The ECB’s merits and costs procedure in the field of European statistics
The merits and costs procedure
The introduction of new or substantially enhanced regulations on European statistics by the European System of Central Banks (ESCB) is subject to a systematic assessment of the merits and costs of the new data collection.
This approach ensures that new statistics are sufficiently justified by high-priority policy needs and it provides incentives to search for the most cost-effective solutions, with the aim to keep the burden placed on the reporting agents to a minimum.
EU Council Regulation (EC) No 2533/98 of 23 November 1998 concerning the collection of statistical information by ECB specifies in Article 3 the modalities for the definition of statistical reporting requirements. The ECB assesses the merits and costs of the collection of the new statistical information in question taking into account the specific collection characteristics, the size of the reporting population and the periodicity, and the statistical information already held by the statistical authorities or administrations.
Since 2000 a merits and costs procedure has been regularly carried out when developing any new statistics via new or amended ECB regulations.
It consists of a number of steps involving (i) ECB internal users, users at the national central banks (NCBs) and the European Commission as well as other EU bodies, who are requested to state, prioritise and justify their requirements; and (ii) compilers of the statistics in the ESCB and beyond and, typically, future respondents or their representative organisations in order to assess the costs of new requirements, with the aim of finding the most cost-effective data collection and ESCB compilation methods.
A qualitative assessment of the merits and costs is considered superior to a quantitative one at this stage.
Based on experience, and given the lack of a standard cost methodology across the EU in the field of European statistics, the ESCB applies a qualitative merits and costs procedure. This may be reviewed in the future depending on developments in the European legislation.
The steps of a merits and costs procedure
- A new statistical requirement emerges, users request new statistics
- Economic circumstances are changing constantly and the decision-making bodies of the ECB may need new statistics to adequately support monetary policy and financial stability analysis, which in turn underpins sound policy decisions.
- ESCB users describe the details of the new requirements and indicate priorities. User requirements are assessed and their usefulness is evaluated, including in terms of effective use (time-limited versus permanent need).
- Fact finding and statistical assessment
- The ECB’s Directorate General Statistics (DG Statistics) supported by the ESCB Statistics Committee (STC) investigates (i) whether existing statistics could cover the substance of the requirements; (ii) the extent to which a new collection is needed; and(iii) the alignment with international statistical reference standards.
- DG Statistics formulates some options for meeting the requirements and assesses their significance, feasibility and methodological aspects, in consultation with experts from the NCBs (via the STC). Where the new statistics requirements concern an area of shared responsibility for statistics at European level, the European Commission (Eurostat) and, if appropriate, the Committee on Monetary, Financial and Balance of Payment Statistics (CMFB) are informed and consulted.
- Costs and merits assessment based on options
- Assessment of costs. The costs of a number of possible options for the new statistical reporting scheme are estimated by the NCBs. The cost assessment is conducted on the basis of a scale ranging from 1 (limited (if any) increase in workload) to 5 (fundamental increase in workload). Costs for compilers, such as the ECB and NCBs, and costs for reporting agents are separately assessed by distinguishing between initial set-up costs (i.e. owing to changes in IT systems/procedures) and recurring regular costs (i.e. mainly owing to additional human resources). The NCBs assess the costs for reporting agents by contacting reporting agents on the basis of common national practice. National estimates are then aggregated into euro area/EU-wide estimates and presented to users to give them a chance to weigh these against the merits and possibly to reconsider, reformulate or reprioritise their requests.
- Assessment of merits and comparison with costs. After the cost estimation, a merits assessment is conducted by users to evaluate the extent to which the collection of new statistics would contribute to the fulfilment of the tasks of the ESCB. The assessment seeks to (i) explain the value added by the new statistics in a systematic manner; (ii) compare the various statistical features covered; and (iii) facilitate the ESCB’s internal decision-making process by including additional qualitative elements to justify the assessment of the various features..
The merits of the various options for a new reporting scheme are assessed on the basis of a number of aspects, such as (i) policy relevance and operational usefulness, (ii) international harmonisation and (iii) data quality enhancement/usefulness for analyses. Within each of these aspects there are several criteria to be assessed using a predefined set of points. This assessment is supplemented by a qualitative evaluation where users are asked to justify the points assigned to the various options and to provide additional detailed explanations.
- Drafting of the Regulation
Following the assessment of the merits against the costs, the STC defines the proposed features of the new reporting scheme. A new ECB regulation is drafted in collaboration with the ESCB’s Legal Committee (LEGCO).
- Governing Council decision
Following consideration by the ECB’s Executive Board, the Governing Council, with the benefit of comments from the General Council, will decide on new ECB regulations on European statistics after the end of the relevant public consultation.
 See Section 2.3, page 7, of Quality assurance procedures within the ECB statistics function, April 2008
 Recital 2 and recital 23 of Council Regulation (EC) No 2533/98 recall the framework for this provision.
Recital 2 reads: "Whereas, in order for statistical information to be effective as an instrument for the performance of the tasks of the ESCB, definitions and procedures for its collection need to be structured so that the ECB has the ability and flexibility to avail itself in a timely manner of high-quality statistics which reflect changing economic and financial conditions and take account of the burden imposed on reporting agents; whereas in so doing attention must be paid not only to the performance of the ESCB's tasks and its independence but also to keeping the burden placed on the reporting agents to a minimum."
Recital 23 reads: "Whereas, for the purposes of Article 5.1 of the Statute, the ECB is required to cooperate in the field of statistics with the Community institutions or bodies and with the competent authorities of the Member States or third countries and with international organisations; whereas the ECB and the Commission will establish appropriate forms of cooperation in the field of statistics in order to carry out their tasks in the most efficient way, trying to minimise the burden on reporting agents".