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Red Tape Council
To: members of the Red Tape Council
From: Edna Assunção, Chair, Red Tape Council; and the Rapporteur, Red Tape Council
Letter to members on the three-of-five pattern result
Dear members,
We are writing to share where the Red Tape Council stands on RT-001, our work on small-business impact tests, permits and licensing. The interim pattern review finds that the reports we have examined meet three of the five pattern tests. That is a meaningful threshold in our process. It is not a finding that every permit system fails, that every delay has the same cause, or that a particular government or official is responsible.
We want you to be able to see the evidence behind the result, understand its limits, and help decide what a responsible next step should look like. We also want to be clear about what is not yet settled. The pattern result is not a final standard, a legal opinion, or a conclusion about the rules in any one country. It gives the Council grounds to continue examining a recurring problem and to consider a draft response with members and the public.
Who we are and what we are responsible for
Reseated is a global assembly of small-business owners, organized through seven councils. The Red Tape Council considers the practical effects of rules, licensing and administrative processes on small businesses. Our work is about practices and systems, not allegations against individual companies or officials. Members remain anonymous unless they choose a public seat.
Our agenda item, RT-001, is the proposed Small Business Impact Standard. Its policy direction is that new rules affecting businesses should include a small-business impact test; that people should be able to use a one-stop digital process where appropriate; that service times should be published; and that permit processes should have a defined “silence is consent” deadline. These are proposals under examination, not adopted requirements.
Reseated’s process begins with reports. The Council then tests whether a pattern is present across five dimensions: Volume, Frequency, Consistency, Spread and Corroboration. If the evidence warrants it, the next steps are a draft fix, public consultation, an Assembly ballot and letters to the chief executives or other decision-makers able to adopt the resulting standard. The Council’s present finding is at the pattern-review stage. It does not pre-empt consultation or an Assembly ballot.
What the evidence shows as of 23 October
The Red Tape Council has 122 members from 41 countries. It has received 304 reports from 47 countries. The median amount reported as at stake is approximately US$4,277. Forty reports were filed in the 30 days preceding the data cut-off. The report record classifies all 304 reports in the permit situation category.
The Council’s records identify the following leading countries by report count. These figures describe where reports came from; they are not estimates of the prevalence of permit problems in each country.
| Country | Reports |
|---|---|
| United States | 48 |
| Country | Reports |
|---|---|
| India | 27 |
| Country | Reports |
|---|---|
| Brazil | 24 |
| Country | Reports |
|---|---|
| Canada | 17 |
| Country | Reports |
|---|---|
| United Kingdom | 16 |
| Country | Reports |
|---|---|
| Italy | 15 |
| Country | Reports |
|---|---|
| Nigeria | 14 |
| Country | Reports |
|---|---|
| Germany | 10 |
The remaining reports came from other countries among the 47 represented. The country counts should be read as a description of submissions received, not as a ranking of governments or a comparison of administrative performance. They are shaped by who has heard of the Council, who has chosen to report, and which experiences members have been able to document.
Members also described the size of their teams. The reported distribution is: just me, 40%; 2–9 people, 38%; 10–49 people, 17%; and 50–249 people, 5%. The submissions represent businesses with different capacities to absorb delays, but this breakdown alone does not establish how outcomes vary by team size.
The aggregate amount at stake does not show whether a particular sum represents a fee, lost revenue, delayed investment or another consequence in any individual case. Those distinctions matter for a useful standard and should be established from reports where the information is available and can safely be shared.
For wider context, the United Nations describes micro-, small- and medium-sized enterprises as approximately 90% of businesses, 60–70% of employment and about 50% of GDP worldwide.2 The International Labour Organization gives an estimate of about 70% of employment worldwide and notes that roughly 80% of MSMEs operate
in the informal economy.3 These are global estimates, not measurements of the members who reported to this Council. They help explain why administrative processes affecting small businesses deserve attention, but they do not prove the Council’s specific finding.
What “three of five” means
The interim review, RC/RT/2026/N.1, dated 29 September 2026, records that three of the five pattern tests are met for permit and licensing delays. The five tests—Volume, Frequency, Consistency, Spread and Corroboration—are the Council’s framework for checking whether reports point to a sufficiently recurring and supported problem.
The interim result is a threshold finding, not a substitute for showing the reasoning behind each test. A clear account of that reasoning should accompany any draft that proceeds to consultation. Members should tell us if they believe the evidence record needs a particular explanation, qualification or additional check before the Council moves forward.
The result does not establish that every reported delay was caused by the same rule, that all permit applications take too long, or that silence by an authority should automatically count as approval in every circumstance. Some approvals may involve safety, environmental, public-health or other considerations that require a decision. Any proposed deadline or deemed outcome must be designed with the type of permit, the rights of affected parties and the consequences of a missed deadline in view.
Legal and policy context
Our members report from many jurisdictions. The applicable statutes, local rules, appeal routes and permit deadlines vary across them. We therefore make no claim here about what the law requires in Brazil, the United States, India, the United Kingdom or any other country represented in the reports.
The available cross-country policy reference is the World Bank’s B-READY 2025 report. It covers 101 economies and reports an average business-readiness result of approximately 60%. Its public-services scores are about 23% below its regulatory-framework scores. The full 164-economy edition was expected at the end of 2026.1
These findings provide context for considering the relationship between rules and the public services that implement them. They are not a permit-delay measurement, do not describe every country in our report set, and should not be treated as a direct validation of the Council’s 304 reports.
For each member, the relevant legal and administrative setting is the one that applies to the permit in question: the responsible authority, the stated service period, the available process for checking status, any review or appeal mechanism, and any rules governing approval or refusal. Those details vary. Before relying on a reported experience as evidence about a legal obligation, we need to verify the relevant jurisdiction and source. The Council’s proposed standard is a policy proposal; it does not replace local legal advice or alter any existing legal deadline.
What we are asking of members
Please review the interim result as a finding about a pattern in submitted reports, not as a verdict on a jurisdiction or a complete account of the permitting environment. If you think the three-of-five result has been misunderstood, tell us precisely what is missing or overstated.
Where you are willing and able, help improve the evidence record. Useful details include the type of permit, the authority responsible, the date an application was submitted, any published service time, the date and form of the response, follow-up steps, and the practical consequence of waiting. Please share only information you are entitled to provide and can share safely.
Where your report concerns a specific rule or deadline, identify the jurisdiction and the public source that sets it out, if you have one. A link or document reference is more useful than an unverified recollection. Do not send confidential material, personal data about officials, or identifying information about another business unless there is a clear and safe basis to do so.
Help us distinguish the different problems that can sit under the broad label “permit delay”: unclear requirements, repeated requests for documents, an inaccessible process, no published service time, a missed stated deadline, or an application awaiting a decision. We are not assuming that these are equivalent or that a single remedy fits each one.
Tell us what safeguards a workable standard would need. In particular, consider which permit types could use a defined response deadline, what notice should be given when a case cannot be decided on time, and where a “silence is consent” rule would be inappropriate or need a carefully framed exception. We seek practical proposals, including reasons for limits and exceptions.
Consider whether service-time information could be published in a way that is useful to applicants: the start and end points measured, how paused or incomplete applications are treated, how often figures are updated, and how applicants can check the status of an individual case. A number without a clear definition may mislead as much as it informs.
When speaking with public bodies, address the office with responsibility for the relevant process—such as the permitting department, licensing board, municipal administration or responsible ministry. Ask for the published rule, service time and review route. We do not attribute views to these offices unless they have made a statement that can be cited and verified.
Join the next stage of work. If the Council prepares a draft, members will have an opportunity to test its language and practical consequences before public consultation. The draft must be open to challenge; the pattern result does not predetermine its provisions or the Assembly’s decision.
Offer to share anonymized data
The Council can offer an anonymized summary of the data underlying this interim review to public offices, researchers and other appropriate recipients. The purpose would be to support examination of the reported pattern, not to identify members or businesses. Any sharing would need to remove direct identifiers and protect details that could reveal a person or business when combined with other information.
We will agree the scope and format with the recipient before sharing. The summary may include aggregate counts and a description of recorded fields. It will not disclose identifiable member submissions or present the report set as a representative survey of all businesses. A recipient seeking case-level material should explain the purpose and safeguards; the Council will assess whether it can be provided safely and lawfully.
Members who want to contribute to that work can tell the Rapporteur whether their submission may be considered for anonymized analysis and flag any details that create a re-identification risk. This is an invitation, not a request to waive confidentiality. Members may ask questions about handling before agreeing to any proposed use.
Next steps and accountability
The Council will continue to test the evidence and clarify the basis of the interim result. If a draft standard is prepared, it will be identified as a draft, opened to consultation and revised in light of responses. Only after consultation would the matter proceed to an Assembly ballot. If a standard is adopted, subsequent letters to decision-makers and the status of any CEO seats will be recorded through the Assembly’s process. No future adoption, response or commitment should be assumed at this stage.
We will report material changes in the evidence, the status of drafting and the Council’s conclusions through the relevant Reseated documents. Members can help make that record stronger by being specific, careful about what their evidence establishes, and willing to identify both the costs of delay and the safeguards needed for good administration.
Thank you for reporting, reviewing and questioning this work. A three-of-five result is a reason to proceed with care. It is also a reminder that the people who encounter a process every day can help identify where it is unclear, slow or difficult to navigate. We welcome your corrections and practical suggestions.
With respect,
Edna AssunçãoChair, Red Tape CouncilSão Paulo, Brazil
RapporteurRed Tape Council
Annex: Sources and record references
The figures in this letter are from the Reseated data record as of 23 October 2026. They are reproduced as supplied and should be read with the limitations stated above. External sources are numbered to correspond with the footnotes in the text.
World Bank, B-READY 2025 findings. The reference in this letter is limited to the facts stated in the source dossier: 101 economies, approximately 60% average business-ready, public-services scores about 23% below regulatory-framework scores, and the full 164-economy edition expected by end-2026.
United Nations, Micro-, Small and Medium-sized Enterprises Day. Global MSME estimates cited for context.
International Labour Organization, Micro, Small and Medium Enterprises. Global employment and informality estimates cited for context.
RC/RT/2026/N.1, Interim pattern review: permit and licensing delays (three of five tests met), 29 September 2026.
RC/RT/2026/1, Call for evidence: Red Tape Council agenda item RT-001, 10 February 2026.
RC/RT/2026/20, Open letter to mayors and city executives: publish your permit times, 18 March 2026.
RC/RT/2026/21, Letter to the World Bank B-READY team offering the Days to Open survey, 13 May 2026.
RC/RT/2026/22, Letter to the OECD SME and Entrepreneurship directorate on small-business impact tests, 17 June 2026.
RC/RT/2026/23, Open letter to licensing boards on silence-is-consent deadlines, 5 August 2026.
RC/RT/2026/24, Open letter: What 30 cities told us about Days to Open (interim), 9 September 2026.
RC/A/2026/2, Rules of Procedure of the Founders Assembly, 19 March 2026.
This document has no standing until adopted under the Founders Charter. Reseated Councils is not affiliated with the United Nations.