Ref. Ares(2020)7734157 - 18/12/2020
Ref. Ares(2022)1441016 - 25/02/2022
EUROPEAN COMMISSION
Regulatory Scrutiny Board
Brussels,
RSB
Opinion
Title: Impact assessment / Commission Implementing Regulation laying down a list
of high-value datasets
Overall opinion: POSITIVE
(A) Policy context
The public sector holds vast amounts of data, which could be a valuable resource for the
digital economy. However, this information is often not made available or re-used to its
full potential. Application of re-use charges, incompatibility of licensing terms, low data
standardisation and poor machine readability are obstacles to enhanced re-use of public
data.
This problem is most prominent for high-value datasets (HVDs), which can create
important benefits for society, the environment and the economy. Six themes are
concerned: companies, geospatial, earth observation and environmental, meteorological,
mobility and statistics.
The Directive on open data and the re-use of public sector information provides the legal
framework for this initiative. It aims to make the data held or funded by the public sector
easily available for re-use. This impact assessment accompanies the implementing act,
which defines a list of HVDs. It assesses different options for the identification of HVDs
and publishing arrangements.
(B) Summary of findings
The Board notes the useful additional information provided in advance of the
meeting and commitments to make changes to the report.
The Board gives a positive opinion. The Board also considers that the report should
further improve with respect to the following aspects:
(1) The report’s intervention logic is not sufficiently coherent. The problem
description and objectives are not sufficiently linked to the options.
(2) The report does not sufficiently justify the set of options.
________________________________
This opinion concerns a draft impact assessment which may differ from the final version.
Commission européenne, B-1049 Bruxel es - Belgium. Office: BERL 08/010. E-mail: xxxxxxxxxxxxxxxxxxxxxxxxx@xx.xxxxxx.xx
(C) What to improve
(1) The intervention logic should cover both the number and type of HVDs and the way the
public sector shares them. The current problems and objectives neglect the number and
type of HVDs, which does not allow a proper link between the problem description,
objectives and options. The report could be clearer on what defines the high value of data.
(2) The report should better explain why the options consist only of a higher intensity and
lower intensity intervention, applying to both the scope and the publication modalities. It
should justify why it does not consider any intermediate options, or options with gradual
elements, such as a longer implementation period for some datasets.
(3) The report should be clearer on the limitations and degree of uncertainty of the
quantitative estimates of the costs and impacts.
The Board notes the estimated costs and benefits of the preferred option(s) in this
initiative, as summarised in the attached quantification tables.
Some more technical comments have been sent directly to the author DG.
(D) Conclusion
The DG may proceed with the initiative.
The DG must take these recommendations into account before launching the
interservice consultation.
Full title
Commission Implementing Regulation laying down a list of
high-value datasets
Reference number
PLAN/2019/5761
Submitted to RSB on
18 November 2020
Date of RSB meeting
16 December 2020
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ANNEX – Quantification tables extracted from the draft impact assessment report
The following tables contain information on the costs and benefits of the initiative on
which the Board has given its opinion, as presented above.
If the draft report has been revised in line with the Board’s recommendations, the content
of these tables may be different from those in the final version of the impact assessment
report, as published by the Commission.
I. Overview of Benefits (total for all provisions) – Preferred Option (policy package 3)
Description
Amount
Comments
Direct benefits (range per annum 2024-2028)
Incremental direct economic impact (GVA/GDP) is estimated as
Economic impact
982 - 5734 million EUR
differential to baseline. Annual values for the years 2024 and 2028
are presented.
Incremental employment impact for the preferred policy package.
10 - 61 thousand persons
Employment
Total number of persons employed, estimated based on the
employed
employment coefficient/ratio to GVA for the EU27 ICT sector.
According to the definition of Eurostat, the governmental revenue is
the sum market output, of taxes, net social contributions, sales, other
current revenues and capital transfer revenues. Combining these
categories of governmental revenue, a weighted coefficient of EU27
Governmental
by GDP is obtained. Following the calculations of Eurostat, this
452 - 2638 million EUR
revenues
coefficient has and approximately value of 46% of GDP for the
EU27. Ratio is applied to the direct economic impact. Hence it
should be noted, that the indicator presented reflects the statistical
revenues for governments in general, induced by the stimulation of
GDP due to the policy interventions.
Indirect benefits (range 2024-2028)
Economic impact
2633 - 15225 million EUR
The analysis focuses on the indirect (forward) impact on
downstream industries, which is considered to be the major indirect
impact. To measure these impacts with regard to the PSI/HVD
28 - 161 thousand persons
economic activity, results of the EU Data Monitoring have been
Employment
employed
analysed. As a result, for the indirect (forward) impact a magnitude
between ca. 2.5 and 3.0 has been identified. To estimate the indirect
(forward) economic impact, multipliers at the lower bound between
Governmental
1211 - 7004 million EUR
2.6 and 2.8 have been applied to the direct impacts.
revenues
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II. Overview of costs – Preferred option (policy package 3)
Citizens/Consum
Businesses
Administrations
ers
One-off
One-off
One-off
Recurrent
Recurrent
Recurrent
Recurr
One-
Recurre
One-off
(low
(high
(medium/
(low
(high
(medium/
ent
off
nt
estimate) estimate) average)
estimate)
estimate)
average)
Defining
Direct
list of
n/a
n/a
n/a
n/a
24.9m€
435.9m€
122.3m€
153.1m€ 1 316.9m€
473.6m€
costs
HVDs free
from
barriers
Indirect
n/a
n/a
n/a
n/a
n/a
n/a
inhibiting costs
their reuse
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Electronically signed on 18/12/2020 11:20 (UTC+01) in accordance with article 11 of Commission Decision C(2020) 4482