9.7.2011   

EN

Official Journal of the European Union

C 203/3

1.

As a producer and user of European statistics, the ECB welcomes the proposed regulation as an important step towards further improving the quality of European statistics, in particular national accounts, by bringing them into line with the changes in the economic and financial environment and methodological progress. The European system of national and regional accounts forms the core of macroeconomic European statistics and is therefore vital for monetary policy purposes.

2.

The ECB also welcomes the intended consistency of the statistical concepts and definitions described within the proposed regulation, among others, with the System of National Accounts (SNA 2008) adopted by the United Nations Statistical Commission, the sixth edition of the International Monetary Fund’s Balance of Payments and International Investment Position Manual (BPM6), the fourth edition of the Organisation for Economic Co-operation and Development Benchmark Definition of Foreign Direct Investment and with the European industrial activity classification (NACE Rev.2). The proposed regulation has also benefited from the abovementioned instruments in terms of consistency and harmonised methodologies.

3.

Both the European System of Central Banks (ESCB) and the European Statistical System (ESS) have been assigned the task by the Treaty of developing, producing and disseminating European statistics, but under separate legal frameworks to reflect their respective governance structures. The proposed regulation impacts the statistics produced by these two systems. Council Regulation (EC) No 2533/98 of 23 November 1998 concerning the collection of statistical information by the European Central Bank (2) entitles the ECB, assisted by the national central banks, to collect statistical information within the limits of the reference reporting population and of what is necessary to carry out the tasks of the ESCB. More specifically, the reference reporting population comprises legal and natural persons residing in a Member State and falling within the sector ‘financial corporations’ as defined in Council Regulation (EC) No 2223/96 of 25 June 1996 on the European system of national and regional accounts in the Community (3) as well as legal and natural persons residing in a Member State, to the extent that they hold cross-border positions or have carried out cross-border transactions.

4.

Ensuring close cooperation and appropriate coordination between the ESCB and the ESS minimises the reporting burden and guarantees the coherence necessary to produce European statistics. This need for close cooperation is also reflected in the Memorandum of Understanding on Economic and Financial Statistics of 10 March 2003 between the Directorate General Statistics of the European Central Bank (DG Statistics) and the Statistical Office of the European Communities (Eurostat) (4).

5.

Given the close relationship in preparing the methodological framework of the proposed regulation, the ECB has agreed at Eurostat’s request to draft various chapters of Annex A closely related to the ESCB statistical framework. In particular, the ECB has provided substantial input on the definition of the sector ‘financial corporations’ in terms of institutional units and subsectors as part of Chapter 2 and the description of financial assets and liabilities and their presentation in the sequence of accounts (Chapter 5 and parts of Chapters 6 and 7). Drafts were also provided on Chapter 17 (social insurance including pensions) and on parts of Chapter 21 (government accounts) and of Chapter 19 (European accounts).

6.

Regarding the definition of the institutional sector ‘financial corporations’ and its subsectors (Annex A to the proposed regulation, Chapter 2), the ECB welcomes that the definition of the subsector monetary financial institutions follows the ECB definition in paragraph 2.67 of Annex A. The definitions of subsectors of ‘other financial corporations’ are consistent, to a large extent, with the approach used in ECB legal acts. To minimise the reporting burden and to guarantee the coherence necessary to produce European statistics, the ECB proposes further aligning the proposed definition of financial vehicle corporations engaged in securitisation transactions with Regulation ECB/2008/30 of 19 December 2008 concerning statistics on the assets and liabilities of financial vehicle corporations engaged in securitisation transactions (5).

7.

Based on the above and given the interdependencies of the ESCB statistical framework and the ESS, the proposed regulation is highly relevant to ECB statistical reporting requirements, among others, in the fields of monetary, financial institutions and markets statistics, balance of payments and international investment position statistics, quarterly financial accounts and government finance statistics. In line with current practice and the need for close cooperation and appropriate coordination between the ESCB and the ESS, in amending the proposed regulation by means of delegated powers, the Commission should ensure the ECB’s due involvement by preparing draft delegated acts in accordance with the proposed regulation.

8.

Furthermore, having regard to the importance of delegated acts adopted under Article 290 of the Treaty, the ECB makes the following observations with regard to the exercise of its own advisory role under Articles 127(4) and 282(5) of the Treaty.

First, Commission draft delegated acts qualify as ‘proposed Union acts’ within the meaning of the first indent of Articles 127(4) and 282(5) of the Treaty (6). Delegated acts constitute legal acts of the Union (7). Significantly, the majority of the language versions of Article 282(5) of the Treaty refers to ‘draft’ Union legal acts on which the ECB is required to be consulted (8). Therefore, the scope of the duty to consult the ECB cannot be confined only to those draft acts based on a Commission proposal.

Second, in the OLAF judgment (9), the Court of Justice clarified that the obligation to consult the ECB is intended ‘essentially to ensure that the legislature adopts the act only when the body has been heard, which, by virtue of the specific functions that it exercises in the Community framework in the area concerned and by virtue of the high degree of expertise that it enjoys, is particularly well placed to play a useful role in the legislative process envisaged’.

Against this backdrop, in order to deploy the full benefits of the exercise by the ECB of its advisory role, the ECB should be consulted in due time on any draft Union acts, including draft delegated acts, falling within its fields of competence. The ECB will exercise its advisory role taking into utmost account the timelines for adopting these acts.

9.

Due to its monetary policy related tasks, the ECB’s statistical focus is on European aggregates. The ECB attaches importance to the quarterly integrated euro area accounts by institutional sector. For that purpose, sufficient data coverage in terms of the provision of national contributions is required in time for monetary policy decisions.

10.

The collection of data for individual Member States has gained further importance in view of the new statistical demands for financial stability and macro-prudential purposes, particularly in connection with the recent establishment of the European Systemic Risk Board and its responsibility for the macro-prudential oversight of the financial system within the Union. Timely and reliable national accounts statistics for individual Member States are also needed to support the goals promoted by the Euro Plus Pact and for the purposes of the European Stability Mechanism.

11.

From a monetary policy and financial stability perspective, the ECB attaches high priority to timely quarterly data of sufficient reliability which takes precedence over detailed annual or lower frequency data. Moreover, the compilation of a full set of tables for recent years should have priority over long series of detailed backdata.

12.

The ECB generally agrees with the transmission programme (Annex B to the proposed regulation). However, the transmission programme should take account of the collection of statistics by the ECB, assisted by national central banks, and should reflect priorities developed between users and data compilers.

13.

The ECB welcomes the improvement in the timeliness of the quarterly items 1-12, 27 and 28 in Table 1 on Main aggregates — quarterly and annual exercise to t + 2 months. However, the ECB objects to the proposed differentiated reporting between larger and smaller Member States referred to in footnotes 4 and 7 of the ‘Overview of the tables’ and footnote 10 in ‘Table 1’, and the related deterioration in timeliness for smaller Member States to t + 80 days for the main aggregates. At present, 17 Member States would be covered by the differentiated reporting, and as a result of the enlargement of the Union an increasing number of Member States will fall below the proposed differentiated reporting threshold. As a consequence, the quality of both the European aggregates and statistical information for smaller Member States will deteriorate.

14.

The ECOFIN Council endorsed in September 2000 the EMU Action Plan on Statistical Requirements and set the target time for quarterly integrated euro area accounts by institutional sector at t + 90 days after the reference quarter to meet the ECB’s monetary policy needs. This implied that Eurostat and the ECB would have to collect the respective national data at t + 82 days. Due to the envisaged schedule of the ECB Governing Council meetings in 2015 and 2016, a reduction in the time lag to t + 85 would suffice for 2015 to 2016. Accordingly, the ECB supports advancing the reporting deadlines for the quarterly sector accounts under the ESA transmission programme to t + 85 days by 2014, aiming at t + 82 days by 2017 to support the compilation of full quarterly integrated euro area accounts at t + 90 days. This is also in line with the G-20 data gaps initiative which identifies sector accounts as one of the priorities in closing data gaps as a follow-up to the financial crisis. In the ESA 2010 transmission programme, this affects Table 801.

15.

Furthermore, the ECB favours a consistent transmission deadline for all quarterly and annual national data regarding general government, implying a synchronisation of quarterly data on general government to the timeliness targets set for Table 801, affecting also Tables 27 and 28, and, similarly, the reporting deadlines for Table 2 and the excessive deficit procedure (EDP) data. Therefore, the ECB supports advancing the reporting deadlines for the quarterly government accounts under the ESA transmission programme and the EDP data to t + 85 by 2014 and aiming at t + 82 by 2017 to support the compilation of full quarterly integrated euro area accounts at t + 90.

16.

In Opinion CON/2010/28 of 31 March 2010 on a proposal for a Council Regulation amending Regulation (EC) No 479/2009 as regards the quality of statistical data in the context of the excessive deficit procedure (10), the ECB also supported improving the transparency of the reporting process by using the national accounts deficit (B.9) for the EDP. By excluding settlements under swaps arrangements and forward rate agreements from the deficit used for the EDP, the deficit figures become less susceptible to manipulations by complex financial transactions. In this context, the ECB welcomes that Annex A to the proposed regulation would no longer define EDP_B.9 and EDP_D.41. This however also implies that all references to these two variables should be eliminated from Table 2 in Annex B. As a consequence, Regulation (EC) No 479/2009 will have to be amended to reflect the fact that the national accounts deficit (B.9) will have to be used for the EDP and to reflect the definition of nominal value in the proposed regulation.

17.

In order to meet the public and policy needs for the measurement of compensation per employee and per hour in the general government sector, focusing on a better understanding of wage dynamics and potential spillover effects between the public and private sectors, the ECB suggests including in Table 801 for the general government sector quarterly data on the number of employees and hours worked, with the compensation of employees in the general government sector already included in the transmission programme.