The “heart” of the Small Business Act: The “Think Small First” principle

According to the "Think Small First" principle contained in the Small Business Act, all legislative initiatives must be designed starting from the needs and characteristics of small businesses at the very early stages of policy making, in order to make legislation more SME friendly. Unfortunately, this principle is far from being commonplace, while we believe that it should be at the centre of the regulatory process at all levels: European, national, regional and local.

The "Think Small First" principle can lead to a transparent and simple regulatory environment, at European and national level. In an ideal case, necessary regulations should be designed right from the beginning in a way that also small enterprises can implement them easily and efficiently without any competitive disadvantage.

This principle should be used consistently and with more ambition throughout the whole regulatory and implementing process. Applying this principle will reduce the need for exemptions for SMEs and will dramatically ease administrative burdens. The principle is extremely important but the result is heavily depending on how it is interpreted in the regulatory or implementing situation. Various tools can be used to make sure that all new and revised rules abide to the "Think Small First" principle. For instance, the consultation of representative business organisations and impact assessments can be of use.

Consultation must be compulsorily addressed to SME organisations, which are still inappropriately excluded or improperly consulted even in countries where governments make daily reference to the importance of SMEs for their economies. The same shortcoming must be redressed in the EU, with the unjustified exclusion of SME sectorial organisations from the EU Sectoral Social Dialogue.

GRTU attaches great importance to effective and independent impact assessments to be carried out prior to all legislative initiatives. Impact assessments, together with Stakeholder Consultation, are key pillars of the "Think Small First" principle of the Small Business Act and a priority not only for enterprises, but also for the European Council and Parliament, which have insisted on their importance in several occasions. The European Commission should provide systematic, specific, real and independent impact assessments for SMEs, taking into account the different categories.

While the principle of impact assessment seems to be somewhat well established, we believe that more must be done on how to put this principle into practice: impact assessments should be drafted for any piece of legislation. Stakeholders should be involved from the very early stages and the European Commission should involve external experts in the process to ensure a rigorous, objective and neutral quantification of the costs and benefits for end users.