Better Regulation Call for Evidence ClientEarth response

• The Commission’s current practice of bypassing impact assessments at the pretense of “political urgency” undermines evidence-based policymaking and exposes EU legislation to significant legal and outcome-related risks.
• Abandoning impact assessments increases the likelihood of unintended consequences, weakens environmental and fundamental-rights safeguards, and hands disproportionate influence to powerful corporate and geopolitical actors.
• Failure to conduct proper assessments and consultations heightens the risk of court challenges as Treaty obligations on transparency and participation are not respected, and erodes public trust in the EU’s democratic legitimacy.
• Recent Ombudsman findings found maladministration and confirm systemic shortcomings in the Commission’s justifications for urgency exemptions, as well as regarding stakeholder selection, transparency, and compliance with the EU Climate Law, among others.
• The Commission must now use the present initiative as an opportunity to reverse these trends, rather than locking-in current practice.
• Public consultations must remain the default: targeted formats cannot replace the legal requirements of participatory democracy, balanced representation, and early, meaningful input.
• True simplification requires stable, predictable laws and robust evidence—not rapid-fire Omnibus revisions that dilute protections of nature and human health, create legal uncertainty and disadvantage European SMEs while benefiting large lobby actors.
  4 February 2026