3. Policies and institutions for regulatory governance in Brazil

In Brazil, the better regulation agenda dates back to 2007 with the creation of the PRO-REG programme. This coincided with the 2008 OECD Review of Regulatory Reform of Brazil (OECD, 2008[1]), which provided recommendations that boosted the policy on better regulation in the country. The main objective of PRO-REG was to improve the quality of regulations issued by the federal administration. In its first phase (until 2013), the programme focused on the diagnosis of the regulatory environment and on the development of capacities for improving the normative framework in the country. After 2013, the main emphasis of the initiative was the dissemination of good regulatory practices and tools. Since 2016, better regulation initiatives have gained momentum.

In 2016-18 Casa Civil emphasised co-ordination efforts aiming at promoting cultural change towards the best regulatory practices and accelerating the implementation of better regulatory tools at federal level. The national government has enacted several legal instruments to reduce red tape in the federal administration, promote the assessment of existing regulations and introduce a more systematic use of regulatory policy tools.

While regulation is not the only avenue to achieve public policy objectives, a high-quality regulatory framework can help administrations attain their goals in an effective manner. Governments have endorsed the regulatory policy cycle as a process that considers the emission, implementation and evaluation of norms to guarantee the development of a regulatory framework that benefits the society, environment, and economy among others. In this cycle, rules are part of a comprehensive process that begins with the identification of a public policy problem (see Figure 3.1). The selection of the instrument to address this problem is considered during the preparation of a regulatory impact assessment (RIA). Ideally, RIAs take into account several options to achieve a public policy objective, regulation being one of the alternatives. If regulation is the selected option, tools such as regulatory enforcement, monitoring, and ex post evaluations become even more relevant.

The Brazilian strategy for the roll-out of a better regulation agenda is in the process of considering each of the blocks as an interconnected system that form the regulatory policy cycle, underpinned by horizontal activities, i.e. public consultation, co-ordination, co-operation and communication, instead of independent self-contained elements. Thus, the legal framework for regulatory policy in Brazil is contained across several instruments. This setup, however, is not exhaustive in the regulatory management tools that it covers nor on the requirement for their implementation across the government.

The Regulatory Agencies Act (Act No. 13.848/2019) and the Economic Freedom Act (Act No. 13.874/2019) are the two main legal documents that underpin the implementation of specific regulatory policy tools in the Brazilian federal administration. The former mandates the adoption of better regulation tools for only 11 regulatory agencies,1 while the latter has a strong focus on economic competition even though it is relevant for most of the federal administration entities.

Several decrees and by-laws have derived from the Economic Freedom Act. These instruments introduce a broader scope for regulatory management and delivery elements namely licensing, regulatory impact assessment, and review of the stock of regulation (see Box 3.1 with more details of these decrees). As in the case of the regulation that supports their development, these decrees apply to a subset of regulations, activities and procedures. For instance, the Decree for the revision of the stock of regulations (Decree No. 10.139/2019) is relevant only for those legal instruments that are lower than a decree. In addition, the Regulatory Agencies Act (Act No. 13.848/2019) makes the public consultation of impact assessment and draft regulation compulsory only for the 11 regulatory agencies and optional for the rest of the federal public administration.

In terms of administrative simplification and reduction of regulatory sludge,2 Brazil is taking steps to improve the business environment. Namely, Act No. 11.598/2007 that creates the Registry and Legalisation of Companies and Businesses (Redesim) and the measures taken as part of the commitment by the current administration to increase the country’s competitiveness and digitisation are the drivers for these efforts. In line with the aspects linked to the Economic Freedom Act, the emphasis of the regulatory burden reduction activities is to improve the business environment by focusing on a defined set of formalities and government procedures.

Brazil has put in place some of the building blocks for the development of a successful regulatory policy. For instance, the country has made RIA mandatory for entities of the federal administration and has introduced the obligation for regulatory agencies to perform public consultations. The implementation of these efforts has yet to be determined as part of a government-wide strategy in better regulation. The approach followed so far builds on the political and economic context to introduce better regulation. Taking advantage of existing opportunities and f the current environment is a good way to introduce regulatory management tools without going through more formal and slower processes. However, it is important that these activities be further integrated to represent an explicit and comprehensive policy on better regulation. Moreover, by incorporating the country’s regulatory policy in a single, high-level document it protects the efforts made so far, as well as future ones, from changes in the political landscape or priorities and ensures their sustainability over time (see Box 3.2 for a snapshot of Canada’s regulatory policy).

As mentioned above, some developments have provided a window of opportunity to introduce elements of regulatory policy. For example, the current administration’s objective to encourage competitiveness and economic competition led to the approval of the Economic Freedom Act. Another example is the use of international obligations to introduce regulatory management tools in the domestic rule-making process. This aspect was particularly salient during the discussions within the framework of the fact-finding mission for this report. In 2020, Brazil signed the Agreement on Trade and Economic Cooperation between the Government of the Federative Republic of Brazil and the Government of the United States of America Related to Trade Rules and Transparency, which has an annex on good regulatory practices. Some stakeholders pointed out the possibility of using the requirement for public consultation established in the Agreement to legitimise its implementation throughout the federal administration.3 Mexico’s experience after the approval of the North American Free Trade Agreement (NAFTA) in 1994 shows that the treaty was an important element to stimulate the adoption of some practices in the country.

Building on international requirements to dictate the adoption of regulatory management tools is a way to start the implementation of certain tools. Nonetheless, it does not consider the lack of a single policy document that sees the regulatory policy cycle as a holistic process with clear responsibilities and leadership. A whole-of-government approach to regulatory policy goes hand in hand with the development of an umbrella document that promotes regulatory quality throughout the administration. This policy statement helps to provide consistency in the actions and responsibilities of the parties concerned. It also helps define objectives and goals and provides a framework against which efforts can be evaluated.

While the publication of an overall statement with explicit objectives and attributions does not represent a necessary condition for the deployment of regulatory management tools in the public administration, one of the main recommendations of the OECD is to aspire to a high-quality regulatory framework (OECD, 2012[4]). With a whole-of-government policy, administrations can establish co-operation mechanisms that take institutions, stakeholders, and policy communities into consideration. Thus, using the resources more efficiently and reaping the benefits of better regulations. Box 3.3 lists the main elements that a whole-of-government policy on better regulation should include.

Even if countries may take different approaches to incorporating regulatory policy in their administrations, it is crucial that an all-encompassing document or statement supporting the policy is issued. In fact, the OECD Recommendation of the Regulatory Policy and Governance encourages countries to “issue a formal and binding policy statement underpinning regulatory reform, including guidelines for the use of regulatory policy tools and procedures” (2012[4]). This recommendation has been widely adopted by OECD member countries. As shown in data from the OECD Indicators of Regulatory Policy and Governance (iREG), in 2018 most OECD member countries already had an explicit whole-of-government policy for regulatory quality (OECD, 2018[5]).

Finally, the policy statement should identify the responsibilities of the different institutions and administrative areas with a role in developing, managing and adopting the regulatory policy in the country. It is also important to include clear and explicit co-ordination arrangements to facilitate the implementation of the regulatory management tools and to promote accountability. The next subsection will offer an overview of Brazil’s institutional arrangement for regulatory policy.

The institutional landscape for regulatory policy in Brazil comprises several bodies with a role in the implementation of regulatory management tools. Given this range of institutions and the way the better regulation efforts have been implemented in the country, some key functions of regulatory oversight have not yet been clearly defined nor allocated. Furthermore, it seems that even in one and the same ministry, administrative areas that make efforts on better regulation work in silos. Box 3.4 describes the main responsibilities of the entities that deal with aspects of the regulatory policy cycle in the federal administration.

It is fundamental that the department leading the design and implementation of the country’s regulatory policy has adequate technical competencies. This ensures that the tools are adopted and implemented in the correctly way throughout the administration and ensures that the oversight and quality control functions are based on expertise. At the same time, it is important for the oversight body to have the political power and support to ensure that the better regulation efforts follow a whole-of-government approach (see Figure 3.2 for a snapshot of the location of ROBs throughout the OECD).

In Brazil, Casa Civil was previously the institution leading the efforts on the implementation of the regulatory policy in Brazil, namely RIA. With the creation of the new Ministry of Economy, the oversight of RIA was transferred to the Secretariat for Competition Advocacy and Competitiveness (SEAE).

The attributions, responsibilities and institutional arrangements of the regulatory oversight system vary among OECD countries. In some jurisdictions, the regulatory oversight functions are concentrated in one body (i.e. National Commission for Better Regulation in Mexico, CONAMER); while in others, they are allocated to several different administrative areas or institutions. Regardless of the configuration, Renda and Castro identify four core functions for regulatory oversight bodies (Forthcoming[6]). The following subsections will describe the Brazilian regulatory oversight ecosystem through the lens of these core functions.

The function of quality control of regulatory management tools focuses on three main elements: regulatory impact assessments, stakeholder engagement and ex post evaluations, being the first one the most broadly developed in OECD member countries. The regulatory oversight body (ROB) responsible for quality control plays a key role in ensuring that regulations are developed using a thorough analysis and following methodologies that assess the potential costs and benefits of the alternatives considered. Additionally, by guaranteeing adequate stakeholder engagement processes, the ROB promotes more inclusive and accepted regulations.

In Brazil, the scrutiny of regulatory management tools is in its early stages and is restricted to the assessment of RIAs. SEAE is the body responsible for scrutinising the RIAs of subordinate regulations (Decree 10.411/2020). Nonetheless, SEAE does not perform a systematic evaluation of the RIAs and its opinions are non-binding. The opinions should be publicly available, which eventually may a encourage higher quality of the assessment by working as a name and shame mechanism. It is important to emphasise that for naming and shaming mechanisms to work, SEAE’s oversight authority should be protected from political interference. When this report was being prepared, the OECD team could not identify evidence to assess the effectiveness of this mechanism nor its potential effect on the quality of the RIAs. Furthermore, the Secretariat is not in a position to return the assessment to the agency submitting it. Finally, Decree No. 10.411/2020 defines the basis for the ex post evaluation of regulations or evaluation of the regulatory result (avaliação de resultado regulatório, ARR); however, it does not define a supervisory body for these assessments.

Perhaps the need to set up adequate resources to perform this function is as important as giving the ROB a clear and explicit mandate for quality control. The regulatory oversight body’s protective role must be supported by staff with the adequate level of expertise and with the right financial resources. As the ROB provides a switchboard function, where it brings together the relevant parties in the administration, officials should have the tools to identify how the potential effects of a regulatory proposal might affect other agencies and stakeholders. When this report was being prepared, SEAE had a team of 22 officials to scrutinise the regulatory impact assessments of the entire federal administration, as well as other tasks. It is too early to say if the Secretariat has the necessary resources available to discharge this function correctly. However, representatives from the centre of government stressed that, given the tight fiscal conditions in the country, they do not plan to allocate more resources to regulatory policy but to change the culture and make better use of the resources available.

The availability of adequate guidance and support is crucial for the implementation of a sound regulatory policy. Regulators, ministries and other institutions should not see better regulation efforts as additional burdens, but rather as tools that encourage the achievement of public policy objectives. Having a regulatory oversight body that is a provider of capacity building activities can help reduce the resistance that ministries or other entities might have towards regulatory policy and can develop their confidence in using regulatory management tools.

In Brazil, the Ministry of Economy spearheaded the efforts to provide guidance and advice for the implementation of regulatory management tools. In fact, several ministries and institutions emphasised the availability of the team from the Ministry of Economy to help deal with questions and doubts in the implementation of RIA. Additionally, to prepare for the new requirement to carry out RIA, the Ministry published a series of manuals and guidelines to help the regulatory impact assessment to be implemented. These documents focus on the executive federal administration, and in some cases special emphasis is place in the Ministry of Economy, but they are publicly available and are a reference for other ministries or institutions. The most relevant guidance documents are:

  • Guidelines for the Elaboration of Regulatory Impact Assessments (Ministério da Economia, 2021[7])

  • Regulatory Impact Assessment, Frequently Asked Questions (Ministério da Economia, 2021[8])

  • Stakeholder engagement in the framework of the Decree on Regulatory Impact Assessment (Ministério da Economia, 2021[9])

  • Collection and treatment of data in the framework of the Decree on Regulatory Impact Assessment (Ministério da Economia, 2021[10])

  • Governance Model of the Regulatory Impact Assessment in the Ministry of Economy (Ministério da Economia, 2021[11])

  • Guidelines for the Evaluation of the Regulatory Outcomes (Ministério da Economia, 2022[12])

Brazilian regulatory agencies have implemented RIA and other regulatory management tools for some years now. This has allowed them to develop expertise and good practices that can be shared throughout the administration. The exchange of lessons learnt can help alleviate the concerns that other agencies might have and could help incorporate regulatory policy into the culture of the ministries and other institutions.

Finally, the National School of Public Administration (ENAP) is also an important player in the provision of training and capacity-building activities. The School conducts courses on impact assessment and other regulatory studies that are available virtually and may be available to a wide range of public officials.. Box 3.5 provides a brief description of the training activities to build expertise in RIA in Australia.

In Brazil, no administrative area or areas are explicitly in charge of co-ordinating the regulatory policy agenda. For instance, both the Ministry of Economy and Casa Civil play a role in assessing the potential effects of regulations. The Ministry of Economy, particularly SEAE, is involved in the quality assurance of RIAs for subordinate regulations (Decree No. 10.411/2020), while Casa Civil can also require an impact assessment for certain decrees and laws. However, there is no working link between both institutions, even if the two entities have a role in the issue of regulations. The lack of a clear mandate makes it hard to assign a leading agency to ensure the quality of RIA, let alone of the entire regulatory cycle.

Previously, Casa Civil led the steering of the regulatory policy in Brazil. The technical resources available in the Ministry of Economy and the political context in the country directed the reallocation of the RIA agenda to the Ministry of Economy. Moving forward, it is important that, once a department or entity is granted the leadership of the better regulation efforts, it embraces a holistic view of the regulatory cycle and it is allocated adequate support. The approval of the better regulation agenda by the country’s political leadership helps reinforce the validity of the institution or administrative area in charge of the policy. Leadership and governance arrangements are critical to ensure the implementation of a successful regulatory policy system (OECD, 2012[4]). Co-ordination and collaboration among the regulatory oversight body (or bodies), ministries and agencies are key to ensuring the adoption of the regulatory management tools and practices.

As in the case of RIA, administrative simplification efforts could benefit from closer co-ordination among the relevant players in the administration. The federal government has set up programmes aimed at tackling the substantial administrative burdens on citizens and businesses in Brazil. The three main initiatives are: i) The Path to the Top 50 Most Competitive Countries, ii) The Digitisation of Public Services Programme, and iii) The National Network for the Simplification of the Registry and Formalisation of Businesses (Redesim) (please refer to Chapter 4 for more details). While the three strategies have generated (and continue to generate) benefits and improved efficiency, these are individual efforts. Each initiative is under the management of a different administrative area of the Ministry of Economy. However, no underlying policy or central co-ordinator encompasses all three programmes. A body that co-ordinates administrative simplification and incorporates it into the regulatory policy in the country can guarantee that the synergies are exploited and that regulations generate the lightest burden for Brazilians. For an example of co-ordinaion among institutions on better regulation, please refer to Box 3.6.

Another aspect in which the ROB plays a key co-ordination role is in regulatory consistency among levels of government. In Brazil, this aspect has been only marginally considered as the strong federal nature of the country has been seen as a disadvantage to the actual development of co-ordination mechanisms. In fact, collaboration on better regulation among the federation, states, and municipalities was perceived as a rather sensitive topic during preparation of this report. While Chapter 5 describes in detail the governance arrangements with sub-national governments, it is important that the regulatory oversight body responsible for co-ordinating the better regulation policy at federal level plays a leadership role in promoting this policy among lower levels of government.

In practical terms, one way to promote collaboration among agencies is by creating networks of policy makers. Currently, two networks exist where regulators and ministries can contact each other to exchange experiences and good practices. The Network for the Articulation of Regulatory Agencies (Rede de Articulação das Agências Reguladoras, RADAR), created in 2018, brings together the 11 regulatory agencies within the scope of the Regulatory Agencies Act. The Network offers an area to discuss topics such as risk-based regulation, inspections and regulatory enforcement, and administrative burdens, among others. On the other hand, ministries and regulatory agencies meet every two or three months to share good regulatory practices at the Meeting of Federal Regulators (Encontro de Reguladores Federais). This is an initiative in the right direction, even if participation in the activities is voluntary and rather informal. It is worth pointing out that there is a specific working group within the scope of these meetings that focuses on trade regulations.

The fourth core function of regulatory oversight bodies refers to the systemic evaluation of regulatory policy. As in the case of other government policies, it is important to define goals and objectives, but also to be able to assess the impact of the efforts and resources devoted to achieving these goals. As Brazil is still in the process of developing a whole-of-government policy on better regulation, now is the right time to define a monitoring and evaluation system. Having a global perspective on the efforts on regulatory policy allows system-wide improvements and leads to the development of feedback loops.

When talking about regulatory policy, usually the focus tends to be on RIA, stakeholder engagement, and ex post evaluation of regulations. High-quality regulation goes well beyond these three building blocks and includes elements such as forward planning, monitoring and assessment of RIA systems, and inspections and regulatory enforcement, among others. In Brazil, several of these tools are already among the tasks performed by some entities; nonetheless, ensuring that these mechanisms are part of the country’s regulatory cycle is important to achieve a thorough policy. The following sub-sections describe the achievements and opportunity areas of the Brazilian administration in terms of regulatory planning and inspection and enforcement activities.

Regulators and regulated parties benefit from the development of agendas that describe the anticipated normative changes. Planning encourages transparency and accountability, as it can improve co-ordination in government institutions and provides stakeholders with a roadmap of the regulator’s work. In Brazil, the publication of a forward plan or regulatory agenda is only mandatory for regulatory agencies within the scope of the Regulatory Agencies Act. The agenda should be in line with the agency’s strategic planning and be publicly available at the entity’s headquarters and internet site (Act No. 13.848/2019, Art. 21). Other institutions might have an internal requirement to publish a regulatory agenda; such is the case of the Securities Commission (Comissão de Valores Mobiliários, CVM). The CVM’s internal regulations state that the Commission should develop a regulatory agenda for the coming year (Ordinance CVM/PTE 190/19). As in the case of the regulatory agencies, the proposed agenda is approved by the Board of Directors/Commissioners and includes a prioritisation of the projects and whether the proposals would be subject to RIA.

In the case of ministries, forward regulatory planning is more institutionalised for primary legislation. As of 2022, Casa Civil is required to publish the government’s priority agenda (Decree No. 10.907/2021). This document includes a compilation of the legislative proposals (primary laws) that ministries deem as a priority for the next year. In 2022, the ministries put forward 531 proposals, which were assessed and refined by Casa Civil. The final agenda included 45 proposals grouped into ten major topics4 (Casa Civil, 2022[17]). The publication of the government’s priority agenda is an effort to increase the administration’s transparency and predictability vis-à-vis the Congress and relevant stakeholders.

While the obligation to set up a regulatory agenda does not apply to ministries, some administrative areas and entities are incorporating forward planning in their normative process. For instance, the Ministry of Infrastructure (MINFRA), in 2020 published its Transit Regulatory Agenda for the period 2021-2022 (Agenda Regulatória de Trânsito, Ordinance No. 2.663/2020). In the same vein, the Ministry of Agriculture made its regulatory agenda for 2021-2022 (Ordinance No. 277/2020) available to the public.

Although this tool has not been systematically adopted throughout the federal administration, the provisions in the recently signed agreement between the United States and Brazil5 should help deploy the use of regulatory agendas in the federal administration. It is not clear, however, when this obligation will come into force. The regulatory agendas of the regulatory agencies as well as those of a subgroup of ministries are available on the Ministry of Economy’s website.

A relevant point in the regulatory policy cycle refers to efforts that administrations make to inspect regulated parties and enforce compliance of the norms. Governments can incorporate key elements for a high-quality enforcement and inspections system in the country’s policy on better regulation. Brazil has taken some steps to encourage better inspections by introducing risk considerations in the Economic Freedom Act and in Decree No. 10 178/2019. The focus of these legislations has been the classification of economic activities based on their risk level and the after-market inspection of those activities considered of low risk. These are steps in the right direction, and could help develop a more articulate strategy for enforcement and inspections with a better regulation viewpoint (please see Box 3.7 for more details on the principles of good inspections and enforcement ecosystems).

Regulatory agencies have taken some steps to strengthen their inspection and enforcement systems. Nevertheless, these efforts are neither systematised nor widespread throughout the administration. Evidence collected by the review team shows that there are deep underlying issues to be tackled to guarantee that regulatory compliance activities are adequate, efficient and evidence-based. Among the key opportunities areas are:

  • The different interpretation of the laws and rules

  • Little standardisation of procedures and co-ordination across institutions and levels of government involved in the inspection process

  • Resourcing structures of inspection entities.


[17] Casa Civil (2022), Agenda Legislativa prioritária do Governo Federal para 2022, https://www.gov.br/casacivil/pt-br/assuntos/noticias/pautas-prioritarias-de-2022 (accessed on 16 March 2022).

[15] Department for Business, E. (2020), Better Regulation Framework, Interim guidance, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/872342/better-regulation-guidance.pdf (accessed on 18 June 2020).

[3] Government of Canada (2018), Cabinet Directive on Regulation, https://www.canada.ca/en/government/system/laws/developing-improving-federal-regulations/requirements-developing-managing-reviewing-regulations/guidelines-tools/cabinet-directive-regulation.html (accessed on 26 April 2022).

[19] Government of Canada (n.d.), Guide to Making Federal Acts and Regulations: Cabinet Directive on Law-Making, https://www.canada.ca/en/privy-council/services/publications/guide-making-federal-acts-regulations/guide-making-federal-acts-regulations-cabinet-directive-law-making.html (accessed on 6 April 2020).

[14] Government of the United Kingdom (2022), Regulatory Policy Committee, https://www.gov.uk/government/organisations/regulatory-policy-committee (accessed on 2 February 2019).

[12] Ministério da Economia (2022), Guia Orientativo para Elaboração de Avaliação de Resultado Regulatório-ARR, https://www.gov.br/economia/pt-br/assuntos/air/guias-e-documentos/GuiaARRverso5.pdf (accessed on 16 March 2022).

[8] Ministério da Economia (2021), Análise de Impacto Regulatório; Perguntas Frequentes, https://www.gov.br/economia/pt-br/assuntos/air/o-que-e-air/copy_of_1.AIRFAQ.pdf (accessed on 7 February 2022).

[10] Ministério da Economia (2021), Coleta e Tratamento de Dados no Âmbito do Decreto da Análise de Impacto Regulatório-AIR, https://www.gov.br/economia/pt-br/assuntos/air/o-que-e-air/3.AIREstrategiadeColetaeTratamentodeDados.pdf (accessed on 7 February 2022).

[7] Ministério da Economia (2021), Guia para Elaboração de Análise de Impacto Regulatório (AIR), https://www.gov.br/economia/pt-br/assuntos/air/o-que-e-air/SEPEC_guiadeair_vfinal_1504211.pdf (accessed on 7 February 2022).

[11] Ministério da Economia (2021), Modelo de Governança da Análise de Impacto Regulatório do Ministério da Economia, https://www.gov.br/economia/pt-br/assuntos/air/o-que-e-air/4.AIRModelodegovernanca1.pdf (accessed on 7 February 2022).

[9] Ministério da Economia (2021), Participação Social no Âmbito do Decreto de Análise de Impacto Regulatório-AIR, https://www.gov.br/economia/pt-br/assuntos/air/o-que-e-air/2.AIRManualdeParticipacaoSocial.pdf (accessed on 7 February 2022).

[13] OBPR (2022), Learning from Australia’s experience of capacity building for Regulatory Impact Analysis (RIA).

[16] OECD (2021), OECD Regulatory Policy Outlook 2021, OECD Publishing, Paris, https://doi.org/10.1787/38b0fdb1-en.

[18] OECD (2018), OECD Regulatory Enforcement and Inspections Toolkit, OECD Publishing, Paris, https://doi.org/10.1787/9789264303959-en.

[5] OECD (2018), OECD Regulatory Policy Outlook 2018, OECD Publishing, Paris, https://doi.org/10.1787/9789264303072-en.

[4] OECD (2012), Recommendation of the Council on Regulatory Policy and Governance, OECD Publishing, Paris, https://doi.org/10.1787/9789264209022-en.

[2] OECD (2011), Regulatory Policy and Governance: Supporting Economic Growth and Serving the Public Interest, OECD Publishing, Paris, https://doi.org/10.1787/9789264116573-en.

[1] OECD (2008), OECD Reviews of Regulatory Reform: Brazil 2008: Strengthening Governance for Growth, OECD Reviews of Regulatory Reform, OECD Publishing, Paris, https://doi.org/10.1787/9789264042940-en.

[20] Regulatory Policy Committee (2019), The RPC-How we work with departments, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/795424/The_RPC_Offer_to_departments_logo.pdf (accessed on 29 June 2020).

[6] Renda, A. and J. Castro (Forthcoming), Defining and Contextualising Regulatory oversight and Co-ordination.


← 1. and Public Sanitation omplementary

← 2. Regulatory sludge: “excessive or unjustified frictions, such as paperwork burdens, that cost time or money; that may make life difficult; that may be frustrating, stigmatising, or humiliating; and that might end up depriving people of access to important goods, opportunities, and services.” (see Sunstein, Cass R. (2019), Sludge Audits, 27 April). Harvard Public Law Working Paper No. 19-21, Forthcoming, Behavioural Public Policy, https://doi.org/10.2139/ssrn.3379367.

← 3. The regulatory agencies covered under the Regulatory Agencies Act already have an obligation to hold public consultations. Please refer to Chapter 3 for more details on stakeholder engagement activities in the Brazilian federal administration.

← 4. Economic, Brazilian Cost (Custo Brasil), Social, Environmental, Security and Defence, Agriculture, Mining, Education, Infrastructure, and Health.

← 5. Agreement on Trade and Economic Cooperation between the Government of the Federative Republic of Brazil and the Government of the United States of America Related to Trade Rules and Transparency.

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