Who Needs RIA: The Strategic Use of Regulatory Impact Analysis

Published: 22 August 2026| Version 2 | DOI: 10.17632/zxc9d39bzp.2
Contributors:
Erico Santos, Carlos Pereira

Description

This dataset contains the main data supporting the conclusions in the paper Who Needs RIA: The Strategic Use of Regulatory Impact Analysis. It consists of the data gathered in archival research (RIAs and contacts) and data generated in two surveys. Tentative abstract for the paper follows: Regulatory Impact Analysis (RIA) is commonly understood as a procedural instrument through which elected officials constrain bureaucratic discretion by requiring regulatory decisions to be supported by technical evidence. This article advances a different interpretation. We argue that once procedural requirements become embedded within organizations populated by specialized career bureaucrats, they become institutional resources through which bureaucrats construct epistemic authority and strategically influence policy outcomes. Rather than eliminating bureaucratic politics, procedural reforms may relocate political conflict from formal decision-making arenas to the production and communication of technical expertise. We examine this argument through a mixed-methods study of Brazil's eleven federal regulatory agencies, combining an original database of 552 Regulatory Impact Analyses, two surveys of bureaucrats responsible for preparing these analyses, and a preregistered survey experiment. The evidence shows that bureaucrats perceive RIAs as increasing the political costs of disregarding technical recommendations and become significantly more willing to employ procedural strategies when political appointees threaten the agency's institutional mission. Rather than openly confronting political authorities, however, bureaucrats overwhelmingly rely on procedural actions embedded within ordinary administrative routines. These findings demonstrate that procedural institutions simultaneously constrain and empower bureaucracy by transforming expertise into a politically consequential institutional resource. Procedural institutions simultaneously constrain and empower bureaucracy by transforming expertise into epistemic authority.

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Institutions

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Survey, Database

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