REGULATORY SCRUTINY BOARD OPINION EU Talent Pool
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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.
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(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
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ANNEX: Quantification tables extracted from the draft impact assessment report
The following tables contain information on the costs and benefits of the initiative on which
the Board has given its opinion, as presented above.
If the draft report has been revised in line with the Board’s recommendations, the content of
these tables may be different from those in the final version of the impact assessment report,
as published by the Commission.
I. Overview of Benefits (total for all provisions) – Preferred Option
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