AmCham Macedonia Summer 2017 (Issue 54) - Page 20

Analysis Michelle Osmanli, Executive Director, AmCham Macedonia M acedonia has a new govern- ment. I recently dug through the new ruling party’s proposed Government Work Program 2017-2020 to see how many of the longstanding issues AmCham members have identified are at least mentioned there. In fact, the proposed pro- gram touches on virtually all of the key economic reform areas AmCham and its peer organi- zations have identified over the years. Thus, it seems that we at least agree on the problems and can be have some optimism about finding workable solutions together. The following is a summary of selected government commit- ments and background on our established stances in relation to them. Summer 2017 / Issue 54 New Government Program Speaks to Many AmCham Priorities New government commitment: Have all institutions critical to the business environment publish official and binding instructions on how to apply the laws they enforce. AmCham stance: This is particularly critical when companies have been punished for interpreting the application of the law differently than enforcement insti- tutions. Companies are often in need of reliable official guidance on the application of laws to their concrete situation. Today, institutions with the authority to decide how a given regulation applies to a concrete company situation do not publish these opinions in that official capacity. This encourages uneven application and means that companies cannot predict how the law will be applied in their case. New government commitment: Fully implement the National e-Register of Reg- ulations (; extend the public com- ment period for proposed legislation to 20-30 days; reduce the government’s use of the “short- ened procedure” for proposed legislation which bypasses public comment entirely; reform the regulatory impact assessment (RIA) mechanism. AmCham stance: We applauded the previous Government’s introduction of ENER as a commendable move toward increasing public comment on pro- posed legislation. Unfortunately, over time, the platform has been used less and less by ministries to notify citizens of planned legisla- tive changes, let alone as a tool to encourage open, 2-way communication. We have also long argued that too many laws were passed without any public comment period whatso- ever (e.g., 80% of all legislation passed in the first half of 2016). Even when it is respected, the minimum period of 10 calendar days for public comment confirmed by the government was simply too short to allow for thoughtful and constructive responses from company representatives. Finally, we have pointed out for some time that government RIAs are too rare and that impact on the private sector is rarely mentioned by lawmakers ݡ)ٕ䁕쁥ɅаMхє)ՑЁЁ́٥Յ䁅݅́ͥɕ( ) 5)55饹)5饹)9܁ٕɹЁѵ+qѡɽtչYPɕɹ́ѡ)Mхєѥ́ѽ݅ɐѡɥمє͕ѽȸ) х)=ȁ́ٔȁ䁅ɕɵ)ЁɕͥѡɅɕ䁽ѡ嵕)Ʌѥ́ՑЁ͕́ѽ݅ɐ́ɥمє͕ѽȁ)Ʌѽ̰́ݕ́ѡȁѥ̸1є嵕Ё)ՑЁ͕́ѽ݅ɐ́ɔɥѕ́ͥ)ѱѼեɽ́ѡչ丁](ذѡ1܁͍́ձѼ)ՑЁ͕̰ѡɔ́٥ѡЁѥѥ)嵕ЁɅѥ́ٔɽٕٕѡMхїe)ѥѼѽȁ͕ѡ́ɽ̀Ѽ)Ց́ՕѼѡ5ѕȁ̼)͕Ʌɕ䁽Չ嵕ЁɅѥ́́)䁵ͥЁѡɕЁѕ)9܁ٕɹЁѵ)Iٔѡɽ́ͅɥ́ٔݡͽ)ɥѥ́ɔЁݕ) х)]ѡٔ݅́ͅ԰Ё݅́ЁݥѠ)ɽȁɽ䁥ѡͥ́չ䁅ɽѕ)ѡٕɹЁѼɕɸѡѼظɽ̸ٕѡ)ͥѡɔ́ɕᕐȁ٥Դ)̰Ё́Ё͕ɕͽѼ܁٥Յɤ)ѥ́Ѽѡ͔ѕ́Ѽɥ͔ݥѡЁи