New textbook on regulatory policy

Earlier this month, OCDE published a new reference book for members of our community: the first edition of the OECD Regulatory Policy Outlook 2015. This magnum opus summarizes 10 years of experience in designing and applying better rules and regulations to achieve economic and societal policy objectives. A press release summarizes the approach and the main conclusions, but experts will need to download the full material, which includes, to illustrate and give practical impact to each dimension (RIA, simplification, regulatory costs, etc), best national practices.

(From the press release): "The report finds that 33 of the 34 OECD countries have adopted an explicit regulatory policy and require regulatory impact assessments and public consultation for all new regulations, while 29 have a designated minister to promote regulatory reform.

However, a third of OECD countries have no policy at all on regulatory compliance and enforcement, and two-thirds have no system for evaluating laws once they are implemented. This creates unnecessary costs for businesses and society, the report says.

Internationally, co-operation in law-making is essential for creating global rules and standards, addressing trade frictions and environmental risks, and reducing the risk of regulatory failures such as the 2008 financial crisis or the recent VW emission tests scandal. Yet only a third of OECD countries have a clear policy for international regulatory co‑operation."

The way forward, viewed from the top (OECD Forum)

(Photo above: Pres. Hollande from France addresses Forum). 

The second day of the 2015 OECD Forum (3 June) had been organised back-to-back with the OECD Ministerial Council Meeting, which saves travel costs and allows delegates to engage high ranking decision makers. As on the first day, the event also offered rich opportunities to explore current trends and network in a variety of attractive formats (i. a. "meet-the-author", "idea factories", "talk together,"  project presentations). Regarding the plenary sessions, the morning slots were devoted to the presentation and discussion of resources compiled and calculated by OECD, chiefly the 2015 economic outlook. These new elements fed into a discussion on structural reforms, which tried to identify the main factors for stimulating investment while pursuing  sustainable and inclusive growth objectives. The second morning session addressed investment in human capital: its conclusions were consensual but predictable (education...) in spite of the efforts of the moderator.

The highlight of the day was naturally the session on Unlocking Growth, with President Hollande (France) and PM Rutte (the Netherlands) taking centre stage, with questions from ministers in a discussion moderated by SG Gurria himself. Both orators were brilliant in combining the competing requirements of sustainability, environment preservation and social inclusiveness in investment policies. Solutions needed to be defined in common (at the European level for countries of that region), and other international fora such as the coming Paris conference on climate change (COP21).

New challenges for better regulation (OECD Forum)

Your blogger attended the first day of the 2015 OECD Forum, where "leaders and influencers ...  gather to debate the most pressing social and economic challenges confronting society." This year's instalment was not directly connected to regulation, but this was not a reason to stay away: we smart regulators do not work in a vacuum, we try to apply or skills to assist governments and regulators in achieving all regulatory outcomes, so it is necessary now and again to take a look at the bigger picture. And the general theme "Investing for the future: people, planet, prosperity" promised to cover all the major challenges confronting policy makers. Please refer to the OECD Forum website for excellent introductory statements and access to resources, my comments are limited to what may interests regulators.

1. The session on "Unlocking investment" naturally examined the role of regulation for fostering the right investment climate . But 80% of participants (polled instantly) thought a return to pre-crisis levels would not come from regulation. Though compliance costs were mentioned as a hindrance to investment, it seemed to me that better regulation policies and tools were not sufficiently well-known. The panel and audience seemed to put more faith in bringing about  a public-private dialogue ensuring a co-ordinated approach between the private and public sectors to develop a new investment culture, where social goals would be on a par with profit. Innovative business models, and Social impact investment approaches were a prime example of that trend. See also blog by Eric Solheim, chairman of the OECD Development Assistance Committee.

2. The Trade & Investment for development session examined how countries could unlock the full growth-inducing potential of trade, which has not retrieved its pre-crisis levels. Speakers agreed that FTA were no longer focused on tariffs, but increasingly addressed NTBs, mainly of regulatory origin. Prime examples of the trend were the  TTIP (Transatlantic Trade and Investment Partnership) and TTP (Trans-Pacific Partnership). Much attention was given to the fragmentation of markets resulting from NTBs, with the ensuing increase in compliance costs (such as mutiple national certification procedures for the same product) and loss of trading possibilities, with corresponding reduced growth estimated at 2% of GDP. Removal of these obstacles could greatly benefit SMEs, as was shown from NZ and CZ examples, who could participate much more in Global Value Chains. More than ever, regulatory coherence was necessary. A new challenge for governments, especially in developing countries, was also to preserve the quality of investment, i.e. that it contribute to sustainable and inclusive growth, and not seek immediate profit.

3. The session on Sustainable Development Goals (SDGs) only rarely touched on regulatory issues but provided a prime example of an integrated policy inspired by international consensus and facing all the challenges of implementation that better regulators are familiar with. The discussion therefore covered very familiar territory: the main challenge, said one of the speakers, was political will  (the audience voted - by 38% - the lack of measurability as the top obstacle), lack of accountability and transparency of governments in pursuing non-binding commitments, need for more evidence-based decisions with data-collection strategies. It was quite surprising, even touching, to note the extent to which the private sector (including multinationals) vowed to support these mainly social goals, apparently to build a good reputation.

"Better regulation can facilitate trade" (OECD)

OECD (Regulatory Policy Committee) work on International Regulatory Cooperation (IRC) has taken a big step forward with the organisation of a one-day joint workshop with the Trade Committee to investigate how sound regulatory policy could enhance the quality and effectiveness of trade agreements. It was also the first time that the newish community of regulatory experts formally joined forces with the Trade pundits to tap the potential of a synergy between the two bodies of expertise.

In the morning delegates heard a series of presentations (including one from A. Alemanno who recently wrote on the TTIP negotiations) researching how trade barriers related to regulatory heterogeneity could weigh down the desirable development of international commerce and thus impede growth. The afternoon session (chaired by your blogger) featured six national cases of successful experience with IRC mechanisms in support of trade policies and FTA negotiations. The closing session, chaired by the UK delegation, outlined a future programme of work that would substantiate the conclusion (formulated by F.van Tongeren from OECD) that "Better Regulation can facilitate trade." No doubt official proceedings will soon be made available on the IRC and Trade pages of the OECD site.

Background. Recent OECD work on Global Value Chains has provided a strong reminder of the importance of reducing protectionist measures, improving inefficient and unnecessary customs and other border procedures, and reducing the cost of ‘behind the border’ measures that constrain trade in goods and services. In particular, regulatory misalignment, both in policy formulation and application, increases the costs facing firms operating internationally and holds back growth and job-creation. The OECD publication "IRC: addressing global challenges" makes the point that IRC is intensifying but there are also concerns that multilateral and regional trade deals could lead to a weakening of legitimate domestic regulations. Achieving regulatory and policy objectives in an increasingly globalised world while respecting the need for openness internationally can be a challenge for governments.

Tanzania announces regulatory reforms

At the official launching of the OECD's investment policy review of Tanzania, the Prime Minister announced his intention to grapple with "the most problematic areas in the performance of business sector in the country (which) include access to credit, corruption, complex procedures in securing construction permits, cross-border trade licenses, payment of taxes, land and property registration... The government would now make delibefrate efforts to review the legal framework and regulations that have been deterring smooth operation of investment projects." A booming economy with enviable growth rates, Tanzania still suffers from a poor Doing Business ranking (145th out of 189 in the 2014 report.) For more, see IP Media and read the summary of the review on the OECD site.

Gulf standardisation agencies study BR tools

(Photo: members of two of the three breakout groups at work under the supervision of Miriam Allam, OECD, in charge of the course. Click to enlarge) 

RIA experts know the importance of checking, at the early stages of analysis of new legislation, the potential of "alternatives to regulation" as another way to reach the substantive policy objectives that their agency or ministry is pursuing without increasing the rule book while improving stakeholder input. Among these alternatives, standards occupy a central position as they can greatly contribute to an efficient business regulatory environment. In this context, the initiative of the Gulf Standardisation Organisation (GSO) to hold a seminar for officials from all Gulf states opens great promise of better regulation in the Gulf region, through the use of better evidence-based and consulted technical standards. Under the title "Building a practical framework for RIA", the course covered all the stages of the RIA process, after which delegates addressed ways and means of making the most of the potential of RIA to improve standards in the region, using international best practice.

The success of the course owes a lot to the hospitality of the Bahrain Ministry of Trade and Commerce (Eng. Al-Moamen) and the supervision of Mr A. Benyaich, senior conformity assessment specialist at GSO. The course was supported by Miriam Allam from OECD (pictured) and your blogger CH Montin (France).

The rôle of parliament in better regulation (Paris conference)

Your blogger was honoured to moderate a half-day conference, organised on 5 December jointly by the OECD and the French Senate, on the rôle of Parliaments in the search for Better Regulation. The event, announced in a previous post, brought together MPs and staffers from France, the UK, Sweden and the EU to compare institutional competences and methods to start sharing best practice. The OECD outlined the issue in a concept paper, the first paragraphs of which are quoted below:
"The Recommendation of the Council on Regulatory Policy and Governance is clear: "Ensuring the quality of the regulatory structure is a dynamic and permanent role of governments and Parliaments". As the institutions responsible for approving legislation, parliaments can exercise oversight and control over the application of better regulation principles for new and amended regulation. Through the public debate of proposed bills and amendments, they can help foster a transparent dialogue on the opportunities and challenges offered by new and amended regulation. Through the control they exercise on public expenditures and government performance, they can help monitor the effectiveness and efficiency of regulation.
OECD surveys of regulatory management show a progressive move towards strengthening the role of parliaments in improving regulatory quality. In 2008, 15 jurisdictions (14 OECD member countries and the EU) had a parliamentary committee or other parliamentary body responsible for regulatory policy or reform against 11 in 2005. In seven cases, this committee or body conducts periodic reviews of the quality of proposed legislation. In eight cases, it conducts quality reviews of subordinate legislation. In five cases, the review process is guided by specific criteria. In six the committee or body regularly reports on progress on regulatory policy and reform across government. Consultation is also often an integral part of the legislative process. For example, in New Zealand, Parliament invites public submissions on almost all bills and these are considered by a select committee before it makes recommendations. "
The first panel was devoted to recent changes in the French approach to the matter, which shows that the traditional emphasis on formal quality of the texts and a concern for full enactment, is gradually incorporating a keener sense of regulatory impacts on the economy, parlty under the influence of the principles of smart regulation promoted by Brussels. The second panel introduced several foreign good practices with contributions from the UK, Sweden and European parliaments. This blog will watch for the publication of the proceedings, which will hopefully reflect the many sound ideas about how parliaments and governments can cooperate, by way of the use of RIAs and other methods, to enact better and economically efficient regulation. Videos of the key moments of the conference are already uploaded on the site of the Senate.

The potential of behavioural economics for regulation (OECD)

At its November session, the OECD Regulatory Policy Committee (RPC) inaugurated a new workstream devoted to tapping the insights of behavioural economics (BE) for better regulatory design. As the topic was new for some delegates, the floor was given to two top experts in the field, Alberto Alemanno and Peter Lunn, for a general presentation of the current situation regarding BE.

Alberto has published "Nudging Legally - On the Checks and Balances of Behavioural Regulation" on SSRN.

Peter Lunn's paper commissioned by OECD, which includes a full bibliography, will shortly be published. It offers an international review of the initial applications of behavioural economics to regulation using some 60 cases, which shows that behavioural findings are having an impact on the content of and the method for designing regulation.

Further work of the OECD on this topic is likely to focus on international comparisons of economically significant cases and best practices of behaviourally-informed regulation.

The new concepts have been layed out in "Libertarian Paternalism" by R. Thaler and Cass Sunstein.

For an update on other topics discussed at the RPC recent session, experts should frequently visit the well-devised section on regulatory policy "Latest Documents" of the OECD website.

Two BR events on 5 December

1/ - Paris: OECD/French Senate workshop on the role of parliaments in better regulation (by invitation from Registration).

"A key task of Parliament is to vote on the law. It is also necessary that the law is clear and enforceable. However, the increasing complexity of contemporary societies has led to a proliferation of bad quality and complex normative texts. To stop this tendency is a government objective taking various routes : codification , simplification laws , legistics, evaluation of the quality and the normativity of the law, etc. In the context of globalization , the challenge is not just legislative drafting and legal quality, public authorities must also ensure effective implementation of the effects of laws passed , and preserve the economic competitiveness and attractiveness of the country.

There are international instruments to promote these goals, especially at the OECD, which has set up a committee on regulatory policy and adopted in 2012 a Recommendation of the Council on Regulatory Policy and Governance . Similarly, parliaments, sharing the objectives of good governance and the quality of legislation, are becoming more attentive to the way laws are implemented and achieve their results, as shown by the development of boards or units providing assessment of bills and laws and the increasing use of assessment tools like CBA and RIA.

This symposium , organized by the Senate Committee for the control of implementation of laws, in partnership with OECD, aims to better identify the role that Parliaments can play in assessing the quality of legislation . Based on testimonies and an exchange of best practices between French institutions and foreign parliamentary assemblies , it will discuss the role of parliaments in the processes and the tools they use for this purpose" (from the organisers' leaflet.)

2/ - The Hague: International Seminar on "Executive discretion and regulatory decision making – Issues and challenges in making regulation more effective" organised by the NL Academy for Legislation (by invitation). 

"The question of the appropriate amount of discretion that the executive branch should wield, and within it in particular regulatory bodies, is central to the understanding of how regulation and enforcement work, and to efforts to make them both more effective and efficient.

Proponents of regulatory discretion consider that it is the only way to escape the conundrum of writing exceedingly specific rules that end up being unwieldy and rapidly obsolete – and lend themselves to “gaming the system” by rogue operators. Critics point towards the risk of abuse, be it regulatory capture or corruption, abuse of power, and breakdown of the rule of law. One of the questions may be if it is at all possible to have enforcement of any type of rule without some sort of discretion." For more information, contact Florentin Blanc.

New RIA handbook from Israel

Our colleagues from Israel have just published online a particularly complete RIA handbook which will enrich the literature on this key tool in the search for "optimal regulation" (the term used in the handbook). The IL approach is quite distinctive and merits consideration, as it breakdowns the RIA process into five "stages" covering the whole regulatory cycle, integrating up-to-date international best practice:

- describing the status quo and defining policy goals;

- risk management, to determine the most efficient regulatory instrument for each "risk component" in the policy under consideration;

- assessing impacts including feedback from consultation procedures and comparing advantages and disadvantages of various projected regulations (options);

- anticipating implementation of the chosen solution to achieve success of the policy (including enforcement and inspection issues);

- public reporting to achieve transparency and accountability in regulatory design.

Other RIA methodologies and resources (from other countries) can be found on the OECD RIA pages.

Regulatory policy and trust in government

Speaking at a recent event organised by Salzburg Global and the Volcker Alliance on ‘Restoring the Public’s Trust: Delivering on Public Policy Goals’, the Secretary General of OECD, Mr Angel Gurria, listed the elements of a "strategy for trust" that OECD could recommend to national governments, built on three pillars: integrity, transparency and engagement. Mr Gurria defined the current situation as a crisis of trust, trust being "the cornerstone of effective governance, the main ingredient to promote economic growth and social progress. Like never before, our countries are running dry of this precious asset. Like never before, our citizens have doubts about their government’s capacities to make the right decisions. And like never before, we need to take the necessary measures to recover that confidence."
Regulatory policy could contribute significantly to improve transparency and restore trust in government, said Mr Gurria: "Our regulatory and supervisory structures have failed us in many important ways. This is resulting in a degradation of the idea of the State as that strong institutional framework that guaranteed our safety, our prosperity, our right to succeed, through a system of checks and balances inspired in a crucial principle: accountability. Our governments now need to make a major effort to restore this certainty and with it the respectability, the credibility, of the State. The OECD is supporting these efforts, with different tools: like our recently updated Principles on Regulatory Quality, the OECD Working Group on Bribery; the Annual High-Level Anticorruption Conference for G20 Governments and Business; and the CleanGovBiz Initiative, to name but a few."

OECD consultation on inspections (deadline 31 August)

The OECD is launching a public consultation on draft Best Practice Principles for Improving Regulatory Enforcement and Inspections. The goal of this consultation document is to present a basis for discussion on key issues as well as some key principles on which effective and efficient regulatory enforcement and inspections should be based in pursuit of the best compliance outcomes and highest regulatory quality. The principles address the design of the policies, institutions and tools to promote effective compliance – and the process of reforming inspection services to achieve results. Each of the principles represent a recommendation on one of the main issues for successful reforms and is accompanied by an explanatory text. For more, visit OECD page. Deadline for contribution: 31 August 2013 (tip from Florentin Blanc).

Measuring Regulatory Policy (OECD, Stockhom, 3-4 June)

This 5th expert workshop in Stockholm is part of the OECD programme on Measuring Regulatory Performance which addresses two very important issues for the Regulatory Policy Committee and the OECD: how can countries measure regulatory performance to diagnose success and failures, improve regulatory policies, programmes and tools, and to communicate progress? How can they demonstrate that an investment in their systems for regulatory policy and management is delivering improvements to their economies and societies? At the 5th workshop, delegates and experts will discuss best practice implementation of the 2012 Recommendation on Regulatory Policy and Governance and how to benchmark progress over time. This is an important step in measuring progress in the implementation of the Recommendation in countries, and the preparation by the OECD of a Regulatory Policy Outlook in 2014.
Background: The 2012 Recommendation provides a list of 12 "principles", which can be used as a checklist of measures that governments can and should take to support the implementation and advancement of systemic regulatory reform to deliver regulations that meet public policy objectives and will have a positive impact on the economy and society.

New economics to support smarter regulation (OECD Forum)

On 28-29 May, the OECD held its Forum, its largest annual open event where economists and policy makers from around the world meet to discuss latest findings and chart the future. The Organisation also uses this high moment to deliver some of its flagship products, such as the Economic Outlook, or the new rankings of its Better Life index, both topics widely reported in the news, or announce diplomatic breakthroughs (for instance the signature at OECD of anti-tax haven instruments). It was expected that an organisation committed to "better policies for better lives" would have a lot to offer smart regulators, whose mission is to ensure more efficient public policies by assisting decision makers with better evidence about economic, social and environmental outcomes. Perhaps the best introduction to the abundant new literature is the 28 May press release "New approach to globalisation and global value chains needed to boost growth and jobs" which provides an entry point to the technical studies on a number of new topics and initiatives. Among the most significant issues is the shift to the "global value chain" approach to international trade, which is based on the fact that "what you do" (the activities of a firm or country) matters more to growth and employment than "what you sell" (the final product). The past decades have witnessed a strong trend towards the international dispersion of value chain activities such as design, production, marketing, distribution, etc. and this challenges how we look at economic globalisation and in particular the policies that we develop around it, such as trade, investment, competitivesss and other policies. A new book on the topic Interconnected Economies: Benefiting from Global Value Chains was also released during the Forum.
Another report released at the same time, New Sources of Growth: Knowledge-based capital (KBC), finds wide differences between countries in the levels of KBC investment, which includes inter alia IT systems, innovative property and economic competencies (including brand equity, firm-specific human capital, networks and organisational know-how). A finer approach to investment is therefore now necessary.
All these new concepts and data series need to be accommodated by smart regulation tools, such as RIA (a new way of calculating economic impacts), ex-post evaluation (which impact to look for), if regulatory policy to keep up with its mission: quite a challenge but an appealing task, so watch this space !

International regulatory cooperation comes of age

24 April 2013: the OECD has published a well-researched and thought-out stocktaking exercise on International Regulatory Cooperation: Addressing Global Challenges which provides an overview of recent trends, the range of existing regulatory cooperation mechanisms (and actors involved) and preliminary lessons taken from selected experiences. Probably the first such ambitious compendium in the field, it builds on 10 case studies covering a vast range of sectors and experiences (which will be published separately), a review of the literature and other sources. There is also a useful bibliography and a glossary at the end of the volume.
For an overview of the project, go to OECD Regulatory Policy pages on IRC.
The report shows the fascinating multiplicity of IRC arrangements and the important benefits that can accrue from greater regulatory cooperation but also, as it acknowledges, "the remaining analytical gaps and the complexity of implementing effective IRC." As one of the principles enshrined in the 2012 Recommendation (n°12) the development of IRC will be actively pursued in coming months and years, starting with the next OECD regulatory event: the 5th expert workshop on Assessing the Implementation of the 2012 Recommendation of the Council on Regulatory Policy and Governance, co-organised by OECD and Sweden in Stockholm, on 3-4 June 2013 (by invitation).

W. Woermans on regulatory compliance

"What can public authorities do in order to promote regulatory compliance? (from the summary) "This paper argues that understanding the compliance motives is key to any enforcement strategy. Simply stepping up the enforcement effort or stiffening penalties is – most of the time – quite ineffective. Especially attempts at engineering criminal law rules to achieve a heightened deterrence effects will generally be ineffective, social science research suggests. And – much in the same vein – raising administrative enforcement efforts does not automatically raise compliance rates proportionally. There is not a one-on-one relation between enforcement effort and compliance outcome, although this idea seems to be underpinning a lot of present-day enforcement strategies. Enforcement efforts are but one of the many norm-support cues to comply. Recent research rather suggests that a sort of bandwagon-effect exists as regards regulatory compliance. Compliant behaviour, or enforcement activities that reminds us of (or merely point out) the existence of a norm, prompt (more) compliant behaviour. Designers of enforcement strategies need to keep this in mind."

World Class Economic Regulators join up in OECD

Economic regulators will soon have their own forum in OECD to discuss, with assistance from the international regulatory experts, issues of common interests such as how to guarantee the right degree of independence from government or how to measure their performance and give their economies value for money. On 24 April, some 20 regulating agencies and supervisory departments from some 15 countries met at OECD HQ for the third time to address a range of governance and efficiency issues. Best practices from the US Energy Commission (by John R. Norris) and the Portugal Water Authority (by J. Melo Baptista, from ERSAR) were scrutinised. The quality of the group's work and potential future contribution to the sustainable management of national public utilities (such as energy, telecom and water) may be recognised by member states by granting the network official status under the Organisation's operating rules. This will ensure that a new wealth of OECD economic literature will be updated for regulators world-wide, drawing lessons from success stories, sharing best practice and providing guidance to governments on when and how it may be best to delegate to an arms-length agency the management of such network assets. Any new published resource will be reported on this blog.

Commission to test the efficiency of national courts

On 27 March, the European Commission launched the EU Justice Scoreboard, "a tool to promote effective justice and growth", which according to the press release, offers a comparison of the justice systems of member states in a bid to assess how their activity can affect economic growth.The justice scoreboard will focus on the business and investment climate, such as the efficiency of EU courts to resolve civil and commercial disputes. The Commisison is working on the assumption that the quality of national courts can affect the entire EU, since a lack of implementation of EU law in one court can affect the functioning of the single market as well as undermine the rights of citizens and businesses operating across borders. Smart regulators will not disagree and they will welcome this additional tool to measure implementation and enforcement of regulation. For more, see Euractiv article: "Commission to test the efficiency of national courts" (tip from L. Allio.)

Simplification "shock" in France

Regulation in the spotlight in France, as factor in economic woes. "France has avoided the most severe impacts of the global economic crisis and turmoil in the euro area, but must now take action to boost competitiveness and create jobs, according to the OECD's latest Economic Survey of France." The Survey, presented in Paris by OECD Secretary-General Angel Gurría to French Minister of Economy and Finance Pierre Moscovici, urges France to attack the pervasive bottlenecks that have limited economic growth and maintained high unemployment over the past decades. "The French economy has tremendous assets and considerable potential, but excessive regulation and high levels of taxation are gradually eroding its competitiveness," Mr Gurria said. See OECD media release, and (posted 28 March) the French ministry of finance website, with the minister's statement.
Mr Gurria's message seems to have been heard: In his television interview on the public channel France 2 on 28 March, President Hollande announced the drastic reduction of the number of administrative procedures, particularly for small and medium-size enterprises, in what he termed a "simplification shock." "Currrently, a small company is obliged to respond yearly to some 3000 requests for information from the administration, yes, 3000!" said the president, who promised: "Tomorrow we will divide that figure by two or by three." This high-level announcement has been widely commented in the media, who also reported, quoting OECD, that the savings to business could reach €60 bn a year, or 3% of GDP.
Speaking on radio on 2 April (today), the minister in charge of public administration reform (Mme Lebranchu) said that this reform drive was different from its predecessors as it was based on the willing participation of the civil service, and not on reducing staff numbers. A site reserved to officials has already collected 1500 simplification ideas from within the administration.

Better Regulation in Greece (OECD report)

Just published, in the "Better Regulation in Europe" series, "Better Regulation in Europe: Greece 2012"
This review of regulation in Greece maps and analyses the core issues which together make up effective regulatory management, laying down a framework of what should be driving regulatory policy and reform in the future.
The executive summary makes interesting reading, and explains how the "heavily legalistic approach" needs to evolve to acommodate Better Regulation principles, chiefly by "embedding strong structures at central level" and "actively embracing and advancing work on a comprehensive and coherent Better Regulation programme."