Guidance

RPC case histories - regulatory scorecard

Published 6 October 2026

Summary and key points

The Green Book places strong emphasis on the assessment of impacts on society as a whole, including social, consumer and environmental impacts, as well as those on business.

These impacts are captured, where they can be monetised, in the Net Present Social Value (NPSV). The Green Book (page 60) recommends:

assessing and comparing options based on their social value. This includes not just impacts on economic output and productivity, but also wider society and the environment.

While direct business impact is still a key issue, the reformed Better Regulation Framework (BRF, published in 2023) encourages greater consideration of a wider range of impacts, including the impacts on households and on the environment.

The regulatory scorecard introduced in the updated BRF gives departments the opportunity to summarise these impacts on society, households and businesses, both monetised and non-monetised, alongside allowing for consideration of the wider impacts on trade, innovation and the environment.

The scorecard is a 2 part table which acts as a point of continuity through the evolution of the impact assessment (IA) for a proposal. Part A of the scorecard includes overall impacts on total welfare, businesses and households, whereas Part B includes assessments of wider impacts such as those on trade, innovation and the environment.

Whether as part of an options assessment (OA) or final stage IA, departments are expected to submit a regulatory scorecard for the preferred policy option to the Regulatory Policy Committee (RPC). A proportionate approach should be taken to the scorecard as it is likely that a department’s analysis will not be fully developed at initial OA stage. However, attempts should be made to estimate the direct impacts on business (equivalent annual net direct cost to business, EANDCB) and, if possible and proportionate, to estimate the direct impacts on households (equivalent annual net direct cost to households, EANDCH).

Introduction

This document provides case history guidance on the regulatory scorecard in options assessments and impact assessments. The guidance covers:

• background
• Better Regulation Framework guidance
• applying the framework and RPC expectations
• issues raised during RPC scrutiny of departments’ regulatory scorecards

Background

Introduction to the regulatory scorecard

Under the previous Better Regulation Framework, the key metric that the RPC validated for final stage impact assessments that accompanied qualifying regulatory provisions was the equivalent annual net direct cost to business (EANDCB). This allowed for a consistent, comparable approach across IAs with a focus on immediate and unavoidable impacts that regulatory change imposed on businesses. However, it could be quite a narrow approach that disregarded other aspects of proposed regulatory policies.

As a result of the 2021 consultation on ‘Reforming the framework for better regulation’, a scorecard approach was selected as an alternative to the EANDCB metric that captures a range of impacts (or direction of travel) that each regulatory proposal would have on different government objectives: for example, environment, innovation.

The current EANDCB, alongside the NPSV and new EANDCH, form part of the scorecard to cover the impacts on overall welfare, business and households. The new approach however was also considered to address one of the weaker parts of previous impact assessments which was the quantification of wider benefits, where data limitations often make robust analysis challenging.

The scorecard approach was also introduced to provide greater transparency and confidence that the impact of regulatory proposals against key objectives has been considered as thoroughly as possible, with a mix of quantitative and qualitative approaches, to aid decision making. For example, the completed scorecard could be used to illustrate how a regulatory proposal may impose £10 million of annual cost on business but generate a range of environmental, regional or innovation costs or benefits (which may or may not be quantified in the overall NPSV) to enable ministers to understand the trade-offs against key objectives and make informed choices.

The RPC provides an overall rating of the scorecard, based on whether the quantification of impacts in the scorecard or, at the very least, the description of possible impacts, is sufficiently proportionate and robust to be used as a tool to inform decision making.

The final outcome of the consideration of the scorecard approach, the regulatory scorecard, was introduced as part of the 2023 Better Regulation Framework to require departments to include in their OAs and IAs a summary of the monetised and non-monetised impacts on overall welfare, households and businesses, distributional impacts and impacts on wider government priorities such as the business environment, trade considerations and natural capital and decarbonisation.

The RPC assesses the scorecard as part of its OA/IA scrutiny, assigning a ‘Good’, ‘Satisfactory’, ‘Weak’ or ‘Very Weak’ rating depending on the quality of submission.

Better Regulation Framework guidance

The Better Regulation Framework explains that as part of an OA or final stage IA, departments are expected to submit a regulatory scorecard for the preferred policy option to the RPC.

The guidance (paragraphs 7.24-7.25, page 26) states that:

At the OA stage proportionate attempts should be made to estimate the direct impacts on business (EANDCB) and, if possible and proportionate, to estimate the direct impacts on households (EANDCH). Annex 4 gives more information.

Additionally, some indication of the scale of other impacts should be presented. The scorecard can be used to indicate a magnitude, or range of impacts, as well as the direction of impacts (whether costs or benefits). This can apply to both monetised and non-monetised impacts where appropriate to do so. The text boxes can be used to explain more complex interactions, or to signpost to a later section where they are explained fully.

The BRF guidance gives an indication of the impacts expected to be included in the scorecard for parts A and B (paragraph 7.22-7.23, pages 25-26), such as how the scorecard should be used to demonstrate impacts on overall welfare, business and households, as well as wider government priorities.

The BRF also provides more detailed guidance on presenting monetised impacts in the scorecard in a technical note (Annex 4). This includes a detailed explanation of the EANDCH, which was introduced as part of the updated framework.

EANDCH (Equivalent Annual Net Direct Costs on Households)

The EANDCH should include the direct costs of the preferred policy on households. If it makes more sense, owing to the nature of the policy, to calculate the costs and benefits on individuals, consumers, employees, or some other person grouping, rather than households, this can be done instead and explained.

However, if a department does decide to calculate EANDCH using households as the person unit, this should be consistent with the definition of household used by Office for National Statistics, which is one person living alone, or a group of people living at the same address who share cooking facilities and share a living room, sitting room or dining area.

There may be cases where the distinction between businesses and households is unclear in relation to how EANDCB and EANDCH impacts should be assessed. For example, some actors in the gig economy may be more like participants in an informal economy, while others are more like micro businesses. It is up to the department to decide how best to categorise business and household impacts in these cases and to explain the reasoning.

EANDCH should include costs or benefits which directly affect people’s budgets. This could be related to wages, or other compliance costs faced by households such as the costs of obtaining documentation and information.

As per the general exemptions this would not include areas related to taxes, duties or levies, such as tax on petrol or alcohol duty. EANDCH should include time costs, including familiarisation and form-filling, as these are regarded as analogous to the administrative costs which are felt by businesses when complying with new policies.

There could be other time costs which are also relevant, such as travel time, or time off work. It is for the department to decide which costs are most significant and to decide on appropriate techniques and data for quantifying and monetising these impacts which may be complex.

Departments are not expected to carry out disproportionately complicated analysis for relatively small impacts. EANDCH is not expected to include general welfare costs and benefits or indirect costs and benefits (with the exception of some types of pass-through, which are discussed below). Once the appropriate person grouping is established and the range of relevant impacts arrived at, the calculation of EANDCH is analogous to calculating the EANDCB.

Pass-through

Pass-through mostly occurs when a business incurs a cost/benefit and passes it on to customers. For costs to business, this is usually passed on in the form of higher prices, although it could also be in the form of changes to the quantity or quality of the business’s products.

In some cases, there may be a regulatory constraint placed on businesses, which may result in a transfer to customers in the form of a benefit. This could take various forms such as lower prices or a safer product being introduced. The Better Regulation Framework sets out when pass-through should be considered in the EANDCB and EANDCH. Departments should reference the RPC’s existing case histories on assessing direct and indirect impacts of regulation on business when deciding whether to count different types of pass-through as direct or indirect.

Better Regulation Framework:  Pass-through, page 57

The pass-through impacts which can be treated as direct in the BRF are:

(a) wherever the regulation explicitly requires businesses to transfer monetised costs/benefits to households/individuals

or

(b) where there is a clear expectation by the design of the policy that businesses will pass through monetised costs/benefits

then departments should:

• adjust EANDCB to account for this

• estimate EANDCH

There may also be cases where the reverse is true, and households pass some cost to business. The same considerations should be made, and the reverse adjustment should be applied.

Departments would be expected to quantify pass-through and adjust the EANDCB and EANDCH in circumstances where: a cost to business results in a benefit to customers (or vice versa) without any intermediate mechanism, a mandated pass-through where a business cost must be partly funded by consumers or an intended pass-through, where the policy intention is that pass-through should happen, possibly around encouraging behavioural change.

Applying the framework and RPC expectations

Departments should justify the level of analysis provided in the OA or IA and set out a plan to conduct further analysis if at OA stage. This should be proportionate to the size and scale of the impacts of the measure in question while accounting for a range of contextual factors.

The RPC’s scrutiny covers the direct and indirect impact on total welfare, the expected impacts on business and on households of the preferred option, as well as the impacts of the preferred option on ‘wider government priorities’, defined in the OA template as, business environment, international considerations and natural capital and decarbonisation.

The degree of quantification and monetisation of impacts is expected to increase between the OA and final stage IA. If there is an overlap between the impacts detailed in part A and part B of the scorecard, and this impact on total welfare includes a significant impact on competition, trade, innovation, and natural capital and decarbonisation, these impacts should be detailed in part B as well as part A. 

It is anticipated that departments will be continuing to develop their analysis as the policy proposal is progressed, with a relatively high-level summary of impacts presented at OA stage covering initial estimates and qualitative summaries, and a more complete analysis being available at the time the final IA is produced.

At the OA stage proportionate attempts should be made to estimate the direct impacts on business (EANDCB) and, if possible and proportionate, to estimate the direct impacts on households (EANDCH). Additionally, some indication of the scale of other impacts, such as non-monetised impacts, should be presented. At final IA stage the scorecard should be finalised.

This means that the impacts in part A should be monetised (EANDCB, EANDCH, NPSV, business NPV), and the impacts in part B, which are proportionate to quantify, should have been evidenced. A proportionate approach to the analysis presented in the scorecard and the subsequent RPC scrutiny will be needed, reflecting the stage of policy development. As a result, the expectations for a ‘good’ or ‘satisfactory’ regulatory scorecard at OA stage will differ from those at final IA stage. Expectations will also differ depending on the size and scale of proposed measures.

The scorecard is designed to be a presentational tool to summarise the key impacts for the preferred option. The analysis underpinning all the figures should be included in the justification for preferred way forward elsewhere in the OA/IA or in an annex.

Issues raised during RPC scrutiny of departments’ regulatory scorecards

This section highlights case study examples of issues raised during RPC scrutiny of regulatory scorecards in IAs and OAs.

Part A of the regulatory scorecard

Presentation of monetised impacts

The RPC is looking for departments to consider the direct and indirect impact on total welfare of the preferred option in part A of the scorecard, in addition to the expected impacts on business and on households of the preferred option.

The Better Regulation Framework does not require departments to provide an (NPSV) or Business Net Present Value (BNPV) at the OA stage. However, it is helpful if early analysis is carried out. Initial estimates of EANDCB (Equivalent Annual Net Direct Cost to Business) are required to be submitted at OA stage, alongside estimates of the EANDCH if possible. These may be early estimates which may be adjusted later.  

Part A of the scorecard in the OA/IA template is designed to provide information on impacts in summary form – the detailed assumptions and calculations are expected to be presented in other sections for example as part of justification for the preferred way forward. 

In the example below, the department has summarised its quantified impacts, including a discussion of pass-through from businesses to households.  

The National Minimum Wage (Amendment) Regulations 2025 impact assessment, opinion reference RPC-DBT-25025-IA(1)

The proposal was to increase the National Living Wage and National Minimum Wage on 1 April 2025, in line with recommendations from the Low Pay Commission. There is a relatively higher increase in the 18-20 rate, under-18 rate and apprentice rate, with the intention of eventually achieving a single adult rate.

The department set out its headline monetised figures, providing estimates for the NPSV, EANDCB and EANDCH. The department does well to provide key analytical details such as the price and present value years, and summarises the key components of each estimate which help demonstrate to the reader the impacts that are driving each of the figures. Full details on the analysis have been included in an annex of the impact assessment rather than in the scorecard itself, allowing the scorecard to function as a high-level summary of the expected impacts.

The IA uses the sections summarising the expected impacts on businesses and households to explain how the policy is expected to result in a direct cost to business paying higher wages and a benefit to individuals in the form of higher wages, which net out in NPSV terms. This leaves familiarisation costs as the only quantified impact included in the NPSV.

The IA also usefully considers to possibility of pass-through effects, where some businesses pass on some of their additional costs to consumers through higher prices, potentially reducing some of disparity in impact between businesses and households. The possibility of higher prices has been discussed in the scorecard but was not monetised or included in the key metrics.  

In the example below, the department estimates an NPSV, EANDCB and EANDCH without any expected pass-through between businesses and households.

Children’s Wellbeing and Schools Act: Children Not in School Registers: regulatory impact assessment, opinion reference RPC-DfE-24016-IA(1)

This bill proposed measures that aimed to reform the regulation of independent schools, improve the education system to make it more consistent and safer for every child and strengthen regulation and oversight in the children’s social care sector.

One of these measures required parents of children who are eligible for inclusion on a new ‘Children Not in School’ register to provide certain information for it, such as the child’s name, date-of-birth, and home address and details about the education provided, such as the amount of time being educated by a parent and by other people.

The IA used monetised estimates of the impact on overall welfare, business and households to help demonstrate the impacts of the proposed policy in the regulatory scorecard. These impacts are supported by a breakdown of the key components of each of the headline estimates, giving them clarity.

The IA did well to quantify a range of direct impacts on households, including familiarisation, reporting and data collection time costs for parents. The scorecard also includes a good qualitative explanation of each of these impacts, directing the reader to analytical annexes for a fuller breakdown of the assumptions used.

The IA example below presents a good summary of its cost-benefit analysis and assessment of distributional impacts.

Employment Rights Bill: Improve access to Statutory Sick Pay by removing the Lower Earnings Limit and removing the waiting period impact assessment, opinion reference RPC-DBT-24003-IA(1)

This proposal was to ensure that employees will be eligible for Statutory Sick Pay (SSP) regardless of earnings and that SSP is payable from the first day of work missed due to sickness.

The department has presented its headline impact estimates for overall welfare, businesses and households, accompanied by a description of the high-level assumptions used and a justification for which costs and benefits have been treated as direct or indirect. The IA does well to explain how the primary impacts act as a transfer between business and households, resulting in a neutral societal impact despite costs to businesses and a benefit for households. The scorecard also links this explanation to its fuller detailed breakdown of the analysis in a subsequent annex, allowing the scorecard to serve as a summary rather than giving full details of the analytical assumptions.

The scorecard also presented a good summary of the distributional impacts. This included a consideration of the disproportionate benefits for low-income and part-time workers, alongside the disproportionate costs faced by small and micro businesses. The IA includes estimates of the share of costs incurred by these smaller businesses contrasted by the proportion of businesses they make up to help demonstrate this disproportionate impact. This summary of distributional impacts was also linked to a further equalities analysis included in an annex, which considered various further impacts on characteristics such as age, gender, religion, ethnicity and region.

Presentation of non-monetised impacts

In some cases it may be disproportionate to quantify some of the costs and benefits of the preferred option, or there may be insufficient evidence to provide reliable estimates. Where this is the case, these effects should be clearly described qualitatively and included as part of the scorecard. Non-monetised impacts on overall welfare, households and businesses should be included in their relevant sections. Justification should be provided where impacts cannot be monetised as well as an indication of the direction and magnitude of the impacts.

In this example, the scorecard has been used to describe a range of non-monetised impacts:

Bus Services (No. 2) Bill impact assessment, opinion reference RPC-DFT-24013-IA(1)

The proposal contained 21 individual measures aimed at improving the bus network and consistency in local areas across the country. The provisions included the facilitation of franchising, permitting the establishment of new local authority bus companies, enhancing the accessibility and safety of bus travel, modifying the registration process for bus services, and aiming to reduce emissions from bus travel.

The regulatory scorecard in this IA sets out non-monetised impacts for both businesses and households, providing a headline impact such as ‘efficiency gains from limiting production lines’ and ‘reduction in noise pollution’, before going into greater detail on each. The department also uses the scorecard to give an indication of the overall direction of the non-monetised impacts, with a ‘neutral’ rating demonstrating the range of costs and benefits identifying for business and a ‘positive’ rating for household impacts.

In the example below, the IA provides a good consideration of the non-monetised impacts on overall welfare where there is limited evidence to provide quantified estimates:  

The Infrastructure Planning (Onshore Wind and Solar Generation) Order 2025 impact assessment, opinion reference RPC-DESNZ-24024-IA(1)

The proposal was to change the Nationally Significant Infrastructure Project (NSIP) regime to increase the threshold at which solar projects are determined as an NSIP, re-introduce onshore wind into the NSIP regime and set the threshold to 100MW.

The IA is only able to use limited evidence available to produce a monetised estimate of the familiarisation and so uses its description of non-monetised impacts and indicative impacts to justify a positive expected impact on overall welfare. The IA provides a headline summary of the expected overall direction of the non-monetised impacts, before giving a description of each, setting out concisely how the preferred policy is expected to deliver this benefit. The IA also does well to justify the expected positive overall impact by using illustrative impacts to help demonstrate the expected benefits despite insufficient evidence to conduct a full analysis.

Part B of the regulatory scorecard

The second half of the scorecard, part B, covers the impacts of the preferred option on ‘wider government priorities’, which currently are business environment (including competition and innovation), international considerations (trade and investment) and natural capital and decarbonisation. These priorities overlap significantly with what could be described as ‘wider impacts’.  

Part B should include a high-level qualitative assessment of the mechanisms by which these impacts occur and their likely scale. For example, the OA could draw on existing literature and evidence from other policy/international examples for how regulation within the broad policy area may impact competition (for example, barriers to entry or market concentration) or innovation (ability to bring new products/processes to market). Departments should aim to make this specific to the proposal itself rather than being too generic. The OA should include justification for where the proposal is not expected to have any impacts.

If impacts on competition, trade, innovation and natural capital are also key objectives, and there is an overlap between the impacts detailed in Part A and Part B of the scorecard, these impacts should be detailed in Part A as well. However, wherever possible, care should be taken in presentation to minimise the risk of readers ‘double counting’ impacts. Previous RPC guidance on impacts that may be included in Part B of the scorecard can be found below.

Previous RPC case histories guidance:

• assessing the impact of regulation on competition

• assessing the impact of regulation on trade and investment

• RPC case histories - December 2016 volume (Section 9)

The following example clearly sets out a range of potential impacts on both the business environment and international considerations.

Late payments consultation stage options assessment, opinion reference RPC-DBT-25033-OA(1)

The proposal was to introduce a set of new regulations designed to address poor business-to-business (B2B) payment behaviour, including late payment, long payment terms, disputed payments, and unfair practices around retention payments in construction contracts.

The OA used a bullet point list to communicate the impacts on wider government priorities the department has identified. This has allowed for a clear and concise summary of these impacts, making for an efficient Part B of the scorecard that readers can easily understand.  The department covers a broad range of business impacts, covering the attractiveness of the business environment, barriers to entry and market structures. The discussion of international consideration usefully covers how the policy compares to similar regulations in place or proposed in other jurisdictions such as the EU.

The following example provided a useful consideration of the impacts on natural capital and decarbonisation.

Planning and Infrastructure Bill impact assessment, opinion reference RPC-MHCLG-25031(1)

This proposal covered multiple measures aimed at delivering a faster process for critical infrastructure, introducing a more strategic approach to nature recovery, improving certainty in the planning system, unlocking new land for large scale investment and introducing new mechanisms for cross-boundary strategic planning.

The IA describes how it expects the proposal to support positive environmental outcomes, providing details on different ways in which this might be achieved. This includes supporting the adoption of decarbonising technologies such as electric vehicles, improved energy infrastructure allowing for greater development of renewable energy and improving natural capital through funding conservation measures. The department also does well to consider potential negative environmental consequences, highlighting the potential for other aspects of the proposal to increase carbon emissions.