copy the linklink copied!5. Assessment and recommendations

This chapter builds on the findings of the overall report regarding the context of international regulatory co-operation policies and practices in the United Kingdom, the unilateral efforts undertaken to support regulatory coherence and the co-operative efforts on regulatory matters. It offers three sets of recommendations to the United Kingdom. For a better streamlining of IRC across government, the United Kingdom should build a holistic IRC vision, strategy and strengthen political leadership for IRC with clearly defined roles and responsibilities for key players. To adapt regulations to the global context, the UK should embed IRC more systematically in regulatory management tools and throughout the rule-making cycle. And finally, to facilitate a more systematic use of IRC, it should increase awareness and understanding about IRC across departments and regulators.


copy the linklink copied!General overview of international regulatory co-operation (IRC) in the United Kingdom

With IRC largely seen as an EU competence to date, the United Kingdom does not have an overarching, cross-government strategic vision and systematic practices on IRC. IRC has mainly been confined to co-operation within the EU, which is strongly framed by specific legal framework and institutions. IRC beyond the EU has been sporadic and sector-specific. Nevertheless, the United Kingdom has a long-standing experience with regulatory policy and strong institutions in place that provide for meaningful opportunities to embed more systematic international considerations in domestic rulemaking and mainstream IRC throughout the rulemaking cycle. As illustrated in Chapter 4, a number of departments and regulators have also developed strong relationships with their peers abroad and as part of their participation in international fora.

The legacy

The United Kingdom has been a leader in promoting the Better Regulation agenda domestically, among EU and OECD members, and beyond. However, IRC is implicitly rather than overtly discussed in its current Better Regulation Framework. It is mainly conducted in an ad hoc manner and mostly seen as an EU responsibility. Having said that, the UK’s regulatory policy, practices and institutional organisation are strengths upon which to rely to mainstream greater IRC considerations into domestic rulemaking. The strong embedding of specific mechanisms for EU legislation offer in themselves strong entry points for broader IRC considerations.

The UK’s request for the OECD to conduct an IRC Review is testament to the country’s ambition of ensuring that its IRC processes follow international best practices. It is a unique opportunity for the UK to continue showing leadership on the regulatory policy agenda, in an emerging policy area where most countries are still struggling to establish the basis of the approach.

The pressure points

Technological changes across the globe are making it increasingly challenging for domestic regulators to achieve their core regulatory objectives in isolation. At the same time, integration in global value chains is making the UK economy increasingly interconnected with and dependent on other economies at a global scale, beyond its immediate neighbours. These trends provide meaningful opportunities for a beneficial approach to IRC.

The United Kingdom’s withdrawal from the EU is also a strong driver of its IRC efforts. It creates pressure to both move away from and remain aligned to EU regulations, and the UK will need to manage the resulting tensions:

  • Building on its years as an EU member, the United Kingdom has both accumulated substantial IRC experience with its neighbouring countries, and delegated a number of regulatory tasks to the EU. With the withdrawal, the mandate of UK departments and regulators is likely to grow with new regulatory responsibilities – the case studies, in particular the ones on product safety and medical products in Chapter 4, provide a prime example and highlights resource implications. This provides an opportunity to embed international considerations in their rulemaking activities more systematically.

  • Given geographical proximity and the intensity of flows and current interactions, the United Kingdom will need to maintain close ties with the EU regardless of the modalities of its withdrawal. Interconnectivity of transport, energy and other physical infrastructure will continue driving substantial trans-boundary co-operation. The EU single market is likely to remain the most important trade partner for the United Kingdom. More broadly, the United Kingdom and the EU have a strong incentive post-withdrawal to collaborate closely to avoid regulatory loopholes and maintain regulatory effectiveness across numerous critical policy areas. The case studies in Chapter 4 highlight the potential weakening of market surveillance and enforcement infrastructure following the withdrawal from the EU. Continuing benefiting from the EU enforcement networks and mechanisms will be particularly critical to preserve regulatory effectiveness.

  • The withdrawal also generates strong imperatives for the United Kingdom to collaborate more strongly with countries beyond the EU in order to diversify its partners and compensate for lost co-operation mechanisms and related privileges. There are co-operation opportunities both bilaterally, plurilaterally and through more active engagement in multilateral international organisations (IOs). The Better Regulation Framework and the past experience of integrating past EU legislation into the UK’s regulatory framework provide opportunities and entry points to embed broader IRC considerations in UK rulemaking.

  • With the withdrawal from the EU, the United Kingdom may lose the benefit of acting through a bigger bloc of countries in a number of international co-operation initiatives. This position still offers many co-operation opportunities but may make bilateral relations costlier for the United Kingdom. Where bilateral or regional co-operation is critical – i.e. for issues and in sectors where there is strong bilateral or regional ties and geographic proximity matters significantly – the consequence for the United Kingdom may be a certain level of unilateral adoption of the partner’s approach. For issues requiring multilateral solutions, channelling the UK’s agenda through international fora (where one country equals one vote or decision is consensus based – regardless of size) or through coalitions of like-minded countries may be more cost effective.

copy the linklink copied!Key priority areas of focus for the United Kingdom on IRC

Whatever the future relation with the EU, the UK regulatory framework would gain from a stronger systematic consideration of the international environment. This involves: i) building a holistic IRC vision and strategy with clearly defined roles and responsibilities; ii) embedding stronger IRC considerations in regulatory management tools (beyond trade and business impacts) and throughout the rulemaking cycle; and iii) updating incentives, awareness and guidance to departments and regulators.

Building a holistic IRC vision, a strategy and political leadership for IRC in the United Kingdom, with clearly defined roles and responsibilities for key players, to develop quality regulation in a globalised context


IRC initiatives in the United Kingdom (beyond those related to the EU framework) are largely fragmented and sector-specific. Whilst there are references to the importance of gathering evidence from international best practice in certain pieces of guidance, including in the HM Treasury Green Book, the main efforts currently undertaken to enhance IRC is in the trade area. This is illustrated by the introduction of a new trade question in the RIA template and related notifications to the World Trade Organization (WTO).

However, IRC is not a purely trade facilitating tool: it has important broader benefits for policy makers, regulators and society, for example via learning from peers abroad, or aligning approaches on common and cross-border policy challenges to strengthen the effectiveness of domestic regulation in achieving its policy objectives. Co-operation is also a cornerstone of effective market surveillance and regulatory enforcement. With the growing dematerialisation of flows transcending borders, regulatory co-operation across different jurisdictions is becoming critical to the identification of non-compliant behaviours, the detection of dangerous products and their remedies. From this perspective, IRC may help achieve other broader objectives such as safety, social and environmental.

The United Kingdom has a strong system of centralised oversight on better regulation. Responsibility for oversight is shared between the Better Regulation Executive (BRE), which develops the framework and guidance for better regulation and the Regulatory Policy Committee (RPC), which provides external, independent scrutiny of evidence and analysis supporting RIAs and ex post evaluations of legislation. This allows these bodies to provide strategic leadership on better regulation, offer guidance and support on all matters related to better regulation and ensure independent scrutiny of better regulation efforts across regulatory initiatives. The Better Regulation Units (BRUs) play an important role in embedding the better regulation agenda across Government Departments. However, IRC is not an explicit area of oversight in the Better Regulation Framework, and relevant tasks are split across a number of bodies, including mainly the BRE, the RPC, the Foreign and Commonwealth Office (FCO) and the Department for International Trade (DIT). Departments and regulatory agencies are key implementers of IRC. This multiplicity of actors involved in the oversight and conduct of IRC, and the lack of incentive for these bodies to work together in a co-ordinated way, results in an ad hoc and case-by-case approach to IRC.

The United Kingdom is taking many measures to prepare for being outside the EU in order to avoid major impacts of the withdrawal for its businesses and citizens. It is pursuing new IRC opportunities globally (e.g. through continuity agreements and regulatory diplomacy for example). The United Kingdom would benefit from a stronger common IRC thread throughout these initiatives, guided by a whole-of-government policy. This would also involve making explicit the IRC considerations which may be currently implicitly contained in the various components of the better regulation agenda. Nonetheless, the political economy of IRC in a post-withdrawal context will not be easy to manage. While stronger IRC policies may be called for to compensate for the loss of EU mechanisms, it should be recognised that certain stronger forms of IRC may limit a country’s regulatory space and sovereignty and attract political controversy.

In this context, a narrative identifying the rationale and benefits of IRC will be important. There are many examples of how such co-operation has benefitted governments, regulators, business and citizens.1 The regulatory challenges of emerging technologies in particular provide a strong rationale for IRC. The Government’s June 2019 White Paper, “Regulation for the Fourth Industrial Revolution”2 illustrates these challenges and delineates a long-term plan to reform the UK’s approach to regulating technological innovation. It highlights existing work and sets out a number of proposals, which have the potential to strengthen the use of IRC in policymaking.


  • Ensure IRC leadership and systematic mainstreaming from the Government institutions responsible for better regulation policy and oversight. To have maximum impact, strong IRC leadership should sit with part of government with sufficient cross-government oversight of cross-sectoral regulatory activity, ideally a committee of ministers to provide political leadership. Examples of such parts of Government that have exhibited these qualities could include the Ministerial Working Group on Future Regulation, tasked with overseeing the implementation of the White Paper reforms (Box 1.5) or the (now abolished) Reducing Regulation Sub-Committee (Box 1.4).

  • Sufficient financial and human resources should be dedicated to ensuring the systematic application of IRC rules within departments. IRC is part and parcel of the regulatory policy agenda – it is an important building block of regulatory quality. As such, there should be dedicated staff strongly connected to the Better Regulation agenda and Framework with sufficient resources and influence to ensure maximum mainstreaming in the rulemaking practices of departments and regulators.

  • Roles and responsibilities on IRC policy and oversight should be clearly defined and close co-operation fostered between the various institutions involved (the BRE, the RPC, the BRUs, the FCO and DIT) to ensure that IRC efforts resonate with regulators. On this, the experience from Canada and New Zealand provides reference points (Box ‎5.1).

  • The BRE and RPC, as oversight bodies for the better regulation framework, should play an active role in pushing forward and mainstreaming the IRC agenda. They should work closely with the BRUs and the wider analytical community and Board Level Champions, to ensure that they have sufficiently detailed technical understanding of IRC, thereby enabling them to challenge their respective departments to integrate IRC into policymaking processes.

  • Develop a whole-of-government strategy, with a single, broad, definition of IRC and common public policy objectives in line with the UK Government’s strategic priorities, taking into account Government departments, regulatory bodies and the devolved administrations. In particular, take into consideration the potential of IRC to pursue regulatory objectives including social and environmental objectives, while also taking into account its benefits for facilitating international trade.

  • The part of government tasked with developing the IRC Strategy must ensure that it is shared across government and designed with inputs from within and outside of government to ensure ownership of the government’s IRC priorities. Regulators know their field and peers. The government objective should be to facilitate their co-operation by clarifying what IRC is and what can be expected from it; and to provide guidance where needed, by facilitating access to the relevant information.

  • Take forward the White Paper proposals and monitor their implementation, as these contain a number of proposals, which could help build UK IRC capacity at a number of levels. These include building methodologies and understanding of the effects of regulation on trade amongst departments/regulators; ensuring that IRC is reflected in trade deals and working upstream to influence IRC in international fora. However, it is crucial that IRC is not viewed solely through a trade lens and the government IRC Strategy also reflects the potential for IRC to align approaches on common and cross-border policy challenges e.g. working closely together to ensure the continued effectiveness of environmental regulatory frameworks relating to air quality and climate change

  • While it is important that the strategic vision supports the transition in the withdrawal from the EU, this vision should be long-term and well rooted into the better regulation agenda. In particular, this involves preventing the UK IRC and regulatory policy agendas more broadly from becoming merely a response to the UK’s withdrawal from the EU and ensuring that they remain state-of-the-art and forward looking.

  • As the UK develops its IRC policy, it should be targeted/focused proportionately upon aspects of economic activity with the largest regulatory impact. It should give priority to key partners for collaboration, taking into account the UK’s degree of “dependence” on other countries, depend on sectors and account for IRC drivers (Box ‎5.2). Given the geographic proximity and historic links, it is likely to entail maintaining close ties with the EU.

  • As Departments implement the new “trade” impact of the RIA / ex-post review processes, it will provide valuable data to feed into the IRC Strategy, inform on areas of priority and potential IRC partners, and support upstream trade negotiations. The case of Norway can also usefully inform UK policy makers on how relate to the EU legislation as a non-member, both to influence and then adopt / implement it (Box ‎5.3).

  • The United Kingdom should leverage further its strong record in regulatory policy to promote good regulatory practices, including IRC, internationally. A strong culture of regulatory quality allows better dialogue on regulatory matters and facilitate the development of trust across governments and regulators.

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Box ‎5.1. Whole of government strategy and organisation of IRC: experiences from Canada and New Zealand


IRC is formally embedded in Canada’s overarching regulatory policy framework, the Cabinet Directive on Regulation (CDR). The CDR requires regulators to assess opportunities for co-operation and alignment with other jurisdictions, domestically and internationally, in order to reduce unnecessary regulatory burden on Canadian businesses while maintaining or improving the health, safety, security, social and economic well-being of Canadians, and protecting the environment. Where a Canada-specific approach is required, regulators must provide a rationale in the regulatory impact assessment statement.

The Government of Canada has a dedicated team responsible for supporting and co-ordinating efforts to foster international and domestic regulatory co-operation. This team sits within the central regulatory oversight body, the Treasury Board Secretariat of Canada (TBS). In Budget 2019, the TBS was granted permanent funding covering 16 full-time employees to co-ordinate domestic and international regulatory co-operation efforts, including management, policy, sector analysts and administrative support.

The team’s activities include working with regulators to ensure that they meet their obligations under the CDR, as well as leading Canada’s participation in three formal regulatory co-operation mechanisms: the Canada-European Union Comprehensive Economic and Trade Agreement Regulatory Cooperation Forum, the Canada-United States Regulatory Cooperation Council and the domestic Federal-Provincial/Territorial Regulatory Reconciliation and Cooperation Table under the Canadian Free Trade Agreement. TBS works with Canadian federal regulators, as with officials in the United States, the European Union, and provinces/territories, to reduce unnecessary regulatory differences and eliminate duplicative requirements and barriers between jurisdictions. TBS also works closely with Global Affairs Canada to negotiate regulatory provisions in trade agreements, including those related to IRC.

New Zealand

In New Zealand, IRC considerations are embedded in core documents, including the Government Expectations for Good Regulatory Practice and the Government’s Regulatory Management Strategy: Building Effective Regulatory Institutions and Practices. Responsibility for oversight and promoting consideration of IRC is shared across several agencies.

The Regulatory Quality Team within the Treasury, a central agency, exercises stewardship over the regulatory management system to maintain and enhance the quality of government-initiated regulation. This team is the lead agency on good regulatory practice for New Zealand.

The Ministry of Business, Innovation and Employment (MBIE), takes the lead on promoting international regulatory coherence, which includes promoting international regulatory co-operation in its many forms. MBIE and Treasury work in close collaboration and are both involved in the negotiation and implementation of cross-cutting GRP and regulatory co-operation chapters in FTAs. Treasury and MBIE share responsibility for representing New Zealand at international regulatory policy fora, and co-ordinating New Zealand’s contribution to benchmarking studies of regulation and the regulatory environment.

The Ministry of Foreign Affairs and Trade is New Zealand’s lead advisor and negotiator on trade policy. The Ministry oversees and provides advice on the process by which the New Zealand Government enters into treaties.

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Box ‎5.2. The IRC drivers

OECD has identified a number of factors that promote, hinder and shape IRC endeavours. These hypotheses may inform policymakers pondering about when, how and with whom to engage in IRC. They do not represent, however, static rules on the political economy of IRC.

  • Geographical proximity: geographical proximity may increase the need and likelihood of co-operation and IRC due to joint challenges, similar worldviews and preferences.

  • Economic interdependence: high trade volumes may increase the likelihood for co-operation so as to lock in a certain level of regulatory openness and to lower trade costs through the dismantling of unnecessary regulatory divergence. Balanced interdependence should moreover promote the use of negotiated IRC instruments, while imbalanced interdependence should promote the use of unilateral IRC instruments such as Good Regulatory Practices (GRP).

  • Political and economic properties of potential partners: IRC should be easier in hierarchical relationships between rule-makers and rule-takers than in hierarchical relationships between two rule-makers or two rule-takers. In non-hierarchical complex relationships, the availability of international regulation and standards should significantly facilitate IRC.

  • Nature of regulation: the political sensitivity of measures subject to regulation – i.e. their inherent risk levels or social and economic nature – should significantly affect the likelihood of IRC. IRC on politically sensitive measures should be more difficult than IRC on less sensitive measures. IRC commitments, moreover, can promote market integration on a preferential basis or non-preferential basis. Preferential commitments should fuel competitive IRC efforts, whereas non-preferential IRC should trigger no such phenomenon. Finally, depending on the sector, regulation and standards can be subject to either positive feedback processes promoting IRC or inter-state competition and free riding dynamics hindering IRC.

  • Domestic regulatory governance: IRC may hinge on transparent regulatory governance and the ability of states to actually enforce regulation and IRC commitments at the domestic level.

Source: Basedow and Kauffmann (2016), “The Political Economy of International Regulatory Co-operation: A theoretical framework to understand international regulatory co-operation”, OECD, Paris, unpublished Working Paper.

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Box ‎5.3. Norway adoption and implementation of EU legislation

The European Economic Area (EEA) brings together the EU member states and three of the European Free Trade Association (EFTA) States (Iceland, Liechtenstein and Norway). It was established by the EEA Agreement in 1992 and enables these three EFTA States to participate fully in the Single Market. The EEA represents a tight and elaborate IRC system with one big and three small partners. In Norway, the formal decision-making process covers the EEA Agreement and the agreements with the EU in the field of justice and home affairs.

The EEA Committee must first make a decision to incorporate new EU legal acts into the EEA Agreement before they can be implemented in Norwegian law through legislative or regulatory decisions.

The government can implement most of the legal acts from the EEA agreement in Norway, but legislative acts must be submitted to the Norwegian parliament (The Storting) if they entail amendments to the law, financial obligations or are considered of particular importance. Due to the principle of uniform development of the regulations in the EEA, an EU legal act should in principle be implemented and come into effect simultaneously throughout the EEA.

The EEA Agreement does not include participation in the EU's decision-making process. It provides, however, the opportunity to observe and participate in an early stage, i.e. when the European Commission (EC)’s proposal is being formulated. The possibilities of being heard for Norway as an EEA-member when the process in the EU is approaching decisions are more limited.

In the preparatory phase of new regulations, Norway has the right to participate in expert groups and committees under the Commission. Expert groups are forums consulted by the EC on a free and informal basis in the preparation of proposals for new regulations. Norwegian experts participate on an equal footing with experts from the member states. The purpose is to strengthen the academic basis for the EC's work. The EC is not bound by their views and recommendations and there is therefore no requirement for them to arrive at a common position.

The EU also has a number of formal committees consisting of representatives of national authorities who assist the EC in the work on supplementary regulations. The committees have a formal role in the EU's decision-making process. This is where the regulations governing the implementation of directives and regulations adopted by the European Parliament and the Council are being prepared. Norway has only observer status and cannot participate in voting.

Norwegian ministries and regulatory bodies spend substantial time and resources on following EU regulatory work in all stages. There is a large Norwegian representation with the EC staffed with diplomats and sector specialists. In addition, many regulators spend significant time travelling to Brussels in the preparatory phase of new EU regulation.

Embed IRC more systematically in regulatory management tools and throughout the rulemaking cycle


IRC is implicit rather than explicit in the UK Better Regulation Framework and related regulatory policy tools and disciplines, resulting in case by case IRC practices by departments and regulators. There are some references to the importance of considering international evidence in the HM Treasury Green Book. However, IRC is de facto mainly promoted in the Better Regulation Framework from a trade facilitation perspective: through the consideration of international standards (which are exempt from the Business Impact Target if implemented via non-regulatory means – an implicit requirement) and the introduction of a trade question in the RIA template.

Supposedly, the RIA process is an opportunity for the gathering of overseas / international intelligence and expertise by departments. However, because of the strong focus of the Better Regulation Framework on regulatory burdens on businesses (driven by the provisions of the SBEE Act that introduced the Business Impact Target), departments and regulators tend to focus on the regulatory costs to business, rather than on the quality of the narrative and the evidence provided in the analysis. In any case, IRC is not particularly considered in the cost / benefit assessment of the RIA processes, or in the BIT assessments that both departments and regulators must undertake.

IRC also is not yet sufficiently embedded into the UK Government’s Post-Implementation Review (PIR) processes, or in the specific regulators’ evaluation processes. The SBEE Act does establish a duty on departments to review regulatory provisions in secondary legislation, which implement EU or international obligations, and to consider if there would be better ways of delivering these changes.3 However, the various guidance documents, including the Better Regulation Framework Guidance, PIR Guidance and the PIR template do not include a requirement for departments to consider to what extent regulation has been consistent with or has departed from international instruments and practices and whether its delivery has had cross border unintended consequences. Departments have nevertheless been so far directed to identify how UK’s implementation of EU measures compares with other EU member states, which provides an important opportunity and entry point to broaden the requirement beyond the EU.

In addition, international expertise and the relevance of foreign or international frameworks for domestic regulatory purposes remains largely undervalued overall (despite the fact that HMT’s Green Book points to the need for consideration of international comparators to form part of analysis). There is no specific promotion of IRC in the Better Regulation Framework Guidance. Whilst the RPC reports considering and promoting the use of international evidence as part of its scrutiny of the robustness of the analysis underlying RIAs, it is unclear how much of an incentive this implicit focus provides to departments. In addition, the existence of a de minimis threshold, with the aim of focusing scrutiny on the highest impact measures, has reduced the number of RIAs scrutinised by the RPC. The proposals falling under the threshold still undergo a degree of scrutiny in their development process, e.g. chief analyst signing off, the interdepartmental collective agreement process and parliamentary scrutiny. However, these are not likely to promote IRC given its largely implicit nature in the Better Regulation Framework.


IRC should be better embedded in policy tools throughout the rulemaking cycle in order to guarantee that they are genuinely and systematically considered by UK departments and regulators. This implies that the Government should:

  • If possible, update the relevant legislation and policy documents, which frame regulatory policy to embed IRC and to ensure that departments and regulators have any necessary legal mandate to undertake such activities. The Government may wish to review whether the SBEE Act provisions regarding the Business Impact Target affect the incentives of departments and regulators to consider IRC when assessing the impact of new regulatory measures. Should the UK Government consider revising the legal requirements around Better Regulation post EU withdrawal, this would provide an opportunity to embed a broader vision of regulatory quality via either legislation or administrative rules. IRC should then be considered on the same level as the other key high-level principles driving regulatory quality, as provided by the 2012 OECD Recommendation on Regulatory Policy and Governance (OECD, 2012[1]).

  • Modify policy guidance on regulatory policy, including the Better Regulation Framework Guidance and other key sources of guidance (e.g. HMT Green Book) to embed explicit recommendations to consider the international environment and to help departments and regulators understand how and when to consider IRC in the regulatory process. It will also be important to consider whether the UK Regulators’ Code needs updating to ensure that regulators are considering IRC in their analytical processes. Canada and New Zealand provide examples of how to embed IRC in the traditional regulatory management tools (Box ‎5.4).

  • Clarify and emphasise the importance of considering the extent to which new regulations are compatible with existing EU, foreign and international evidence, regulatory options and experiences in the Better Regulation Framework, in the related guidance, and in the criteria used by the RPC for analysing RIAs. In particular, the use of relevant foreign and international evidence could be explicitly mentioned as being an important element of quality evidence to be used in RIA and PIR. Systematic references to international practices in the same field could be encouraged as part of the policy development for any new regulatory measure and the reasons for departing from them explained (even for those measures under the de minimis threshold). Box 5 provides examples of requirement to consider international standards and other relevant regulatory frameworks in other jurisdictions.

  • Provide departments and regulators methodological help to consider IRC in the cost and benefit calculation for the BIT. As an example, Canada has introduced IRC as a credit in the “one-in, one-out” exercise (Box ‎5.6).

  • The Government should consider whether regulatory bodies have sufficient resourcing to increase their level of IRC activities. IRC is not a cost-free activity and adequate resources will be a critical success factor in their ability to systematically embed IRC in their rule making processes. Ultimately, there are efficiency and effectiveness gains of regulatory co-operation to balance these costs.

  • As the UK Government works to add the measurement of trade impacts into the RIA process, the RPC will have a critical role in providing independent assurance over the robustness of the calculations and assisting in the development of the underlying methodology. In addition, the RPC could build upon its previous work to provide methodological training and guidance materials (in co-ordination with BRE and DIT) to departments and regulators. Evidence on the trade impacts of individual regulations will also be useful more generally for future trade policy.

  • Broaden the scope of ex post review policy, by updating PIR guidance (e.g. Better Regulation Framework Guidance and other related documents such as the PIR template) to prompt departments to address inconsistency in the stock of regulation with international instruments and build on international expertise and practice. There may also be scope for joint ex post evaluations with key partners and greater connection with evaluation initiatives of international organisations. Box ‎5.7 provides example of integration of IRC considerations in ex post evaluation in Canada and of cross-jurisdictional reviews between Australia and New Zealand. Evidence gathered through PIRs could be leveraged to identify the priorities for the strategic IRC vision and where to target specific IRC efforts.

  • In a post withdrawal context, early warnings of potential regulatory divergences and frictions with major partners are essential to inform future UK rulemaking. This calls for strengthening UK’s forward planning tools that help offer information on upcoming regulations to both domestic and foreign stakeholders, including through the WTO notification process, and enabling them to provide comments (see Box ‎5.8). It also calls for early engagement in major partners’ regulatory activities, including the EU.

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Box ‎5.4. Embedding IRC in regulatory management tools: the example of Canada and New Zealand

In the updated version of Canada’s Directive on Regulation that came into effect in September 2018, regulatory co-operation is embedded throughout the lifecycle:

  • Regulators are required to assess early opportunities for alignment with other jurisdictions (domestically and internationally) to reduce unnecessary regulatory burden on Canadian businesses while maintaining or improving the health, safety, security, social and economic well-being of Canadians, and protecting the environment

  • Where a Canada-specific approach is required, regulators must provide a rationale in the regulatory impact assessment statement

  • Forward regulatory plans require identification of regulatory co-operation issues

  • As part of stock reviews, regulators must identify new opportunities to reduce regulatory burdens on stakeholders through regulatory co-operation activities

The New Zealand Government Expectations for Good Regulatory Practice apply to all New Zealand’s regulatory systems and therefore to all kinds of regulatory measures and actors.

Part A of the Expectations sets out expectations for the design of regulatory systems. This provides that “the government believes that durable outcomes of real value to New Zealanders are more likely when a regulatory system … is consistent with relevant international standards and practices to maximise the benefits from trade and from cross border flows of people, capital and ideas (except when this would compromise important domestic objectives and values)”. The term international standards in this context is used more broadly by New Zealand than in the current report, going beyond the WTO definition to cover all international instruments.

 Part B sets out expectations for regulatory stewardship by government agencies. The regulatory stewardship role includes responsibilities for monitoring, review and reporting on existing regulatory systems. Regulatory agencies are expected to “periodically look at other similar regulatory systems, in New Zealand and other jurisdictions, for possible trends, threats, linkages, opportunities for alignment, economies of scale and scope, and examples of innovation and good practice”.

As part of regulatory stewardship responsibilities for robust analysis and implementation support for changes to regulatory systems, regulatory agencies are expected to undertake “systematic impact and risk analysis, including assessing alternative legislative and non-legislative policy options, and how the proposed change might interact or align with existing domestic and international requirements within this or related regulatory systems”.

Source: and

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Box ‎5.5. How is the need to consider international standards and other relevant regulatory frameworks conveyed in other jurisdictions

In Australia, there is a cross-sectoral requirement to consider “consistency with Australia’s international obligations and relevant international accepted standards and practices” (COAG Best Practice Regulation). Wherever possible, regulatory measures or standards are required to be compatible with relevant international or internationally accepted standards or practices in order to minimise impediments to trade. National regulations or mandatory standards should also be consistent with Australia’s international obligations, including the WTO Agreement on Technical Barriers to Trade and on Sanitary and Phytosanitary Measures (SPS). Regulators may refer to the Standards Code relating to the WTO TBT Agreement’s Code of Good Practice for the Preparation, Adoption and Application of Standards. In addition, the Australian Government Guide to Regulation makes clear that Regulatory Impact Analysis requirements apply to the development of standards used for domestic regulatory purposes, even when developed by an independent body (such as Standards Australia) or other third parties. If a regulatory option involves establishing or amending standards in areas where international standards already apply, the proponent should document whether (and why) the proposed standards differ from the international standard. To support greater consistency of practices, the Australian government has released a publicly available Best Practice Guide to Using Standards and Risk Assessments in Policy and Regulation.

In the United States, the guidance of the Office of Management and Budget (OMB) on the use of voluntary consensus standards states that “in the interests of promoting trade and implementing the provisions of international treaty agreements, your agency should consider international standards in procurement and regulatory applications”. In addition, the Executive Order 13609 on Promoting International Regulatory Cooperation states that agencies shall, “for significant regulations that the agency identifies as having significant international impacts, consider, to the extent feasible, appropriate, and consistent with law, any regulatory approaches by a foreign government that the United States has agreed to consider under a regulatory cooperation council work plan.” The scope of this requirement is limited to the sectoral work plans that the United States has agreed to in Regulatory Cooperation Councils. The scope of this requirement is limited to the sectoral work plans that the United States has agreed to in Regulatory Cooperation Councils.

Source:Australian Government Guide to Regulation:; Australia COAG Best Practice Regulation Guide:; Australian Government Best Practice Guide to Using Standards and Risk Assessments in Policy and Regulation: ; US OMB Circular A 119:; US Executive Order 13609:

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Box ‎5.6. Regulatory Co-operation in Canada: a credit under one-in, one-out

Canada’s Red Tape Reduction Act establishes a one-for-one rule to control the amount of administrative burden (paperwork burden) that is imposed on business through federal regulations. Whenever a new or amended regulation is brought forward by a department, it must take an equal value of administrative burden out of its regulatory stock, and must also remove a regulatory title (if a new regulation is being introduced).

In 2018, as an incentive to increase regulatory co-operation, Canada introduced amendments to the Red Tape Reduction Act to allow Canadian regulators to count reductions in administrative burden to Canadian businesses that occur in other jurisdictions, should they result from a work plan under one of Canada’s three formal regulatory co-operation tables (i.e., Canada-European Union Comprehensive Economic and Trade Agreement Regulatory Cooperation Forum, Canada-United States Regulatory Cooperation Council, Federal-Provincial/Territorial Regulatory Reconciliation and Cooperation Table under the Canadian Free Trade Agreement).

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Box ‎5.7. Embedding IRC in ex post reviews in Canada and in Trans-Tasman co-operation

Canada’s Cabinet Directive on Regulation requires regulators to conduct a regular review of their existing stock of regulations, including technical guidance and associated policy, to ensure that the regulations continue to be appropriate and effective and achieve their intended policy objectives. When undertaking a review, regulators must examine regulations according to a set of criteria that includes, among other things, identifying new opportunities to reduce regulatory burdens on stakeholders through regulatory co-operation activities.

In 2018, the Government of Canada announced funding over three years to conduct targeted reviews of regulatory requirements and practices that are bottlenecks to economic growth and innovation. During the first round of regulatory reviews, stakeholders highlighted the importance of regulatory co-operation and harmonization, noting that misalignment within Canada and between other international jurisdictions increases unnecessary burden on industry and acts as a barrier to trade, competitiveness, and growth.

For example, certain sectors of the agri-food industry outlined that food compositional standards are outdated, stifle innovation and are difficult to amend. Specifically, issues around the standards of production of vodka were raised. Consequently, Canada's vodka compositional standards were updated in June 2019, allowing the country's spirits industry to be more innovative, provide more choice for consumers, and enhance trade. Allowing the use of new additional agricultural products, such as honey, apple, or dairy, in vodka production has helped better align with international standards used by key trading partners, like the U.S. and European Union, which allow vodka to be produced from a wider range of materials.

The second round of targeted regulatory reviews will include a focus on international standards. By examining strategic opportunities for Canada to better incorporate international standards in regulation and accelerate its leadership in the development of international standards, this review will provide an opportunity to support regulatory streamlining and international regulatory co-operation.

The Trans-Tasman Mutual Recognition Arrangement (TTMRA) operates between Australia and New Zealand to address behind the border barriers to the movement of goods and skilled people. The TTMRA includes a specific commitment to undertake regular reviews of the operation of the arrangement and its related legislation. The TTMRA also provides that the review “will assess the effectiveness of the arrangements in fostering and enhancing trade and workforce mobility between Australia and New Zealand and should consider whether any changes to the Arrangement or related legislation are required to improve the operation or coverage of the Arrangement”.

Reviews to date have been undertaken by the Australian Productivity Commission (PC). In the most recent review in 2015, the PC was asked to assess the coverage, efficiency and effectiveness of the TTMRA and recommend ways to further improve inter-jurisdictional movement of goods and skilled workers, and reduce red tape. The PC was also asked to consider other issues related to the operation of the scheme. In undertaking the study, the Commission was to consult relevant stakeholders in Australia and New Zealand, including the Cross-Jurisdictional Review Forum and to substantiate its recommendations.

Back in 2004, the PC also undertook research on the Australian and New Zealand Competition and Consumer Protection Regimes in response to a joint request by the Australian and the New Zealand governments. The objective of the study was to examine the potential to improve the trans-Tasman business environment through greater co-ordination, co-operation and integration of the Australian and New Zealand consumer protection and competition policy regimes.

Source: and

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Box ‎5.8. Forward planning as a tool to inform domestic and foreign stakeholders in other jurisdictions

A number of OECD jurisdictions have a forward regulatory planning that can inform stakeholders, including foreign, of regulatory intents. In Canada, regulators must post their plans to develop or amend regulations over the next 24 months publicly on their websites. Each plan includes information on what regulatory co-operation efforts have been undertaken to date or that may be considered in the development of the regulatory proposal. The European Commission’s work programme sets out the overall planned action for the upcoming 12 months.

In Mexico, the national standardisation programme (Programa Nacional de Normalización, PNN) is the instrument for planning, co-ordination and information with regards to the development of technical regulations and standards. The PNN is developed by the Ministry of Economy and published in the Official Gazette once a year (a supplement can be issued mid-year) for informational purposes. On its own initiative, Mexico is the only WTO member to circulate its PNN as a WTO document to all WTO members, going beyond TBT Agreement obligations and committee recommendations. This has the benefit of giving considerable visibility to this instrument, which has the potential of serving as a baseline for early consultations, including with foreign stakeholders.

Trade agreements provide additional opportunities for parties to commit to forward planning as a way to inform one another of regulatory proposals. For example, under the Canada-United States-Mexico Agreement (CUSMA), the three countries have committed to annually publishing a list of regulations that they respectively reasonably expect to propose or adopt within the next 12-month period. This list must include a description of the proposed regulation, the name of a knowledgeable contact person who could answer any questions about the proposal, an indication of sectors that could be affected, and whether there are any expected significant impacts on international trade or investment. The parties have also committed to publishing the draft legal text and regulatory impact assessment for public consultation, and have agreed that interested stakeholders from all three countries will be afforded equal opportunity to provide comments.

Increase awareness and understanding about IRC across departments and regulators, including on the variety of existing IRC practices, and engage stakeholders to inform the development of IRC initiatives


There is uneven awareness about IRC across Departments and regulators. Some are very active in embedding international considerations in their rulemaking, whether of the EU (e.g. OfCOM) or beyond (e.g. ONR; MHRA; FCA). Overall, however, because of the absence of government policy and/or guidance on IRC, there is limited awareness about IRC and the possibility to benefit from international experience for feeding into domestic rulemaking.

The UK withdrawal from the EU has also shed light on the risk of a weakening of market surveillance and regulatory enforcement infrastructure in a context where digitalisation and other technologies are transcending borders. Going forward, the critical importance of co-operation for the proper implementation of laws and regulations needs to be more systematically emphasised and become an integral part of the enforcement policy and strategy of departments and regulators.

Various authorities co-operate actively with their foreign peers, bilaterally, regionally, plurilaterally and multilaterally. However, there is no entity within the Government that oversees or promotes IRC activities across Whitehall. The FCO has responsibility on the UK’s foreign policy and oversees participation in various IOs under its authority. However, its overview is not comprehensive as the FCO does not have an overall view of individual UK authorities’ participation in IOs. The FCO’s role in IRC activity could be enhanced as the new Regulatory Diplomacy project develops and becomes established.

The government has organised several working groups bringing together departments and / or regulators across Whitehall on horizontal regulatory matters, e.g. BRUs; BRE Regulators Forum; Regulatory Diplomacy; Network of Economic Regulators. These working groups provide valuable opportunities for raising awareness about IRC and providing an impetus to deepen IRC efforts across the government. Nevertheless, their scale and scope remain, for the time being, limited. These networks either meet sporadically, are organised along functional organisation (independent regulators meeting separately from departments) or are seen as opportunities for information sharing from the centre. They do not yet provide a genuine opportunity for a community of practice on areas of common interest – as is the case for the Community of Federal Regulators in Canada and of the Government Regulatory Practice Initiative in New Zealand (see Box ‎5.9).

The withdrawal from the EU will impact upon the regulatory co-operation initiatives of departments and regulators. Beyond the participation of the UK government in the EU institutions, there is a strong intertwining of EU national regulators through various networks and bodies. They all have different governance and organisation. To prepare and deliver effective IRC following withdrawal, a mapping of various departments and regulators’ situations and co-operation needs, going beyond the overview of four sectors provided in the case studies of Chapter 4, would be helpful.

Beyond the Regulatory Co-operation Council under the CETA, of which the UK is part indirectly until the end of the transition period, it does not have specific regulatory co-operation bodies (or even less formal arrangements) with any other bilateral trading partners. Going forward, these platforms can act as vectors of information and inputs, including from the stakeholder community.


  • The Government should mandate the BRE to conduct a survey of existing IRC initiatives and efforts, and the approaches used across a range of departments and regulators. This survey should leverage BRE’s oversight role on better regulation and its regular contacts with actors across Whitehall, the regulator community as well as the private sector. This exercise would allow highlighting positive experiences of regulators with IRC (as well as examples of where it has not been as successful), identifying Departments and/or regulatory agencies with most successful examples of IRC and giving them visibility to serve as example for other Departments and/or regulatory agencies.

  • Raise awareness of IRC among departments and regulators and offer them greater incentives to make use of IRC. This could include asking departments and regulators to consolidate the information on international/foreign instruments used in a repository to help other related regulators or future administrations in their search for related references. This could also involve promoting practices such as the development of IRC strategy (following for example the model of the Office for Nuclear Regulation strategic framework for international engagement) or the systematic consideration of the risk of non-cooperation for effective policy implementation in their enforcement policy / strategy.

  • Leverage existing regulators fora that exist in the UK government to build a community of IRC practices and other regulatory policy topics, raise awareness about IRC tools, and identify training needs when relevant. The community of practice should be an interactive platform where both Departments and independent regulators feel safe to interact and bring the wealth of their own experience – it should not be seen as solely an information vector from the centre (Box 9).

  • Create more systematic links between international units throughout Government with the FCO (perhaps through the Regulatory Diplomacy initiative) and improve information flows about active participation in IOs to give the FCO a broader view of the UK’s activity in multilateral fora. This could enable the FCO to identify gaps and opportunities in the UK’s engagement with IOs.

  • Consider setting up regulatory co-operation fora with key trading partners (Box ‎5.10) to allow for regular exchange of information and provide opportunities for identifying the regulatory frictions and co-operation opportunities and priorities of mutual benefit (see forthcoming OECD working paper on Good regulatory practices and international regulatory cop-operation approaches in trade agreements). Such an initiative could also represent an important political commitment in support of IRC between the respective governments.

  • Use regular stakeholder engagement platforms between BRE and businesses to identify regulatory frictions and specific IRC initiatives that can benefit businesses, and SMEs in particular. To do so, various business associations should be consulted for input into the design of the horizontal IRC strategy; and international SME federations in domestic consultation procedures should be targeted. To this effect, consider drawing from the lessons under Canada’s interface with stakeholders in the Regulatory Co-operation Council and the Australia New Zealand Leadership Forum (Box ‎5.11).

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Box ‎5.9. Structuring communities of regulatory practices in Canada and New Zealand

Canada’s Community of Federal Regulators (CFR) is a partnership of Canadian regulatory organisations at the federal level that aims to facilitate professional development, collaboration and advancement of the regulatory field. The CFR focuses its events, activities and resources to meet three strategic objectives:

  • Talent Management – initiatives to strengthen the regulatory profession across the system;

  • Collaboration – events to connect organisations to foster collaboration and sharing of regulatory expertise;

  • Experimentation – pursuing prototypes, projects and other activities to increase community understanding of innovative regulatory concepts and enabling their application.

Key activities include an annual two-day Regulatory Conference, annual one-day Law Enforcement Symposium, Regulatory Professional Development Program, Regulatory Speaker Series, Regulatory Excellence Awards, Prototyping Workshops and Communities of Practice/Working Groups on specific regulatory issues.

The community serves approximately 40 000 regulatory professionals who support Canada’s regulatory lifecycle including policy analysts, program officers, compliance and enforcement officers, performance evaluators, risk assessors, legal counsel, cost-benefit analysts, amongst others. The community is governed by a Deputy Minister Champion, two Assistant Deputy Minister Co-Champions and representatives from each of the departments and agencies providing financial support to the community, responsible for setting direction and areas of focus for the community in conjunction with the CFR Office.

While much broader than IRC, the CFR awards dedicate a specific category to Excellence in Regulatory Cooperation & Collaboration. This award recognises a regulatory initiative that has demonstrated success through a collaborative or co-operative endeavour with another organisation and/or jurisdiction. Nominations must clearly highlight examples of how the candidate or team:

  • demonstrated successful outcomes on a collaborative or co-operative initiative;

  • produced efficiencies as a result of collaborative activities;

  • improved regulatory policy or service delivery through the harmonisation, alignment and/or

  • co-ordination of regulatory requirements;

  • reduced duplication or redundant regulatory requirements;

  • implemented an innovative method for co-operating with partners.

New Zealand Government Regulatory Practice Initiative (G-REG) is a network of central and local government regulatory agencies established to lead and contribute to regulatory practice initiatives. G-REG focuses on developing people capability, organisational capability, and building a professional community of regulators. It is a network for all regulators in the public sector, whether at central or local government.

Among other things, G-REG implements the recommendations of the New Zealand Productivity Commission, which reported in 2014 on the need “to build on the hard work and dedication of those individuals who see the practice of being a regulator as important, and who have sought to improve the capability of regulatory agencies and those that work within them”.

G-REG’s primary activity to date has been the development and delivery of a qualifications framework. Having a common qualification in the public sector is intended to make it easier for regulatory agencies to work together, when their people have common ways of operating and transferable skills and qualifications.

G-REG is working to unify and professionalise the regulators of New Zealand and has made the sector more aware of itself, by bringing it together through a series of workshops, in highly successful annual conferences, articles in industry journals, and intellectual credibility by establishing a Chair in Regulatory Practice at Victoria University of Wellington. Collectively this represents the development of a professional community of regulatory professionals.

The Chair in Regulatory Practice plays a crucial role in connecting the New Zealand regulatory community to the rest of world. The Chair’s research programme incorporates advances in regulatory practice outside New Zealand, focusing on innovative regulators, regulatory instruments and processes. This enables international regulatory best practice and knowledge to be disseminated to G-REG and the wider regulatory community (through blogs, seminars and guest lectures), so New Zealand can learn from the rest of the world. G-REG’s peer learning framework incorporates an international element by, among other things, focusing on the need to minimise the potential for unintended negative impacts of regulatory activities on regulated entities or affected supplier industries and supply chains, which are often international or regional.

G-REG is a key audience and community of knowledge for wider international regulatory co-operation initiatives in New Zealand. For example, G-REG members provided their expertise for a report on international regulatory co-operation prepared by the New Zealand Institute of Economic Research. G-REG will also be a key audience for the New Zealand IRC toolkit that is currently being developed.

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Box ‎5.10. Examples of international Regulatory Cooperation Fora related to trade agreements

The Canada-European Union Comprehensive Economic and Trade Agreement (CETA) establishes the Regulatory Cooperation Forum (RCF) to facilitate and promote regulatory co-operation between Canada and the European Union. The RCF considers a broad range of regulatory measures in order to improve regulatory planning, promote transparency, and enhance the efficacy of regulations by seeking to reduce duplication and misalignment. These efforts will help lower trade barriers, make it easier to do business in both markets, and improve choice for consumers. The first RCF work plan was negotiated in 2018 and contains five areas for co-operation.

Among the early RCF successes, one is the signature in November 2018 of an administrative agreement between Canada and the EC to exchange information between the EU RAPEX alert system and RADAR, Canada’s consumer product incident reporting system. The exchange of information started on 5 June 2019 providing Canadian and European regulators detailed consumer product safety information. This allows for easier access to important information related to recalled products, better capacity for co-ordination of recall and/or surveillance activities, and improved collaboration between regulators of both jurisdictions in order to keep citizens safe.

The Canada-U.S. Regulatory Cooperation Council (RCC) was established in 2011 and brings together regulators from both Canadian and U.S. departments with health, safety, and environmental protection mandates to reduce unnecessary differences between their regulatory frameworks. The RCC provides a forum for stakeholders, including industry, consumers, and non-government organisations, to discuss regulatory barriers and identify opportunities for regulatory co-operation between Canada and the United State. The RCC has a two-year work planning cycle, as laid out in a Memorandum of Understanding, which includes publishing work plans, biannual reporting, and hosting a biennial forum that brings together stakeholders and senior regulators in both countries to discuss areas of misalignment and solutions to address them. The Council is co-chaired by the Secretary of the Treasury Board Secretariat and the Administrator of the U.S. Office of Information and Regulatory Affairs, and meets annually to set the high level direction and priorities.

Examples of RCC success include co-operation in relation to sunscreens. In February 2017, Canada launched a pilot project for sunscreen products manufactured in U.S. facilities that have already undergone inspection and testing by the Food and Drugs Administration, to enter into Canada without being quarantined and tested for a second time at the border. It is estimated that this regulatory co-operation initiative will save the consumer health product industry CAD 100 000 annually per sunscreen product. Due to the success of this pilot, a similar initiative was launched between Canada and the EU under the CETA-RCF in February 2019.

The depth and breadth of the trans-Tasman relationship means that there are many avenues for regulatory co-operation opportunities to be identified and discussed, both formal and informal.

The New Zealand and Australian Prime Ministers and other Ministers regularly hold formal talks, and they have frequent contact at regional and international meetings. In recognition of the close relationship between the two countries and their many shared objectives, New Zealand ministers attend some meetings of the Council of Australian Governments, Australia's highest intergovernmental forum.

Parliamentary committees, political parties, and government agencies also have strong connections. For example, a number of agencies on each side of the Tasman have arrangements in place for information sharing and dialogue, and have representation on each other's boards.

There are joint bodies such as Food Standards Australia New Zealand (FSANZ) which develops food standards for New Zealand and Australia, and Joint Accreditation System of Australia and New Zealand which is an independent third-party accreditation body established by a treaty between Australian and New Zealand. The Regulatory Quality Team at the New Zealand Treasury and the Australian Office of Best Practice Regulation operate a protocol for commenting on Regulatory Impact Statements from the other jurisdiction that involves a trans-Tasman issue.

The Australia and New Zealand School of Government (ANZSOG) was established in 2001 by Australian and New Zealand national and state/territory-level governments, in partnership with universities and business schools, to develop strong links between our respective public sectors. ANZSOG has provided a forum for sharing experience on regulatory co-operation. See, for example, its paper Arrangements for Facilitating Trans-Tasman Government Institutional Cooperation.

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Box ‎5.11. Collecting views from stakeholders for more targeted IRC

Stakeholder input is a key element of the work of the Canada-U.S. Regulatory Co-operation Council (RCC). To date, there have been six written consultations and in-person events with stakeholders. The most recent event was held in December 2018 and brought together approximately 300 stakeholders and regulators to discuss advances made over the previous year and to consider priorities and ideas for the next planning cycle of RCC initiatives. According to the RCC Memorandum of Understanding, a stakeholder-regulator forum is to be held every 2 years.

In preparation for such events, Canada and the U.S. invite stakeholders to share proposals on how to address regulatory differences between the two countries. In particular, stakeholders are invited to comment on issues to be considered for future co-operation, including proposals to align existing regulatory systems, streamlining of unnecessary or duplicative procedures, and areas that will be impacted by new technologies, which are not yet regulated. In the last consultation in the lead-up to the December 2018 event, the Canadian Federation of Independent Business, which represents SMEs in Canada, provided a submission as part of this consultation. Results of the consultation process are posted publicly.

The New Zealand and Australia Leadership Forum (ANZLF) is a business-led initiative designed to further develop both the Australian and New Zealand bilateral relationship, and to provide a vehicle for direct business input into the trans-Tasman economic integration agenda. The ANZLF brings together Ministers and leaders of business, government and academia to create an independent public platform for discussing the Australia New Zealand relationship. The ANZLF has been influential in setting the trans-Tasman agenda in the past, particularly in economic matters, such as supporting the acceleration of the Single Economic Market initiative and advancing the concept of “net trans-Tasman benefit”.


[1] OECD (2012), Recommendation of the Council on Regulatory Policy and Governance,


← 1. They are highlighted in the OECD work on IRC. See for instance the Brochure on IRC: Canada’s Treasury Board also showcases some of the results of its IRC with the United States and others on its website:

← 2.

← 3. Section 30 (3) & (4) of the Small Business, Enterprise and Employment Act 2015.

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