Analytical Competence

   

To what extent does the government effectively incorporate sustainability assessments within the framework of RIAs?

EUOECD
 
High-quality sustainability assessments are incorporated within regulatory impact assessments.
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High-quality sustainability assessments are, for the most part, incorporated within regulatory impact assessments.
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Austria
The potential environmental effects of legislative proposals must be evaluated as part of RIAs, as must effects on employment. Various decrees require that financial and other issues be assessed. Analysis may focus on short-term, medium-term, or long-term effects according to specific RIA legal requirements, though the typical analysis focuses on a period of five years. In its annual RIA reports, the government explicitly commits to addressing the SDGs.

While Austria has an overarching sustainability strategy, there remains considerable room for improvement. However, the formation of a new government in early 2020, which included the Greens as a junior coalition partner to the ÖVP, has led to several improvements, even if some are partially symbolic. In 2020, the government published its first voluntary national report on the implementation of SDGs (Freiwilliger Bericht zur Umsetzung der Nachhaltigen Entwicklungsziele / SDGs). In 2021, for the first time, the government’s budget included specific information about which SDG is to be accomplished by the respective legislative projects of each department. This means that legislative goals are now systematically linked to sustainability goals. Furthermore, efforts have been made to engage and involve Austrian civil society. In September 2021, the first SDG Dialogforum Österreich: Building Forward mit der Agenda 2030 took place. The forum used a hybrid format with participants representing various sectors and was intended to provide the basis for intensive collaboration between government, public administration, the science community, and civil society. This has been followed by an SDG Dialogue Forum 3.0 in October 2023.

In late 2022, the cabinet decided that Austria would present its second voluntary national report concerning the implementation of Agenda 2030 to the United Nations by July 2024. The plan was to use ideas and insights for that report gained from the 3.0 Dialogue Forum.
Citations:
https://www.bundeskanzleramt.gv.at/themen/nachhaltige-entwicklung-agenda-2030.html

https://sustainabledevelopment.un.org/content/documents/26661VNR_2020_Austria_Report_German.pdf

https://www.bundeskanzleramt.gv.at/themen/nachhaltige-entwicklung-agenda-2030/veranstaltungen-agenda2030/sdg-dialogforum-3-0.html
Denmark
When RIAs are conducted, they must cover all positive or negative consequences of an economic, administrative or environmental nature that are likely to affect the state, municipalities, regions, business, citizens or relations with the European Union. This includes questions of sustainability. Sustainability is a central concern in government policy and includes economic, fiscal and environmental sustainability.

Since the enactment of the Climate Law, the Climate Council has produced a yearly report assessing whether current policies are sufficient to meet the emission goals set in the law. The council is independent from ministries and has its own secretariat. Although these reports are not part of formal RIAs, they significantly inform policy because they receive considerable attention in cases when they suggest that it is very unlikely that the government will meet its own goals.
Finland
Generally speaking, aspects of sustainability are an integral part of the assessment process. Variations between forecasts and actual outcomes are monitored over time. Every four years, the government submits a report to parliament on the progress made in implementing the Agenda 2030 goals in Finland. The report additionally reviews how government goals align with the Sustainable Development Goals (SDGs).

However, the government does not have a specific strategy for implementing Agenda 2030 goals that has been broken down into concrete action plans. The status of sustainable development in Finland is systematically monitored through agreed-upon indicators within the National Sustainable Development Monitoring Network. Experts from various thematic areas compile annual assessments based on these indicators, providing comprehensive descriptions of the state of sustainable development in different domains. Citizens actively contribute to this assessment through the annual Citizens’ Panel on Sustainable Development. These facts demonstrate the capacity to monitor sustainable development.

The Prime Minister’s Office and the Finnish National Commission on Sustainable Development review discussions, selecting topics for further promotion. Key messages are consolidated and presented annually in May at an event addressing the current state of and future prospects for sustainable development. The overarching objectives of the monitoring and ensuing discussions are to: 1) generate a holistic understanding of Finland’s success in advancing sustainable development; and 2) identify challenges and pain points in sustainable development, helping to inform the formulation of consistent policies.

The monitoring process aligns with the Society’s Commitment to Sustainable Development instrument, encapsulated in “The Finland we want by 2050,” which serves as Finland’s implementation of the global 2030 Agenda for Sustainable Development and its Sustainable Development Goals. The commitment outlines eight objectives representing the envisioned state of sustainable development in Finland by 2050, as defined by the Finnish National Commission on Sustainable Development in 2013 (Finnish National Commission on Sustainable Development n.d.). Progress toward these objectives is monitored through 10 indicator baskets associated with the commitment. These indicators, established in 2017 by a network of experts, are updated annually. Public authorities familiar with the content of each basket provide interpretations of the indicators, assessing the state of the basket from the perspective of sustainable development. The updating process occurs between September and May, with a preliminary estimate for the timing of each basket’s update.

To sum up, sustainability checks are not legally required as part of RIAs, and they do not include analyses that span multiple time periods, including short-term, medium-term and long-term perspectives. The limitation of the mechanism is that there is no legal requirement for sustainability assessment, and there is no official government strategy for the implementation of Agenda 2030. However, the sustainability assessments draw upon a comprehensive set of appropriate impact indicators that encompass aspects of economic, social and environmental sustainability. The analyses are provided for different time periods, including short-term, medium-term and long-term perspectives.
Citations:
Finnish National Commission on Sustainable Development. n.d. “Society’s Commitment to Sustainable Development.” https://kestavakehitys.fi/en/commitment2050
Germany
Germany has committed to a formal sustainability strategy since 2002 and has continuously developed this strategy, now aligning with the SDGs. The last update of the strategy occurred in 2021 (Bundesregierung, 2021), and the next revision is ongoing, with a further update expected in 2024 (Bundesregierung, 2023).

There are no explicit SDG-related action plans, but the ministries are bound by this strategy when developing their policies. The Federal Chancellery leads on sustainability issues, and oversight, advisory, consultative, and cross-government coordination mechanisms are in place. A system of SDG-related indicators is used to define targets and check for compliance.

Since 2009, the Joint Rules of Procedure of the Federal Ministries (GGO) have stipulated that impact assessments must demonstrate whether the effects of a project align with sustainable development (Section 44 (1) sentence 4 GGO). This requirement entails examining the effects on the Sustainable Development Goals (SDGs) and their specific targets, as well as the goals and indicators of the German Sustainable Development Strategy, in detail. The GGO explicitly requires consideration of the long-term consequences of the measure. To facilitate this assessment, a web-based tool for electronic sustainability assessment (eNAP) is available (BMJ, 2023).

In the German Bundestag, the Parliamentary Advisory Council on Sustainable Development monitors German sustainability policy. One of its tasks is to oversee the sustainability assessments conducted by the ministries as part of the legislative impact assessment.

The capacity to measure progress is generally strong. Germany’s statistical agencies, both at the federal and state levels, possess substantial capabilities, high expertise, and integrity, ensuring they provide reliable data on progress concerning the SDGs.
Citations:
Bundesregierung. 2021. Deutsche Nachhaltigkeitsstrategie, Weiterentwicklung 2021. Berlin.

Bundesregierung. 2023. “Die Deutsche Nachhaltigkeitsstrategie, Ein Kompass für die Zukunft.” www.bundesregierung.de/breg-de/themen/nachhaltigkeitspolitik/deutsche-nachhaltigkeitsstrategie-318846

Bundesministerium der Justiz. 2023. “Nachhaltige Gesetzgebung.” www.bmj.de/DE/ministerium/nachhaltigkeit/gesetzgebung/gesetzgebung_node.html
Sweden
Environmental sustainability has been well integrated into the policy process. All government bills, procurements, and directives to commissions of inquiry are required to be assessed to determine their impact on environmental sustainability.

As for other types of sustainability criteria, there has been little evidence about the extent to which they are considered in the RIA process. The 2022 memorandum issued by the Department of Finance aims to change this by proposing clear social, economic, and environmental dimensions in RIAs (Government Offices of Sweden, 2022).
Citations:
Government Offices of Sweden. 2022. Bättre konsekvensutredingar. Ds 2022:22 https://www.regeringen.se/rattsliga-dokument/departementsserien-och-promemorior/2022/08/ds-202222/
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Canada
Canada has maintained a robust system of environmental assessments for many years (Mitchell et al. 1977). Although these assessments are typically project-based, they are generally high-quality and rigorous, including public hearings and other participatory mechanisms. Technically, formal RIAs are used to examine these impacts.

The Cabinet Directive on Regulation requires departments to assess the positive and negative environmental impacts of regulatory proposals as part of the RIA. Guidance from the Treasury Board directs departments to account for environmental impacts on ecosystems, carbon emissions, and pollution levels, including over the long term where feasible.

RIAs often include a section detailing the potential positive or negative impacts a regulatory change may have on the environment or environmental goals. When relevant, RIAs quantify impacts on sustainability, such as estimating changes in greenhouse gas emissions or effects on biodiversity resulting from a new regulation (Hunsberger et al. 2020).
Citations:
Hunsberger, Carol, Sarah Froese, and George Hoberg. 2020. “Toward ‘Good Process’ in Regulatory Reviews: Is Canada’s New System Any Better than the Old?” Environmental Impact Assessment Review 82: 106379. https://doi.org/10.1016/j.eiar.2020.106379

Mitchell, B., R. Turkheim, and R. R. Krueger. 1977. “Environmental Impact Assessment: Principles, Practices, and Canadian Experiences.” In Managing Canada’s Renewable Resources, 47–66. Toronto: Methuen.
New Zealand
New Zealand has adopted the United Nations’ Sustainable Development Goals (SDGs) and integrated them into its policy framework. Although there is no single, comprehensive national strategy solely dedicated to sustainable development explicitly based on the SDGs, the government has aligned its policymaking with these goals and undertaken various initiatives to achieve them. For example, Statistics New Zealand has developed Indicators Aotearoa New Zealand – Ngā Tūtohu Aotearoa, a set of statistical indicators focusing on sustainable development and the need to report on the SDGs (Stats NZ 2019). Another example is the Living Standards Framework (LSF) developed by the Treasury, which is designed to prompt thinking about the sustainability implications of policy (Treasury 2022).

There is no legal requirement explicitly mandating sustainability checks as part of RIAs. Nevertheless, cabinet and Treasury guidelines strongly encourage the consideration of sustainability factors in the RIA process. In particular, these guidelines advocate for a “triple bottom line” approach, emphasizing the consideration of economic, social and environmental impacts.

In addition, broader legal frameworks often encourage government agencies to consider sustainability factors as an integral part of their regulatory impact assessments. For example, the Resource Management Act requires environmental considerations in planning and decision-making processes.
Citations:
Stats NZ. 2019. “Indicators Aotearoa New Zealand – Ngā Tūtohu Aotearoa.” https://www.stats.govt.nz/indicators-and-snapshots/indicators-aotearoa-new-zealand-nga-tutohu-aotearoa

The Treasury. 2022. “Our Living Standards Framework.” https://www.treasury.govt.nz/information-and-services/nz-economy/higher-living-standards/our-living-standards-framework
Netherlands
When in the early 1970s, environmental impact assessments (EIAs) blew over from the United States to Europe, imitation and adoption was fairly straightforward. The purpose was – and still is – to give EIA its rightful place in public decision-making and thereby also increase policy transparency and the involvement of stakeholders and citizens. An Environmental Impact Law determined an EIA procedure in the Netherlands, specifying conditions for public registration of new activities, creating an expert commission (Commissie mer) to advise on all quality aspects and definining the scope of the EIA report (both at the start – scoping document – and the end – the quality assessment – of the report-writing process). It defined the legal requirements for positive decisions by the competent authorities (mostly provincial and municipal governments), although these of course frequently initiated initiatives requiring EIAs themselves themselves. This latter fact underlined the importance of the EIA Commission (Commissie mer) as an independent third party of experts. Under the current EMA (valid until 1 January 2024), competent authorities are required to request all strategic environment assessments (SEAs) and ordinary EIAs for certain complex projects, and ensure that these are reviewed by the National Commission for Environmental Assessment (NCEA). In effect, this means the NCEA has a monopoly for independent quality review of these SEAs and EIAs. In 2017, the NCEA reviewed about 140 projects, 50 of which had been requested voluntarily. The NCEA reviews the documents to ensure the information is complete and correct. In 2017, for example, 70% of the assessments reviewed proved to lack essential information.

Since those early days, the volume and complexity of legislation relating to spatial and environmental aspects of the physical environment and its impact on human beings (particularly but not only, health) has exploded. As a result, current environmental law is fragmented and divided among a large number of different laws and regulations. Each law focuses on a partial interest, and has its own system and terminology. As a result, one law sometimes contradicts another. Environmental law thus delays and frustrates many activities, and sometimes even makes new developments toward greater sustainability impossible.

In the early 2010s, experts started to contemplate possibilities for a more consistent, integrated and procedurally simpler and faster approach to EIA.
The key idea was to turn the attitude of EIA experts and policymakers from, essentially, “No, unless…” into its opposite, “Yes, provided that…” In an “environment vision,” a municipality defines the boundary conditions that activities must meet. As a result, the EIA report, now considered the starting point for developing an environment vision, also changes from thinking about a new activity “from the inside out” to thinking “from the outside in” – that is, the new activity as accommodating and fitting into a broad and flexible environment vision. During the term of the plan, details regarding which developments occur where can be filled in more flexibly than before. Monitoring and interim evaluation studies are part of a flexible, learning-oriented new planning style. Breaking down complex new initiatives into time-specified action plans becomes a repeated learning process without any specific time horizon.

By 2016, the effort to streamline a confusing patchwork of sectionally segmented zoning plans for coherent sustainable development goals resulted in the preliminary decision to replace the rigid system of area-wide “bestemmingsplannen,” or zoning plans, with open and flexible “environment visions” (“omgevingsvisie”) to be developed by all competent authorities. The new Environment Act integrates all 26 laws and regulations in the environmental domain into one law, four governmental decrees or general administrative orders (Algemene Maatregel van Bestuur, AMvB), and one regulation. This system change is among the largest legislative operations in the Netherlands’ recent history, and has major consequences in practice. For this reason, the government reserved a long period for experimenting and experience gathering before actually putting the law into force on 1 January 2024. Both the Ministry of Infrastructure and Environment and the National Commission for Environmental Assessment (NCEAS) have published a considerable number of pilot reports with case studies. To what extent this is a representative sample or the result of cherry-picking is uncertain.

To make the implementation and operation of the law as simple and unambiguous as possible, the Environmental Law systematics are based on those of EU regulations. By keeping the granting of permits as simple as possible, procedures will not take unnecessarily long. Initiators can quickly obtain clarity for all the activities they wish to carry out by making a single application at a single desk (one-stop shop). To make integrated licensing and decision-making possible, good and coherent data must be available. Digital support – one of the crucial requirements for putting the Environment Act in force – turned out to be a near insurmountable bottleneck, resulting in five delay decisions between 2016 and 1 January 2024, when the law finally took effect.

Of course, not everybody is happy about having a broad and flexible Environment Act. Many interest and stakeholder groups have lost their legal shields; more generally, citizen groups, stakeholder organizations and legal experts have voiced grave concerns about legal assessments and protection under the law. The implementation capacity of the cottage industry of consultancies that produce EIA reports, as well as the supervisory quality-testing capacity of the NCEAS will be stretched to the utmost in the beginning. ICT support is also likely to remain a bottleneck. It could be argued that the idea of broadening EIA procedures and making them more flexible with a view to consistent sustainability policymaking boils down to an effort to replace closed expert and legal judgment with more open and flexible political considerations, in which competing interests will have to be balanced via integrated political judgments. Whether or not this will be successful will in large part depend on the degree to which the public genuinely participates in vision development and monitoring practices.
Citations:
Mer Commissie voor de minirapportage. n.d. “Factsheet: Milieueffectrapportage in een notendop.” commissiemer.nl, consulted January 14, 2024

Infographic, Hoe werkt de mer-procedure. commissiemei.nl, consulted 14 January 2024

NOS. 2015. “Tientallen wetten gebundeld in een Omgevingswet.” Nieuws, May 31.

Ministerie van Infrastructure en Milieu. April 2016. “Omgevingswet in het kort. Ruimte voor ontwikkeling, waarborgen voor kwaliteit.”

Commissionmer. n.d. “Infographic Een goed omgevingsplan (begint) met milieueffectrapportage.”

G. Hoevenaars. 2018. “Independent Quality Control: How Does It Work in the Netherlands?” In Netherlands Commission of Environmental Assessment, Views and Experiences of the NCEA.

G. Hoevenaars. 2018. “The Role of the NCEA in the Netherlands.” In Netherlands Commission of Environmental Assessment, Views and Experiences of the NCEA.

Dirkzwager Legal and Tax. 2024. “Omgevingswet.” www.dirkzwager.nl/omgevingswet/
USA
The National Environmental Policy Act of 1969 requires all federal agencies to prepare Environmental Impact Statements (EIS) and Environmental Assessments (EAs) when pursuing policies that affect the environment (Eccleston and Doub 2016). However, some types of actions can be granted a categorical exclusion (Tzoumis and Finegold 2000).
NEPA also established the Council on Environmental Quality (CEQ), which sits within the Executive Office of the President (EOP) and is tasked with coordinating environmental and sustainability objectives across the federal departments (Conant and Balint 2011).
There is no overarching statutory requirement for sustainability assessments in RIAs. However, several executive orders and agency guidelines address this issue. President Joe Biden issued Executive Order 13990, which instructs federal agencies to prioritize environmental justice and consider climate change impacts in regulatory actions (Polk 2021).
The Office for Management and Budget (OMB) has issued circulars (A-4 and A-11) that instruct agencies to include environmental impact assessments in the Regulatory Impact Analyses (RIAs) (Ellig and Brito 2009). Although the term “sustainability” is not explicitly used, the instructions effectively aim at sustainable goals.
Citations:
Kelly, Tzoumis, and Linda Finegold. 2016. “Looking at the Quality of Draft Environmental Impact Statements over Time in the United States: Have Ratings Improved?” Environmental Impact Assessment Review.
Charles Eccleston and J. Peyton Doub. 2016. Effective Environmental Assessments. Boca Raton: CRC Press.
James Conant and Peter Balint. 2011. “Environmental Reviews and Case Studies: The Council on Environmental Quality at 40.” Environmental Practice.
Amber Polk. 2021. “President Biden’s Executive Orders on the Environment: Praiseworthy Policy, Political Red Herring, or Both.” University of Illinois Law Review.
Jerry Ellig and Jerry Brito. 2009. “Toward a More Perfect Union: Regulatory Analysis Performance Management.” Florida State University Business Law Review.
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Australia
The Australian government has developed frameworks to account for environmental sustainability in regulatory impact statements. The Office of Impact Analysis (OIA) provides guidance on evaluating environmental assets, describing impacts, and accounting for uncertainty. In addition to these general frameworks, there are specific plans to preserve high-value environmental assets, like the Great Barrier Reef (DCCEEW 2023). Despite these frameworks, Australia’s emissions have not significantly decreased, and some high-emitting industries have increased outputs. Some assessments of the sustainability assessments (and other regulatory measures) suggest that the framework is new and therefore it is too early to assess its impact on actual practice, while others point to emerging loopholes and weak implementation as emerging issues (Kraner-Tucci 2022).
Citations:
OIA. 2023. “Environmental Valuation.” Office of Impact Analysis, Australian Government Department of the Prime Minister and Cabinet. https://oia.pmc.gov.au/resources/guidance-assessing-impacts/environmental-valuation

DCCEEW. 2023. “Climate Change.”Energy, the Environment and Water. https://www.dcceew.gov.au/climate-change/policy/environment

Kraner-Tucci, R. 2022. “Australia Ranks ‘Very Low’ on Climate Action Performance.” Pro Bono Australia. https://probonoaustralia.com.au/news/2022/11/australia-ranks-very-low-on-climate-action-performance/
Czechia
Sustainability checks are an integral part of every RIA, but they are not very comprehensive (Cvachovcová and Polášek 2020). The checklist requires a response to the question of whether there are effects on social, economic and
Environmental issues and the impacts they have are indicated through a set of 2016 amendments to the RIA guidelines, which specified how to assess or quantify these effects. Relevant ministries refine these criteria on an ongoing basis. Changes made in 2023, referred to as Effective Regulatory Impact Assessment, strengthened sustainability checks.
Citations:
Cvachovcová, P., and M. Polášek. 2020. “Možnosti zahrnutí perspektivy udržitelného rozvoje do systému.”
hodnocení dopadů v ČR. Prague. https://www.cr2030.cz/zavazky/wpcontent/
uploads/sites/4/2021/03/Moz%CC%8Cnost i-zahrnuti%CC%81-perspektivyudrz%
CC%8Citelne%CC%81ho-rozvoje-do-syste%CC%81mu- hodnocen%C3%AD-dopadu%CC%8A-v-
%C4%8CR_final.pdf
Estonia
The dimension of sustainability is included in the methodological guidelines for RIA. The guidelines demand an assessment of the reviewed policy’s impact over the short, medium and long term. However, sustainability concerns play a marginal role in the overall impact assessment process. The existing set of indicators is not explicitly linked to a sustainability check. Estonia’s long-term strategy, Estonia 2035, presents an integrated vision for the country’s balanced and sustainable development. Nine national priorities, outlined in the strategy, explicitly reference the 17 Sustainable Development Goals.
Norway
There is no formal requirement for sustainability checks in the Regulatory Impact Assessment (RIA) regime. Sustainability impact assessments, as defined by the OECD, should include all three dimensions of sustainability. Since the inclusion of considerations for both society and the environment in the Norwegian RIA regulation in 2017, one could argue that sustainability checks are being performed, even without an explicit formal requirement.

In practice, two indirect mechanisms strengthen the de facto sustainability assessments. First, all new policy initiatives must align with Norway’s commitments to adopt EU policies, as laid out in Norway’s EEA agreement with the EU. Second, new policies must not violate Norway’s international commitments and obligations. This implies that sustainability assessments are being conducted, but not in a nationally standardized manner, nor are they systematically monitored.
 
High-quality sustainability assessments are rarely incorporated within regulatory impact assessments.
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Greece
The Greek government has developed a sustainable development strategy based on the Sustainable Development Goals (SDGs). This strategy has been translated into concrete National Action Plans to implement specific SDGs, though these plans do not yet cover all policy areas. For example, there are action plans in areas such as public health, mental health, protection of people with disabilities, social economy, energy conservation, green public procurement, and digital skills.

Sustainability checks are mandated by law to be integrated into RIAs. Civil servants responsible for drafting RIAs must complete a template provided by the Secretariat of Legal and Parliamentary Affairs, which includes specific fields for sustainability checks, such as questions on the environmental impact of proposed legislation.

However, these checks are sometimes limited by a lack of empirical data or by time constraints during the preparation of draft legislation. External pressures or the ambition of government ministers to demonstrate productivity may also lead to rushed RIA preparation.
Citations:
Greece’s sustainable development strategy is presented in detail in the “National Voluntary Review 2022 on the Implementation of the 2030 Agenda for Sustainable Development”: https://hlpf.un.org/sites/default/files/vnrs/2022/VNR%202022%20Greece%20Report.pdf

Regarding sustainability checks, Law 4622/2019 article 62 paragraph 3 requires that the RIA includes detailed data.
Ireland
Ireland’s most recent assessment of its sustainable development strategy, based on the Sustainable Development Goals (SDGs), was conducted in October 2022 (DECC 2022). This assessment suggests that the strategy is actively implemented. However, when Ireland’s performance in achieving the environmental SDGs is benchmarked against peer nations in the EU, the results indicate that capacity-building for implementation was poor (Murphy et al. 2023).

While RIA is effectively mandatory for all primary laws and major subordinate regulations, and the environment is one of seven focus areas, the assessments are largely qualitative (OECD 2021). The current national guidelines, which have been in place since 2009, provide little guidance on sustainability beyond mentioning “environment,” “poverty” and “socially excluded or vulnerable groups.” This suggests that the guidance is both outdated and inadequate for addressing the complexity of sustainable development tasks.
Citations:
https://www.gov.ie/en/policy-information/ff4201-17-sustainable-development-goals/
Department of the Environment, Climate and Communications (DECC). 2022. Policy Update on Ireland’s Implementation of the Sustainable Development Goal Targets. Ireland: Government Publication.
O’ Riordan, T. 2024. Ireland’s Climate Change Assessment: An Independent Review. Wexford: EPA.
Murphy, E. et al. 2023. “Nation-Based Peer Assessment of Europe’s Sustainable Development Goal Performance.” PLoS ONE 18 (6): e0287771. https://doi.org/10.1371/journal.pone.0287771
OECD. 2021. OECD Environmental Performance Reviews: Ireland 2021. https://doi.org/10.1787/9ef10b4f-en
Italy
Italy formally adopted a Sustainable Development Strategy based on the SDGs, approving a detailed implementation plan in 2017, revised in 2022. The strategy encompasses five major programs aimed at achieving the Sustainable Development Goals, built around five fundamental pillars of the 2030 Agenda: People, Planet, Prosperity, Peace, and Partnership. These pillars unfold into fifteen strategic choices covering various areas, from responsible management of natural resources to addressing social inequalities. The renewed NSSD introduces annual monitoring targets against 55 headline indicators.

The strategy also highlights “sustainability vectors” and proposes Policy Coherence for Sustainable Development (PCSD), with an annexed National Action Program for PCSD, and multilevel governance as cross-cutting implementation mechanisms. Additionally, it emphasizes the role of culture in sustainability, focusing on education, training, and communication.

Active participation, reinforced by the Rules of Procedure of the Forum for Sustainable Development, is essential for a well-structured and inclusive development path. Despite gradual improvements, sustainability reviews remain underdeveloped. Reports from the Prime Minister’s Office to parliament indicate that sustainability reviews are not yet systematically integrated into the RIA and often prioritize economic indicators over social and environmental ones.

A 2017 decision mandated stricter control over adopting sustainability criteria in regulation by the Prime Minister’s Office and the Ministry of the Environment. However, the attention to this aspect in RIA reports has not improved significantly. The monitoring of the Sustainable Development Goals (SDGs) is not based on the RIA procedure, and the government is slow in responding to emerging problems, though regional applications, such as in Emilia Romagna and Trentino-Alto Adige, are more coherent.

Currently, the RIA procedure and the assessment of SDG achievement levels are two separate streams of activity at the national government level.
Citations:
- Italian Strategy for Sustainable Development: https://www.mase.gov.it/sites/default/files/archivio/allegati/sviluppo_sostenibile/ALL1_SNSvS_2023_Strategia_e_allegati.pdf
- Last monitoring report (2021-22): https://www.mase.gov.it/sites/default/files/archivio/allegati/sviluppo_sostenibile/SNSvS_eventi/relazione_annuale_stato_attuazione_Strategia_Nazionale_Sviluppo_Sostenibile-2021-22.pdf

-Presidenza del Consiglio dei Ministri. 2023. RELAZIONE AL PARLAMENTO SULLO STATO DI
APPLICAZIONE DELL’ANALISI DELL’IMPATTO DELLA REGOLAMENTAZIONE. https://presidenza.governo.it/DAGL/uff_studi/Relazione_2022_AIR.pdf
Latvia
A cabinet regulation outlines how to assess the impact of new laws and regulations and evaluate their effect on the economy, society, environment, and governance. Although impact assessment does not cover the sustainable development goals (SDGs), sustainability is considered via environmental sustainability, climate neutrality, and potentially its impact on social situations.

The State Audit Office’s 2023 audit of the implementation of sustainable development goals found that Latvia requires better management of the entire process toward these goals. There is no specific implementation plan, and stakeholders lack clear awareness of their tasks and roles. The implementation process of the SDGs in Latvia needs to be better organized, managed, and overseen (Valsts Kontrole, 2023). Consequently, Latvia lacks a regular, systematic, and inclusive approach to sustainable development goals. This deficiency negatively affects public perception of the SDGs and the subsequent implementation steps expected in both the public and private sectors.

Integrating sustainability assessments into Regulatory Impact Assessments is still evolving. These limitations may include a lack of comprehensive and diverse impact indicators and constraints in expertise and resources. The extent to which these assessments provide analyses for different periods – short-term, medium-term, and long-term – must be more consistent across all policy-planning documents.

The integration of sustainable development goals (SDGs) into Latvia’s highest-level national long-term and mid-term planning documents has not yet been fully realized. This incomplete integration presents challenges in ensuring the consistent application of these goals across different levels of planning. Not all SDGs relevant to Latvia have been effectively incorporated into its policy-planning documents, indicating room for improvement in aligning national planning with sustainable development objectives.
Citations:
Ministru kabinets. 2021. “Ministru kabineta noteikumu Nr. 617 Tiesību akta projekta sākotnējas ietekmes izvērtēšanas kārtība.” https://likumi.lv/ta/id/325945-tiesibu-akta-projekta-sakotnejas-ietekmes-izvertesanas-kartiba
Valsts kontrole. 2023. “Vai Latvijā ir izveidoti priekšnosacījumi ANO ilgtspējīgas attīstības mērķu sasniegšanai?” https://lrvk.gov.lv/lv/revizijas/revizijas/noslegtas-revizijas/vai-latvija-ir-izveidoti-prieksnosacijumi-ano-ilgtspejigas-attistibas-merku-sasniegsanai
Slovakia
Slovakia’s national sustainability strategy, which sets national SDG priorities, was adopted in 2016. The government regularly evaluates progress. For example, the “Second Report on Results in Achieving National Priorities of the Agenda 2030” was approved by the government on June 22, 2022, and the “Second Voluntary National Review of the Slovak Republic – VNR” was published in 2021. The main coordinating body for implementing the 2030 Agenda in Slovakia is the Government Council of the Slovak Republic for the 2030 Agenda for Sustainable Development, founded in 2017. In addition to these official materials, the Slovak Statistical Office published a comprehensive report in March 2023 about the achievement of selected SDG targets (Fričová, 2023).

The VNR report states (141): “…when it comes to means of implementation, the strategy falls short of aligning the national budget with SDGs, and it also does not address some of the systemic transformations in governance structure which are necessary for more effective implementation of policies.” The report notes, “in several cases, indicators are reminding us of considerable gaps and the need to speed up implementation.” These gaps have been exacerbated by multiple crises, including climate change, COVID-19, and the war in Ukraine. “Uneven progress in the past eight years has demonstrated that, in addition to setting ambitious global goals and establishing worldwide monitoring mechanisms, a more intensive international coordination of implementation is also inevitable.”

Systemic sustainability checks are not legally required as part of RIAs. However, the current scope of RIAs encompasses many sustainability elements. In practice, though, sustainability checks are neither prominent nor conducted systematically. The country’s monitoring capacity – the availability of data, information, and statistical abilities – is only partly sufficient to measure progress. The VNR report states: “data continue to be a serious challenge” (140). Čepelová and Douša (2020) also emphasize the lack of a sound system of indicators and deficiencies in systematic monitoring for guiding public policies.
Citations:
Ministry of Investment, Regional Development and Informatization of the Slovak Republic. 2022. Druhá správa o dosiahnutých výsledkoch v národných prioritách implementácie Agendy 2030. Bratislava: Ministry of Investment, Regional Development and Informatization of the Slovak Republic.

Ministry of Investment, Regional Development and Informatization of the Slovak Republic. 2023. Druhá dobrovoľná správa SR pre OSN o implementácii Agendy 2030. Bratislava: Ministry of Investment, Regional Development and Informatization of the Slovak Republic.

Fričová, I. 2023. Slovenská republika a ciele udržateľného rozvoja. Bratislava: Slovenský štatistický úrad.

Čepelová, A., and M. Douša. 2020. “Slovakia and the Czech Republic on the Path Towards Sustainable Development.” Bulletin of Geography. Socio-Economic Series 47 (47): 7–25. https://doi.org/10.2478/bog-2020-0001
Spain
Adopted in 2021, the Spanish Sustainable Development Strategy 2030 was approved by the Council of Ministers with input from all ministerial departments, autonomous communities, and local entities. Since then, the government has established a comprehensive institutional governance system to ensure that the Sustainable Development Goals (SDGs) form a common basis for decision-making.

The Ministry of Social Rights and Agenda 2030 holds executive powers for developing and coordinating actions related to the SDGs. The government’s Delegated Commission for Agenda 2030 oversees interministerial dialogue, while the Sectoral Conference for Agenda 2030 facilitates coordination with autonomous community governments. The Sustainable Development Council acts as an advisory body, involving the private sector, trade unions, academia, and civil society organizations (CSOs). Additionally, the parliamentary Joint Commission for the Coordination of the Agenda 2030 Strategy monitors the implementation of these initiatives.

The National Strategy includes 144 specific impact indicators for monitoring SDG implementation, which are also referenced in the RRP and the annual budget law. The action plan for implementation includes specific policies, such as the National Strategy to Prevent and Combat Poverty and Social Exclusion (2019–2023). The Council of Ministers approved the 2023 Progress Report in July 2023.

The RIA framework does not include explicit indicators for sustainability checks, focusing instead on gender impact and administrative costs.
Citations:
Government of Spain. 2023. “2030 Sustainable Development Strategy Progress Report.” https://www.mdsocialesa2030.gob.es/agenda2030/documentos/IP23_EDS.pdf
Switzerland
The government conducts effective sustainability checks within the RIA framework. However, given Switzerland’s decentralized political and administrative system, they are used in only a few departments.

The Federal Office for Spatial Development uses the Sustainability Impact Assessment (Nachhaltigkeitsbeurteilung, NHB) process, while the Federal Office for the Environment uses the Economic Impact Assessment (Volkswirtschaftliche Beurteilung, VOBU) process. There is no social impact assessment at the federal level. According to the Federal Act on the Protection of the Environment, cantons have the obligation to proceed with an environmental impact assessment for the construction or renovation of specific types of infrastructure.
Furthermore, most of the cantons have sustainability, health promotion or social cohesion programs that are inspired by the Sustainable Development Goals (SDGs). These tend to take the form of mission statements rather than of binding frameworks, however.
UK
In the United Kingdom, the RIA process aims to support sustainable policymaking. These assessments consider a wide range of indicators, including social, environmental, and ecological factors, though economic indicators are often prioritized. The RIAs analyze the impact of regulation over various time periods – short, medium, and long term – and attempt to account for external shocks and irregular developments. A sustainable development impact test is required for all relevant policy proposals. The devolved governments in Scotland and Wales have shown innovation in this area. The Scottish Government’s National Performance Framework and the Well-being of Future Generations (Wales) Act 2015 are notable examples of their efforts to integrate sustainability into policy planning and assessment (de Vito 2024).
Citations:
de Vito, L. 2024. “Foresight for Sustainable Development and Well-Being Governance in Wales.” https://shapingwalesfuture.blog.gov.wales/2024/01/29/foresight-for-sustainable-development-and-well-being-governance-in-wales/
Scottish Government. 2024. “National Performance Framework.” https://nationalperformance.gov.scot
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Belgium
In 2007, Belgium added Article 7bis to its constitution, stating that various levels of power must “pursue the objectives of sustainable development in its social, economic, and environmental dimensions, taking into account intergenerational solidarity.” This legislation mandates environmental impact assessments for any significant policy before implementation. Despite being highly constraining on paper, implementation quality varies, and Belgium’s overall climate policy faces legal challenges.
Belgium’s main problem in achieving its SDG goals is typical of its institutional setup: governments are run by coalitions that have a hard time agreeing on a simple and clear policy direction, and the design of its federal system, one of “coordination” between the federal and federate entities, prevents the central authority from imposing policy targets on regions without negotiation. As a result, while the European Commission’s “Green Deal” assigns a number of targets to achieve, Belgium’s regional and federal levels never managed to agree on how to implement them.
Accordingly, Belgium’s sustainable development strategy encourages multiple actors to take action rather than implementing a coordinated top-down policy. Actions are inventoried on the dedicated website sdgs.be, which highlights efforts by companies, trade unions, mutual societies, NGOs, schools, youth movements, and citizens. However, this inclusive approach can lead to fragmented outcomes, with varied interpretations of “sustainable” across different state levels.
Citations:
https://www.lesoir.be/541949/article/2023-10-07/six-enseignements-de-laffaire-climat
https://www.oecd.org/gov/regulatory-policy/Impact-assessment-in-Belgium-June-2015%20fr.pdf
Sustainable Development Report 2023 (sdgindex.org)
Indicateurs de développement durable (vlaanderen.be)
Belgium country profile – SDGs and the environment – European Environment Agency (europa.eu)
SDG Index and Dashboards Report for European Cities – CIFAL Flanders (cifal-flanders.org)
Leidraad voor de opmaak van een reguleringsimpactanalyse (RIA) | Vlaanderen.be
https://bosa.belgium.be/sites/default/files/content/documents/DTdocs/Simplification/AIR%20Manuel%20-%20FR%20oct2014.pdf
France
A national roadmap for the sustainable development transition was established for the 2015 – 2020 period. A more encompassing strategy was created for the subsequent period, called France 2030 (Ageri 2022), leading to the slogan of “France, green nation.” This also allowed space for more specific plans such as the national strategy for biodiversity. The switch from one to the other has shifted attention toward more economic development through technological innovation with a specific focus on nuclear energy as the centerpiece of the national strategy.

These plans encompass several concrete actions, from a call for proposals for 3,200 “innovating projects” to more specific pledges such as positioning 10% of the national territory under a strong protection strategy, halving light pollution and halving the use of phytosanitary products.

RIAs and overall evaluation assessments are limited in these plans. They are set as general objectives without binding commitments, and with no specific interim evaluations. Data to monitor changes is expected, but no specific means are established for the actual delivery of precise information. Agencies already in place are expected to provide expert opinions on all dimensions. The output of these evaluations remains of limited practical value (SNTEDD 2020).
Based on past performance, the full application of these plans is far from guaranteed. The reduction in the use of phytosanitary products has thus been announced several times, resulting in an observable trend to limit the increase in use. Pledges and indicators too often tend to be symbolic rather than driving genuine structural transformations.

Currently, the government’s general strategy has centered on simplifying the decision-making process rather than creating more complementary points of oversight (Conseil d’Etat 2022).
Citations:
Conseil d’Etat. 2022. “Colloque sur la simplification administrative, Paris, 14 October 2022.” https://www.conseil-etat.fr/publications-colloques/colloques-et-conferences/revoir-colloque-sur-la-simplification-normative
SNTEDD. 2020. “Stratégie de transition écologique vers un développement durable : bilan 2015-2020.” Document de travail du Gouvernement. Retrieved 15 January 2024 from https://www.agenda-2030.fr/IMG/pdf/bilan_sntedd_2020.pdf
Hungary
In Hungary, the strategic environmental assessment (SEA) approach aligns with the stipulations of the European Union Directive 2001/42/EC and the UNECE’s SEA Protocol under the Convention on Environmental Impact Assessment in a Transboundary Context. This assessment process is obligatory when crafting local spatial strategies and territorial development frameworks. The Hungarian parliament passed a National Sustainability Strategy in March 2013 and a National Energy Strategy in 2019. After the adoption of the National Sustainability Strategy, the parliament’s environmental committee was transformed into the Committee of Sustainable Development, consisting of parliamentarians and supported by the National Sustainability Council. The National Sustainability Strategy and regulatory impact assessment (RIA) processes have not yet been coordinated, and sustainability checks (SEAs) happen infrequently during the RIA process. The system of sustainability checks in the government was recently reformed with government decree 1262/2023 VII.4., specifically in the field of public spending, after severe criticism of the low standards of sustainability checks in procurement procedures. The government has no environmental ministry. This portfolio is represented only at an inferior administrative level, as a state secretariat subordinated to the Ministry of Agriculture. A regional authority, the Government Office of Pest County (Pest Megyei Kormányhivatal), carries out the National Environmental Impact Assessment. At the subnational level, county government offices (megyei kormányhivatalok) are responsible for the issue, and there is no functional equivalent at the local level. For cross-border issues, the Department of Environmental Protection of the Ministry of Agriculture is responsible for performing sustainability checks and any required public hearings. Strategic environmental assessment (SEA) aligns with the European Union Directive 2001/42/EC stipulations and the UNECE’s SEA Protocol under the Convention on Environmental Impact Assessment in a Transboundary Context. This assessment process is obligatory for crafting local spatial strategies and territorial development frameworks. While SEA is a routine practice in larger and medium-sized urban areas, particularly those with county rights, its application is less consistent in smaller towns (OECD 2018).
Furthermore, SEAs are prerequisites for formulating policies and plans across various sectors. The regulatory environment for environmental impact assessments (EIAs) is fragmented and lacks coherence. However, the issue has gained more prominence in public discourse due to the government’s rushed attempt to attract foreign direct investment by subsidizing the establishment of new battery plants in 2023. This initiative led to popular protests in several locations and may increase pressure on the government to conduct and publish EIAs more transparently.
Citations:
OECD Environmental Performance Reviews: Hungary 2018, https://www.oecd-ilibrary.org/sites/9789264298613-9-en/index.html?itemId=/content/component/9789264298613-9-en
Portugal
The Sustainable Development Report indicates that Portugal has achieved an SDG (Sustainable Development Goals) Index Score of 80%, showing a positive trajectory in goals pertaining to gender equality, access to clean water and sanitation, and the eradication of poverty. Portugal has shown a 61% progression toward the development goals set by the United Nations.

However, sustainability assessments are not systematically incorporated into environmental impact studies. Their inclusion is left to the discretion of the assessing entity, resulting in an inconsistent approach. Consequently, while some evaluations may consider sustainability, others might overlook it. This inconsistency is also evident in the use of sustainability-centric indicators and the consideration of long-term effects in the analyses.
Citations:
Sustainable Development Solutions Network. n.d. “Sustainable Development Report – Portugal.” https://dashboards.sdgindex.org/profiles/portugal

Jornal de Negócios. 2024. “Portugal apresenta na ONU melhoria de 61% em indicadores dos Objetivos do Desenvolvimento.” https://www.jornaldenegocios.pt/economia/detalhe/portugal-apresenta-na-onu-melhoria-de-61-em-indicadores-dos-objetivos-desenvolvimento
Slovenia
The Development Strategy for Slovenia 2030, adopted in 2017, includes a chapter on implementation and monitoring. It emphasizes the importance of consistently following instructions, monitoring implementation success, addressing deviations, and adapting to new situations and challenges to effectively achieve the set goals.

The strategy acknowledges that implementation has historically been the weakest aspect of development planning. It provides a general framework for implementation, stipulating that it should be based on medium-term planning aligned with the medium-term financial framework. Monitoring the achievement of the strategy’s goals by 2030 or 2050 is planned using the OECD framework for evaluating the agreed measures.

For each development goal, the strategy defines two to three main performance indicators with baselines and target values. These indicators are monitored and analyzed by the Institute for Macroeconomic Analysis and Development. The sustainability aspect of monitoring the strategy’s objectives will determine whether the starting points for development need to change during implementation.
Citations:
Vlada Republike Slovenije. 2017. “Strategija Razvoja Slovenije 2023.” https://www.gov.si/assets/ministrstva/MKRR/Strategija-razvoja-Slovenije-2030/Strategija_razvoja_Slovenije_2030.pdf
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Lithuania
High-quality sustainability assessments are rarely incorporated within regulatory impact assessments. Formally, sustainability assessments must be considered when conducting impact assessments. However, because the impact assessments are often not conducted properly, the sustainability assessments are also typically absent.
Poland
In Poland, there is no separate sustainable development strategy. Formulated in 2017, the Responsible Development Strategy covered the period through 2020, with an outlook until 2030. The document serves as a framework for nine new sectoral strategies aligned with the 2030 National Environmental Policy (2030 NEP) set in 2019. These strategies include:

• The Strategy for Sustainable Development of Rural Areas, Agriculture and Fisheries, through 2030 (2019)
• The Sustainable Transport Development Strategy, through 2030 (2019)
• The National Strategy for Regional Development (2020)
• The Social Capital Development Strategy (2020)
• The Human Capital Development Strategy (2020)
• The Energy Policy of Poland until 2040 (2022)
• The Productivity Strategy (2022)
• The Strategy for Efficient and Modern State (not approved in 2023)

Most of these strategies reference the Sustainable Development Goals and adopt a long-term perspective looking through 2030. However, they do not include mechanisms for monitoring sustainability assessments. In general, sustainability checks are not legally required as part of RIAs.
 
Sustainability assessments are not incorporated within regulatory impact assessments.
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Japan
In December 2016, the SDGs Promotion Headquarters, composed of all ministers, issued the SDGs Implementation Guiding Principles, which set eight priority areas in line with the SDGs. As a result, SDG action plans have subsequently been released on an annual basis. Since 2017, SDG awards have been given to entities who have successfully achieved SDG-related goals.

In October 2023, the SDGs Promotion Headquarters referred to the OECD report from 2022 to demonstrate Japan’s progress in achieving two goals (goal eight: decent work and economic growth; and goal nine: industry, innovation and infrastructure), while pointing to challenges in achieving two other goals (goal five: gender equality; and goal 10: reduced inequalities). However, the verification of SDGs is not based on RIAs. The criteria for evaluating policies from the 2001 Government Policy Evaluations Act refer to three indicators: necessity, efficiency and effectiveness. None of these indicators are directly related to the SDGs. In addition, the Implementation Guidelines for Policy Evaluation of Regulations, amended in 2017, do not give any consideration to sustainability or the SDGs.

The Financial Services Authority in 2022 announced a code of conduct for financial data providers when reporting on ESG data. The Government Pension Investment Fund (GPIF), which ranks among the largest in the world, has increasingly adopted ESG criteria in its investment decisions and is evaluating the impact of its investment decisions.
Citations:
Prime Minister’s Office of Japan. 2023. “Jizoku Kanôna Kaihatsu Mokuhyô (SDGs) Jisshi Shishin Kaitei-an” [Draft Revised Implementation Guidelines for Sustainable Development Goals (SDGs)]. https://www.kantei.go.jp/jp/singi/sdgs/pdf/jisshi_shishin_r051027.pdf

Ministry of Internal Affairs and Communications. 2001. “Government Policy Evaluations Act.” https://www.soumu.go.jp/english/kansatu/evaluation/evaluation_09.pdf

Ministry of Internal Affairs and Communications. 2007. “Implementation Guidelines for Policy Evaluation of Regulations.” https://www.soumu.go.jp/main_content/000556223.pdf

OECD. 2023. “Governance at a Glance 2023.” Paris: OECD.
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Israel
Neither the law, government decisions nor detailed guidelines on RIAs include any reference to a sustainable development strategy. There are no sustainability checks or assessments. The law and detailed guidelines only refer in passing to the need to assess environmental and social implications.
Citations:
Regulation Authority – PMO. 2023. “The Government Guide for the Formulation of Regulation.” https://www.gov.il/BlobFolder/generalpage/reg-method-guide/he/file_rgu-guide2023.pdf
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