Summary record of the fourth session of the Red Tape Council

Summary record of the fourth session of the Red Tape Council

Symbol: RC/RT/2026/SR.4
Date: 22 May 2026
Kind: Minutes
Status: Published
Chair: Edna Assunção, Chair of the Red Tape Council, São Paulo, Brazil
Recipient: —

Sittings: Asia-Pacific sitting, 06:00 UTC; Europe/Africa/Americas sitting, 16:00 UTC. The two sittings considered the same agenda and their proceedings are summarized together below.

Attendance: The session-specific attendance count and the number of countries represented at the sittings were not recorded in the available register. As at 22 May, the Red Tape Council comprised 49 members from 27 countries. Those membership figures are not presented as a count of participants at this session. The member names used in this record are identifiers; no member’s business is named.

Agenda: (a) review of evidence received under RT-001; (b) discussion of the five-part pattern test; (c) design questions concerning the proposed Small Business Impact Standard; (d) public-facing evidence work, including the Days to Open index and Permit Timer; (e) follow-up to the Council’s correspondence with the World Bank B-READY team; and (f) next steps and the next session.

Proceedings

1. Opening the session, the Chair recalled that the Council’s task was to describe recurring practices affecting small businesses, rather than to make findings about any one authority. She placed RT-001 in its current procedural stage: members had submitted reports and the Council was reviewing whether the evidence demonstrated a sufficiently consistent pattern. The proposed remedy had not been tested, drafted or submitted to a ballot. The Chair emphasized that discussion of a possible standard at this meeting did not amount to a Council decision on its wording or adoption.

2. The Chair noted that the Council’s evidence submission and correspondence had developed over several months. The call for evidence, RC/RT/2026/1, had invited accounts relevant to the RT-001 agenda item. The Council had also issued an open letter to mayors and city executives asking them to publish permit times, RC/RT/2026/20, and had written to the World Bank B-READY team offering the Days to Open survey, RC/RT/2026/21. Members were asked to distinguish personal experience from conclusions about the prevalence of a practice and to identify the type of process involved wherever possible.

3. The Secretariat’s evidence snapshot as at 22 May was presented for discussion. The Council had 49 members from 27 countries and had received 77 reports from 29 countries. The median amount at stake was approximately US$5,472. The reports described permit situations; the figures below record the Council’s then-current internal evidence, not a measure of all permit processes or all small businesses. Twenty-six reports had been filed in the preceding 30 days.

1. The country distribution was reviewed as an aid to identifying where further evidence might be sought. The largest report counts were from the United States (14), India (11), Brazil (8), Canada (5), the United Kingdom (5), Argentina (3), Germany (3) and Viet Nam (3). The Chair cautioned that counts reflected submissions received, not comparative permit performance. Members agreed that the Council should avoid treating a larger number of reports from a country as proof that its procedures were worse than those elsewhere.

2. Ms. Ananya Rao, a member from Bengaluru, India, described the practical difficulty of planning a small operation when a permit application has no clear published timetable. She said that uncertainty could affect decisions about staffing and premises even when an applicant had completed the requested steps. She urged the Council to record separately the date an application was submitted, any request for additional information, and the date a decision was communicated. The Chair noted that such detail could help distinguish delay in processing from delay caused by an incomplete application.

3. Mr. Rafael Nascimento, a member from Recife, Brazil, focused on repeated requests for information through different channels. He considered that a process could be formally digital while still imposing substantial coordination costs if applicants had to resubmit documents or seek updates from separate offices. He supported examining a one-stop process, but said that the evidence should identify whether duplication arose from the design of the system, inconsistent instructions or an individual case. The Chair recorded the point as relevant to both consistency and corroboration.

4. Ms. Amina Yusuf, a member from Kaduna, Nigeria, spoke about the importance of clear notice when an application is delayed or refused. In her view, a published service time would be useful only if applicants could see when the clock began, what events paused it and what explanation followed when the time was exceeded. She asked that future evidence prompts invite members to describe the information they received, without asking them to disclose private documents or identify individual officials. The Chair agreed that evidence collection should be proportionate and protect members’ anonymity.

5. Mr. Daniel Okafor, a member from Accra, Ghana, raised the proposed idea of a deadline after which silence could count as consent. He considered that a default deadline might prevent applications from remaining unresolved indefinitely, but cautioned that automatic approval could be inappropriate where public safety, environmental protection or the rights of other parties were involved. He proposed that the Council examine whether the remedy should instead require a reasoned decision or escalation when the published time expires, and whether any exceptions would need to be narrow and transparent. No wording was agreed.

6. Ms. Thảo Nguyễn, a member from Da Nang, Viet Nam, emphasized that a one-stop digital process should not become a barrier for applicants with limited connectivity, language access or ability to use a particular digital system. She asked members to report whether an offline route existed and whether the same service time applied to it. The Chair observed that the proposed standard would need to assess access as well as the number of online steps. Members did not conclude that one delivery channel would be suitable for every authority or jurisdiction.

7. Mr. Samuel Clarke, a member from Kingston, Jamaica, supported measuring service times in terms that an applicant could verify. He suggested that a published figure should state whether it was a target or an observed average and should explain how exceptions were counted. Without those distinctions, he said, publication might create an appearance of certainty without enabling comparison. The Chair noted that the Council had not selected a measurement method and that the suggestion should be tested against evidence from different permit processes.

8. Ms. Elena Petrova, a member from Plovdiv, Bulgaria, asked that the proposed small-business impact test be usable before a new rule or procedure took effect, rather than only after businesses had experienced its effects. She considered that a test should ask who would bear administrative costs, whether a smaller applicant could comply without specialist help, and whether transition time was adequate. The Chair said that these were design questions for the evidence and any later draft, not findings already established by the Council. Members were encouraged to provide cases that could be assessed without naming a business or authority.

9. The Council considered the five elements of its pattern test: Volume, Frequency, Consistency, Spread and Corroboration. Members distinguished the number of reports from the breadth of the underlying experience; a report count alone could not establish that a practice was common. Frequency would require attention to recurrence over time, while consistency would require comparison of the reported circumstances. Spread would consider whether similar accounts arose in different places or types of process, and corroboration would consider supporting detail or independent evidence. The Chair reminded participants that the test was intended to discipline the Council’s assessment, not to turn incomplete data into a claim of certainty.

10. In discussion of the World Bank’s B-READY 2025 findings, the Chair referred to the assessment’s coverage of 101 economies and its reported average of about 60 per cent for business readiness. The findings also indicated that public-services scores were about 23 per cent below regulatory-framework scores.¹ Members considered the distinction relevant to RT-001: a rule may be clear on paper while the service used to carry it out remains difficult to navigate. They agreed that the World Bank figures were contextual evidence and did not establish the performance of any particular permit process. The Chair noted the Council’s 13 May letter offering the Days to Open survey and said that any use of that work should preserve this distinction.

11. Members discussed the proposed Days to Open index and Permit Timer as evidence-gathering tools. The index could make it easier to compare the time required to complete defined steps in different cities, while the Permit Timer could help applicants record milestones and delays in a consistent way. Participants cautioned that neither tool should imply that different permits were directly comparable without a clear description of the process measured. They also asked that participation be voluntary and that published results avoid identifying individual members or disclosing sensitive application details.

12. On the wording of RT-001, the Chair restated the four elements under examination: a small-business impact test for new rules affecting businesses; a one-stop digital process; published service times; and a deadline for permit decisions, described in the agenda as silence is consent. Members discussed these as proposals for a possible standard, not as obligations already in force. The discussion identified unresolved questions about scope, accessibility, time measurement, notice, exceptions and remedies when a service time is missed. No draft text was authorized, and no member was asked to treat the four elements as settled.

13. On the pattern test, the Council made no finding that RT-001 had passed or failed. The evidence snapshot was acknowledged, and members agreed that it should be read with the limits identified in the discussion. The Council also made no decision to begin public consultation, submit a standard to the Assembly or send adoption letters to any chief executive. Those steps would follow only if the relevant evidence review, drafting, consultation and Assembly procedures were completed.

14. The Chair summarized the procedural position: the immediate work remained evidence review and clarification of the proposed remedy. Members were asked to continue submitting accounts that identify the kind of permit, the steps and dates involved, the information supplied by the relevant process, and any outcome known to the applicant. They were reminded not to include the name of their own business in public-facing material and not to identify an authority or individual in a manner that could turn a description of a practice into an unsupported accusation.

Conclusions and action items

1. The Council recorded the evidence snapshot and the limits on interpreting it. It agreed that reported counts should be presented with their date, source and scope; that country totals should not be presented as rankings of permit performance; and that the five-part pattern test should remain open until the evidence had been assessed. These points were procedural guidance for the continuing review and did not constitute adoption of a standard.

2. The following actions were assigned:

   • Secretariat: retain the 22 May evidence snapshot as a dated internal record and ensure that any subsequent summary distinguishes Council membership from session attendance and submissions from population-level estimates.

   • Red Tape Council members: provide further permit accounts, where available, with dates and process stages sufficient to assess frequency and consistency, while omitting business names and unnecessary personal information.

   • Chair, Edna Assunção: coordinate the next review of the five pattern-test elements and identify what evidence remains necessary before the Council can make a finding.

   • Secretariat: continue development of the Days to Open and Permit Timer evidence work, including clear definitions of the process measured, treatment of exceptions and safeguards for member anonymity.

   • Chair and Secretariat: carry forward the questions raised about the small-business impact test, service-time measurement, accessible routes and the meaning of a missed deadline. No drafting instruction on the silence-is-consent proposal was issued.

3. The next Red Tape Council session was scheduled for June 2026, in keeping with the monthly Open Table cycle. Its exact date was not fixed in this record. The agenda would include a further evidence review and consideration of whether the material was sufficient for a formal pattern-test determination.

4. There being no further business recorded, the Chair closed the sittings. This summary record does not report a vote, adoption of a policy, or a finding beyond the procedural conclusions stated above.

Source

1. World Bank, B-READY 2025 report. ¹

Notes and sources

Sources

1. World Bank, B-READY 2025 report