Writing good, unbiased reports – helpful advice for treasurers

It is good to know that officialdom takes its report writing duties seriously. The European Commission has its own internal guidelines on writing the Impact Assessments that are needed to justify any new regulations, and it makes a good piece of advice. For anyone doing investment or business project appraisals these guidelines could be adapted to become a good prompt sheet on what to look for and, especially, how to ensure an absence of bias.

Right now the Secretariat-General of the European Commission has been consulting on the new draft which has given the ACT the opportunity to urge that Impact Assessments be produced for all EU regulatory initiatives.

The consultation itself suggests that work on Impact Assessments should be proportionate (agreed). But they say this will now be taken to mean, for minor impact proposals, no IA. However, no IA means stakeholders get no opportunity to comment on it – hence the ACT’s position is that an IA consisting simply of the statement (assumption) that impact is trivial is essential, so that the assumption can itself be challenged.

In an earlier blog we wrote:

 But the Justice and Home Affairs directorate of the European Commission claimed there would be no impact when they proposed converting the Rome I Convention between States governing the law applicable to contracts into an EU Regulation (why?). So, naturally, with no impact, there was no need to make an Impact Assessment. 

If the Commission actually had done an Impact Assessment on the proposed Rome I Regulation, stakeholders’ comments on the IA should have been properly considered by the officials handling the IA. This would have made the faults much clearer much earlier. Officials focused on technical drafting naturally gave much less attention to comments on impact. With “better regulation” guidelines followed, we would all have saved a great deal of time.