Gender Impact Assessment
The European Commission deploys a variety of methods in its approach to gender mainstreaming. These methods span the whole policy cycle, from policy definition, through implementation to monitoring and evaluation.
In the policy-definition phase, gender impact assessment is integrated within the European Commission’s impact assessment system. Indeed, the Commission does not perform gender impact assessments as a separate, standalone exercise. Rather, it has integrated the consideration of gender issues within its general impact assessment system.
Since 2002, the Commission has introduced a centralised system of impact assessment for major legislative proposals, non-legislative initiatives that define future policies, and implementation measures to replace previously used single-sector types of assessment (such as gender impact assessment). The Commission’s impact assessment system aims to enhance the coherence of initiatives across policy areas, and the quality of new policy proposals.
To do this, the Commission has set up an integrated approach to impact assessments, incorporating three different dimensions. The aim is to assess the potential economic, social and environmental consequences that proposed initiatives may have. The gender-related impacts are to be addressed under social issues.
Impact assessment gathers and presents evidence that helps determine possible policy options and their comparative advantages and disadvantages. The impact assessment runs parallel with and feeds into the development of the Commission’s proposal and is carried out before a proposed activity is adopted. Impact assessments in the Commission accompany legislative, regulatory or other policy proposals which have an economic, social and/or environmental impact and which are presented in the Commission’s Work Programme or Annual Policy Strategy.
A robust quality assurance system is in place, with detailed guidelines, support and helpdesk functions, training, and a review system. Furthermore, the Commission strives for transparency and accountability within the system and publishes all impact assessments online. All opinions of the Impact Assessment Board (see Actors involved section) are also published once the Commission has adopted the relevant proposal.
Impact assessments are organised in a decentralised way in the Commission. Directorates-general and services are responsible for implementing their respective functions and activities. Yet Commission-wide networks have also been set up to coordinate activities at Commission level. They are organised by a central unit in the Secretariat-General for Impact Assessment.
The Impact Assessment Board
The Impact Assessment Board (IAB) is a central quality control and support function working under the authority of the Commission President. It was created at the end of 2006. It is chaired by the Deputy Secretary-General for Better Regulation. The IAB examines and makes public opinions on all the Commission’s impact assessments.
The IAB is composed of the Deputy Secretary-General (Chair) and eight permanent officials at director level, who participate in IAB meetings on a rotating basis. Two directors are nominated from each of the following areas of expertise:
The members are appointed in a personal capacity and on the basis of their expert knowledge. The IAB is independent of the policymaking departments.
The IAB examines and comments on the quality of draft impact assessments prepared by the Commission departments. It can draw on external expertise. Upon request, the IAB can also provide advice to Commission departments on methodology at the early stages of preparation of impact assessments.
When scrutinising draft impact assessments, the IAB has to perform the following tasks:
- Check the application of Commission guidelines and agreed standards in impact assessment work;
- Deliver an opinion as to whether the degree of analysis in the impact assessment is proportionate to the potential broad economic, social and environmental impacts of the proposed initiative;
- Assess whether the analysis is of sufficient quality with reference to the reliability of the data used and the tools/methodology applied for the analysis of the options.
The opinions of the IAB are not binding. However, the opinion accompanies the draft initiative together with the impact assessment report throughout the Commission’s political decision-making process. Ultimately it is the Commission that decides whether or not to adopt an initiative, taking account of the impact assessment and the IAB’s opinion.
The Impact Assessment Steering Groups
They bring together representatives of the Commission services with an interest in the development of the proposal submitted for impact assessment. They are fully involved in all phases of impact assessment work, and provide important expertise toward the development of the impact assessments.
The Impact Assessment Working Group
This is a network of officials who contribute to the Commission’s impact assessment work and its coordination. It is coordinated by the General Secretariat. In 2011, it met four times and discussed topics such as guidance documents on assessing fundamental rights and impacts on competitiveness, and initiatives to improve inter-service cooperation in collecting and managing data and in enhancing the reliability and credibility of estimates and modelling results used in impact assessments.
This integrated approach is coherent with the principles of gender mainstreaming, and should ensure that the gender dimensions of legislative and policy initiatives are not overlooked. The use of a centralised system of impact assessment in the Commission should contribute to the quality and coherence of major initiatives taken by the European Commission, including from a gender perspective.
The latest general EU Guidelines for Impact Assessment were issued in 2009. The document outlines three major steps:
- Identification of economic, social and environmental impacts;
- Qualitative assessment of the more significant impacts;
- In-depth qualitative and quantitative analysis of the most significant impacts.
The guidelines also draw attention to the fact that a proposal may appear gender neutral, but in practice has a different impact on women and men, for example due to differences in the lifestyles of women and men.
Regarding further guidance on gender impact assessment, specific guidelines have been drafted to support civil servants in the analysis of social impact. These guidelines promote both a gender analysis and the necessity of promoting gender equality.
According to the EC guidance on social impact assessment, the questions to be asked when conducting a gender impact assessment are:
- a. Does the option have a different impact on women and men
- b. Does the option promote equality between women and men
This guidance document explains how the gender perspective should be integrated into the analysis, and how potential impacts on gender should be assessed:
The assessment of potential impacts on gender should take into account the existing differences between women and men that are relevant to the given policy field, in particular in terms of participation rates, distribution of resources, benefits and responsibilities in private and public life, and in the norms/values, attitudes and behaviour that influence gender roles. Analysis of impacts on gender means to compare and assess, according to the gender criteria abovementioned and sex-desegregated data, the current situation/trend with the expected developments resulting from the introduction of the proposed policy, in order to ensure that the proposal contributes to eliminate inequalities and promote the Community objective of equality between women and men. Gender attention is required in particular in the analysis of groups affected and “should take into account the existing differences between women and men that are relevant to the given policy field”. More specific references are given under job quality, workers’ rights, social inclusion and social protection of specific groups of women. (p. 19 EC guidance on Social Impact Assessment)
The guidance recalls that gender mainstreaming is a commitment at European level, provides reference to articles in the Treaty of Amsterdam and states that the gender perspective should be integrated in all policies at each stage of policy development — design, implementation, monitoring and evaluation. Equality between women and men should be promoted at all levels and in all policy area.
Strenghts and weaknesses
The European Commission set up an integrated approach to impact assessments, incorporating the economic, social and environmental dimensions. The gender-related impacts are to be addressed under social issues. A robust quality assurance system is in place, with detailed guidelines, support and helpdesk functions, training, and a review system.
This integrated approach is coherent with the principles of gender mainstreaming, but still has some risks. It is interesting to analyse its strengths and its weaknesses in order to use the different steps as drivers for gender mainstreaming and the promotion of gender equality.
- Integrated approach (guidelines, helpdesk, training, review system)
- Transparency and accountability
- Lack of guarantee of gender expertise during the process and within the system
- Risk of overlooking the gender dimension
The Commission’s impact assessment should take advantage of its strengths and take into account the risk of overlooking the gender dimension.
Coverage of policy cycle
The ex ante impact assessment relates to the initial definition and planning phases of the policy cycle and applies a structured ex ante assessment of impacts, including those related to gender equality.
From a gender mainstreaming perspective, gender analysis should be conducted in the identification of economic, social and environmental impact and should also be integrated in the in-depth analysis of important impacts. Gender mainstreaming requires that ‘people’ are made visible as potential beneficiaries or final users. It also implies assessing the gender dimensions across groups (young people, older people, migrants, etc.), since women and men have different social positions due to gender roles.
Commitment and leadership
Gender is a value stated in general guidance documents (guidelines for impact assessment; social impact guidance). Since the impact assessment guidelines refer to articles of the Treaty of Amsterdam and to the necessity of taking gender equality into consideration, attention to gender equality within the impact assessment mechanisms should be given in a systematic and institutionalised way.
To do this, it is paramount to involve gender experts in the process, to provide gender training and to ensure systematic reporting on gender equality issues. In the Commission’s approach, a good practice section on impact assessment exists and it could benefit from the inclusion of examples of good impact assessment exercises in terms of gender. The impact assessment performed for the Communication on the European Research Area, for instance, is an interesting example.
An important aspect of the impact assessment process is the consultation of interest groups and stakeholders. Those groups can be traditional counterparts (representatives from Member States, relevant industry or sector, research centres, etc.), social partners or specific bodies in the field. As a way to gather the relevant experience of groups affected by or benefiting from a policy initiative, stakeholder consultation is a key factor for gender mainstreaming.
In this context, consultation of organisations working on gender equality would ensure that a gender perspective is taken into account when analysing any policy proposal under consideration. Providing up-to-date information about gender equality expert groups, women’s organisations and NGOs could be very useful to facilitate this work.
Access to gender expertise is clearly needed to strengthen the quality of the analysis for social, economic and environmental impacts. This expertise can be provided internally or externally. As mentioned above, gender equality bodies should play a relevant role together with gender experts from the different fields. In any case, statistics and indicators on gender gaps are not enough. Specific knowledge is needed in order to be able to analyse the data and information from a gender perspective.
Finally, it is important to highlight that a number of specific evaluations of gender aspects (mid-term or ex post), in particular in the social and employment field, have been conducted over the years. Their results should also be used in the impact assessment process.
The Commission organises impact assessment training regularly. It would be very useful to open up the possibility of organising such gender-specific training in the framework of this systematic activity.
As knowledge on gender inequalities is needed to develop gender impact assessment, the Gender Equality Unit could also provide a useful helpdesk function when required. EIGE could also act as a useful resource for the provision of data, reports or gender experts’ contacts that can possibly be called upon in steering groups.
Structured understanding of gender inequalities
The social impact guidance document precisely explains what gender analysis is about: it is about existing differences in terms of participation rates, distribution of resources, benefits and responsibilities in private and public life, and in norms, values, attitudes and behaviours.
However, knowledge and expertise as well as awareness-raising on gender issues are required to be able to identify such existing differences. In this respect, a number of relevant resources on gender inequalities and on the integration of the gender perspective in a number of sectors are being produced by EIGE.
Guiding questions to make people aware of the gender relevance of specific policies is very important. The gender impact assessment guide commissioned by the European Commission in 1998 can be useful in this respect.
Transparency and accountability structures
Impact assessment reports together with IAB opinions are systematically published on the Web when the report has been accepted and the proposal is formally approved by the Commission.
Recommendations are not binding but as they are public this can be seen as a positive incentive to improve the attention to social and in particular to gender issues. Transparency about the coverage of the gender dimension in impact assessment exercises is achieved by including an explicit question on gender in the IAB reporting template.
There is still significant variation in how the gender equality dimension is addressed and understood. That is why it could be important to use the work performed to identify good practices of impact assessment exercises in terms of gender.
The aim would be to generate a common understanding about the gender dimension within the impact assessment system and to promote learning processes toward gender equality.