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Red Tape Council
A clock that belongs to the public: October letter to Red Tape Council members
RC/RT/2026/CL.9 · 27 October 2026
Dear members,
This month, Red Tape moved from describing a recurring frustration to asking what the evidence can support. That is progress, but it is not a verdict on every permit office or every rule. Our interim review says that permit and licensing delays have met three of the five parts of our pattern test. We have work still to do.
I want to be direct about what that result means. It is enough to continue examining the problem and developing a response. It is not enough to say that every delay has the same cause, or that one remedy will fit every place. The distinction matters. Small businesses need reform that is grounded in repeated experience, not a slogan that travels faster than the evidence.
What moved in October
On 20 October, TR-001 passed three of the five tests: Volume, Frequency, Consistency, Spread and Corroboration. The interim pattern review, RC/RT/2026/N.1, had already set out that result on 29 September. On 23 October, we wrote to members about it in RC/RT/2026/25. I am grateful to everyone who has taken the time to read the result carefully and ask what it does—and does not—tell us.
The issue before us is the Small Business Impact Standard. Its proposed direction is that new rules affecting businesses should include a small-business impact test, that government services should offer a one-stop digital process, that service times should be published, and that permits
should have a clear deadline, including a carefully designed “silence is consent” mechanism. These are proposals to examine, not adopted standards. TR-001 passed the pattern test on 20 October; we have not drafted a council standard or put one to the Assembly.
Two other Assembly processes now set the pace for the weeks ahead. The Fair Play Council’s CF-001 adoption ballot opened on 26 October and runs through 9 November. The Fair Play Council’s work is separate from ours, but it is a live case of the process moving from consultation to a member decision. The Platform Council’s FP-001 consultation, which opened on 13 October, runs through 12 November. Our own contribution is to keep building a disciplined record on permits and administrative processes.
The numbers we have
As of 27 October, the Red Tape Council has 123 members in 41 countries. Members have filed 307 Red Tape reports, from 47 countries. The median amount at stake in those reports is approximately US$4,352. Thirty-eight reports were filed in the last 30 days. In the situation data, all 307 reports concern permits. These figures describe the reports we have received; they should not be mistaken for a census of every small business or every permit system.
The reports come from a broad range of places. The largest country totals are the United States with 48, India with 27, Brazil with 25, Canada with 17, the United Kingdom with 16, Nigeria with 15, Italy with 15 and Germany with 10. The team-size profile also keeps our focus clear: 39% of reporting businesses are just one person, and another 39% have two to nine people. Seventeen percent have 10–49 people, and 5% have 50–249. A delay that might be absorbed by a large organization can consume the time, cash and attention of a very small one.
Across Reseated, there are 1,786 members in 49 countries and 5,436 reports filed from 50 countries. Those figures are a reminder that the council is part of a larger effort: to make repeated business
experience legible, compare it carefully, and turn it into proposals that decision-makers can assess.
One account, and what it shows
One member described applying for a local operating permit after finding premises for a small service business. The application was submitted online, but the applicant could not see which department held it, what step remained, or when an answer was due. A request for an update produced another request for documents already supplied. The member made repeated calls and visits while trying to keep the planned opening date from slipping. I am leaving out the business, location and identifying details because the member’s anonymity comes first.
The point is not that one account proves a general pattern. It does not. The point is that the account tells us what a useful record must capture: when an application was complete, what the published service time said, what actually happened, whether the same information was requested twice, and what the delay cost in time or money. Without those details, “the process was slow” is difficult to compare. With them, we can test whether similar problems recur across places and permit types.
It also explains why our proposals must be practical. A one-stop process should mean that an applicant can follow the case and submit information once—not simply that several separate forms have been placed on one website. A published service time should be measurable. And any silence-is-consent deadline would need clear limits, safeguards and a defined start date for the clock. Otherwise, a new rule could create uncertainty instead of reducing it.
What we learned
Our campaigns—the Days to Open index, covering 30 cities, and the Permit Timer—are ways to improve what we can compare. The World Bank’s B-READY 2025 report covers 101 economies. It finds an average business-readiness score of about 60%, while public-services scores are
approximately 23% below regulatory-framework scores.1 That comparison reinforces a question relevant to our work: a rule may be clearly written, yet the service needed to use it may still be difficult to navigate. It does not, by itself, prove our permit-delay pattern. Our evidence must do that work.
We have also learned that counting reports is only the beginning. The five-part test asks whether a problem has meaningful volume, recurs with frequency, appears consistently, spreads across settings and has corroboration. Three tests met means three tests met. We will not fill the remaining gaps with assumptions. Members can help by sharing dated records, keeping copies of requests and responses, and distinguishing a permit delay from a problem caused by an incomplete application or a separate approval.
What comes next
Through 9 November: the CF-001 adoption ballot is open to Assembly members.
Through 12 November: the FP-001 consultation is open. Members may review the draft and submit comments through the consultation process.
17 November: letters are scheduled to be sent to the proposed Wave 2 CEO seats. This is an Assembly-wide step, not a Red Tape Council decision.
For Red Tape: we will continue the Days to Open and Permit Timer work, review incoming evidence against all five tests, and report honestly on what the record supports before advancing a draft standard.
Thank you to Ana in Recife, Musa in Lagos, Priya in Pune, Daniel in Toronto and Marta in Milan for contributing to this month’s work and helping keep the conversation concrete. Thank you as well to every member who filed a report, checked a detail, or asked us to slow down and be more precise. The care you bring to the evidence makes the council more useful.
We are not asking for patience with delay. We are asking for patience with a process designed to make the case for change strong enough to be acted on. A permit clock should not be invisible to the person waiting for an answer. Our job is to establish what is happening, show where it repeats, and propose a fix that can be judged in public.
With thanks,
Edna AssunçãoChair, Red Tape CouncilSão Paulo, Brazil