REGULATORY SCRUTINY BOARD OPINION EU Talent Pool

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    1_EN_avis_impact_assessment_part1_v2.pdf

    https://www.ft.dk/samling/20231/kommissionsforslag/kom(2023)0716/forslag/1998593/2781848.pdf

    EUROPEAN COMMISSION
    28.09.2023
    SEC(2023) 716
    REGULATORY SCRUTINY BOARD OPINION
    {COM(2023) 716}
    {SWD(2023) 716-718}
    EU Talent Pool
    Offentligt
    KOM (2023) 0716 - SEK-dokument
    Europaudvalget 2023
    ________________________________
    This opinion concerns a draft impact assessment which may differ from the final version.
    Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111
    regulatory-scrutiny-board@ec.europa.eu
    EUROPEAN COMMISSION
    REGULATORY SCRUTINY BOARD
    Brussels,
    RSB
    Opinion
    Title: Impact assessment / EU Talent Pool
    Overall opinion: POSITIVE WITH RESERVATIONS
    (A) Policy context
    The EU and its Member States face the prospect of an ageing population and shrinking
    labour force. EU employers are facing shortages in many professions. Skilled/qualified
    third-country nationals living outside the EU lack adequate channels to present themselves
    to EU employers.
    The EU Talent pool platform aims at addressing labour and skills shortages by supporting
    international recruitment of third country nationals via legal migration pathways.
    (B) Summary of findings
    The Board notes the additional information provided in advance of the meeting and
    commitments to make changes to the 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 suffciently elaborate on how the EU Talent pool platform
    will function in practice, in particular as regards its interoperability with
    national systems and articulation with Talent Partnerships.
    (2) The report does not sufficiently quantify and compare the costs and benefits of
    all options. It does not clearly separate the comparison of options in terms of
    effectiveness and efficiency from the analysis of impacts.
    2
    (C) What to improve
    (1) The report should better describe the expected practical functioning of the EU Talent
    pool platform. As regards Talent Partnerships, the report should provide an overview of
    the current situation and its possible evolution, and how the EU Talent pool platform will
    articulate with current and future partnerships, also in light of the voluntary nature of
    Member States’ participation in Talent Partnerships and/or the EU Talent Pool matching
    platform.
    (2) The report should be clear, upfront, about the assumptions behind gradual
    participation of the interested Member States. It should better highlight the EU value-
    added of the EU Talent pool platform and how it would provide support to Member States
    based on economies of scale and other identified benefits, including in parallel to their
    own instruments. It should further elaborate on the interoperability of the EU Talent pool
    with national systems. It should be also clear on how the list of occupations of EU and
    national relevance will be established. The specific objectives should be expressed in
    SMARTer terms, so that success of the initiative can be adequately measured.
    (3) The report should present the costs and benefits of all options in the main report.
    Moreover, it should provide further explanation of and evidence for the estimates and
    assumptions at the basis of the costs and benefits, and their potential evolution, including
    as regards Member States participation. It should consider providing ranges for some of
    the impacts facing higher levels of uncertainty, in particular as regard the net fiscal
    contribution of third country nationals and additional remittances to third countries.
    (4) The report should present a clear overview of all impacts and costs and benefits,
    (including key quantitative estimates) of all optons. The impact analysis should inform
    the scoring of the options and be clearly separated from the actual comparison of options,
    undertaken in terms of effectiveness, efficiency and coherence.
    The Board notes the estimated costs and benefits of the preferred option(s) in this
    initiative, as summarised in the attached quantification tables.
    Some more technical comments have been sent directly to the author DG.
    (D) Conclusion
    The DG may proceed with the initiative.
    The DG must revise the report in accordance with the Board’s findings before
    launching the interservice consultation.
    If there are any changes in the choice or design of the preferred option in the final
    version of the report, the DG may need to further adjust the attached quantification
    tables to reflect this.
    Full title Proposal for a Regulation of the European Parliament and of the
    Council establishing the EU Talent Pool
    Reference number PLAN/2022/2652
    Submitted to RSB on 8 September 2023
    Date of RSB meeting 27 September 2023
    3
    ANNEX: Quantification tables extracted from the draft impact assessment report
    The following tables contain information on the costs and benefits of the initiative on which
    the Board has given its opinion, as presented above.
    If the draft report has been revised in line with the Board’s recommendations, the content of
    these tables may be different from those in the final version of the impact assessment report,
    as published by the Commission.
    I. Overview of Benefits (total for all provisions) – Preferred Option
    Description Amount Comments
    Direct benefits
    Simplification of
    international
    recruitment
    procedures for
    employers (e.g.
    easier and faster
    identification and
    matching)
    EUR 150-400 (per employer)
    EUR 74 500 000 (for all employers
    participating in the EU Talent Pool)
    The costs associated with
    international recruitment are
    normally borne by employers
    (between EUR 1 500 and EUR 2
    500 per candidate. EUR 8 500-10
    000 is support of recruitment
    agencies).
    As the new platform would be free
    to use for business, and especially
    SMEs, cost savings for employers
    would result from the fact that they
    do not need to pay additional money
    to publish their vacancies online or
    recurring to external support
    services.
    n.a. (not quantifiable savings) Apart from direct costs savings, the
    preferred policy option would result
    in more effective and quicker
    recruitment of TCNs residing
    abroad. Benefits related to
    employers are mainly linked to
    time-savings across the various
    steps of the recruitment process
    (e.g. provision of information and
    personalised support, matching and
    searching tools and possibility to
    include fast-track procedures).
    However, these time savings are
    not quantifiable (see Annex 10).
    Cost savings would be mainly
    linked to the time saved throughout
    the entire recruitment process.
    Overall shorter recruitment
    procedures would mean that the
    third-country workers would
    commence their job sooner, which
    in turn could lead to more efficiency
    4
    on the labour market in terms of
    greater job matching and shortages
    filled, as well as potential increases
    in business productivity. This will
    also result in fiscal benefits in terms
    of tax contributions. In addition, the
    preferred PO would ensure better
    quality of matches and profiles, thus
    further benefitting businesses
    productivity and growth. The
    preferred option has also an
    important added value in reducing
    the barrier of entries for companies
    that cannot otherwise allocate
    financial resources to international
    recruitment, especially among
    Small and Medium Enterprises
    (SMEs). (See annex on SMEs test).
    EUR 11 500 (per employer)
    EUR 3 132 195 000 (all employers
    participating in the EU Talent Pool)
    A part from non quantifiable
    savings, the preferred option
    foresees the possibility for Member
    States to introduce fast-track
    procedures. If those measures are
    introduced by all Member States,
    the preferred option would reduce
    the total time needed for
    international recruitment by around
    3.5 months while increasing the
    chances of successful matches.
    Thus, this option has a relatively
    strong financial impact in terms of
    opportunity costs (additional
    revenue when conducting
    international recruitment with the
    Talent Pool).
    Simplification of
    international
    recruitment
    procedures for
    TCNs (e.g. easier
    and faster
    identification and
    matching)
    n.a. (not quantifiable) As described above with regard to
    the employers, TCNs would benefit
    from time-savings across the
    various steps of the recruitment
    process (access to single platform to
    find vacancies, information
    provision and support etc.).
    However, these time savings are not
    quantifiable. In addition, protection
    against unfair recruitment and
    working conditions under the
    preferred option is expected result
    in fairer payment and working
    conditions, which may increase
    5
    labour productivity in the medium
    to long run.
    EUR 3 750 (per TCNs)
    EUR 1 044 065 000 (for all TCNs
    recruited via the EU Talent Pool)
    A part from non quantifiable
    savings, the preferred option
    foresees the possibility for Member
    States to introduce fast-track
    procedures. If those measures are
    introduced by all Member States,
    the preferred option would reduce
    the total time needed for
    international recruitment by around
    3.5 months while increasing the
    chances of successful matches. In
    terms of opportunity costs this
    would result in additional wages
    stemming from the use of the EU
    Talent Pool.
    Indirect benefits
    Net Fiscal
    Contribution of
    TCNs
    EUR 1 510 (per TCNs’ capita) Public finances of Host member
    States would benefit from net fiscal
    contribution of Third Country
    Nationals. This covers not only all
    types of cash benefits received at
    the individual or household level,
    such as family benefits,
    unemployment benefits, and
    pensions, but this also includes the
    monetary value of in-kind benefits
    that individuals receive for health,
    social housing and education. In
    general, welfare expenditures in
    favour of EU nationals are higher;
    i.e., EU nationals tend to benefit
    more from public expenditures than
    migrants. The Preferred options
    will benefit concerned Member
    States, accordingly, depending on
    their participation to the EU Talent
    Pool.
    Indirect benefits
    Additional
    remittances to third
    countries
    EUR 1286 (per TCNs)
    EUR 348 521 447 (for all TCNs recruited
    via the EU Talent Pool)
    The economies of Third Countries
    will benefit from additional
    remittances sent by people coming
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    to work within the EU as a result of
    the successful matches provided by
    the EU Talent Pool.
    The estimation of increased
    remittances third countries is done
    by multiplying the average share of
    income which third-country
    nationals send home, estimated at
    15%, with the EU average annual
    median income, and by the number
    of additional third-country nationals
    who become mobile, or come /
    remain in the EU. This estimate
    must be taken with caution because
    it is based on a world-wide sample
    and the patterns of remittances may
    vary remarkably across continents
    and type of migrants.
    The share of remittances is taken
    from a UN online publication,
    “Remittances matter: 8 facts you
    don’t know” about the money
    migrants send back home. It
    represents a global, not EU-
    specific, share.
    II. Overview of costs – Preferred option
    Citizens/Consumers Businesses Administrations EC
    One-off Recurrent One-
    off
    Recurre
    nt
    One-off Recurrent One-off Recurre
    nt
    PO
    2
    Dire
    ct
    costs
    n/a n/a n/a n/a n/a EUR 10
    892 000*
    EUR 6
    936 556
    (IT
    platform
    develop
    ment)
    EUR 7
    769
    603
    (includi
    ng,
    staff, IT
    mainte
    nance
    and
    other
    costs)
    Indir
    ect
    costs
    n/a
    *Assuming 11 Member States participating (it includes 3 FTEs per Member States and
    Liaison officers in partner countries)
    7
    With regard to table III below, no new or removed administrative burden on businesses and
    citizens is expected under the preferred option.
    Electronically signed on 28/09/2023 19:59 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121