The European Economic and Social Committee (EESC) opinion C/2025/2012, drawn up at Poland's request, stresses the need to modernise EU cohesion policy after 2027 by adapting it to new geopolitical complexities and regional disparities. The study concludes that future policy must be more flexible, cutting bureaucracy and strengthening the involvement of local authorities in order to secure a just green and digital transition. It recommends introducing territorially specific approaches and focusing on strengthening administrative capacity, not merely on funding infrastructure projects. How the implementation of these recommendations is going in 2026, we can see for ourselves “on the ground”...
Is the “all-electric” principle more important than openness to technologies?
The core idea of European Union (EU) climate protection – the EU Emissions Trading System (EU ETS) – is both simple and effective. In industry, and now also in construction and transport, the right to pollute is set quantitatively and progressively reduced by means of ETS certificates, which provide guarantees that the Paris climate targets will be met. The rest is handled by the market, as the price of fossil resources rises. A properly functioning ETS can make it possible to simplify reporting under the Corporate Sustainability Reporting Directive (CSRD), the EU Taxonomy Regulation and related environmental rules, such as the EU Buildings Directive.
The US Inflation Reduction Act (IRA) covers combustion efficiency as well as electric mobility, whereas EU legislation is based on a ban on internal combustion engines without a clear life-cycle and impact assessment. The EU's obligation to renovate buildings is designed to prompt homeowners to invest, rather than allowing the climate protection guarantees of emissions trading to be delivered without bureaucracy by raising the price of fossil resources. Another example is the question of hydrogen. The EU defines hydrogen as climate-friendly only if it is produced using wind or solar power, instead of also including CO₂-free and cost-effective hydrogen obtained from natural gas and nuclear energy: the “all-electric” principle takes precedence over openness to technologies.
This is how harmful bureaucracy arises, and how the market economy and innovation are stifled.
The bureaucratic side of the Green Deal has not only blocked lending to medium-sized enterprises; it also generates dissatisfaction among businesses and workers and high costs for consumers, who in fact do want the energy system transformed and the environment protected.
An assessment of how the Commission has implemented its voluntary 2019 commitment to the “one in, one out” principle likewise indicates that the EU legislative process is overloaded. The European Parliament, which usually makes legislation stricter, complained that this principle was not being observed, and this was also pointed out in the Mario Draghi report, which calculated the ratio at 2.5 to 1.
The “production” of legislation, European style
It is precisely European bureaucracy and excessive regulation that were put forward as the central issue in the Helsinki Declaration adopted by the council of ORGALIM, the European engineering industries association, on 30 October 2024. It draws attention to the fact that, between 2019 and 2024, the United States adopted 3,500 pieces of legislation at federal level, while over the same period the European Union adopted 13,000 – that is, almost four times as many.
The unclear and complicated division of responsibilities within the European Commission should also be questioned (for example, supply chain matters falling under the remit of the Commissioner for Justice). An effective organisational structure must be put in place to provide a clear overview of all legislation in force, together with its interactions, overlaps and possible contradictions, so as to ensure consistency.
In recent years the Commission has done a great deal to reduce the administrative burden, but…
...these initiatives did not fully deliver a consistent reduction in the administrative burden, and a more ambitious programme is needed. Moreover, from a purely quantitative perspective, the coming period promises no improvement. The Commission's register of documents currently contains 470 pieces of legislation still to be adopted, 413 implementing acts and 57 delegated acts. Since the register includes only currently planned legislation, these numbers will increase substantially in future. There are new legislative initiatives: the political guidelines for the 2024-2029 legislative cycle set out 160 projects.
Mario Draghi called on the EU institutions to apply a principle of “self-restraint” in policymaking, both by selecting future initiatives more carefully and by streamlining the existing acquis. The European Economic and Social Committee takes the view that the question of “self-restraint” should also be addressed by the member states with regard to gold-plating.
The portfolio of the Commissioner for the Economy and Productivity, Implementation and Simplification should be broadened to include a specific focus on small and medium-sized enterprises (SMEs), so as to ensure that all the various requirements placed on small and medium-sized enterprises by EU legislation are managed consistently. One of the Executive Vice-Presidents should have a strong mandate for the implementation and simplification of legislation, as announced by Commission President Ursula von der Leyen in her political guidelines, presented before her election in the European Parliament. At the start of the parliamentary term, the European Commission should identify overlaps in legislation by means of a comprehensive procedure (as proposed in the Letta report), and in particular introduce relief measures for small and medium-sized enterprises, workers and public administrations.
The 25% reduction in bureaucracy referred to in the relief package is a minimum figure. The forthcoming Corporate Sustainability Reporting Directive alone contains some 1,200 reporting requirements. It is vital that reporting requirements are communicated in plain language, with a one-stop-shop service in all 27 member states. In line with the principle of transparency, such an overview could also cover penalty provisions affecting collective claims under civil, administrative and criminal law, as well as an impact assessment concerning the staffing and costs of judicial and administrative bodies. The EESC recommends making better use of digital instruments and artificial intelligence and machine learning tools to create an easy-to-use single reporting tool that could provide SMEs, mid-cap companies and other businesses with information on all EU-related reporting obligations, deadlines and penalties.
The European Commission may need an internal reform of the process for drawing up legislative proposals
The Regulatory Scrutiny Board must be substantially strengthened and made more independent. At the start of the process of preparing each piece of legislation, it should carry out a consistency and subsidiarity check, and it should be granted appropriate rights of review and consultation in respect of new legislation where this threatens competitiveness. Strengthening the Regulatory Scrutiny Board should be included in the forthcoming interinstitutional agreement. The number of delegated acts should be substantially reduced and they should be made more transparent. The European Parliament and stakeholders should be involved in an effective procedure.
The European Parliament should develop a fast-track procedure for the opportunity, impact and risk assessments and life-cycle analyses carried out by its policy department where amendments are tabled that would substantially change proposals adopted by the Commission. The Committee of the Regions should make far greater use of its status as guardian of subsidiarity and address the question of European-level competence at the very start of the drafting of legislation, so as to avoid imposing a financial burden on Europe's regions.
The European Economic and Social Committee recommends that, in order to implement all these requirements, a binding legal act on reducing bureaucracy be adopted, that policy be evaluated ex post, and that targets be set for cutting bureaucracy.
More than a year has already passed, as the recommendations were published in Brussels on 26 February 2025