Written by: Fabiola Olivia Perales Fernandez | @FabiolaOPerales
Research article
Regulatory Forward Plans (in Spanish Agendas Regulatorias) are mainly short-term planning instruments. Strictly speaking, a Regulatory Forward Plans is the list of regulations that will be created, modified or eliminated in a period of six months or one year (Coglianese and Walters, 2016, p. 95; and Perez, 2019). The Regulatory Forward Plans are recognized as a good regulatory practice, as they provide advance notice of future regulatory activity, allowing for public participation and transparency in the regulatory process (Perez, 2019). In addition, Regulatory Forward Plans are legally required, that is, they are initiated in response to legal mandates, so they are not entirely discretionary (Coglianese and Walters, 2016, p. 100).
In this sense, I worked in this article to identify the Latin American countries that have been established legal frameworks for the elaboration of Regulatory Forward Plans. In this brief research I covered eight countries of the region, these are: Brazil, Chile, Costa Rica, Colombia, Ecuador, El Salvador, Mexico and Peru. I’ve identified that seven out of the eight countries reviewed have legal instruments that force government institutions to develop Regulatory Forward Plans or similar plans. From these seven countries, six have already implemented Regulatory Forward Plans. Below, I’ve made a brief description of how the agendas or plans work in the countries analyzed.
Brazil
Brazil has a long tradition of developing regulatory agencies and implementing good regulatory practices in these institutions. According to Bastos and Ortega (2018), Brazil has ten regulatory agencies, these are: Brazilian Electricity Regulatory Agency (ANEEL), National Telecommunications Agency (ANATEL) and National Agency of Petroleum, Natural Gas and Biofuels (ANP), Brazilian Health Regulatory Agency (ANVISA) and the National Supplementary Health Agency (ANS), National Water Agency (ANA), Brazilian Film Agency (ANCINE), National Land Transport Agency (ANTT), National Agency for Waterway Transportation (ANTAQ) and the National Civil Aviation Agency (ANAC). Reviewing their websites, I observed that nine out of ten regulatory agencies have fully implemented for several years Regulatory Forward Plans. They often define them as: “a management tool that provides greater advertising, predictability, transparency and efficiency to an agency’s regulatory process, allowing society and the regulated agents to follow up on the commitments pre-established by the regulatory agency” (Anatel, 2018, p. 31). Regulatory Forward Plans in Brazil must contain “all the regulatory projects that the Agency must carry out in the reference period” (p. 31). The reference period can be either two-year[1], three-year[2], or four-year[3]. Each agency regulates the content, the reference period and the way in which its Forward Plan is drawn up. Brazilian´s regulatory agencies have the good practice of keeping current and historical Regulatory Forward Plans public.
Chile
During 2019, Chile developed the regulatory framework to implement regulatory improvement actions. Among the documents issued, the following stand out: the Chilean Guide for Good Regulation, Presidential Decree # 3, to prepare Regulatory Impact Assessment reports and Presidential Decree # 4, to prepare Regulatory Simplification reports. Presidential Decree # 4 establishes in numeral II.5, the obligation of informing to the Ministry General Secretariat of the Presidency, in the month of December of each year:
“Laws, decree-laws, decrees with the force of law, regulations and other administrative rules of general scope whose validity is suggested to be revised because they are considered redundant, unnecessary, obsolete, tacitly repealed or dispensable; Laws, decree-laws, decrees with the force of law, regulations and other administrative rules of a general scope which in their opinion require a consolidated, coordinated and systematized text when it is convenient for their better execution; and, A plan setting out how to proceed with respect to the above numbers (…), within one calendar year, including the degree of implementation of the previous year’s reduction and systematization plan”. (Emphasis added)
Although the actions of the plans referred to in Presidential Decree # 4 will be aimed at regulatory simplification, it is a good start for the Chilean State to generate the necessary experience, in order to later discuss the creation of unified regulatory forward plans (Agendas Regulatorias Unificadas), that is, those that include simplification, deregulation and regulatory actions.
Costa Rica
In Costa Rica, the instruments that most closely resemble the concept of Regulatory Agendas are the Annual Regulatory Improvement Plans, which are based on the Regulation of Law no. 8220: Protection of Citizens against Excessive Requirements and Administrative Procedures (Executive Order no. 37045 – MP-MEIC and its reforms). Regulatory improvement plans (Improvement Plans) are an instrument that contain the formalities (also called paperwork), services and procedures to be improved within a calendar year, as well as all the related actions to carry out these improvements, such as: “objectives, goals, indicators, activities, execution times, responsible parties and evaluation and follow-up actions” (Art. 19). For the development of Improvement Plans, regulators in Costa Rica may incorporate citizen opinion to the process of continuous improvement of formalities (Art. 19). To this end, each year during the month of November, all Preliminary Regulatory Improvement Plans should be published for public consultation in the Costa Rica’s Digital System of formalities[4]; these must be submitted in their final version within the first ten days of December. The Annual Improvement Plan is a tool that the Government of Costa Rica has institutionalized to the extent that it must be linked to the institutional operating plans and annual budgetary goals of each institution (Art. 19). The Digital System of formalities offers the historical Improvement Plans records since 2016 and also the plans for 2020 can already be consulted.
Three considerations on this exercise in Costa Rica are: first, the public and historical access to the institutions’ regulatory improvement plans records are an interesting and positive practices, since it generates a historical memory regarding the procedures that have been improved, which avoids reworking or improvements in opposite directions that procedures; likewise, it would allow to identify and quantify the improvements made in a period of time. Second, making public the roadmap of how the procedures are to be improved is an important accountability exercise since it forces the institutions to carry out these activities or, at some point, to point out why they were not developed. Third, the annual improvement plans in Costa Rica have a limited scope since they only contain improvements for the simplification of formalities (paperwork), services, or procedures, which only allows stakeholders to have a partial view of the changes in the regulatory scenario. With this experience, it could be easy for Costa Rica to move towards the generation of unified regulatory forward plans.
Colombia
Colombia is one of the countries that have regulated the development of regulatory forward plans since 2004 through the Decree 2696. Article six of this legal instrument force to the Regulatory Commissions to prepare an annual regulatory forward plan in which the issues or matters of a regulatory nature to be worked during a year are established. This provision does not limit the Colombian Regulatory Commissions to work on matters not contemplated in the plan. By 2015, Colombia issued the Decree 1081 of 2015[5], and later Colombia modified it through the Decree 270 of 2017. These decrees extended the scope of regulatory improvement measures to other government entities. Article 2.1.2.1.20 states that regulatory authorities[6] should publish a regulatory forward plan draft on their website, no later than 31 October of each year, “with a list of specific regulations of a general nature that are expected to be issued in the following year”. The regulatory forward plan draft should be presented in a specific format established by the Legal Secretariat of the Presidency of Colombia and should be submitted for public consultation during November of each year. Once the comments have been assessed, each regulated entity must publish the final regulatory forward plan by December 31 of each year and send it to the Legal Secretariat. If the public entities require modifications to the agenda, these changes should be justified to the Legal Secretariat. In Colombia, it is mandatory to keep, throughout the year, the Regulatory forward plans and their modifications public.
On the other hand, the Colombian government proposes to publish and concentrate all regulatory forward plans in the Unified System of Public Consultation (SUCOP)[7]. However, there are no records of regulatory forward plans in the SUCOP (at the time of writing this article). Nonetheless, there are several examples of institutions that have been fully implemented the regulatory forward plans, for example: the Communications Regulation Commission, which recently presented the 2020-2021 regulatory forward plan[8] and has had a registry of Regulatory forward plans since 2005[9] and the Ministry of Health[10]. In this regard, it is important to recognize the sustained work that Colombian institutions have been doing to improve regulation. Increasing the credibility and use of SUCOP is a challenge for Colombia in 2020. The Publication the Regulatory forward plans in the SUCOP will be an important step in consolidating the system itself, the planning tool and the Regulatory Improvement Policy.
Ecuador
On May 4, 2018 through Executive Decree 372, the Government of Ecuador declared as State Policy the improvement and simplification of formalities (paperwork). In this sense, Ecuador has given priority to the administrative simplification and although the development of Regulatory forward plans is not yet contemplated, it does contemplate the elaboration of annual institutional plans for simplification of formalities. In order to implement this policy, the Government of Ecuador issued the “Law for the Optimization and Efficiency of Administrative formalities” on October 23, 2018 and Executive Decree 743 on June 10, 2019, which issued the “Regulations for the Law on the Optimization and Efficiency of Administrative Procedures”[11]. All public entities in Ecuador, including the executive, legislative and judicial branches, are subject to the law.
Article 21 of Decree 743 states that “administrative formalities simplification plans are tools for planning and implementing priority and simplification actions for administrative formalities, carried out in public administration bodies and organizations”. Also, Article 6 of the Law establishes the following elements as the content of the plans: 1. Identification and classification of the existing formalities in the entity; 2. Diagnosis of the formalities that have the highest cost for the citizens. 3. Identification of the existing formalities in the entity that will be subject to review. 4. Simplification´s objectives, goals and strategies to be achieved, in a given of a period; and, 5. The management indicators according to which the evaluation of the execution of the plans will be carried out. The plans must be sent to the Technical Secretariat for Planning (formerly SENPLADES) within the first fifteen days of the beginning of each fiscal year (Art. 21, Decree 743). Also, administrative simplification actions must be prioritized according to the following criteria: 1. annual demand for the formalities; 2. volume of complaints associated with a formality; 3. cost of the formality to the public administration; 4. volume of returns; 5. response time; 6. citizen needs; and 7. susceptibility to corruption. The Government of Ecuador foresees a public consultation to discuss the prioritization of the simplification of formalities proposed by government institutions (Article 22, Decree 743).
The great challenge for Ecuador in 2020 will be the implementation of the annual institutional plans for simplification of formalities. Based on this experience, Ecuador could discuss the incorporation of Unified Regulatory Forward Plans in the coming years. Notwithstanding the above, I identified that Ecuador and Colombia have developed binational regulatory forward plans, in which include sectoral issues such as transportation, trade and energy[12][13]. This binational regulatory forward plan is an example of a regulatory cooperation mechanism in the region. The document identifies sectoral risks and problems, as well as objectives and regulatory actions.
El Salvador
El Salvador’s Regulatory Improvement Law, issued through Decree 202 of January 9, 2019, requires government institutions[14] to develop annual regulatory forward plans. Articles 5 and 15 of this law define the regulatory forward plan as “a list of regulations that are planned to be approved, modified, suppressed or presented for approval during each calendar year in order to make the regulatory exercise predictable, facilitate inter-institutional coordination and allow for citizen participation”. Likewise, Article 16 states that the regulatory forward plans must be approved in the first three months of each year with updates in the months of April, July and October. The Law establishes that the regulatory forward plans must be permanently available in the various institutional media. One element to be highlighted is the restriction to issue regulations in case they are not incorporated in the regulatory agenda of the year in question. According to information published on the website of El Salvador’s Regulatory Improvement Agency (OMR), the regulatory forward plans are expected to be developed for the first time in 2020[15].
Mexico
In Mexico, the closest precedent to a regulatory forward plan is the National Standards Program (PNN)[16]. This annual program contains a list of topics to be standardized during a calendar year[17] through official Mexican standards (NOMs—Spanish acronym), Mexican standards (NMXs—Spanish acronym) and reference standards (NFRs—Spanish acronym). It must be approved by the last day of February of each year and then published in the Official Gazette of the Federation (DOF—Spanish acronym). It is defined as “an instrument of planning, coordination and information about the standardization activities at national level, both of the public and private sectors” (Art. 55, RLFMN). The PNN is a fully implemented exercise in Mexico and its relevance lies in its mandatory nature on NOMs, since no official Mexican standard can be modified, cancelled or created if it is not contained and foreseen within the PNN for the year in question or in its supplement, this with the exception of if it is an emergency NOM (That regulation continues in force).
Taking as a reference the experience in the PNN, the General Law of Regulatory Improvement (LGMR—Spanish acronym) issued in May 2018, establishes the development of regulatory forward plans as a tool of the National System of Regulatory Improvement (Art. 11, LGMR). The regulatory forward plans are defined in the Law as “the proposal of the Regulations that the subjects bound by Law intend to issue” and are proposed to inform the public “about the proximity of the listed regulations”. According to Article 64 of the same Law, the plans must be submitted to the Regulatory Improvement Authority (CONAMER or State Regulatory Improvement Commissions) “in the first five days of the months of May and November of each year”. Subsequently, they must be submitted for public consultation within 20 working days. The regulatory forward plans must contain the following information: (1) preliminary name of the regulatory proposal; (2) subject matter of the regulation; (3) problem to be solved by the regulatory proposal; (4) justification for issuing the regulatory proposal, and (5) tentative date of submission (Art. 64, LGMR).
The General Law on Regulatory Improvement states that regulations may not be issued if they are not included in the regulatory forward plans that have been approved and published, with the exceptions established in Article 65 of the General Law. These exceptions include the following: (1) regulations that address an emergency situation, (2) those that require non-publicity to avoid compromising the objectives that the regulation is intended to achieve, (3) those that do not generate compliance costs for individuals, (4) those that are issued by the head of the federal or state executive branch, and/or (5) those that represent a substantial improvement that reduces the compliance costs of the regulation in force, simplifies formalities or services, or both.
Currently, Mexico has not yet implemented the creation of Regulatory forward plans in federal agencies, in accordance with the General Law. Although a Proposal for a Sub-national Regulatory Agenda for Freight Transport[18] was issued in November 2019 by the National Regulatory Authority (CONAMER) in cooperation with the Federal Competition Commission (COFECE), this document is not yet a commitment by the authorities that have the power to modify the regulation. In this sense, we can generate two reflections for Mexico: 1. the implementation of Regulatory forward plans in federal agencies is urgent, since at least in the Energy Sector, abrupt changes of regulatory policy have been identified, without previous discussions with the regulated subjects and other stakeholders of the sector, which has generated uncertainty and put at risk the regulatory governance of the sector. 2) It is advisable to seek a reform of Article 65 of the LGMR, which sets out the exceptions to include regulations or issues into the regulatory forward plans. This is because these exceptions could be exempting 75%[19] of regulations issued annually. That would discourage the use of regulatory forward plans and thus render their issuance meaningless by jeopardizing their objective, i.e., State planning and Predictability for the citizens.
On the other hand, it is observed that the harmonization of the state laws of regulatory improvement to the General Law also implies the obligation to elaborate regulatory forward plans at the sub-national level. In this regard, some states and municipalities have taken on the task of regulating the preparation of their regulatory forward plans and are beginning to implement them, highlighting: the State of Mexico[20][21], Morelos[22] and Yucatán[23]. Some municipal regulatory forward plans were also identified in the municipalities of Puebla[24], Celaya[25], Tenancingo de Degollado[26], Cuernavaca[27], Atizapan de Zaragoza[28], among others. It is worth recognizing the initiative that these Federative Entities and municipalities have had to implement the Regulatory Forward Plans and begin to generate an environment of greater planning in these public spaces.
Peru
Peru has undertaken actions for the institutionalization of the Regulatory Improvement Policy, as well as actions to reduce the administrative burdens of its regulations. However, so far, no legal instrument has been identified that regulates the preparation of annual or biannual Regulatory forward plans in a systematic manner.
Pacific Alliance
The development of Regulatory forward plans is especially relevant for the countries that are part of the Pacific Alliance, since the First Amendment Protocol to the Additional Protocol to the Framework Agreement of the Pacific Alliance[29] issued on July 3, 2015, contemplates in its article 4 the incorporation of Chapter 15 bis, of Regulatory Improvement (also called Better Regulation Chapter), which, in turn, proposes to develop Annual Regulatory Plans in the countries that are part of it. Article 15 bis, 5: Implementation of Good Regulatory Practices, number 8, stipulates as follows: “Each Party should publish annually a notice, in a manner it considers appropriate and in accordance with its law, of any covered regulatory measure that it provides for its regulatory authorities to issue or modify during the following 12 months” (Emphasis added). This provision enters into force “on the first day of the third month following the date on which the Depositary (Colombia) receives the last notification by which the parties report that they have completed the legal approval procedure in their country or on such other date as the parties may agree”.[30]
In a brief web review, I’ve identified that the four countries of the Pacific Alliance have already completed the internal procedures for approval of the First Amendment Protocol: Chile (2016), Colombia (2018), Mexico (2017) and Peru (July 2019); and although it was not possible to fully locate any document confirming the entry into force of the Pacific Alliance’s Better Regulation Chapter , it is foreseeable that the First Amending Protocol is about to enter into force or has already entered into force, so it could be expected that a meeting of the Pacific Alliance’s Better Regulation Committee will take place at the end of 2020 or early in 2021, with the aim to review the progress of the implementation of the Good Regulatory Practices contained in the chapter. In this sense, it would be important that those in charge of the Pacific Alliance Regulatory Cooperation Working Group or those who are members of the Better Regulation Committee could generate a micro website of the group’s work and the countries’ progress in the adoption of good regulatory practices in order to contribute to regulatory transparency in the region.
Final remarks
It is a reality that Latin America has been advancing in the development of the Policy of Regulatory Improvement, and in the implementation of its tools, among them the Regulatory Forward Plans, which are planning instruments of the regulations, that allow to guarantee the transparency and the accountability in the process of elaboration of regulations, grant predictability to the society, and allow to the same society to get integrated to the process of modification of the regulatory framework of its interest. The clearest advances in the implementation of regulatory forward plans are presented by Brazil and Colombia, thus the region could take the experiences, successes, failures and challenges of these countries and learn about them.
Box 1. Regulatory forward plans in Latin America |
|||||
Country |
Obligation in Law, Agreement or Decree |
Implementation |
Plans include Simplification and/or Deregulation Actions (only) |
Plans include Regulatory actions (only) |
Unified Plan (both) |
Brazil |
Yes |
Yes |
No |
Yes |
No |
Chile |
Yes |
In process |
Yes |
No |
No |
Colombia |
Yes |
Yes |
No |
Yes |
No |
Costa Rica |
Yes |
Yes |
Yes |
No |
No |
Ecuador |
Yes |
In process |
Yes |
No |
No |
El Salvador |
Yes |
In process |
No |
Yes |
No |
Mexico |
Yes |
No |
No |
Yes |
No |
Peru |
No |
No |
No |
No |
No |
Note: this analysis does not consider the Regulatory Improvement Programs of Mexico because although they can be annual, biennial, triennial or six-yearly and contemplate actions of administrative simplification and improvement of regulation, it is also true that they have to be issued and called by the Regulatory Improvement Authority (art. 80 LGMR), which does not necessarily make them systematic and predictable. NNPs were also not considered because they are only limited to NOMs. In the same sense, the administrative simplification actions of Peru were not considered, since its regulation does not yet establish the systematization of the process through regulatory planning tools, such as the Regulatory Agendas in semiannual or annual. |
Source: Own elaboration
In the United States, scholars are well advanced in discussions of regulatory forward plans, particularly Coglianese and Walters (2016) suggest analyzing the phase of agenda-setting of the regulatory forwards plans, which define as “the stage where most critical decisions are made to define what issues will eventually make it to the important later stages of promulgation and implementation” (p. 94). No doubt this is a relevant discussion, which Latin American countries could take up for the design of their regulatory forward plans system. This is because early agenda-setting decisions affect and structure all that comes afterwards, can have a major impact on the regulatory performance of agencies and face opportunity costs, since the decision to address a problem through the rule-making necessarily crowds out attention to other problems (Coglianese and Walters, 2016, p. 94).
Therefore, it would be advisable for Latin American countries to build a broader vision of what regulatory forward plans are and how they should be systematized, that is, that the plans can include both administrative simplification and deregulation actions, as well as future regulatory actions. On the other hand, given the importance of regulatory forward plans in the governance of economic and social sectors, it would be relevant for Latin American countries to integrate into their forward plans system a compliance assessment, identifying: the degree to which planned actions were carried out, as well as the regulations that were issued during the reference period and that were not contemplated in the forward plans. This would make it possible to evaluate the effectiveness of regulatory planning by public entities.
The challenge for 2020 for Latin America is to continue promoting the development of Regulatory forward plans, their systematization, as well as to deepen the study of setting phase of plans and those who participate in the processes, and to monitor compliance plans and their effectiveness. The Organization for Economic Cooperation and Development (OECD), the Inter-American Development Bank (IDB), the World Bank and the Ibero-American and Caribbean Network for Regulatory Improvement could serve as advisors and catalysts for the development of these actions.
Written by Fabiola Perales, Specialist on Better Regulation
Translation from the original article in Spanish called “Agendas Regulatorias en América Latina: un instrumento de planeación de corto plazo”, published on January 11, 2020 on the blog www.mejoresgobiernos.org
Cite this publication as:
Perales-Fernández, F. (2020). Regulatory Forward Plans in Latin America: a short-term planning tool. Blog Mejores Gobiernos. www.mejoresgobiernos.org
References
ANATEL, 2018. Manual de Boas Práticas Regulatórias. Brasil. Disponible en: https://www.anatel.gov.br/Portal/verificaDocumentos/documento.asp?numeroPublicacao=348609&pub=original&filtro=1&documentoPath=348609.pdf
Bastos, C. S. P., & Ortega, D. S. (2018). Agencias reguladoras federales de Brasil y acceso a la información: analisis de los servicios de informacion al ciudadano de agencias reguladoras brasileñas. Conpedi Law Review, 4(1), 24-46.
Coglianese, C., & Walters, D. E. (2016). Agenda-Setting in the Regulatory State: Theory and Evidence. Admin. L. Rev., 68, 93.
Perez, D. (2019) “2019 Spring Unified Agenda”. Regulatory Studies Center. The George Washington University. https://regulatorystudies.columbian.gwu.edu/sites/g/files/zaxdzs1866/f/downloads/GW%20Reg%20Studies%20-%202019%20Spring%20Unified%20Agenda%20-%20DPerez.pdf
[1] Anatel, Aneel, Anp, Ancine, Antt, Antaq, Anac.
[2] Ans.
[3] Anvisa.
[4] Also called System for Simplification of Procedures and Regulatory Improvement. Consult it on: https://tramitescr.meic.go.cr/PMR/BuscarPMR.aspx
[5] Available at: http://es.presidencia.gov.co/normativa/normativa/Decreto-1081-2015.pdf
[6] As referred to in the first paragraph of Article 2.1.2.1.3. of this Decree, that is: “ministries and administrative departments, entities of the Executive Branch of the Public Power in national order and territorial entities in relation to the decrees and general resolutions of the Mayors and Governors”.
[7] “SUCOP is a platform that standardizes and facilitates citizen participation in the national government’s normative production process… Its] function will be to centralize the National Government’s substantial draft decrees, including the explanatory report, technical studies that support them (among them the Regulatory Impact Assessment) and any other document that serves as support, such as comments, suggestions or even alternative proposals”. https://www.sucop.gov.co/inicio
[8] Available at: https://www.crcom.gov.co/uploads/images/files/agenda2020/AR-TIC-2020-2021-SCC.pdf
[9] Here available the historical records of Regulatory forward plans: https://www.crcom.gov.co/es/pagina/agenda-regulatoria
[10] Available at: https://www.minsalud.gov.co/Normativa/Paginas/agenda-regulatoria.aspx
[11] Available at https://www.gob.ec/sites/default/files/2019-06/Decreto%20743.pdf
[12] Available at: https://www.planificacion.gob.ec/agenda-regulatoria-se-socializo-con-entidades-del-ejecutivo/
[13] http://www.sbi-ecuador-colombia.info/documentos/Agenda_Regulatoria_Ecuador_Colombia_2017.pdf
[14] The following are the subjects bound by El Salvador’s Law on Regulatory Improvement: “the Executive and its dependencies, autonomous entities and other public bodies, even when their Law of creation is described as special, municipalities and the legislative and judicial bodies, the Court of Accounts of the Republic, the Attorney General of the Republic, the Attorney General for the Defense of Human Rights, the Attorney General of the Republic, the Superior Council of Public Health, the Supreme Electoral Tribunal and, in general, any institution of a public nature” (Article 3).
[15] See the OMR´s website, in the section on the implementation of the Law, year 2020: https://omr.gob.sv/
[16] Which has as its legal basis the Article 61-A of the Federal Metrology and Standardization Law and Articles 55 to 58 of the Regulations of the Law.
[17] Additionally, the PNN has a supplement which is issued in the month of August of the corresponding year of the Program.
[18] Available at: https://www.gob.mx/cms/uploads/attachment/file/512968/COFECE_-_CONAMER-_TRANSPORTE_portal.pdf
[19] According to the 2018-2019 CONAMER´s Work Report, from November 1, 2018 to October 31, 2019, CONAMER received a total of 1,171 Regulatory Proposals (RP), of which 884 (75.49%) did not generate compliance costs, and of the 143 (12.21%) that generated compliance costs for citizens, three (2.10%) presented an Emergency situation, which gives a total of 887 RP that could be within the exceptions, without counting the PR with compliance costs issued by the federal executive, or those that request no publicity, or those that generate a simplification or substantial savings. This cannot be quantified from publicly available data.
[20] The State of Mexico implemented the Regulatory Forward Plans for the first time in 2019. Available at: http://cemer.edomex.gob.mx/sites/cemer.edomex.gob.mx/files/files/Manual%20%20para%20Elaborar%20la%20%20Agenda%20Regulatoria%202019.pdf
[21] 2019, Regulatory Forward Plans: http://cemer.edomex.gob.mx/agenda_regulatoria
[22] Morelos has placed the platform to implement the Regulatory Forward Plans in 2020. https://cemer.morelos.gob.mx/agenda-regulatoria
[23] Yucatan implemented the Regulatory Forward Plans in 2019. Check it out at: http://www.yucatan.gob.mx/mejora-regulatoria/agenda.php
[24] Available at: http://gobiernoabierto.pueblacapital.gob.mx/mejora-regulatoria/agenda-regulatoria/noviembre-23; http://gobiernoabierto.pueblacapital.gob.mx/mejora-regulatoria/agenda-regulatoria
[25] Available at: https://www.celaya.gob.mx/cya/direcciones/desarrollo-economico/cmryc/agenda-regulatoria/
[26] Available at: https://tenancingo.gob.mx/agenda/
[27] Available at: http://cuernavaca.gob.mx/dmer/?page_id=395
[28] Available at: http://www.atizapan.gob.mx/agenda-regulatoria/
[29] Available at: https://alianzapacifico.net/download/primer-protocolo-modificatorio-del-protocolo-adicional-al-acuerdo-marco-de-la-alianza-del-pacifico/
[30] Consultation on Article 19.3 and 19.4 of the Additional Protocol to the Framework Agreement of the Pacific Alliance.
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