requirements that will be proved to be feasible (by for
instance conducting pilot studies) will also be easier to manage if LMB statistics are all
consolidated in one single basic act.
Finally, as LMB data collections are usually collected by the same bodies in the member states,
the integrated framework would allow a better balancing and controlling of the burden on
respondents over time, including for future new needs to be implemented in the context of the new
flexibility.
Taking into account all these elements, option 4 has been discarded.
The features and differences of the options considered for the analysis of their impacts are
summarised in Table 6.
Table 6. Options 0 (baseline) as well as 1, 2 and 3 under a single new framework regulation
main features and differences
Cluster of measures Option 0
(baseline)
Option 1 Option 2 Option 3
GPG annual data
collection
No Compulsory Full implementation Full implementation
Coverage No Voluntary Micro enterprises covered in
SES (for main information)
NACE Rev. 2 section O
covered in SES and LCS.
Full coverage for JVS.
Micro enterprises covered
in SES (for all information)
and LCS.
NACE Rev. 2 section O
covered in SES and LCS.
Full coverage for JVS.
Timeliness and
Frequency
No Voluntary
(timeliness
only
Timeliness improved but
limited to LCI and slightly
for SES.
No increase of frequency of
SES and LCS
Timeliness improved for
LCI, significantly for SES
and moderately for LCS.
The frequency of SES and
LCS is doubled
Quality reporting,
use of administrative
data and innovative
sources
No Voluntary
(compulsory
for GPG)
Full implementation Full implementation
Emerging needs No Voluntary Yes Yes
6. WHAT ARE THE IMPACTS OF THE POLICY OPTIONS?
The three policy options are assessed using a partial quantitative assessment of the efficiency of
the policy options, with impacts monetised to the greatest extent possible, based on the available
evidence.
Moreover, a qualitative assessment is carried out for each of the policy options covering
the following criteria:
 Effectiveness;
 Coherence with the overarching objectives of EU policy and consistency with
the proportionality principle;
32
 Efficiency;
 Impacts including on fundamental rights and wider social, environmental, digitalisation
and on administrative burden of enterprises;
o By its nature, statistics can only indirectly impact fundamental rights and
contribute to social, economic developments by allowing monitoring them.
o As the LMB statistics collects information on businesses it contributes to an
administrative burden on them related to data reporting although limited.
o Statistical processing is a beneficiary and contributor to digital development.
For the qualitative assessment, a scoring approach is defined as indicated below.
Scoring approaches used in the report
The consistency of each policy option with the principle of proportionality is rated as
‘Pass’, ‘Uncertain’ or ‘Fail’.
The options have also been qualitatively scored against the criteria of effectiveness,
coherence and efficiency Each option was scored against these three criteria using the
following scoring system:
Scoring system
Level of impact Score
Strong negative impact --
Slight negative impact -
No impact compared to baseline 0
Slight positive impact +
Strong positive impact ++
The baseline has been scored as ‘0’ against all three criteria (effectiveness, coherence and
efficiency). All other options have been scored relative to this baseline using the above
scoring system. The options have also been scored relative to one another. Thus, two or
more options with a similar strength of impact against the same criterion have been given
a tied score.
The scores and the breakpoints between them are, to the extent possible, grounded in the
evidence gathered from the consultation and desk research.
Quantitative analysis of the options
Policy option 0 is the baseline scenario. The costs associated with this option are therefore an
estimate of current costs, assuming these costs would remain constant over 10 years. The cost
assessment of the baseline scenario has been carried out based on the evaluation results. It is
important to note that the baseline costs estimated as part of this Impact Assessment are the costs
associated with the current legal framework. The baseline costs estimated include all costs currently
incurred to produce the various LMB datasets that could potentially be affected by the policy
33
measures and options proposed. Datasets not regulated and voluntary are not included in
the baseline costs.
The costs assessed for policy options 1, 2 and 3 are expressed in comparison with the baseline
(policy option 0). These only estimate the additional costs associated with the implementation of
each of the measures/actions required under each option, over and above the baseline situation, i.e.
costs that would be incurred in any option. As such, total costs for each option are equal to
the costs reported for policy option 0 plus those reported for each other relevant option.
The study supporting this impact assessment has been able to assess the minimum costs expected
for a number of cost items, in particular:
 EC (Eurostat):
- one-off costs for amending the framework regulation and implementing regulations
- Recurring costs for monitoring compliance by MS.
 MSs/NSIs
- One-off costs for adapting the existing data collections to the new requirements under the
revised LMB framework regulation
- Recurring costs for data collections
- One-off cost to communicate the change
- Recurring costs for reporting to the EU
There are other cost items and cost savings involved that the study could not ascertain, which
include:
 The costs of adapting IT systems to new regulations
 Indirect cost savings due to improved policymaking as a result of the changed framework
regulation.
The assessment of the costs for businesses is based on a detailed study conducted by Eurostat in
cooperation with the compilers (NSIs and other national authorities in charge of LMB).
Table 7 provides a high-level overview of the approximate costs. The assumptions are shown in
Annex IV and V.
34
Table 7. Overview of costs, in Euro
Type of
costs
PO0
Baseline
PO1 Reliance
on the
voluntary
nature of
contributions
PO2 High
coverage,
better
timeliness and
other measures
PO3 Highest
coverage and
increased
frequency
EC/ESTAT
Developing the
framework regulation
and amending
implementing
regulations
One-off 0 28,545 35,682 42,818
Monitoring
compliance
Recurring 0 8,182 12,273 13,909
MS/NSIs
Adaptation and
preparation for using
the revised text of the
LMB framework
regulation
One-off 0 45,537 91,075 106,254
Data collections Recurring 0 66,814 3,259,423 19,021,716
Communicate the
change
One-off 0 88,315 88,315 88,315
Issuing guidance and
training
One-off 0 7,081 110,394 110,394
Reporting to the EU Recurring 0 6,900 10,349 11,729
Businesses
Costs for participating
in surveys
Recurring 0 92,365 4,618,254 38,002,583
Totals 0 343,739 8,225,765 57,397,718
35
Benefits such as potential cost savings or reductions in the administrative burden associated with
each policy option could generally not be quantified. This depends in particular on future progress
in IT and data collection techniques (such as ‘web-scraping’) which have not been implemented
yet. These techniques are expected to decrease the LMB burden in the long run so that the estimates
provided in this study should be taken as maximum amounts (caps). Estimates for the expected cost
savings would be severely limited and hence add little value. In order to enable a choice to
the policymaker between policy options 0 to 3, the available cost estimates and the qualitative
assessments of the options are considered to be sufficient.
Many benefits on the availability, accessibility and use of LMB data sets have different effects on
stakeholder groups (data users), making them challenging to define, quantify or monetise.
Analysis of the policy options
An overview of the qualitative assessment for the four options retained for the impact assessment
has been carried out. It starts by an assessment of proportionality, followed by assessments of
effectiveness, efficiency and coherence. A detailed scoring of the policy options is provided in
the Section 2 of Annex 3.
6.1. Policy option 0 (baseline): No targeted EU action
The baseline passes the criterion on consistency with the proportionality principle, however on
form of action (choice of instrument) it is uncertain whether this option can deliver satisfactory
achievement of the objective and effective enforcement.
All effectiveness, efficiency and coherence criteria under policy option 0 score ‘0’ to enable
meaningful comparisons with options 1, 2 and 3. For the baseline scenario there is no further EU
action.
36
6.2. Policy option 1: Reliance on the voluntary nature of contributions
Figure 8. Intervention logic for option 1
Under policy option 1, there will be limited mandatory changes at the EU level and a larger number
of voluntary changes. The measures, however, generally represent a continuation of the status quo
under the baseline.
Policy option 1 passes the criterion on consistency with the proportionality principle, including
choice of an instrument. This option scores “+” on effectiveness in all specific objectives. It scores
“+” on impact on fundamental rights and social impact and is neutral “0” on impact on Sustainable
Development Goals.
The results of the consultation on cost and burden with the NSIs and the further qualitative study
showed that the introduction of a compulsory data collection on GPG would lead to an increase of
costs of 34 % (+ 215 000 Euro) for this data collection. For the whole LMB, however, this means
an increase of less than 1 % in total. The estimated increase in costs related to burden on enterprises
would be negligible (less than 100 000 Euro). This is mainly linked to the fact that the GPG data
collection is based on the existing sources and the burden is mainly on the statistical authorities to
compile the data and prepare quality report.
This option would have limited effectiveness in addressing the problems identified with the current
EU legal framework as, relying on national willingness, it would not ensure that improvements are
implemented Union-wide. While it passes the proportionality principle simply because it is
a simplification compared to the existing framework, its effects are modest and do not meet
the expectations for a general review of LMB legislation. While there are some positive social
impacts, the overall coherence with EU policies is not deemed well-served by this option, thus
making it sub-optimal.
37
In summary, this option would be somewhat more effective in addressing the problems identified
with the LMB framework compared to the baseline, although it still falls short from users
expectations identified through the LMB evaluation exercise.
6.3. Policy option 2: High coverage, better timeliness and other measures
Figure 9. Intervention logic for option 2
As highlighted in the intervention logic, most of the drivers are addressed in option 2. It is therefore
highly effective in achieving most of the policy objectives. In terms of coverage, option 2 does not
foresee the extension of LCS to cover micro firms but extends SES to micro firms although only for
main information (SES 2). Option 2 also offers better timeliness but the frequency remains
unchanged – as with the baseline scenario (4-yearly). The option leaves limited gaps with
the identified set of problems and drivers. While it is anticipated that the increase in timeliness will
allow for better research and evidence from SES and LCI, the frequency of LMB statistics would
not increase although this issue was often mentioned by stakeholders. Whereas cyclical indicators
(JVS for labour shortages, LCI for hourly labour costs) are provided with sufficient frequency
(quarterly), some users would appreciate a shorter periodicity for structural data such as the LCS
and the SES. Nevertheless, option 2 would also cover important actors and segments of
the population to allow for better research and policy analysis. This option also introduces new
templates for the collection and quality reporting for the use of administrative data and innovative
sources as well as more alignment in terms of concepts and definitions of relevant data domains
including national accounts and the European business statistics.
The policy option 2 passes the criterion on consistency with the proportionality principle, including
choice of an instrument. This option scores “++” on effectiveness related to specific objective 1.1
“Adapting the regulatory framework to allow flexibility in meeting emerging needs” and 1.3 “To
promote the use of innovative sources and methods of duly assessed quality”. It scores however “+”
on specific objective 1.2 “To release more timely statistics”. On specific objective 2 “Improving the
coverage of statistics to the whole economy and ensure exhaustive GPG data” option 2 scores “+”
38
and on objective 3 “Improving the consistency with related statistical domains” it is assessed to
be“++”.
Impact on fundamental rights and on Sustainable Development Goals is positive “+” and social
impact “++”. Indeed, in addition to the improvements related to the gender pay gap data, the
extension of the SES coverage to the micro firms and NACE Rev. 2 section O would allow better
assessment of the low–wage earners and contribute to the monitoring of the directive on minimum
wages adequacy. Option 2 scores “+” on coherence as it would address most of the shortcomings of
the baseline in terms of coverage of the economy and answering emerging needs and further
harmonisation of standards (definitions, concepts, templates for quality reports). A clear effort on
collecting these types of data would better ensure meeting overarching EU objectives.
The costs for compilers and time burden on businesses on statistical reporting related to data
collections were assessed based on a quantitative survey of NSIs and Other National Agencies
(ONAs) in charge of LMB statistics. This was complemented by a qualitative survey of the LAbour
MArket Statistics (LAMAS) working group carried out in the July-August 2022 and the study
conducted for the purpose of evaluation and impact assessment.
The Table 8 provides an overview of the increase in costs for NSIs across datasets for NSIs, for
policy option 2
Table 8. Increase in costs of NSIs for policy option 2
Total annual costs of
baseline for NSIs (in
EUR)
Increase of NSI´s cost (in
EUR)
% Increase of total
NSIs´costs
JVS 5,659,238 586,191 10%
LCI 9,318,641 865,516 9%
LCS 7,185,434 529,808 7%
SES 7,386,671 1,511,227 20%
GPG 628,709 214,647 34%
Total LMB 30,178,693 3,707,389 12%
Overall, the increase of costs for NSIs is approximately. 12 % (EUR 3.7 million) of which SES is
the costliest with 1.5 million (20 %) followed by LCI with close to 0.9 million (9 %). Costs for
mandatory data collection on GPG are marginal.
39
The table below provides an overview of the increase in costs for businesses across datasets.
Table 9. Increase in costs for businesses for policy option 2
Total annual costs of
baseline for businesses (in
EUR)
Increase of businesses cost
(in EUR)
% Increase of total
costs of business
JVS 4,472,272 723,594 16%
LCI 12,001,564 11,935 0.1%
LCS 10,703,029 456,720 4%
SES 16,079,802 3,426,005 21%
GPG 0 92,365 na
Total LMB 43,256,667 4,710,619 11%
Overall, the increase on businesses amounts to approximately EUR 4.7 million (11 %), of which
EUR 724,000 (16 %) for JVS, EUR 12,000 (0.10 %) for LCI, EUR 457,000 (4 %) for LCS, EUR
3.43 million (21 %) for SES and EUR 92,000 for GPG.
To summarize, option 2 would create a limited increase in burden, mainly due to the extending SES
to micro-firms. The costs implied (8.2 million) represent a negligible part (less than 1%) of the
costs European Business Statistics (annual total costs of around 980 million Euro in 2017)29
. The
real amounts will be even smaller as ten NSIs have already extended SES to micro-firms. Therefore
option 2 scores “++” on efficiency.
29
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1342-European-business-statistics-FRIBS-
_en
40
6.4. Policy option 3: Highest coverage and increased frequency
Figure 10. Intervention logic for policy option 3
Option 3 fully captures all important business actors and allows for the monitoring of socio-
economic phenomena across the whole EU economy. It leaves no meaningful gaps with the
identified set of problems and drivers.
The extension of both the SES and LCS scope to micro-firms would also fill in the existing data
gaps for this part of the economy. The addition of new data, improvements in timeliness, increased
frequency of SES and LCS and alignment of definitions would result in more complete full filling
users’ needs leading to better evidence-based policy making with issues such as discrimination and
inequalities being better covered by European official statistics. All these improvements would
significantly enhance the scope and depth of policy research on earnings, labour costs and labour
shortages.
The policy option 3 passes the criterion on consistency with the proportionality principle, including
choice of an instrument. However, the increased frequency and timeliness entail sustained further
efforts that may, strictly speaking, not all be necessary to meet objectives of the initiative.
Therefore the option is uncertain to pass on the criterion of costs being commensurate with the
objective of the initiative.
This option scores “++” on effectiveness related to specific objective 1.1 “Adapting the regulatory
framework to allow flexibility in meeting emerging needs”, objective 1.2 “To release more timely
statistics” and 1.3 “To promote the use of innovative sources and methods of duly assessed
quality”.
41
On specific objective 2 “Improving the coverage of statistics to whole economy and ensure
exhaustive GPG data” option 3 scores “++” and on objective 3 “Improving the consistency with
related statistical domains” it is assessed to be“++”.
Impact on fundamental rights, social impact and on Sustainable Development Goals is highly
positive “++”.
Option 3 scores “+” on coherence as it would address most of the shortcomings of the baseline in
terms of coverage of the economy and answering emerging needs and further harmonisation of
standards (definitions, concepts, templates for quality reports). A clear effort at collecting these
types of data would better ensure meeting overarching EU objectives.
The table below provides an overview of the increase in costs for NSI’s across datasets, for policy
option 3
Table 10. Increase in costs for NSIs for policy option 3
Total costs of baseline for
NSIs (in EUR)
Increase of NSI´s cost (in
EUR)
% Increase of Total
costs
JVS 5,659,238 2,198,958 39%
LCI 9,318,641 1,379,390 15%
LCS 7,185,434 8,348,942 116%
SES 7,386,671 7,409,460 100%
GPG 628,709 1,658 0%
Total LMB 30,178,693 19,338,408 64%
The total cost of NSIs as reported in the Eurostat’s costs and burdens study suggests an overall
increase of around + €19 million (+64%) of LMB statistics for policy option 3 as compared to the
baseline. The higher increase would be for LCS 8.3 million (116 %), followed by SES (100%, +7.4.
million).
The table below provides an overview of the increase in costs for businesses across datasets.
Table 11. Increase in costs for businesses for policy option 3
Total costs of baseline
for businesses (in EUR)
Increase of businesses cost (in
EUR)
% Increase of total
costs of businesses
JVS 4,472,272 2,715,790 61%
LCI 12,001,564 11,935 0%
LCS 10,703,029 15,187,811 142%
SES 16,079,802 20,087,048 125%
GPG 0 0 0%
Total LMB 43,256,667 38,002,583 88%
Similarly to NSIs, businesses would also face a significant increase in costs, In monetary terms,
policy option 3 would increase costs for businesses of an estimated EUR 38 million, of which EUR
12,000 for LCI, EUR 2.7 million (61%) for JVS, EUR 15.2 million (142%) for LCS and EUR 20
42
million (125%) for SES. Overall this would mean 88% increase in costs for businesses compared to
the baseline.
Option 3 would create much higher costs for NSIs and a significant increase in the burden for
respondents. Therefore it scores “+” on efficiency.
Options 1, 2 and 3 are to the same extent likely to have a rather neutral indirect environmental
impact when considering the European Green Deal and is not different from the baseline. There are
no to negligible impacts on competitiveness, research and innovation and all three options are
fully in line with the principle of “Do No Significant Harm”. All those options are also fully in
line with the principle of digital-ready policymaking: digitalization is at the core of statistical
processes within the European Statistical System (‘digital by default’). The specific measures will
be implemented through digital techniques (web-forms, digital processes, IT programmes) with
a view to minimize the costs for NSIs and burden on respondents for all options.
43
7. HOW DO THE OPTIONS COMPARE?
Table12 below summarises scoring for all options assessed.
Table 12. Summary assessment table
Assessment
Score
Option 1
Option
2
Option
3
Consistency with the
proportionality
principle (Pass /
uncertain / fail)
Does the option go beyond what is necessary to satisfactorily
achieve the objectives?
Pass Pass Pass
Is the scope of the option limited to aspects that Member States
cannot achieve satisfactorily on their own, and where the Union
can do better?
Pass Pass Pass
Are costs for the Union, national governments, regional or local
authorities, economic operators or citizens commensurate with
the objectives of the initiative?
Pass Pass Uncertain
Is the form of action (choice of instrument) as simple as possible
and coherent with a satisfactory achievement of the objective and
effective enforcement?
Pass Pass Pass
Effectiveness (-- to
++)
SO1.1: Adapting the regulatory framework to allow flexibility in
meeting emerging needs
+ ++ ++
SO1.2: To release more timely statistics + + ++
SO1.3: To promote the use of innovative sources and methods of
duly assessed quality
+ ++ ++
SO2: Improving the coverage of statistics to whole economy and
ensure exhaustive gender pay gap data
+ + ++
SO3: Improving the consistency with related statistical domains + ++ ++
Impacts on fundamental rights including the promotion of
equality
+ + ++
Social impacts + ++ ++
Sustainable Development Goals 0 + ++
Coherence with
overarching
objectives of EU
policy (-- to ++)
Coherence - + +
Efficiency Efficiency 0 ++ +
All options presented in the impact assessment are largely in line with the first judgement criteria
on whether the option go beyond what is necessary to satisfactorily achieve the objectives because
they are limited to what is necessary to satisfactorily achieve the objectives. They do not attempt to
address any additional problems beyond those defined in the problem definition.
Moreover, policy options 1, 2 and 3 clearly pass the criterion the extent to which each policy option
is limited to aspects that cannot be achieved satisfactorily by the Member States on their own.
Ensuring consistency in the geographic, temporal and thematic breakdowns of LMB statistics at EU
44
level requires EU intervention and cannot be left solely to the Member States (necessity and
subsidiarity tests are passed).
The third criteria concerns the extent to which the costs (for the Union, national governments,
regional or local authorities, economic operators or citizens) are commensurate with the objectives
of the initiative. Based on the above assessment on cost and burden, all policy options are judged as
having costs that are commensurate with the objectives of the initiative and passing the test. Even
policy option 3, which would be the costliest option to implement, is judged as passing this test.
On the fourth criterion, as to whether the form of action (choice of instrument) is as simple as
possible all options pass the test for the simple reason that a new framework regulation – required
for all options – would be a clear simplification compared to the baseline. While the benefits for
option 1 are cancelled out by its inherent inefficiencies, the form of action is still the simplest one
possible.
Effectiveness
Option 1 would aim to increase effectiveness of the existing framework by considering elements
that were not part of the existing regime. While these are voluntary in nature the mere consideration
of these needs, and in responding to problems, this option compares favourably with the baseline.
Consistency with related statistical domains would be improved somewhat, though the voluntary
nature of the regime would greatly mitigate these potential benefits.
The impact on fundamental rights is not fully neutral. Given on the compulsory collection of the
gender pay gap in particular the impact on fundamental rights of collecting these types of data will
be partially served through this option.
Both option 2 and 3 would help to significantly improve the depth of statistics by further adapting
the framework to evolving needs, sources and methods by considering numerous elements that are
not part of the existing regime.
The coverage of statistics will be improved in particular for GPG data, extending SES to micro
firms, better coverage of the economy through including NACE Rev. 2 section O “administration”,
new elements of quality reporting allowing assessment of quality of innovative or administrative
data sources, aligned definitions and concepts, and addressing emerging needs.
This together with improvements in LCI timeliness would further contribute to modernising social
statistics.
In terms of social impacts there are positive effects in both option 2 and 3, with the mandatory
collection of data on gender pay gap and on additional variables and breakdowns to be further
detailed in the secondary legislation. The mandatory collection of information on employees (e.g.
carer breaks) would expand the range of possible analyses on segregation, subject to legal
constraints on privacy and data protection.
All three options have a rather neutral indirect environmental impact when considering the
European Green Deal and not different from the baseline.
45
Overall option 3 compares favourably to option 1, and is more ambitious than option 2 when it
comes to the frequency of SES and LCS. The timeliness and frequency improvements do match an
expressed need of some users and thereby it makes the LMB more effective than under option 2.
Coherence
In terms of coherence both option 2 and 3 are expected to provide strong positive impact. On the
other hand, option 1 would not address all the shortcomings of the baseline (option 0) in terms of
the somewhat more complex nature of the various existing datasets, the divergence of outcomes
due to the voluntary nature of many of the measures and thereby the rendering of coherence in EU
policies somewhat less favourable than possible.
Both option 2 and 3 would address most of the shortcomings of the baseline in terms of coverage,
answering emerging needs and further harmonisation of standards (definitions, concepts, templates
for quality reporting). It is anticipated that these policy options would align LMB statistics with
other EU flagship initiatives such as the EP and Council Directive on minimum wages,
Commission proposal for a Directive on pay transparency and the principle 6 of the European Pillar
of Social Rights.
Efficiency
All options would incur higher costs compared with the current LMB framework taken as the
baseline. Costs in policy option 1 are mainly for NSIs and related to the GPG. Costs of option 2 (for
Eurostat, NSIs and enterprises) are mainly driven by the costs of producing the statistics on wages
and job vacancies on the extended population of enterprises, to a lesser extent on labour costs and
the gender pay gap. In terms of impacts for respondents, option 2 would be far less burdensome (+
11% increase in costs for businesses) than Option 3 (+88%).
Therefore, although option 3 presents the highest effectiveness, this comes at a high price and
option 2 scores far better in terms of efficiency.
Potential obstacles that might be encountered for an effective implementation
The problem of the LMB statistics currently lies in non-legally binding collections (at EU level),
particularly for micro firms. For instance, 12 member states (and 2 EFTA countries) transmitted
those data in the latest SES 2018. Section O is covered in the SES by 24 member states and by 22
member states in LCS. Hence, the main impact in terms of extension of the coverage will be for the
data collection of the SES on micro-firms, i.e., the effort will be for Belgium, Denmark Greece,
France Croatia, Italy, Luxembourg, Hungary Malta, Austria, Poland, Portugal, Romania, Finland
and Sweden. In job vacancy statistics, most member states already achieve a full coverage of
economy. However, data for three of them (Denmark, France and Italy) are not fully comparable
with those of the rest of the EU. In both France and Italy, public institutions are not covered within
the sectors of public administration, education and human health (NACE Rev. 2, sections O, P and
Q). Furthermore, France only includes units with 10 employees or more whereas Denmark only
covers units within the business economy (NACE Rev. 2, sections B-N).
46
8. PREFERRED OPTION
8.1. PREFERRED OPTION
Policy option 2 has been identified as the most effective option, which addresses the needs of data
users and providers in the most cost-efficient way. In the online workshop with stakeholders this
option was the preferred option. Although data users would like to see more ambitious proposals
such as option 3, participants in the online workshop insisted that the selected option be realistic in
terms of what can be achieved with Member States in the current context of cost and burden
limitation and what could be possibly accepted for implementation by the EU statistical
community. All options ensure proportionality. Although option 3 is the best performing option in
terms of effectiveness, it is also the most expensive and causes the highest burden on enterprises.
According to data providers, the implementation of option 3 would also raise serious difficulties on
the field. The preferred option is therefore option 2.
8.2. REFIT (simplification and improved efficiency)
REFIT: Simplification and improved efficiency
Options 1, 2 and 3 would require a new framework regulation. This entails integrating the 3
existing framework regulations for LMB into one single basic act.
The favoured option (option 2), will lead to simplifications and improved efficiency through three
main channels:
a) Merging the existing three framework regulations into one single legal act. A single
framework regulation will clearly set the scope of LMB statistics and underline their common
nature (collected from businesses) and purpose (to inform about developments in EU labour
markets). Each concept will be defined only once and thus fostering consistency (also in future
updates) and sparing users cumbersome cross-references. Moreover, at the member states level,
a single and coherent framework regulation will facilitate use of the same tools for different
purposes and limit consequently data collections and burden. Similarly, it will facilitate the use of
administrative or innovative sources as the discussions with data owners will focus on the same
concepts and finding the best source for them instead of having to repeat the same exercise with
different concepts, building on different sources and delaying the decrease of the burden on
businesses by using other / new sources.
b) Fostering the use of alternative administrative sources and modern digital techniques,
including automatically transferring payroll data and web scrapping, which will play a role in
mitigating the burden on enterprises in general and SMEs in particular. This may be achieved by
extracting data on earnings and labour costs from payrolls and job advertisements from the internet.
It is expected that new administrative or innovative data collections will also help covering
emerging needs.
c) Limiting collection of variables on apprentices in the LCS only from those countries where
they represent a sizeable share (more than 1%) of all employees;
47
The legislation will empower the Commission to adapt statistical requirements with implementing
or delegated acts. Secondary legislation will cover technical details related to periodicities,
reference periods, description of variables, modalities, statistical classifications and data
breakdowns, precision targets, the metadata to be transmitted as well as on the content and the
deadlines for transmission of the quality reports. These instruments are expected to be used for
covering also future emerging needs.
Option 3 also entails the above simplifications but would extend the SES data collection to micro-
enterprises for all variables. This is not the case for option 2 that limits this future data collection on
micro-enterprises to a core set of key variables, most of which are available from administrative
sources therefore simplifying as much as possible the extension of scope.
By contrast, option 1 may not lead to simplification and efficiency gains if different choices are
made across LMB datasets, a clear risk due to the non-harmonised and uncoordinated nature of this
option.
For the above reasons, only options 2 and 3 would pass the REFIT test as they would both improve
the efficiency of evidence-based policymaking, including through enhanced possibilities for
comparative research across member states. Nevertheless, option 2 would come first (++ against +
for option 3) as it refrains from increasing the frequency of labour cost and structure of earnings
surveys, thus bringing lower costs and larger efficiency gains.
At the same time, the additional measures added under the options, in particular options 2 and 3,
can also require a slight additional need for follow-up, reporting (more frequent and timely data
collection) and enforcement. Nevertheless, it is expected that some cost saving could be made by
reducing the current administrative burdens borne by both the Commission (Eurostat) and NSIs.
The table below sets out a qualitative analysis of the possible simplifications brought about by this
initiative. The stakeholder group benefiting from these savings is specified in the final column of
the table.
REFIT Simplification and improved efficiency
Option Description Impacts by
group
1 Improved efficiency in evidence-based policymaking,
alignments of concepts and definitions
MS, COM
2 As for 1, with the addition of:
Marginally reduced costs associated with new templates for
quality reporting, possibility of using innovative data sources.
Improved efficiency of comparative research
Eurostat,
enterprises
Data users
3 As for 2, with the addition of:
Further improvements in the efficiency of evidence-based
policymaking (Due to higher frequency for LCS and SES and
new variables on wage determinants)
Even further improvement of efficiency in comparative
research (same reasons)
COM, MS
Data users
48
8.3. Application of the ‘one in, one out’ approach
No burdens on citizens will be caused by the initiative as it concern statistical collections on
businesses.
For businesses as explained in the SME test, only a small subset of businesses are required to
produce the datasets under LMB (sample surveys, i.e. only the very limited number of businesses
selected in the sample), even under options 2 and 3.
While the specific information demands are higher for option 3, the total burden on enterprises
remains negligible for option 1 and 2, higher for option 3.
8.4. SME test
SMEs represent around 85% of new jobs in Europe and are hugely important to the EU economy.
The four steps of the SME Test are set out below, explaining the assessment carried out and
estimated impacts on SMEs of the policy option 2.
8.4.1. SME Test: four steps
Step IA approach taken, outputs and
mitigation
Estimated outcome/results
Identification
of affected
businesses
The initiative is proposing to extend the
scope of the four-yearly structure of
earnings survey (SES) to a subsample
of microenterprises. Those are the
Small and Medium Sized Enterprises
with less than ten employees.
Enterprises employing 10 persons or
more are already in the SES sample.
This extension does not concern
Bulgaria, Czechia, Germany, Estonia,
Ireland, Spain, Cyprus, Latvia,
Lithuania, Netherlands, Slovenia, and
Slovakia that already provide data for
firms employing one to 9 persons.
Hungary and Finland cover firms with
more than 5 employees.
In the preferred option, the SES would
still take place with a four-yearly
frequency.
Only the sampled microenterprises will
be affected. For countries collecting
SES data on enterprises with 1 to 9
employees, the number of enterprises
in this category in the sample represent
1.5% of the whole population of
SMEs.
If all countries had to start transmitting
data for the enterprises with 1 to 9
employees the EU sample would need
to be extended by the same rate.
However, if we account for the fact
that 10 countries already cover micro-
firms (+ 2 partly), which represent
together 32% of the EU population of
SMEs, the increase would be 1%
(1.5% × 68%), every four years.
Moreover, in most cases, the micro-
firms concerned by the extension of the
SES scope would not have any
response burden as only core SES
variables will be requested, which are
normally available from administrative
registers.
49
Consultation
of SME
stakeholders
To ensure that the direct views of SMEs
are captured and information is collected
on the cost and burden on SMEs,
particularly micro-enterprises for the
different policy options, the consultant
(ICF) has tried to collect information
from different sources:
SME Europe was contacted and the
organisation circulated request for data
collection among their members
Local network contact points of
Enterprise Europe were contacted in the
following Member States: BE, BG, HR,
IT, ES, NL, RO, FR, DE, SK, LV
The ICF used a sample from the Orbis
database to reach out to ten micro-
enterprises from: CZ, EL, ES, IT, PL,
SK
In addition during workshops two
organisations expressed interest to help
facilitate data collection from micro-
enterprises: Confederation of Danish
Employer and the Austrian Federal
Economic Chamber.
The Confederation of Danish Employer
liaised with its members and provided
four contact details to SMEs from which
one organisation responded to
questionnaire. All other sources resulted
in no responses from SMEs.
The study team received one reply from
a representative industry association, but
they declined carrying out an
assessment.
Following no replies from the direct
consultation of the SME, information
coming from the NSIs is used for
assess the impact of the proposal on
the SMEs.
Measurement
of the impact
on SMEs
Information on the burden on enterprises
was also assessed by the NSIs in the cost
and burden study.
This showed that the effects are limited
due to the low number of businesses
selected in the sample and the
simplification of the questionnaire
addressed to micro-enterprises. In
particular, only core variables will be
collected most of which are available
from administrative registers.
The results of the study done with the
NSIs showed that the initiative will
cause a median increase in the time
spent by all responding units
(enterprises with one and more
employees) of around 16%, every
four years.
Considering that SMEs represent 86%
of the SES sample, on average, this
means that the total time spent by all
responding SMEs will increase by
50
16% × 86% = 14 %.
This does not account for the fact that
10 Member States already provide
SES data for micro-enterprises and 2
(Hungary and Finland) do it partly.
Altogether, these countries account
for almost one third (32%) of the SES
sample of SMEs, EU wide.
With an average sampling rate of
2.5% for SMEs, we estimate that the
burden increase for SMEs caused
by the extension of SES to micro-
firms amounts to 0.24% (2.5% ×
14% × 68%) of the current average
burden, for the whole population of
SMEs, every four years.
Assessment
of alternative
mechanisms
and
mitigating
measures
The SES questionnaire for
microenterprises will be limited to the
main information (core variables) most
of which are already available from
administrative sources.
Another simplification proposed under
the LMB review consists in limiting the
collection of labour cost survey data on
apprentices to countries where they
represent less than 1% of the total
number of employees. This would
simplify the LCS questionnaire where
6 out of 22 variables (excluding the
derived totals) would become
voluntary, for all EU Member States
except Germany, Denmark, France,
Italy and Austria.
Following the subsidiarity principle,
countries are free to use data collection
method chosen nationally and being the
most effective in terms of costs and
burden. In addition, the extension of
the population could also take place by
reallocation of the total SES sample.
That means, given the precision of
information collected is of the same
quality, NSIs will be free to decrease
the number of SMEs employing 10 and
more persons to compensate the
extension to micro enterprises.
Thanks to the simplification of the
LCS data collection on apprentices,
the total time spent by the sampled
SMEs in filling LCS questionnaires
will be reduced by 27% (6/22) for all
EU Member States except Germany,
Denmark, France, Italy and Austria.
The latter countries represented 34%
of the population of EU SMEs, in the
LCS 2016 sample.
Estimating the LCS burden from the
number of variables collected, we
conclude that the LCS simplification
would reduce the burden by 18%
(27% × 66%), every four years for the
sampled enterprises.
Taking 4% as a lower bound for the
LCS sampling rate, the burden
reduction for the whole population of
SMEs would be at least 0.7% (18% ×
4%), every four years.
This compares with the burden
increase on SMEs caused by the SES
extension to micro-firms (+0.24%).
Under the favoured option (option 2),
the LMB review would therefore have
no net impact on the burden for
SMEs.
The additional decreases in the SME
51
burden obtained through a
reallocation of the sample (between
SMEs and larger firms) was
impossible to estimate due to different
sampling schemes and various data
collection methods used in the
countries, according to the
subsidiarity principle.
9. HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED?
Monitoring and evaluation form an integral part of the policy cycle and must be undertaken through
the implementation, application and review stages of the LMB initiative. The performance of the
new LMB framework should be monitored and evaluated in relation to its operational objectives
(shown in the table below). The next sections briefly describe the main considerations for
monitoring and evaluation at each stage of the policy cycle.
Implementation stage
The choice of approach remains open, whether largely voluntary data collection under the LMB
framework or different forms of mandatory changes to the LMB framework.
During the implementation phase of the new legal framework, the Commission (Eurostat) will
continue organising regular expert group meetings with partner NSIs in the ESS to discuss and
clarify any issues that may arise, continuing a long-standing history of good and close cooperation
between Eurostat and its ESS partners on technical and statistical matters. This includes diligent
joint preparation of key implementing acts regulating the detailed new statistical data and metadata
requirement, which will be of central interest to both statistics users and producers. For instance,
Eurostat can establish topical task forces to address specific technical challenges in achieving the
objectives of the new legislation. The implementation stage is planned to conclude with a first
evaluation focussing on the implementation, functioning and initial impacts of the new legal
framework. To obtain sufficient information on the performance, this evaluation is planned within
three to five years after the entry into force of the new legal framework, in line with better
regulation advice that evaluations should have access to at least three full years of data.
A monitoring and evaluation clause is normally included in any new, or amended, legislative act to
facilitate the collection of the necessary information.
Application stage
During the application stage, the Commission (Eurostat) plans to undertake an evaluation of the
functioning and impact of the legislation every three to five years. The following table provides
some suggestions on potential indicators for monitoring the effectiveness of the LMB initiative
against its objectives. It also indicates some of the data sources that might be used.
It will be important to ensure that the indicators can be measured through methods and sources that
are easily available and credible. Eurostat’s user satisfaction survey and more targeted surveys (e.g.
52
among NSIs) could be relevant sources of evidence. Quality reports, annual compliance assessment
exercises are also important tools for this purpose in the European Statistical System.
53
9.1.1. Possible key performance indicators, targets and data sources for operational objectives
Specific
objective
Operational
objectives
Monitoring indicators Current
benchmarks
Data sources Targets
1. Adapting
the regulatory
framework to
allow
flexibility in
meeting
emerging
needs, to
release more
timely
statistics and
to promote the
use of
innovative
sources and
methods of
duly assessed
quality
1.1. LMB addresses
emerging needs
(depending on the
option)
MI 1.1.1 Number of Member States providing
new voluntary/mandatory variables in SES
N/A Data received via Edamis All MS
MI 1.1.2 Number of Member States providing
new voluntary/mandatory breakdowns in JVS
7 Data received via Edamis All MS
MI 1.1.3 Number of Member States providing
new voluntary/mandatory variables in LCI
N/A Data received via Edamis All MS
1.2. Datasets are
provided in a timely
and frequent manner
MI 1.2.1 Number of Member States providing
SES data) in T+16 months / T+11 months
1 Data received via Edamis
Eurostat annual compliance
assessment
All MS
MI 1.2.2 Number of Member States providing
LCS data in T+15 months
N/A Data received via Edamis
Eurostat annual compliance
assessment
All MS
MI 1.2.3 Number of Member States providing
LCI at T+45 days for large ‘flash’ countries (no
NACE breakdown)
8 (pilot
data)
Data received via Edamis
Eurostat annual compliance
assessment
9 MS
MI 1.2.4 Number of Member States complying
with the increased frequency of SES (bi-annual)
between the (bi-annual) LCS years
N/A Data received via Edamis
Eurostat annual compliance
assessment
All MS
MI 1.2.5 Number of Member States complying
with the increased frequency of LCS (bi-annual)
between the (bi-annual) SES years
N/A Data received via Edamis
Eurostat annual compliance
assessment
All MS
54
1.3. The legal
framework is
sufficiently flexible to
adapt as users’ needs
evolve
MI 1.3.1. Proportion of users who agree that,
overall, Eurostat’s LMB data meet their needs
(broken down by type of user, e.g. policymaker,
academic, media, commercial)
65 % (value
for all users
coming
from the
PC)
Eurostat User Satisfaction
Survey,
Targeted surveys with
representatives from Eurostat
and Commission statistical
correspondents
80 %
MI 1.3.2. Extent to which Eurostat and
Commission officials agree that it is possible to
adjust the legal framework to meet users’ evolving
needs
N/A Targeted surveys with
representatives from Eurostat
and Commission statistical
correspondents
80 % of
satisfied
policy users
1.4. Quality reports
are provided and
administrative and
innovative data
sources are
documented
MI 1.4.1 Number of Member States providing
information about the use of administrative and
innovative data sources
N/A Quality reports received in
the metadata handler
All MS
2. Improving
the coverage
of statistics to
the whole
economy and
ensure
exhaustive
GPG data
2.1. GPG data made
compulsory
MI 2.1.1 Number of MS providing annual GPG
data
25 Data received via Edamis All MS
2.2. SES coverage
extended to micro
enterprises and NACE
Rev. 2 section O
MI 2.2.1 Number of MS providing SES data for
microenterprises
12 Data received via Edamis All MS
MI 2.2.2 Number of MS providing SES data for
NACE Rev. 2 section O
24 Data received via Edamis All MS
MI 2.2.3 Information on earnings for all economy
published for EU/EA aggregates
N/A Eurobase All tables
provide
aggregates
for EU and
EA
55
2.3. LCS coverage
extended to micro
enterprises and NACE
Rev. 2 section O
MI 2.3.1 Number of MS providing LCS data for
microenterprises
11 Data received via Edamis All MS
MI 2.3.2 Number of MS providing LCS data for
NACE Rev. 2 section O
22 Data received via Edamis All MS
2.4. JVS coverage
extended to micro
enterprises and NACE
sections B to S
MI 2.4.1 Number of MS providing JVS data for
microenterprises
26 Data received via Edamis All MS
MI 2.4.2 Number of MS providing JVS data
covering NACE sections B to S
24 Data received via Edamis All MS
3. Improving
the
consistency
with related
statistical
domains
3.1. Concepts are
further aligned and
definitions match
relevant domains
MI 3.1.1 Extent to which concepts and definitions
are applied in practice
N/A Quality reports All MS
MI 3.1.2 Users’ views on the consistency of
concepts and definitions across datasets
31 % (value
for all
stakeholders
coming
from the
PC)
Targeted surveys with
representatives from Eurostat
and Commission statistical
correspondents.
70 %
56
ANNEX 1: PROCEDURAL INFORMATION
1. LEAD DG, DECIDE PLANNING/CWP REFERENCES
Lead DG Eurostat
Decide
Planning
PLAN/2021/1202430
CWP reference
2. ORGANISATION AND TIMING
After political validation of the LMB initiative in November 2021, an interservices steering group
(ISG) chaired by Eurostat and composed of representatives of Commission DGs31
was set up to
supervise the progress on the combined evaluation and impact assessment including stakeholder
consultations. The ISG met 5 times to discuss this evaluation SWD:
Meeting date Topics discussed
11/11/2021 Background information on LMB statistics and need for review
Call for evidence
Draft consultation strategy
Draft terms of reference of a tender for a study supporting the
evaluation and impact assessment
Draft Public Consultation (PC) questionnaire (launch of written
consultation)
28/04/2022 Presentation of the progress on PC
Presentation of the work plan and consultant
Intervention logic
Draft evaluation matrix
13/07/2022 Presentation of the results of the public consultation
Presentation of the interim report from the consultant
Proposed measures for the impact assessment
21/10/2022 Presentation of the draft SWD on consultation synopsis
30
https://intragate.ec.europa.eu/decide/sep/?view-dossier-details-id=DORSALE-DOSSIER-2021-24018
31
ECFIN, EMPL, JUST, JRC, RTD, SG and SJ
57
Presentation of the draft SWD on evaluation for
comments/endorsement
Problem definitions and drivers for the assessment
2/12/2022 Presentation of the main changes in the draft SWD on evaluation for
approval
Presentation of the draft SWD on impact assessment for comments
and forthcoming endorsement
13/03/2023 Revised draft SWD on impact assessment for endorsement of changes
addressing the RSB opinion
3. CONSULTATION OF THE RSB
The RSB was consulted on this impact assessment on 18 January 2023.
The Board findings and recommendations were addressed in the impact assessment report as
follows (text in italics):
Summary of findings
The Board notes the additional information provided and commitments to make changes to the draft
report.
However, the report still contains significant shortcomings. The Board gives a positive opinion with
reservations because it expects the DG to rectify the following aspects:
(1) The report does not clearly analyse the scale of the problem as well as its consequences for
policy making. It does not adequately explain the rationale for intervention.
(2) The report does not sufficiently address the simplification potential of the preferred policy
option. 2
What to improve
(1) The report should clarify the size of the problem. It should better explain the rationale for
intervention, given that the evidence shows that most of the contacted stakeholders in the public
consultation seem to be satisfied with the current situation. It should bring out more clearly any
public interest case for new and more frequent data for EU policy areas.
Specific section discussing on size of the problem (section 2.3) was added to the report.
The rationale for intervention was reinforced by refocusing the narrative from the analysis
of satisfaction with the current LMB statistics to reflection of users related to the possible
improvements. This is described mainly in the analysis of the problems drivers (section 2.2).
(2) The simplification potential of the preferred policy option should be better explained and
elaborated. The report should explain how the replacement of the three existing Regulations with
58
a single framework will foster simplification. It should identify and analyse any additional
simplification aspects such as reducing the data requirements to the strict minimum and using data
sources other than surveys.
Advantages of using a single legal act on LMB are discussed in sections 5.3 (in relation to
the discarded option) and section 8.2 related to simplifications. Further simplifications are
also described there. Details on using alternative data sources are provided in analysis of
driver D2 in section 2.2 on problem drivers.
(3) The report should discuss potential problems with compliance and enforcement, where relevant.
It should provide further information on the possible implementing or delegated acts of key
importance for the impact or the success of the initiative.
Potential obstacles that might be encountered for an effective implementation are discussed
in section 7 on comparison of the options.
Framing of options 2 and 3 in the secondary legislation is described in section 5.2 on
description of policy options.
(4) The report should better explain the scale of provision of statistics on a voluntary basis by
Member States and its consequences. In addition, it should provide further detail on how the sub-
objectives on quality reporting, the use of administrative data and innovative sources by Member
States and the response to emergent needs will be achieved.
The situation related to provision of data on voluntary basis is described in the description
of current issues with LMB statistics. Biases in the data have been illustrated as some
countries provide the data covering full economy voluntarily. More information about
countries providing the data voluntarily was added in the analysis of the problem driver D4.
The consequences and compilers opinion on voluntary character of GPG collection are
described in the analysis of problem driver D5.
Use of administrative data and innovative sources as well as related quality reporting are
described in the analysis of problem driver D2.
(5) The report should improve the presentation of stakeholder views. The consultation activities
findings should be provided with the necessary granularity and should not be presented as
aggregate percentages. The report should clarify to which consultation activities the results are
referring to. The reader should also be able to understand what stakeholder category expressed a
certain concern or opinion and to what extent this evidence is significant and robust.
Relevant graphical presentation and comments on stakeholder consultation was changed
across the document, to cover more granular information on type of stakeholder and to add
absolute figures.
(6) The report should better explain the problems with the evidence-base and data availability, its
methodological choices as well as the limitations and the uncertainties of the consultation activities.
It should explain how limited use of the public consultation results to assess possible impacts, in
particular on respondents to the LMB statistics (enterprises), has been mitigated.
59
Issues related to data availability and mitigation of problems related to low coverage of
enterprises in the results of consultation are further complemented in section 4 (Evidence,
sources and quality) of Annex 1 on procedural information.
The Board notes the estimated costs and benefits of the preferred option in this initiative, as
summarised in the attached quantification tables.
Some more technical comments have been sent directly to the author DG.
In order to limit the number of pages in the main text of impact assessment, the section on
policy relevance of the LMB data was shortened; the detailed scoring of the policy options
was moved to the Section 2 of the Annex 3. Scoring and narrative in the assessment of
options were aligned.
4. EVIDENCE, SOURCES AND QUALITY
Evidence Sources
Desk research  Statistical data and metadata published during the evaluation period,
and partially before as available (baseline)
 Legal acts related to the intervention
 Commission reports on implementation of legislation
 Methodological guidelines and papers
 Policy documents establishing statistical needs
The fact that the existing legal framework evaluated here was
adopted before Better Regulation guidelines were in place presented
a major obstacle, as the available documentation does not provide
information typically required for evaluation. The stakeholder
consultations attempted to balance resulting gaps to the extent
possible.
Opinion of
statistics users:
Commission
services
 In-depth interviews with selected organisational statistics users
 Bilateral exchanges to pinpoint specific needs
 PC survey
 Interviews
Opinion of
other statistics
users
 In-depth interviews with selected organisational statistics users
 PC survey
 Workshop
Opinion of
statistics
producers
 Regular consultations of Labour Market Statistics/LMB
 Directors of Social Statistics and The European Statistical System
Committee was also informed about the progress
 PC survey
The LMB statistics are specific as for the type of information they provide and users they target,
meaning a highly specialised domain with relatively scarce sources for evaluation. The
60
stakeholders’ consultation (public consultation and targeted interviews as well as workshop with
data users validating the policy options) was therefore extensively used to complement the first
findings of the evaluation. To ensure the highest coverage of most important stakeholders, the
public consultation was advertised through correspondence with most important data user
(Including European Statistical Advisory Committee, Directors of Social Statistics, Business
Statistics Directors Group, Labour Market Statistics Working Group, EUROFOUND, EIGE, ECB,
DG EMPL CIVIC DIALOGUE, Employment Committee Indicators Group (EMCO IG) and
Indicators' Sub-Group of the Social Protection Committee (ISG SPC) of the Council, SME Envoy
Network, LMB data collection correspondents, SES microdata users, European Economic and
Social Committee labour market observatory, Business Europe, SMEunited, ETUC (European
Trade Union Confederation), Platform of European Social NGOs and international organisations
such as ILO, OECD and UNECE). In addition, different social media channels were used to catch
general public. Unfortunately, very few replies from the general public were received. However,
while not constituting a real survey outcome in the statistical sense (small number of replies, no
probabilistic selection of the sample or respondents), the public consultation confirmed the needs
accumulated over the years (for instance during the regular hearings between Eurostat and the
Commission policy DGs). They were complemented by the targeted interviews and technical level
correspondence between Eurostat and for instance the ECB. In addition, a careful analysis of
Commission reports to the European Parliament and the Council on implementation of the labour
costs index and job vacancy statistics, allowed to observe the developments in the implementation
and compliance improvements of those data collections (evaluation SWD section 3.1). For its part,
the systematic review of the quality reports that is a daily work in Eurostat allowed identification of
main issues with the data. This way the information existing and/or collected in the consultation
exercise together with the desk research analysing the legal LMB was triangulated to best evaluate
the current initiative.
The limited use of the public consultation results to assess possible impacts in particular on
respondents to the LMB statistics (enterprises) was planned to be mitigated by ensuring that the
direct views of SMEs are captured and information is collected on the cost and burden on SMEs,
particularly micro-enterprises for the different policy options. The consultant (ICF) made effort of
contacting SME Europe to circulate a request for data collection among their members. Local
network contact points of Enterprise Europe were also contacted in the following Member States:
BE, BG, HR, IT, ES, NL, RO, FR, DE, SK, LV. In addition, the ICF used a sample from the Orbis
database to reach out to ten micro-enterprises from: CZ, EL, ES, IT, PL, SK. Moreover, during the
workshop two organisations expressed interest to help facilitate data collection from micro-
enterprises: the Confederation of Danish Employer and the Austrian Federal Economic Chamber.
The Confederation of Danish Employer liaised with its members and provided four contact details
to SMEs from which one enterprise responded to questionnaire. All other sources resulted in no
responses from SMEs. This situation was further mitigated by assessing the burden of possible
options on businesses via assessments of national statistical institutes. Indeed, they provided, in
specific on-line consultation and costs assessment consultation, qualitative (on the descriptive
levels of burden) and quantitative (on the time estimated to provide additional information as
foreseen in the options) information related to the response burden.
Moreover, at the workshop that gathered main LMB data users (institutional policy users, trade
unions, business associations and international organisations) draft findings of the impact
assessment and results regarding the problem definition, feasibility, effectiveness, efficiency, and
61
wider impacts of the policy options were validated. In particular, the trade unions representative at
the workshop highlighted the importance of structure of earnings survey data on collective pay
agreements (which is also a data requirement under the minimum wage directive).
USE OF EXTERNAL EXPERTISE
Eurostat carried out this evaluation with topical support from a contractor study contributed by ICF
SA, Belgium. In particular, the evaluation and the impact analysis, as well as public consultation
analysis, organisation and analysis of stakeholders consultations activities (excluding public
consultation prepared by Eurostat), were provided through the support study. Parts of this
evaluation SWD are therefore based on the final report on evaluation support and other analysis
documents prepared by the contractor.
Eurostat has also monitored the work of the external support contractor regularly (at least every two
weeks) and assessed the quality of the final report on evaluation from the external support study.
The overall work quality and deliverables were found to be in line with the contract and generally
sufficient to be used for this impact assessment.
62
ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT)
1. CONSULTATION STRATEGY
In line with the European Commission’s Better Regulation guidelines, the consultation strategy
aimed to gather input on whether population statistics continue to provide the necessary evidence
base for EU policies and other relevant use cases; if there are new and emerging data needs and
potential obsolete data requirements; the cost and burden of statistics, as well as the potential to
improve the efficiency and for regulatory simplification. This represented both backward looking
elements (explore what works well and what works less well in the current legal base) and
forward-looking elements (the impacts of improvement options on all relevant stakeholder
groups) to meet the needs of the back-to-back evaluation and impact assessment.
There were three main stakeholders groups. Data providers represented administrative data
providers that are public administrations providing source data to statistical authorities for
producing European statistics, and respondents (enterprise level data providers)who are
participating directly in the data collection (sample surveys). Statistics producers were the
national statistical institutes (NSIs) and other national authorities collecting, treating and
transmitting to Eurostat statistics on earnings, labour costs structure, job vacancies and gender pay
gap. Statistics users were a diverse group. They included institutional users that are directly
involved in EU policymaking. At EU level, they were the actual policy makers, and at international
and national levels, they support policymaking and contribute to it. Institutional users include EU
bodies, international organisations, national ministries and government research institutes.
Furthermore, there were other professional users who contribute occasionally and indirectly to the
policymaking process at EU level. These were universities, research institutes, professional
organisations, advisory councils, NGOs, individual private companies and business associations.
The media and the general public were also part of the users’ group.
The strategy envisaged the use of different consultation activities per stakeholder as shown in Table
1.Table 1 Consultation activities per user group
Stakeholder Group/Activity Public consultation
Expert
consultations
Interviews
Institutional data providers X
Individual data providers X X
Data producers X X32
X
Institutional users X X33
Other professional users X X
Media X X
General public X
32
Working Group on labour market statistics (LAMAS WG).
33
ECB; Commission DGs: ECFIN, EMPL, GROW, JUST, REGIO, agencies: EIGE, EUROFOUND
63
In addition, a specific cost and burden survey related to assessment of current and possibly future
costs and burden of data collections that are in the scope of the LMB (and GPG collected
voluntarily) took place in the framework of the technical discussions with data producers (National
Statistical Authorities). This survey was launched on the 17 December 2020 to LAMAS delegates
who were invited to fill the questionnaire and send it back to Eurostat by 30 April 2021. Apart from
the assessment of cost, information on time spent annually per respondent in minutes and of time
spent annually by all respondents for each LMB domain was collected. The exercise was tentatively
concluded before launching of the evaluation and impact assessment procedure (LAMAS WG on
19-20.10.2021) as further on, in July – August 2022 the countries were consulted to provide
additional (qualitative information) on the policy options and needs that emerged from the
evaluation study.
2. METHODOLOGY AND TOOLS USED TO PROCESS THE RESULTS
A mixed-methods approach was chosen for the consultation and included the following activities:
public and targeted consultations, targeted workshop, interviews with key stakeholders as well as
desk research.
Public consultation, targeted consultation with national statistics institutes took place through
online tools, including EUSurvey questionnaires. Workshop and interviews took place as virtual
meetings due to health considerations and specific working arrangements related to the COVID-19
pandemic.
The call for evidence and the public consultation34
were run via the Have Your Say website of the
European Commission35
. No feedback was received by the Commission (Eurostat) on the call for
evidence. The public consultation was available in all official EU languages. These consultations
aimed at gathering information and feedback from the general public and all relevant stakeholder
groups as input into the evaluation and impact assessment as a step towards the preparation of
a legislative proposal.
The public consultation was promoted via different channels: Have Your Say, Eurostat website
a dedicated news item on 23 February 2022, social media campaign and Eurostat email banners,
emails to stakeholders as well as nationally by several NSIs. Public Consultation (PC) questionnaire
had a section assessing the LMB statistics in general and specific sections on each data collection
that are a part of the LMB. The latter covered questions on satisfaction and attitude towards
possible improvements or simplifications.
As NSI have been consulted by Eurostat several times throughout the review process it was agreed
that their contributions would be most beneficial in an online survey format instead of semi-
structure interviews. The questionnaire sent for the purpose of the targeted consultation with NSIs
asked for more detailed opinions of statistics producers. The survey contained qualitative questions
on costs and burden related to introduction of possible improvements per data collection. In
34
See the Factual summary report on the public consultation of LMB: https://ec.europa.eu/info/law/better-
regulation/have-your-say/initiatives/13266-European-labour-market-statistics-on-businesses-LMB-/public-
consultation_en
35
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13266-European-labour-market-statistics-on-
businesses-LMB-_en
64
addition, open questions on anticipated difficulties other than those related to cost or burden and
identification of elements that were listed as potential improvement but are not needed in the
opinion of the NSI.
Interviews were run, first for scoping purposes then in-depth. They had a semi-structured format
and were addressing LMB users. No interviews with the NSIs were conducted due to the time
contains. The most important element of them were integrated into the targeted on-line
questionnaire.
One workshop was scheduled to present the draft findings of the impact assessment and to validate
the results regarding the problem definition, feasibility, effectiveness, efficiency, and wider impacts
of the policy options. Participants were given the opportunity to discuss their views and provide
feedback on the research findings.
Consultation with SMEs was foreseen by the study accompanying supporting the impact
assessment work to test directly the burden of the new proposals. Although several attempts were
made to receive the information no replies were provided directly by the SMEs. Instead,
information provided by the statistical institutes was used as a proxy assess the burden.
The responses to all consultation activities were carefully analysed. To analyse the public
consultation results, all replies were first mapped onto the key stakeholder groups and then assessed
by each group. Where relevant, the synopsis report presents the diverging views of various groups
of stakeholders on the same issue.
3. STAKEHOLDER PARTICIPATION
The consultation activities mentioned above were implemented by Eurostat and/or the contractor
supporting Eurostat during the evaluation and impact assessment - ICF S.A., Belgium. Table 2
presents the timeline of key consultation actions.
Table 2 Timeline of key consultation actions
In terms of level of participation, no replies were received during the 4-weeks consultation on call
for evidence while the public consultation resulted in 79 replies from 21 Member States,
Montenegro, and the United Kingdom. Most responses were received from Italy, followed by
Latvia, Sweden and Belgium. Almost half of the respondent (46 %) represented public authorities,
followed by academic and research institutions (19 %). Trade unions and companies represented
each 4 % of the respondents. In terms of size, the majority of respondents came from large
organisations with 250 or more employees (71 %), while only 6 % of respondents represented
micro and small organisations.
Consultation action Timeline
Call for evidence 03 December 2021 - 31 December 2021
Public consultation 09 February 2022 - 13 May 2022
Targeted interviews April- September 2022
Targeted consultation with NSIs 22 July - 26 August 2022
Workshop 14 September 2022
65
In total 63 stakeholders were invited for interviews. Out of this number, 28 interviews were carried
out with data users representing institutional policy users, trade unions, business associations,
research organisations and international organisations.
A total of 27 responses were received during the on-line consultation with the NSI´s from the
following countries: Austria, Belgium, Bulgaria, Czechia, Cyprus, Denmark, Finland, France,
Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta,
Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, and Switzerland.
Contributions were high quality and adequate and were used to feed into the impact assessment.
The workshop was attended by 9 participants.
No response from the media were received during the consultation. This was not considered to be
problematic as the LMB statistics does not normally attract much of the media attention.
The consultation ensured appropriate stakeholder coverage for statistics producers and several
types of statistics users. All NSIs of EU Member States and EFTA countries in charge of compiling
LMB statistics and transmitting it to Eurostat were involved in the various consultation activities.
Limited feedback was obtained from administrative data providers (three replies to the public
consultation).
To ensure that the views of SMEs are capture and information is collected on the cost and burden
on SMEs, particularly micro-enterprises for the different policy options, the study team has tried to
collect information from different sources:
 SME Europe was contacted and the organisation circulated request for data collection
among their members
 Local network contact points of Enterprise Europe were contacted in the following Member
States: BE, BG, HR, IT, ES, NL, RO, FR, DE, SK, LV
 The study team used a sample from the Orbis database to reach out to ten micro-enterprises
from: CZ, EL, ES, IT, PL, SK
In addition during the workshop two organisations expressed interest to help facilitate data
collection from micro-enterprises: Confederation of Danish Employer and the Austrian Federal
Economic Chamber.
The Confederation of Danish Employer liaised with its members and provided four contact details
to SMEs from which one organisation responded the questionnaire. All other sources resulted in no
responses from SMEs.
Furthermore, LMB review was presented and discussed with Commission informal expert groups.
These were mostly meetings of Eurostat-led expert groups with the participation of Member State
experts, namely a LAMAS Working Group, the Directors of Social Statistics as well as the
European Statistical System Committee (2 meetings in total).
66
4. MAIN RESULTS FROM THE STAKEHOLDER CONSULTATION
4.1. General feedback on current statistics
Results of the public consultation show that overall stakeholders are satisfied with the quality of
European labour market statistics on businesses. The main quality elements that were highly rated
by stakeholders include:
 Overall high quality
 Relevance
 Sufficiently reliable and accurate
 Contribute to the public good and
 Are impartial and objective.
Results of the semi-structured interviews confirm the findings of the public consultation and
showed an overall positive outlook on the quality of LMB statistics while some areas for
improvement were identified.
4.2. Areas for improvements
The elements of LMB that were found important to be further improved in the public consultation
were:
 extending the coverage of the survey to micro firms and for NACE Rev. 2 section O for the
SES, LCS and for the missing countries in the JVS;
 improving timeliness of the SES and LCS as well as LCI, in particular for the EU and euro
area for the latter;
Collecting and publishing the numerator (labour costs) and the denominator (index of hours
worked) of the LCI ratio for several NACE aggregates or quarterly data on the ‘total number of
hours worked’ was found as needed by stakeholders.
Moreover, the consultation results showed that increasing the frequency to every 2 years for the
SES was supported by 55 % of data users but only 39 % of producers of LMB statistics. The
increase of frequency of the LCS was supported by 45 % of data users compared to 23 %
producers.
During interviews, the users manifested a growing interest in new topics such as the impact of
economic crises on the labour market, the inflation factor from the labour costs, mismatches of
skills of the work force, types of pay schedules and possible discrimination in the labour market.
One of the most pressing problems highlighted by data users was in relation to data on gender pay
gap, which is currently provided by Member States only on voluntary basis. For users this means
that evidence is not comprehensive and suitable for cross-country comparison. In this regard,
stakeholders offered detailed examples. Data users expressed also their need for detail on certain
datasets including adding work history to study gender pay gap, data and availability of information
by NUTS regions. Furthermore, with regards to the need of additional breakdown and variables,
67
stakeholders expressed the need for additional detail, including more detailed level of
disaggregation of information on occupation in the SES, adding work history to study GPG, (and
data by NUTS region), which is not currently included in the SES. Moreover, further information
on e.g. net earnings and annual earnings in kind would be appreciated by some GPG users as a way
to analyse other aspects of gender segregation and/or discrimination in pay.
Stakeholders shared the view that it would be beneficial to include more innovative data collection
method as it has the potential to decrease burden on data providers. The ESS is also working on
new techniques such as web scraping. However, some stakeholders noted that one should ensure
that data from innovative sources are of high quality and comparable with other data sources.
4.3. Qualitative assessment of areas needing improvements.
The quantitative evaluation of costs and burden related to the improvements took place at the
technical level prior the start of evaluation and impact assessment of the LMB review. Following
problem definition of the LMB and identification of preliminary policy options, the NSI´s where
addressed with the targeted consultation to assess the possible improvements. This assessment
covered qualitative questions on improvements related to coverage, frequency and timeliness of the
particular data collections constituting the LMB statistics and monetary and qualitative assessment
addressing some punctual needs related to for instance missing variables in one data collection
(SES).
Coverage of the LMB
Extending the coverage of the SES to micro firms (1-9 employees) for main information would
cause significant increase in costs for 53% of the NSI´s (for 15% it will be one off cost for 38%
regular every time the survey takes place). For 46% of NSI´s the increase will be no significant or
zero. Extending the coverage of the SES to micro firms (1-9 employees) for whole set of variables
would cause significant increase in costs for 62% of the NSI´s (for 4% it will be one off cost for
58% regular every time the survey takes place). For 38% of NSI´s the increase will be no
significant or zero.
Extending the coverage of the LCS to micro firms (1-9 employees) would cause significant increase
in costs regular every time the survey takes place for 62% of NSI´s. No increase or insignificant
would be according to 38% of NSI´s.
Naturally, the extension of the coverage for JVS (both for the micro enterprises and for the NACE
Rev. 2 section O) will affect only the 3 countries that do not do it yet.
For costs relating to extending the coverage to NACE Rev. 2 section O, over half of respondents
(69%) noted no increase in costs for SES datasets. 19% noted an increase compared to the baseline
every time the survey takes place. The remaining 12% noted costs when starting-up. For LCS, most
respondents (81%) indicated no increases in cost. 15% of respondents indicated significant cost
every time the survey takes place and the remaining 4% indicated a significant increase when
starting up.
68
Frequency and timeliness
Transmitting all LCI results earlier, 65 days instead of 70 days after the end of the reference quarter
would, according to NSI, not lead to significant increases in cost compared to the baseline (64%).
Likewise, improving timeliness of the SES by two months is not likely to result in increases in cost
compared to the baseline (58% of NSI´s).
Costs associated with collecting SES data every two years instead of every four years may be high
as a large majority of respondents (84%) noted a significant increase compared to the baseline in
cost every time the survey takes place. The remaining 16% noted no increase in costs.
For the LCS survey, most NSI´s (76%) reported an increase in cost every time the survey takes
place every two years instead of four. The 20% of respondents indicated no increase in costs.
Additional variables
Replies to the NSI´s consultation showed that introduction of variables needed for deep policy
analysis (e.g. disability status of employees according to the administrative concept in the SES,
career brakes) would be problematic. The reason being the differences in the definitions at the
national level, lack of this information to the employer, issues related to confidentiality and ethics
as well as a high burden they cause on the employers.
At the same time other variables (e.g. occupation to be collected at more disaggregated level in the
SES) seem to be relatively easier to be collected.
Other
Comments made by participants during the online showed that, while participants welcomed the
additional measures and the full regulatory approach it was noted that there should be a balance
between ambition and realism. It was emphasized that assessing the burden on enterprises for the
proposed new measures would be crucial before making any final decisions.
5. CONCLUSIONS
The stakeholder consultation was implemented in line with Commission’s Better Regulation
Guidelines. It reached successfully the intended stakeholder groups except for the administrative
data providers and media organisations. Given the technical nature of the subject, the overall
engagement of respondents was considered sufficient to support the back-to-back evaluation and
impact assessment of the LMB.
The consultation supported the ongoing Commission initiative on LMB statistics and
acknowledged importance of the data that constitute it. It also pointed out the existence of statistical
gaps and the emergence of new statistical needs that cannot be satisfied within the current legal
framework.
All stakeholders confirmed the need to plan statistical improvements although they did not always
agree on the level of ambition of such improvements and statistics producers were somehow more
prudent to changes than statistics users.
69
Statistical topics that gathered support across all stakeholder groups as priority topics were increase
of the coverage in particular to the NACE Rev. 2 section O for all data collections and to
microenterprises for the SES and better timeliness of the LMB data.
The main statistical topics where producer and users had different views concerned the increase of
frequency of the SES or LCS. Producers and users also had different views regarding the addition
of specific variables in SES.
70
ANNEX 3: WHO IS AFFECTED AND HOW?
1. PRACTICAL IMPLICATIONS OF THE INITIATIVE
The preferred option (option 2) would require the following changes in the LMB data collections.
Labour cost index
It is proposed to develop a flash LCI, to be transmitted by all countries representing more than 3%
of the total number of employees at EU level (currently: Belgium, Germany, Spain, France, Italy,
the Netherlands, Poland, Portugal and Romania). The flash LCI should be transmitted at t+45 days
(in addition to the final data transmitted at t+70 days as is already the case) and published three
working days later (i.e. at t+50 days at the latest).
Job vacancy statistics
For JVS, the main proposal consists in eliminating possible biases by covering all economic
activities and enterprise sizes, which is not yet the case for three Member States. In France and
Italy, public institutions are not covered within the sectors of public administration, education and
human health (NACE Rev. 2 sections O, P and Q). In France, only units with 10 employees or more
are included. Denmark only covers units within the business economy (NACE Rev. 2 sections B-
N).
Gender pay gap
Annual (unadjusted) on gender pay gap data are currently collected under a gentlemen’s agreement.
Under the LMB review, it is proposed to introduce a legal basis for the transmission of this
important indicator. This will also serve the needs of the proposed directive on pay transparency
whose monitoring will require annual on gender pay gap data.
Structure of earnings survey
It is proposed to extend the scope of the four-yearly Structure of Earnings Survey to micro firms
(with 1 to 9 employees) and to public administration (NACE Rev.2 section O). The SES extension
aims to correct the existing biases in the mean and median earnings which are used in a number of
policy-relevant policies including the newly adopted directive on adequate minimum wages and for
the on gender pay gap.
It is also proposed to shorten the deadline for transmitting SES data to Eurostat.
Labour cost survey
It is proposed to extend the scope of the four-yearly labour cost survey to public administration
(NACE Rev.2 section O) and to shorten the deadline of transmission of data to Eurostat.
Moreover, the proposal will limit the data collection on apprentices to Member States where they
represent more than 3% of the total number of employees at EU level (currently: Germany,
Denmark, France, Italy and Austria).
71
General
To compensate for the resulting increase in the response burden, the LMB review will foster the use
of administrative and innovative (e.g. web-scraping) sources for the compilation of LMB data.
Quality reporting templates will be adapted to fit administrative data and multiple sources. In
addition the emerging needs related to new variables in SES, indices for hours worked and labour
costs in LCI and more detailed breakdowns of the JVS will be implemented These will be done in
the secondary legislations.
The data are collected by the Members States based on the sample survey, based on the extraction
of the information already available in the administrative registers, as a combination of the methods
described above. National Statistical Institutes or Other National Authorities are free to choose the
method that is the most efficient in terms of burden and the statistical quality.
2. DETAILED SCORING BY POLICY OPTION
Table 13. Policy Option 0: No targeted EU action (baseline)
Policy Option 0 (baseline, no targeted EU action)
Assessment criterion Score Brief description
Consistency with
proportionality
principle
(Pass /
uncertain
/ fail)
Does the option go
beyond what is
necessary to
satisfactorily achieve
the objectives?
Pass Under the baseline, no further EU action would be taken and
therefore does not go beyond what is necessary.
Is the scope of the
option limited to those
aspects that Member
States cannot achieve
satisfactorily on their
own and where the
Union can do better?
Pass Under the baseline, no further EU action would be taken. Current
EU action is limited to those aspects that Member States cannot
achieve satisfactorily on their own, such as EU-wide comparative
data that follow harmonised standards in areas such as labour
costs, earnings and job vacancies. Results from the evaluation
show that current EU action provides clear added value.
Are costs for the
Union, national
governments, regional
or local authorities,
economic operators or
citizens commensurate
with the objectives of
the initiative?
Pass Under the current LMB legal basis, compilers were already called
upon minimizing the costs subject to the objectives set by the EU
legislation. Under the subsidiarity principle, compilers were free
to choose the most efficient sources and methods given the
national context, provided they meet the objectives fixed at the
time with the high level of quality expected for official statistics.
Is the form of action
(choice of instrument)
as simple as possible
and coherent with a
satisfactory
Uncertain Under the baseline, no further EU action would be taken. Each
statistical domain would continue to be implemented as a separate
statistical process based on its own EU legislation. Thus, all
existing pieces of legislation would remain which does not favour
easy enforcement and achievements of the objectives, in
72
achievement of the
objective and effective
enforcement?
particular the coherence and clarity of EU legislation.
Nonetheless, the various stakeholders are accustomed to the
current regime which has been in place since several years and it
cannot be considered as ‘failing’ on this part of the
proportionality assessment.
Effectiveness in
achieving policy
objectives:
(-- to ++)
SO1.1: Adapting the
regulatory framework
to allow flexibility in
meeting emerging
needs
0 Under the baseline, no further EU action would be taken to
further adapt the framework to evolving needs, sources and
methods.
Maintaining the current system would mean that LMB statistics
would not fully satisfy emerging user needs, as the current
problems would remain unaddressed.
SO1.2: To release
more timely statistics
0 The deadlines of release of the LMB statistics will stay the same
as currently
SO1.3: To promote the
use of innovative
sources and methods
of duly assessed
quality
0 No reporting on quality of administrative and innovative data
sources will take place and assessment of their quality will not be
assured therefore use of innovative sources will not be promoted.
SO2: Improving the
coverage of statistics
to whole economy and
ensure exhaustive GPG
data
0 Under the baseline, no further EU action would be taken to
change the coverage of statistics in terms of topics and actors.
SO3: Improving the
consistency with
related statistical
domains
0 Under the baseline, no further EU action would be taken to
improve consistency with related statistical domains.
Impacts on
fundamental rights and
the promotion of
equality
0 The impact on fundamental rights is not, however, entirely
neutral. As policymakers and other stakeholders are involved in
protecting population sub-groups at risk of inequality (in terms of
pay discrimination based on gender or disability, there may be
impacts).
This option has no impacts on the promotion of equality.
Social impacts 0 Under the baseline scenario, no further EU action would be taken,
hence no social impact.
Environmental impacts 0 Policy option 0 is likely to have a rather neutral indirect
environmental impact when considering the European Green
Deal.
Competitiveness 0 Under policy option 0 there are no impacts on competitiveness,
research & innovation.
73
Do no significant
harm, including
climate consistency
check
0 This option has no impact on the principle of “Do no significant
harm”.
Digital by default 0 The option has no impacts on digital-ready policymaking.
Sustainable
Development Goals
0 Under this option there is no impacts on the SDG.
Coherence with
overarching objectives
of EU policy
(-- to ++)
Coherence 0 Maintaining the status quo would mean that some shortcomings
of the current framework would not be resolved (i.e. partial
coverage of the economy causing biases in key indicators).
Considering that most of the drivers would remain unaddressed in
the baseline scenario, it is highly likely that the misalignment
between LMB statistics and other relevant EU flagships and
initiatives will remain. For instance, the findings from evaluation
identified a need for a more coherent and harmonised approach to
data on equality.
Hence, with option 0, LMB statistics will not be aligned with
initiatives such as the recently adopted Directive on adequate
minimum wages, the Commission proposal for a directive on pay
transparency, and Principle 6 of the European Pillar of Social
Rights.
Efficiency
0 Under Policy option 0, stakeholders will incur the same level of
ongoing costs as under the current LMB framework of legal acts.
Costs in Policy option 0 (for Eurostat, NSIs and enterprises) are
mainly driven by the costs of regularly producing the various
types of LMB statistics on wages, labour costs, and job vacancies.
Benefits remain unchanged.
Overall, NSIs are permanently optimizing their sources and
methods, given the national contexts, so that the efficiency is high
as also confirmed by the evaluation
74
2.1. Policy option 1: Reliance on the voluntary nature of contributions
Table 14. Policy Option 1: Reliance on the voluntary nature of contributions
Policy Option 1 Reliance on the voluntary nature of contributions
Assessment criterion Score Brief description
Consistency with
proportionality principle
(Pass /
uncertain
/ fail)
Assessment
Does the option go
beyond what is
necessary to
satisfactorily achieve the
objectives?
Pass As part of policy option 1, most measures are voluntary in nature,
with only GPG data being mandatory. The nature of other
measures being voluntary ensures that the option does not go
beyond what is necessary to satisfactorily achieve the initial
objectives.
A new regulation would be created for regulating GPG. This
satisfies the criterion in that the only avenue for addressing the
specific issue of gender pay gap information is through specific
legislation and cannot be achieved in a voluntary manner. This is
therefore consistent with the proportionality principle.
Is the scope of the
option limited to aspects
that Member States
cannot achieve
satisfactorily on their
own, and where the
Union can do better?
Pass Under option 1, some but restricted mandatory further EU action
would be taken. Current EU action is limited to those aspects that
Member States cannot achieve satisfactorily on their own, such as
EU-wide comparative data that follow harmonised standards in
areas such as labour costs, earnings, and job vacancies. The
indicators added and the improvements to timeliness are
comparatively minor in nature, rendering option 1 limited to
aspects that Member States cannot achieve on their own.
Are costs for the Union,
national governments,
regional or local
authorities, economic
operators or citizens
commensurate with the
objectives of the
initiative?
Pass As part of option 1, limited further mandatory EU action is taken
when compared to the baseline. The costs for additional data
collection (on GPG) are limited. In particular, the future
mandatory transmission of GPG data would be strictly limited to
the current (voluntary) data collection transmission. It thereby
passes the test of the costs being commensurate with the
objectives of the initiative.
Is the form of action
(choice of instrument) as
simple as possible and
coherent with a
satisfactory achievement
of the objective and
effective enforcement?
Pass Under option 1, one framework regulation is proposed with a
limited degree of mandatory legal changes required -inclusion of
GPG. All statistical domains would be covered under one EU
legislation, allowing for better harmonisation and planning.
In a certain way, the voluntary nature of the collection of some
data would render the overall framework opaquer. It would not be
as simple as possible as it creates divergence across Member
States.
75
Nonetheless, given the limited impact of the current regime on the
various stakeholders, it is unlikely that this would be considered a
‘fail’ on this part of the proportionality assessment.
Effectiveness in
achieving policy
objectives:
(-- to ++)
SO1.1: Adapting the
regulatory framework to
allow flexibility in
meeting emerging needs
+ As part of option 1, the framework would be slightly more
adapted (due to its voluntary character) to constantly evolving
needs (in particular the new needs on GPG), sources and methods
by considering elements that were not part of the existing regime.
SO1.2: To release more
timely statistics
+ Improvements to timeliness would be minor as the early data
transmission will take place voluntarily
SO1.3: To promote the
use of innovative
sources and methods of
duly assessed quality
+ Quality reporting on use of administrative and/or innovative
sources will be voluntary.
SO2: Improving the
coverage of statistics to
whole economy and
ensure exhaustive GPG
data
+ The coverage of statistics will be improved in particular for GPG
data. Moreover, with the voluntary nature of the extension of
coverage of other LMB data -, adapting quality reporting
frameworks, aligning concepts and definitions - there are a
number of improvements to be made compared to the baseline.
SO3: Improving the
consistency with related
statistical domains
+ Consistency with related statistical domains would be improved,
in particular through the single basic act with updated references
to the related statistical domains (National Accounts, European
Business Statistics) but voluntary nature of extension to public
administration may still leave not full resolved issue related to
definition of an employee.
Impacts on fundamental
rights including the
promotion of equality
+ Making GPG data collection compulsory would have a positive
impact on the monitoring of fundamental rights as regards gender
issues.
A mandatory legal basis for the data collection of GPG data
would also be in line with the proposal for a Directive on pay
transparency.
However, further information on the GPG collected in the
underlying source (SES) would be collected voluntarily, posing a
risk of low compliance and hence limited data availability. This
would limit future developments in GPG analyses (adjustments
based on detailed occupations, impact of social contributions on
the GPG etc.)
Therefore, the impact on fundamental rights is slightly positive.
Social impacts + The modernisation of social statistics began with Regulation (EU)
2019/1700 on European social surveys. This regulation
constituted the first milestone of the modernisation of social
statistics, setting up a specific framework for European statistics
on people and households based on data at an individual level,
and collected from samples.
Some of the proposed measures, such as on regularisation of
76
gender pay gap, would further contribute to the promotion of
social inclusion and the monitoring of social cohesion at national
and regional levels. The European Pillar of Social Rights is about
better delivering the rights for citizens towards a strong social
Europe that is fair and inclusive.
In terms of social impacts, there are positive effects in regard to
the mandatory collection of data on the gender pay gap. This
would nonetheless be a net positive result for this criterion.
Sustainable
Development Goals
0 For LMB statistics, SDG 5 on gender equality and SDG 10 on
reduced inequalities are relevant. The mandatory collection of
GPG data will provide policy makers with more complete
information to support policies in the area of gender equality and
contribute to both SDG objectives. However, the voluntary data
collection on microenterprises would lead to limited data
availability on enterprises employing less than 10 persons
preventing Eurostat from correcting the existing bias in the global
SDG indicator on gender pay equality (the GPG).
Coherence with
overarching objectives
of EU policy
(-- to ++)
Coherence - Option 1 would not address all the shortcomings of the baseline in
terms of the somewhat more complex nature of the various
existing datasets, the divergence of outcomes due to the voluntary
nature of many of the measures, and thereby the rendering of the
coherence in EU policies being somewhat less favourable than
expected. It can also be questioned whether a voluntary approach
would bring overarching EU objectives any closer. It is likely
therefore that the effect is slightly negative compared to the
baseline.
However, as a new sole framework regulation is used, the risk of
discrepancies between the domains will be lower, providing for
better coherence of the LMB package in terms of definitions,
concepts, approaches and planning.
Efficiency
0 Under policy option 1, stakeholders will incur slightly higher
ongoing costs than under the current LMB framework of legal
acts.
Costs in policy option 1 are mainly driven by the costs of
regularly producing GPG. Those costs however are negligible for
the enterprises as the data collection will be done by the NSI
mainly based on the existing sources.
There would, however, be a positive impact on benefits given the
voluntary nature of most of the measures and thus the benefits are
also comparatively modest.
Overall efficiency may still be relatively high based on findings
from the evaluation.
77
Results of the consultation on cost and burden with the NSIs and the study estimation combined,
provided that introduction of the compulsory data collection on GPG would lead to increase of costs
for this data collection by 34 % (+ 215 000 Euro). For the whole LMB, this means an increase of less
than 1 % in total. Estimated, increase in costs related to burden on enterprises would be negligible
(less than 100 000 Euro). This is mainly linked to the fact that GPG data collection is based on the
existing sources and the burden is mainly on the statistical authorities to compile the data and prepare
quality report.
In relation to burdens associated with creating a legal basis for the mandatory transmission of annual
unadjusted GPG data, 54% of respondents (14 NSIs) indicated no increases in response burden and
an additional 35% (9 NSIs) noted that data was already collected or available. Nevertheless, 12% of
respondents indicated an increase in response burden 4% (1 NSI) medium and 8% (2 NSIs) high.
When asked about the possible increase in burden associated with collecting and publishing quality
reports for the yearly GPG, most respondents (62%, 16 NSIs) noted no increases in response
burdens. 27% (7 NSIs) also noted that data was already available or collected. Increases are however
noted by the remaining 12% of respondents with 8% (2 NSIs) indicating a high increase and 4% (1
NSI) indicating no increases in response burdens. Negligible increase in total burden on the
enterprises is expected, coming mainly from the country that either do not provide data already (e.g.
IE).
Overall assessment
Under policy option 1, there will be limited mandatory changes at the EU level and a larger number
of voluntary changes. The measures, however, generally represent a continuation of the status quo
under the baseline.
This option would have limited effectiveness in addressing the problems identified with the current
EU legal framework and while it passes the proportionality principle simply because it is a
simplification compared to the existing framework, its effects are modest and do not meet the
expectations for a general review of LMB legislation. While there are some positive social impacts,
the overall coherence with EU policies is not deemed well-served by this option, thus making it sub-
optimal.
In summary, this option would be somewhat more effective in addressing the problems identified
with the LMB framework compared to the baseline, although it still falls short from users
expectations identified through the LMB evaluation exercise.
78
2.2. Policy option 2: High coverage, better timeliness and other measures
Table 15. Policy Option 2: High coverage and timeliness; GPG regulated
Policy Option 2: High coverage and timeliness; GPG regulated
Assessment criterion Score Brief description
Consistency with
proportionality
principle
(Pass /
uncertain
/ fail)
Assessment
Does the option go
beyond what is
necessary to
satisfactorily achieve
the objectives?
Pass The new mandatory additions under option 2 relate to an
extension of the coverage in certain areas, including of micro
firms and NACE Rev. 2 section O for the SES, improved
timeliness, adapting templates for quality reports, aligning
concepts and definitions, making GPG data compulsory and
addressing emerging needs.
To ensure compliance with the principle of proportionality, the
intervention of the EU in the field of European statistics must
ensure a higher level of comparability of the relevant LMB
datasets.
The option is not deemed to go beyond what is necessary to
satisfactorily achieve the objectives because it covers areas where
data users have expressed a need and addressed emerging needs
that the evaluation found are currently missing. It also updates
concepts, definitions and templates to ensure alignment.
Timeliness increases considerably in some respects.
Is the scope of the
option limited to those
aspects that Member
States cannot achieve
satisfactorily on their
own, and where the
Union can do better?
Pass Under option 2, further mandatory EU action is taken in the range
of areas described above. It is reasonable to assess that Member
States would not be able to cover alone those areas that the
evaluation has found are gaps and limitations of the current
regime. Several of the proposed measures concern coordination
efforts (on definitions, templates for quality reports, concepts)
and addressing needs in any case already expressed in EU
strategies (such as extension of the coverage). It is clear the
Union can do better than the totality of the Member States.
Are costs for the
Union, national
governments, regional
or local authorities,
economic operators or
citizens commensurate
with the objectives of
the initiative?
Pass As part of option 2, considerable EU action is taken compared to
baseline. There would be higher costs for measures that are
currently not in place, though these are assessed as reasonable
compared to the wider EU policies, strategies and objectives, and
the needs for rendering the framework future-proof.
It thereby passes the test of the costs being commensurate with
the objectives of the initiative.
Is the form of action
(choice of instrument)
as simple as possible
Pass Under option 2, mandatory action is taken, and this is done by
merging the existing 3 framework regulations into a single
integrated legal act. It can be considered comparatively simpler
79
and coherent with a
satisfactory
achievement of the
objective and effective
enforcement?
than discrete regulations for each type of data.
The mandatory nature of the collection of data, expansion of the
coverage and addressing of emerging needs, as well as the
updating of concepts, definitions and templates for quality reports
would render the overall framework more future-proof. It helps to
achieve the objectives more satisfactorily than is currently the
case. It expands the scope of LMB statistics while reducing the
complexity of the current legal framework.
Option 2 therefore passes this test.
Effectiveness in
achieving policy
objectives:
(-- to
++)
SO1.1: Adapting the
regulatory framework
to allow flexibility in
meeting emerging
needs
++ As part of option 2, the framework would clearly help in further
adapting to meet constantly evolving needs (including the needs
identified in the evaluation), sources and methods by considering
numerous elements that were not part of the existing regime.
SO1.2: To release
more timely statistics
+ The timeliness of the statistics will be improved, in particular for
the LCI and to a lesser extent for the SES.
SO1.3: To promote
the use of innovative
sources and methods
of duly assessed
quality
++ The use of administrative and innovative sources will be
promoted by better reporting of their quality
SO2: Improving the
coverage of statistics
to whole economy and
ensure exhaustive
GPG data
+ The coverage of statistics will be improved in particular for GPG
data, extending SES to micro firms, providing better coverage of
the economy through including administration in the SES and
also in the LCS, full coverage of the economy including micro
firms, public institutions and the non-business economy (O to S)
in the JVS, new templates for quality reports, definitions and
concepts, and addressing emerging needs.
This helps to significantly to improve the coverage to whole
economy.
SO3: Improving the
consistency with
related statistical
domains
++ Consistency with related statistical domains would be improved,
in particular through the single basic act with updated references
to the related statistical domains (National Accounts, European
Business Statistics).
Impacts on
fundamental rights
including the
promotion of equality
+ Compared with the baseline, option 2 will regulate GPG
transmissions thus increasing coherence with the current legal
framework, specifically with Article 23 of the EU Charter, the
European Pillar of Social Rights, Directive 2006/54 on the
implementation of the principle of equal opportunities and equal
treatment of men and women in matters of employment and
occupation as well as the Gender Equality Strategy 2020-2025.
With extension of the SES to NACE Rev. 2 section O and
microenterprises coverage, users will get unbiased results on
wages allowing better analysis of the gender differences.
80
Social impacts ++ Some of the proposed measures, such as extension of the SES
coverage to the micro firms and NACE Rev. 2 section O would
allow better assessment of the low–wage earners and contribute
to monitoring of the directive on minimum wages adequacy.
They will also further contribute to modernising social statistics.
Modernisation of this kind may be needed to support various
Union actions, such as the promotion of social inclusion and the
monitoring of social cohesion at national and regional levels. The
European Pillar of Social Rights is about better delivering the
rights for citizens towards a strong social Europe that is fair and
inclusive.
There are positive effects with the mandatory collection of data
on the gender pay gap, indices of hours worked and labour costs,
variables identified as emerging need in SES. There would
clearly be a net positive result for this criterion.
Sustainable
Development Goals
+ SDG 5 on gender equality and SDG 10 on reduced inequalities
were assessed under this option. Regulated data collection for
GPG, has the potential to increase data accessibility on GPG data
and provide policy makers with more up to date information to
support policies in the area of gender equality and contribute to
SDG 5 on gender equality. In addition, under this option SES data
collection is extended to micro-enterprises, this increases the
coverage of economy and provides more detailed and accurate
information on gender pay gap and contributes to an unbiased
calculation of SDG indicator on gender equality.
Coherence with
overarching objectives
of EU policy
(-- to
++)
Coherence + Option 2 would address most of the shortcomings of the baseline
in terms of coverage, covering emerging needs and further
harmonisation of standards (definitions, concepts, templates for
quality reports). A clear effort at collecting these types of data
would better ensure meeting overarching EU objectives.
The impact of policy option 2 would be further aligned with the
aforementioned EU flagship initiatives such as the Equality
Employment Directive (2000/78/EC), EP and Council directive
on minimum wages, Commission proposal for a directive on pay
transparency and Principle 6 of the European Pillar of Social
Rights.
Last but not least, a unified legal framework (single legal act) will
improve the clarity and coherence of the whole LMB legislation.
Efficiency
++ (see assessment below)
The costs for compilers related to data collections were assessed based on a quantitative survey of
NSIs and Other National Agencies (ONAs) in charge of LMB statistics. This was complemented by
a qualitative survey of the LAbour MArket Statistics (LAMAS) working group carried out in the
July-August 2022 and the study conducted for the purpose of evaluation and impact assessment
81
The table below provides an overview of the increase in costs for NSIs across datasets for NSIs, for
policy option 2 Increase in costs of NSIs for policy
Table 16. Increase in costs of NSIs for policy option 2
Total annual costs of
baseline for NSIs (in
EUR)
Increase of NSI´s cost (in
EUR)
% Increase of total
NSIs´costs
JVS 5,659,238 586,191 10%
LCI 9,318,641 865,516 9%
LCS 7,185,434 529,808 7%
SES 7,386,671 1,511,227 20%
GPG 628,709 214,647 34%
Total LMB 30,178,693 3,707,389 12%
In the qualitative survey among the MSI´s most respondents (64%, 16 NSIs) noted insignificant
costs for transmitting all LCI results earlier, 65 days instead of 70 days after the end of the
reference quarter. 24% (6 NSIs) reported a significant increase every time the survey takes place
and 13% (Malta, Belgium, Greece, France and Bulgaria) when starting up. NSI respondents from
BE, DE, ES, FR, IT, NL, PT, and PL were asked to evaluate the level of costs in terms of providing
the data for a flash LCI at 45 days after the end of the reference quarter. Half of them respondents
noted a significant increase in costs every time the survey takes place.
Most NSIs respondents (58%, 15 NSIs) also noted an absence of increase in costs for transmitting
all SES results earlier (T+16 months instead of T+18 months). 19% (5 NSIs) noted an increase
when starting up and the remaining 23% (6 NSIs) noted one every time the survey took place.
In a nutshell, option 2 would trigger limited costs for NSIs whose main part could be financed
through by EU grants.
Costs for respondents
The costs for respondents was assessed in a survey of compilers complemented with a qualitative
study. The costs for enterprises were calculated based on the median time spent by enterprises to
comply with the data collection request multiplied by hourly labour costs in Member States. The
sum of costs of the available countries, plus the EU median value for the missing countries not
reporting any cost were added to calculate the total costs.
The table below provides an overview of the increase in costs for businesses across datasets.
Table 17. Increase in costs for businesses for policy option 2
Total annual costs of
baseline for businesses (in
EUR)
Increase of businesses cost
(in EUR)
% Increase of total
costs of business
JVS 4,472,272 723,594 16%
LCI 12,001,564 11,935 0.1%
LCS 10,703,029 456,720 4%
SES 16,079,802 3,426,005 21%
GPG 0 92,365 na
Total LMB 43,256,667 4,710,619 11%
82
In relation to the burden associated with extending the coverage of LMB datasets, 42% of the NSIs
(11 NSIs) noted a high increase in response burden in extending coverage of SES datasets to micro-
firms for main information. The remaining respondents either noted that data was already collected
(38%, 10 NSIs), Finland, Belgium, Luxembourg and France (16%) recorded no increase and only
Latvia (4%) reported a low increase in response burden.
Responses regarding extending the coverage of the SES survey to NACE Rev. 2 section O (‘public
administration and defence, compulsory social security’) suggest data is either already collected or
available (73%, 19 NSIs). Impacts of response burdens for the remaining countries are either
medium (15%, 4 NSIs) or high (12%, 3 NSIs). For LCS datasets, most respondents (77%, 20 NSIs)
noted data availability.
Only three respondents noted high increases in response burdens for transmitting all SES results
earlier, at T+16 months instead of at T+18 months (T being the end of the reference year). 19% (5
NSIs) indicated data availability and 42% (11 NSIs) of respondents noted no increases in response
burdens.
To summarize, option 2 would create a limited increase in burden, mainly due to the extension of
the SES scope to micro-firms. The costs implied (8.2 million) represent a negligible part (less than
1%) of the costs European Business Statistics (annual total costs of around 980 million Euro)36
. The
real amounts will be even smaller as ten NSIs have already extended SES to micro-firms.
Overall assessment
The overall assessment of option 2 is that it passes the proportionality test, ensures enhanced
coherence with EU policies, goes a significant way in meeting policy objectives and has positive
social impacts. The option leaves limited gaps with the identified set of problems and drivers.
Most of the drivers are addressed. Option 2 is highly effective in achieving most of the policy
objectives. In terms of coverage, option 2 does not foresee the extension of LCS to cover micro
firms but extends SES to micro firms although only for main information (SES 2). Option 2 also
offers high timeliness but the frequency remains unchanged – as with the baseline scenario (4-
yearly).
While it is anticipated that the increase in timeliness will allow for better research and evidence
from SES and LCI, the frequency of LMB statistics would not improve. Whereas cyclical indicators
(JVS for labour shortages, LCI for hourly labour costs) are provided with sufficient frequency
(quarterly), some users would appreciate a shorter periodicity for structural surveys such as the
LCS and the SES.
Nevertheless, option 2 would also cover important actors and segments of the population to allow
for better research and policy analysis. This option also introduces new templates for the collection
and quality reporting for the use of administrative data and innovative sources as well as more
alignment in terms of concepts and definitions of relevant data domains including national accounts
and the EBS.
36
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1342-European-business-statistics-FRIBS-
_en
83
2.3. Policy option 3: Highest coverage and increased frequency
Table 18. Policy Option 3: Highest coverage and increased frequency
Policy Option 3: Highest coverage and increased frequency
Assessment criterion Score Brief description
Consistency with
proportionality
principle
(Pass /
uncertain
/ fail)
Assessment
Does the option go
beyond what is
necessary to
satisfactorily achieve
the objectives?
Pass The full set of mandatory aspects under option 3 relate to an
extension of the coverage in certain areas, including of micro
firms, improved timeliness, adapting templates for quality reports,
aligning concepts and definitions, making GPG data compulsory
and addressing emerging needs.
To ensure compliance with the principle of proportionality, the
intervention of the EU in the field of European statistics must
ensure a higher level of coherence and comparability of the
relevant LMB datasets.
The option goes further than option 2 in particular in improving
both timeliness and frequency of the publication of datasets. The
frequency and timeliness were cited as key points of
improvements by data users. Overall, the set of measures is not
deemed to go beyond what is necessary to satisfactorily achieve
the objectives because it covers areas where data users have
expressed a need and addressed emerging needs that the
evaluation found are currently missing. It also updates concepts,
definitions and templates to ensure alignment. Such alignment
can be considered reasonable.
Is the scope of the
option limited to those
aspects that Member
States cannot achieve
satisfactorily on their
own, and where the
Union can do better?
Pass Under option 3, significant mandatory EU action is taken in a
wide range of areas. It is reasonable to assess that Member States
would not be able to cover those areas that the evaluation has
found are gaps and limitations of the current regime. Several of
the proposed measures concern coordination efforts (on
definitions, templates, concepts) and addressing needs in any case
already expressed in EU strategies. It is clear the Union would do
better than the totality of Member States in this policy area.
The most far-reaching option adopts an overhaul of the entire
legal framework but the scope of the option is limited to what is
necessarily required. The new legislation would rationalise the
legal basis and hence be a simplification.
Are costs for the
Union, national
governments, regional
Uncertain As part of option 3, considerable EU action is taken to cover
significantly the shortcomings identified in the evaluation. There
would be higher costs for measures that are currently not in place,
84
or local authorities,
economic operators or
citizens commensurate
with the objectives of
the initiative?
increasing frequency and timeliness. These are generally
commensurate to objectives: LCS and SES frequency cannot
double without increasing the burden by a similar proportion.
However, the increased frequency and timeliness entail sustained
further efforts that may, strictly speaking, not all be necessary to
meet objectives of the initiative.
It is therefore somewhat uncertain if it passes the test of the costs
being commensurate with the objectives of the initiative.
Is the form of action
(choice of instrument)
as simple as possible
and coherent with a
satisfactory
achievement of the
objective and effective
enforcement?
Pass Under option 3, mandatory action is taken and this is done by
producing a single new framework regulation.
The mandatory nature of the collection of data, expansion of the
coverage and addressing of emerging needs, as well as updating
of concepts, definitions and templates for quality reports would
render the overall framework more future-proof. It helps to
achieve the objectives more satisfactorily than is currently the
case through its legal streamlining (1 instead of multiple
regulations). It expands the scope of LMB statistics but does not
expand its current level of complexity.
Option 3 therefore passes this test.
Effectiveness in
achieving policy
objectives:
(-- to ++)
SO1.1: Adapting the
regulatory framework
to allow flexibility in
meeting emerging
needs
++ As part of option 3, the framework would clearly help in further
adapting the framework to constantly evolving needs, sources and
methods by considering extensively elements that were not part of
the existing regime.
SO1.2: To release
more timely statistics
++ The timeliness of the statistics will be significantly improved, in
particular for the SES, LCI and LCS.
SO1.3: To promote the
use of innovative
sources and methods of
duly assessed quality
++ The use of administrative and innovative sources will be
promoted by better reporting of their quality
SO2: Improving the
coverage of statistics to
whole economy and
ensure exhaustive GPG
data
++ The coverage of statistics will be improved in particular for GPG
data, creating better coverage of the economy through extending
the LCS and SES to micro firms for all variables as well as to
administration, new templates for quality reports, definitions.
This helps to significantly improve the coverage and depth of
statistics.
85
SO3: Improving the
consistency with
related statistical
domains
++ Consistency with related statistical domains would be improved.
Impacts on
fundamental rights
including the
promotion of equality
++ Considering EU strategies on equality, and the gender pay gap in
particular, the impact on fundamental rights through collecting
these types of data would be aided positively by this option.
With any fundamental right drawbacks being limited, the overall
assessment is positive.
This option has the potential to increase the impact of LMB
statistics and creating a stronger legal basis for collecting such
data and increasing coherence with the current legal framework,
specifically with Article 23 of the EU Charter, the European Pillar
of Social Rights, Directive 2006/54 on the implementation of the
principle of equal opportunities and equal treatment of men and
women in matters of employment and occupation, the Gender
Equality Strategy 2020-2025. The increased frequency of SES
data collection would allow for more frequent provision of
benchmarked GPG and better monitoring of the equality policies.
Social impacts ++ Some of the proposed measures, such as mandatory collecting of
data on gender pay would further contribute to modernising social
statistics. Modernisation of this kind may be needed to support
various Union actions, such as the promotion of social inclusion
and the monitoring of social cohesion at national and regional
levels. The European Pillar of Social Rights is about better
delivering on rights for citizens towards a strong social Europe
that is fair and inclusive. The increase of frequency of SES and
LCS is an additional element with a social impact.
In addition, there are positive effects with the mandatory
collection of data on the gender pay gap, data, indices of hours
worked and labour costs, pay schedules and additional variables
in SES data. There would be a clearly net positive result for this
criterion.
Sustainable
Development Goals
++ SDG 5 on gender equality and SDG 10 on reduced inequalities
were assessed under this option. Regulated data collection for
GPG, has the potential to increase data accessibility on GPG data
and provide policy makers with more up to date information to
support policies in the area of gender equality and contribute to
SDG 5 on gender equality. In addition, under this option SES data
collection is extended to micro-enterprises and provided more
frequently. This increases the coverage of economy and provides
more frequent and accurate information on benchmarked gender
pay gap and contributes to an unbiased calculation of SDG
86
indicator on gender equality.
Under this policy option additional variables in SES identified as
emerging need SES would be collected on a mandatory basis.
This information could be used to support the calculation of
SDGs scoreboard in relation to reduced inequalities.
Coherence with
overarching objectives
of EU policy
(-- to ++)
Coherence + Option 3 would address most of the shortcomings of the baseline
in terms of coverage, covering emerging needs and further
harmonisation of standards (definitions, concepts, templates for
quality reports). A clear effort in collecting these types of data
would better ensure meeting overarching EU objectives.
It is expected that with the introduction of new variables (for
instance, covering ‘pay schedule’) and mandatory collection of
GPG data, LMB statistics will be fully aligned with flagship
initiatives such as the EP and Council directive on minimum
wages, the Commission proposal for the directive on pay
transparency and Principle 6 of the European Pillar of Social
Rights.
Efficiency
+ See assessment below
Option 3 offers the highest effectiveness but also comes at a high price. This is the most costly and
burdensome option.
The table below provides an overview of the increase in costs for NSI’s across datasets for NSI’s,
for policy option 3
Table 19. Increase in costs for NSIs for policy option 3
Total costs of baseline
for NSIs (in EUR)
Increase of NSI´s cost (in
EUR)
% Increase of Total
costs
JVS 5,659,238 2,198,958 39%
LCI 9,318,641 1,379,390 15%
LCS 7,185,434 8,348,942 116%
SES 7,386,671 7,409,460 100%
GPG 628,709 1,658 0%
Total LMB
30,178,693 19,338,408 64%
Participant responses in qualitative survey among NSI´s were balanced in relation to transmitting all
LCS results earlier, at T+15 months instead of at T+18 months. Although 46% of respondents (12
NSIs) noted a significant increase in cost every time the survey takes place, and 15% (4 NSIs)
indicating cost increases when starting-up, 38% of responses (10 NSIs) also suggest no significant
increase in cost would take place.
87
Costs associated with collecting SES data every two years instead of every four years will be high
as a large majority of respondents (84%, 21 NSIs) noted a significant increase in cost every time the
survey takes place. The remaining 16% (Iceland, Hungary, Denmark and Switzerland) noted no
increase in costs. In terms of collecting LCS data every two years instead of every four years, a
large majority of respondents (76%, 19 NSIs) indicated significant increases in costs every time the
survey takes place. Portugal indicated significant costs when starting up and respondents from
Ireland, Iceland, Denmark, Switzerland and Romania (20%) also noted no increase.
Most respondents (60%, 15 NSIs) also noted an increase in costs associated with transmitting all
SES results much earlier, at T+11 months (instead of T + 16 months) with a reference month
change. 20% noted increases in costs when starting up (5 countries) and 20% noted no increases in
cost.
The table below provides an overview of the increase in costs for businesses across datasets
Table 20. Increase in costs for businesses for policy option 3
Total costs of baseline
for businesses (in
EUR)
Increase of businesses cost (in
EUR)
% Increase of total
costs of businesses
JVS 4,472,272 2,715,790 61%
LCI 12,001,564 11,935 0%
LCS 10,703,029 15,187,811 142%
SES 16,079,802 20,087,048 125%
GPG 0 0 0%
Total LMB 43,256,667 38,002,583 88%
Turning to the qualitative study, most respondents (64%, 16 NSIs) indicated a high increase in
response burden due to doubling the SES frequency (every two years instead of every four years).
Only five respondents (20%) indicated that SES data were already available with a bi-annual
frequency.
A similar response was provided as regards the impact of doubling the LCS frequency: 60% of the
respondents (15 NSIs) noted high increases in response burdens while only 20% (5 NSIs) indicated
that LCS was already collected every two years.
As concerns collecting JVS data by occupation, it will cause high increase in burden according to
67% of NSIs (16 replies), in 5 countries data by ISCO is collected already. Regional data (at NUTS
1 level) for JVS is collected already in 11 countries (46% of NSIs). 4 of NSIs report possible high
increase in burden.
Results of the qualitative survey were more balanced as regards improving the timeliness of SES
from T+16 months to T+11 months (T being the end of the reference year): 32% of respondents (8
NSIs) indicated high increases in response burdens and similarly another 8 NSIs indicated no
increase in response burden. Only 12% (3 NSIs) noted that the data were already available within
the shorter deadline of T+11 months.
For LCS datasets, responses suggest mixed impacts in terms of burdens associated with transmitting
all LCS results earlier, at T+15 months instead of at T+18 months (T being the end of the reference
88
year). Two respondents (8%) noted a high increase in burden, 27% (7 NSIs) noted a medium
increase in response burden and another two a low increase. The remaining 40% of respondents (10
NSIs) noted no increases in response burdens.
To summarize, option 3 would create a large increase (+88%) in the LMB response burden, This
increase would be notably higher for LCS (+ 142%) and SES (+ 125%), mainly due to doubling the
frequency of those costly data collections (+ the extension to micro-firms for LCS). Collecting job
vacancy data by occupation and region would also have a large impact on the response burden.
Overall assessment
The overall assessment of option 3 is that it may pass the proportionality test, though its high level
of ambition in frequency of publication may not necessarily be the least costly approach needed to
meet objectives. The option ensures enhanced coherence with EU policies, ensures policy
objectives are met and has positive social impacts. The option leaves no meaningful gaps with the
identified set of problems and drivers.
Option 3 is the most ambitious and effective among the policy options. It is also the most impactful
option as it addresses all drivers, and the achievement of policy objectives is maximised even if
implying a higher burden on data compilers as well as respondents The foreseen legislative changes
under policy option 3 are likely to significantly impact all stakeholders.
Indeed, the findings from the evaluation and stakeholder consultation have stressed the need for
LMB statistics to adapt to new and emerging user needs, data sources, and methods. Option 3 offers
an extension of the coverage of LMB statistics and the best timeliness and frequency in the richest
(and most costly) sets of LMB data (SES and LCS). It also provides for detailed information on
labour shortages by occupation and region.
Option 3 fully captures the important actors and allows for the observation of socio-economic
phenomena across the EU economy.
The extension of both the SES and LCS scope to micro-firms would also fill the existing data gaps
for this part of the economy.
All these improvements would significantly enhance the scope and depth of policy research on
earnings, labour costs and labour shortages.
The addition of new data, improvements in timeliness, frequency and alignment of definitions
would result in an increased satisfaction for data users leading to better evidence-based policy
making with issues such as discrimination and inequalities being better covered by European
official statistics.
On the downside, this would create much higher costs for NSIs and a significant increase in the
burden for respondents.
89
I. Overview of Benefits (total for all provisions) – Preferred Option
Description Amount Comments
Direct benefits
Better EU level timeliness and completeness of statistics across all
Member States
Not quantified EU level institutional users
Better EU level comparability and coherence of statistics across all
Member States
Not quantified
Underlying data on earnings and related indicators not biased Not quantified
Better data evidence for monitoring and policy making Not quantified
Better EU level timeliness and completeness of statistics across all
Member States
Not quantified Other institutional users (national
and sub-national levels)
Improved comparability of statistics with other Member States Not quantified
Underlying data on earnings and related indicators not biased Not quantified
Improved comparability of statistics with other Member States Not quantified Statistics producers (NSIs)
Underlying data on earnings and related indicators not biased Not quantified
Reduced administrative burden (through improved use of
administrative and/or other data sources)
Not quantified
Reduced administrative burden (trough limitation of the LCS data
collection on apprentices to all EU Member States except Germany,
Denmark, France, Italy and Austria)
Not quantified
Reduced administrative burden (relating to regulatory changes to
adapt to evolving policy needs)
Not quantified
Better EU level timeliness and completeness of statistics across all
Member States
Not quantified General public
Better EU level comparability and coherence of statistics across all
Member States
Not quantified
Underlying data on earnings and related indicators not biased Not quantified
Reduced administrative burden (relating to regulatory changes to
adapt to evolving policy needs)
Not quantified Eurostat
Reduced administrative burden (related to quality assurance) Not quantified
Indirect benefits
Reputational gains from improved policy-making and EU decision-
making in general Not quantified EU level institutional users
Not quantified EU level institutional users
Reputational gains from improved visibility and transparency in
a European context
Not quantified Other institutional users (national
and sub-national levels)
Increased ability to meet legal requirements Not quantified Statistics producers (NSIs)
Increased staff skills Not quantified
Benefits from improved policy-making Not quantified General public
Advancement of Eurostat mission ‘to provide high quality statistics
and data on Europe’
Not quantified Eurostat
Improved collaboration with EU level policy users Not quantified
90
Reputational gains from enhanced international standing of
European statistics free for all
Not quantified
Administrative cost savings related to the ‘one in, one out’ approach*
The simplification of the LCS data collection on apprentices will
lead to reduction of the total time spent by the sampled enterprises
in filling LCS questionnaires.
Not quantified The time spent be the enterprises
will be will be reduced by 27%
(6/22) for all EU Member States
except Germany, Denmark, France,
Italy and Austria.
(1) Estimates are gross values relative to the baseline for the preferred option as a whole (i.e. the impact of individual
actions/obligations of the preferred option are aggregated together); (2) Please indicate which stakeholder group is the
main recipient of the benefit in the comment section;(3) For reductions in regulatory costs, please describe details as to
how the saving arises (e.g. reductions in adjustment costs, administrative costs, regulatory charges, enforcement costs,
etc.;); (4) Cost savings related to the ’one in, one out’ approach are detailed in Tool #58 and #59 of the ‘better
regulation’ toolbox. * if relevant
II. Overview of costs – Preferred option
Citizens/Consumers Businesses Administrations
One-off Recurrent One-off Recurrent One-off Recurrent
Action (a)
Direct adjustment
costs
N/A N/A N/A N/A 234,391 N/A
Direct
administrative
costs
N/A N/A N/A N/A 91,075 N/A
Direct regulatory
fees and charges
N/A N/A N/A N/A N/A N/A
Direct
enforcement costs
N/A N/A N/A 4,618,254 N/A 3,282,045
Indirect costs N/A N/A N/A N/A N/A N/A
Costs related to the ‘one in, one out’ approach
Total
Direct adjustment
costs
Indirect
adjustment costs
Administrative
costs (for
offsetting)
(1) Estimates (gross values) to be provided with respect to the baseline; (2) costs are provided for each
identifiable action/obligation of the preferred option otherwise for all retained options when no preferred
option is specified; (3) If relevant and available, please present information on costs according to the
standard typology of costs (adjustment costs, administrative costs, regulatory charges, enforcement costs,
indirect costs;). (4) Administrative costs for offsetting as explained in Tool #58 and #59 of the ‘better
regulation’ toolbox. The total adjustment costs should equal the sum of the adjustment costs presented in the
upper part of the table (whenever they are quantifiable and/or can be monetised). Measures taken with a view
to compensate adjustment costs to the greatest extent possible are presented in the section of the impact
assessment report presenting the preferred option.
91
3. RELEVANT SUSTAINABLE DEVELOPMENT GOALS
III. Overview of relevant Sustainable Development Goals – Preferred Option(s)
Relevant SDG Expected progress towards the Goal Comments
SDG 5 – Gender equality Assured data evidence for monitoring and
relevant policies
Gender pay gap data delivered based on the
legal requirements (measures GPG1 and
GPG2)
92
ANNEX 4: ANALYTICAL METHODS
Detailed approach to the quantification of costs (efficiency)
The costs estimated as part of this evaluation were those associated with the current LMB
framework specifically focusing on data collections defined by:
 Council Regulation (EC) No 530/1999 of 9 March 1999 concerning structural statistics on
earnings and labour costs, (applicable for SES and LCS),
 Regulation (EC) No 450/2003 of the European Parliament and of the Council of 27
February 2003 concerning the labour cost index (LCI)
 Regulation (EC) No 453/2008 of the European Parliament and of the Council of 23 April
2008 on quarterly statistics on Community job vacancies (JVS)
In addition the costs of voluntary gender pay gap data collection were assessed.
In order to get information on the current costs and the burden of the data collections, a survey was
launched by Eurostat for National Statistical Authorities.
The questionnaire was structured along three parts, covering respectively:
(1) the costs for compilers (direct and indirect, both including FTE),
(2) the time per respondent (in most of the cases the respondent in LMB statistics is an enterprise,
few countries however collect data for SES directly from the employees). For the sake of
simplification, all costs for respondents are treated as costs of businesses.
(3) the time for all responding units. For the sake of simplification, all respondent related costs are
treated as businesses costs.
Countries were asked to report the whole costs and burden for scenario of no changes in the
legislation, and for the possible policy options, both the direct and indirect costs, after converting
occupied posts in Full Time Equivalents (FTEs37
) Costs had to be reported in national currency and
were converted into euros according to the latest exchange rates38
available. The survey aimed to
cover the whole production cycle - from the preparation of collecting the information via a survey
or administrative sources, applying the corresponding legislation, the methodological work, the
verification of the data in the country, all work related to dissemination - until the moment of
sending the data to Eurostat.
37
FTE: Full Time Equivalents varies (in respect of working days and working hours per day) across countries, it is
proposed to use the following standards: one year corresponds to 215 working days (used as well in Commission’s unit
cost methodology), and one working day equals 8 hours worked. However, NSIs are free to decide to use their own
(country wise) definition of ‘FTE’. In that case, the NSI was invited to communicate (for each survey) how many
working days and hours one ‘FTE’ corresponded in the reporting country.
38
https://appsso.eurostat.ec.europa.eu/nui/show.do?dataset=ert_bil_eur_m&lang=en
Euro/ECU exchange rates - monthly data [ert_bil_eur_m] extracted on 05 May 2021.
93
On burden, countries were asked to report on time spent annually per respondent in minutes and of
time spent annually by all respondents. The results were requested to be annual to account for
differences in frequencies of LMB data collections (quarterly, yearly, 4 yearly). The burden was
requested to be provided only in relation to scope required by the EU.
Eurostat has estimated the cost and burden for enterprises to provide data for LMB data collection.
For costs of compliers, (NSI), EU totals were derived as a simple sum. When a country did not
report any costs or when the results had not been confirmed in the validation process, the values
were imputed using the results from a country with a similar number of employees.
Given the low country coverage of the survey on burden by median time spend by all responding
units, the values for missing countries were imputed by the EU median value calculated based on
the available countries information. To monetise burden of respondents, time for all responding
units in hours was multiplied by the mean hourly labour costs for the country concerned. It should
also be noted that in some cases authorities extract data from administrative resources or data are
derived from other surveys.
The data from compilers were complemented by results of study from the ICF as no clear
distinction of one-off costs and recurrent costs were available from the compilers survey. The
assumptions used for this assessment are provided in the Annex IV
94
ANNEX 5: ASSUMPTIONS USED FOR THE DISTRIBUTION OF COSTS
TO THE BR TYPOLOGY
The contract support study on this impact assessment has assessed a total of three
options:
Option 1: Reliance on the voluntary nature of contributions
Option 2: High coverage, better timeliness and other measure
Option 3: Highest coverage and increased frequency
Costs have been considered for three main stakeholder groups, namely 1) Member States
and their National Statistical Institutes (NSIs), 2) the European Commission, including
Eurostat specifically and 3) data producers/businesses. The cost of businesses
participating in the data collection for all three policy options were assessed in the
Eurostat study conducted with the NSIs (as described in the Annex IV). Similarly, the
baseline costs of LMB were assessed for NSIs and businesses in the same study. The
results collected as annual to account for differences in frequencies of LMB data
collections (quarterly, yearly, 4 yearly). And in the consolidation of results, they were
considered as recurrent and related to the data collections for the NSIs and costs for
participating in surveys for the businesses.
Assumptions related to other types of costs (not related to data collection or participation
of businesses in the LMB surveys) are summarised in the Table 1.
Further assumptions used (e.g. the hourly costs rates for the one-off costs in the NSIs) are
annexed to the ICF study report.
Benefits were generally not appropriate for quantification. For example, the benefits to
non-institutional data users from increased access to high quality labour market statistics
on businesses would be challenging to quantify since this would depend on several
additional factors, such as how this data would be used or the cost of accessing data
through alternative sources. Therefore, estimates for benefits are not available.
95
1. DETAILED OVERVIEW OF ESTIMATE COSTS
EC/MS/ Cost category Cost item
Stakeholder
s affected
Type
Value
(EUR)
Description of assumption
Comments/not
es
Policy Option 1
EC Administrative
costs
Developing a Framework
Regulation and amending
implementing legislation (in
particular for GPG)
Eurostat One-off cost 28,545 2 EU officials (AD10) * 20 days
Monthly salary for AD10 is 9,000
22 days worked per month (based on Eurostat
2019: average of 36.2 hours worked per week)
value in EUR
EC Compliance
costs
Monitoring compliance by MS Eurostat Recurrent cost 8,182 2 EU officials (AD10) * 10 days
Monthly salary for AD10 is 9,000
22 days worked per month (based on Eurostat
2019: average of 36.2 hours worked per week)
value in EUR
MS Administrative
costs
Adaptation and preparation for
revised text of the LMB FR
The 27 MS
bound by the
FR
One-off cost 45,537 220 days worked per year (based on Eurostat
2019: average of 36.2 hours worked per week)"
value in EUR
MS Administrative
costs
Issuing guidance and training. 27 MS
affected
One-off cost 7,081 2 MS officials for 10 days value in EUR
MS Compliance
costs
Communicate the change. 27 MS
affected
One-off cost 88,315 4 MS officials for 8 days value in EUR
EC/MS/ Cost category Cost item
Stakeholder
s affected
Type
Value
(EUR)
Description of assumption
Comments/not
es
MS Compliance
costs
Data collections This would
affect all MS
bound by
legislation
Ongoing cost 66,814 Value based on Eurostat survey value in EUR
MS Administrative
costs
Reporting to EU This would
affect all MS
Ongoing cost 6,900 Derived from the baseline assumption re FTE
for reporting (i.e. 1 official per MS 2.5 days per
year)
value in EUR
Businesse
s
Costs for
participating in
the surveys
This would
affect the
businesses
selected
Recurring 92,365 Estimated at 2% the cost of PO 2 considering
that GPG data (the only mandatory element) is
roughly 2% of the baseline costs for NSIs.
value in EUR
Policy Option 2
EC Administrative
costs
Developing a Framework
Regulation and amending
implementing legislation (in
particular for GPG)
Eurostat One-off cost 35,682 2 EU officials (AD10) * 25 days
Monthly salary for AD10 is 9,000
22 days worked per month (based on Eurostat
2019: average of 36.2 hours worked per week) value in EUR
EC Compliance
costs
Monitoring compliance by MS Eurostat One-off cost 12,273 2 EU officials (AD10) * 15 days
Monthly salary for AD10 is 9,000
22 days worked per month (based on Eurostat
2019: average of 36.2 hours worked per week)
value in EUR
MS Administrative
costs
Adaptation and preparation for
revised text of the LMB FR
The 27 MS
bound by the
FR
One-off cost 91,075Derived from the baseline assumption re FTE
for the transposition of the LMB into national
law per MS (i.e. 2 official per MS, 5 to 10 days of
their time on this activity per month, 6 months
value in EUR
EC/MS/ Cost category Cost item
Stakeholder
s affected
Type
Value
(EUR)
Description of assumption
Comments/not
es
Here we assume that transposition of
amendments will take 30% of the total time
required to transpose the whole LMB initially.
MS Administrative
costs
Issuing guidance and training. "27 MS
affected
One-off cost 110,3942MS officials for 20 days value in EUR
MS Compliance
costs
Communicate the change. "27 MS
affected
One-off cost 88,3154 MS official for 8 days value in EUR
MS Compliance
costs
Data collections "27 MS
affected
Recurring 3,259,423Value based on Eurostat survey value in EUR
MS Administrative
costs
Reporting to EU "27 MS
affected
Recurring 10,349Derived from the baseline assumption re FTE
for reporting (i.e. 1.5 official per MS 2.5 days per
year)
value in EUR
Businesse
s
Costs for
participating in
the surveys
This would
affect the
businesses
selected
Recurring 4,618,254Value based on Eurostat survey value in EUR
Policy Option 3
EC Administrative
costs
Developing a Framework
Regulation and amending
implementing legislation (in
particular for GPG)
Eurostat One-off cost 42,8182 EU officials (AD10) * 30 days
Monthly salary for AD10 is 9,000
22 days worked per month (based on Eurostat
2019: average of 36.2 hours worked per week)
value in EUR
EC/MS/ Cost category Cost item
Stakeholder
s affected
Type
Value
(EUR)
Description of assumption
Comments/not
es
EC Compliance
costs
Monitoring compliance by MS Eurostat Recurring costs 13,9092 EU officials (AD10) * 17 days
Monthly salary for AD10 is 9,000
22 days worked per month (based on Eurostat
2019: average of 36.2 hours worked per week)
value in EUR
MS Administrative
costs
Adaptation and preparation for
revised text of the LMB FR
The 27 MS
bound by the
FR
One-off cost 106,254Derived from the baseline assumption re FTE
for the transposition of the LMB into national
law per MS (i.e. 2 official per MS, 7.5 days of
their time on this activity per month, 6 months
Here we assume that transposition of
amendments will take 35% of the total time
required to transpose the whole LMB initially.
value in EUR
MS Administrative
costs
Issuing guidance and training. "27 MS
affected
One-off cost 110,3942 MS officials for 20 days value in EUR
MS Compliance
costs
Communicate the change. "27 MS
affected
One-off cost 88,3154 MS official for 8 days value in EUR
MS Compliance
costs
Data collections "27 MS
affected
Recurring 19,021,716Value based on Eurostat survey value in EUR
MS Administrative
costs
Reporting to EU "27 MS
affected
Recurring 11,729Derived from the baseline assumption re FTE
for reporting (i.e. 1.7 official per MS 2.5 days per
year)
value in EUR
Businesse
s
Costs for
participating in
the surveys
This would
affect the
businesses
selected
Recurring 38,002,583Value based on Eurostat survey value in EUR
1.1.1. Mapping of the costs categories to typology used in the Annex II
Commission NSIs Businesses
One-off Recurrent One-off Recurrent One-off Recurrent
Direct adjustment
costs
Amending the
Framework
Regulation and
Implementing
Regulations
Communicate the
change + Issuing
guidance and
training
Direct
administrative
costs
Adaptation and
preparation for
revised text of the
LMB framework
regulation
Direct regulatory
fees and charges
Direct
enforcement costs
Monitoring
compliance
Data collections +
Reporting to the EU
Costs of for
participation in surveys
Indirect costs