皇冠体育app

皇冠体育app proposal is to enable the implementation of the Border Target Operating Model (BTOM), a global risk-based model for sanitary and phytosanitary (SPS) border controls for Great Britain.

As originally submitted, the IA was not fit for purpose. 皇冠体育app RPC had concerns with the counterfactual position used when calculating the EANDCB. 皇冠体育app Department has since adjusted their counterfactual by using the Official Controls Regulation (OCR) position. 皇冠体育app IA notes that this represents a scenario with no further legislation, and, on this basis, it appears to be in line with a traditional 鈥榙o nothing鈥� counterfactual. 皇冠体育app RPC considers this to be acceptable as the primary counterfactual in the IA. However, the IA would benefit from providing further explanation. 皇冠体育app IA appears to correctly identify direct and indirect costs to business but would benefit from providing further justification for this. 皇冠体育app IA appropriately includes estimates of the cost to business against the 鈥榓s is鈥� counterfactual. This shows a net increase in cost and will more closely reflect business experience. 皇冠体育app IA should present this assessment more transparently.

皇冠体育app RPC also found originally that the Small and Micro Business Assessment (SaMBA) was not fit for purpose as it did not consider mitigations for small and micro businesses who the IA explains are likely to face disproportionate costs. 皇冠体育app SaMBA now includes mitigations the Department has put in place to reduce the burden on small and micro businesses. 皇冠体育app IA should expand its assessment to include a specific section on the impact upon medium-sized businesses. 皇冠体育app RPC now rates the IA as fit for purpose.

皇冠体育app revised was published by the department alongside the SI on 22nd April 2024.