15 June 2022
The IA provides a qualitative and quantitative assessment, which is based on the evaluation of the existing ITS Directive, the external supporting study, extensive stakeholder consultations, and various data sources. The IA informs openly about uncertainties and limitations in the analysis, for instance regarding estimates of administrative costs. The problem definition would have benefited from a further description of the expected consequences and evolution of the problem, and it would have been useful if the findings of the evaluation had been explained in more detail. The IA comprehensively presents three policy options, which are cumulative and not actual alternatives. With regard to substantiating the preferred option, a further clarification of proportionality aspects, and more detailed information on the stakeholders' views would have been useful. Stakeholder views are referred to in the context of policy measures, but the views of different stakeholder groups on the fully fledged policy options have not been presented. The IA refers to 'wide support' of stakeholders, while pointing to 'some reservations', without however explaining which stakeholder groups have doubts, to which extent the views diverge, and whether all stakeholders find the measures of the policy options proportional. Moreover, the description of the stakeholder consultation results is limited, with the IA referring to the IA supporting study, which does not appear to be publicly available. Overall, this transparency issue weakens the IA's quality.