Working Group Meeting “Statistics on Living Conditions” 12-13 June 2018

EUROPEAN COMMISSION EUROSTAT

Directorate F: Social statistics Unit F-4: Income and living conditions; Quality of life

LC/211/18/EN

Working Group meeting “Statistics on Living Conditions”

12-13 June 2018

Eurostat-Luxembourg

3.2 SILC implementing regulation

Commission européenne, 2920 Luxembourg, LUXEMBOURG - Tel. +352 43011 http://ec.europa.eu/eurostat

1. INTRODUCTION Folowing the WG meeting in November 2017, comments were received regarding all the elements of the SILC regulation. Those comments are provided in the last part of to this document.

As a reminder, the SILC implementing regulation will be accompanied by 4 annexes:

Annex 1-definitions

Annex 2-list of variables

Annex 3-quality reports

Annex 4- technical aspects of the fieldwork

The discussion on list of variables (Annex 2 of the SILC Regulation) takes place stepwise. This discussion covers list of variables for the nucleus, answer modalities; classification into topics and subtopics-also variables on rolling modules that are not yet finalised; flags and is presented in a separated points 3.2c and 3.2e of the agenda. In addition variables that are not allowed to be asked by proxies will be defined in the Annex 2 following the discussions in the point 3.2d of the meeting agenda.

Annex 3 on quality reports was already presented in relation to the SILC in 2017 and will be discussed once cross surveys draft regulation on quality reporting will be made available (most probably towards the end of this year), so that the SILC specific element can be identified and incorporated in the Annex 3 of the SILC regulation.

The revised body text of the SILC Regulation as well as Annex 1 and 4 are presented in this document. In the section: COMMENTS RECEIVED ON THE REGULATION FOLLOWING THE SILC WG MEETING IN NOVEMBER 2017 all the comments received are presented below the article they refer to.

1.1. Tracing rules At the WG meeting in June 2017 modifications in the text of the implementing regulation were proposed to allow reconciliation of differences in the conditions for tracing rules between sample designs based on persons and households, as EU-SILC tracing rules are implemented differently in countries applying Selected Respondent Model (SRM) and Complete Household Model (CHM). That proposal caused discussion and controversies and since then, the discussion on the tracing rules concentrated on the issues related to the Selected Respondent Model. Elements of that discussion were the two consultations with the SRM countries on the possibility of collecting the extra data needed from split-off households available from registers and on topics for further work and possible studies related to tracing rules. The results of the consultation are available in the TF SILC document LC-LEGAL 02-18 Tracing rules (available here: https://circabc.europa.eu/w/browse/4ae97561-8aa4-435d-8a69-501ecd653a8f ). Proposals for possible ways for improvement of the situation of income estimates received during the consultations were for instance:

 increasing sample size,  more efficient sampling (stratification),  weighting and calibration or developing methods for imputing data not available from registers. Moreover, as the degree of successful implementation of the of tracing rules is different between the countries using Complete Household Model (CHM), the elements proposed for consideration are of the relevance for more countries. Therefore, the topic will be discussed during the SILC workshop this year and is covered by the 2018 SILC grant action. All that to improve the way of following the tracing rules as recommended by the SILC WG in June 2017 by:  Preparation of practical guidelines on implementation of tracing rules including recommendations on procedures for minimising non‑response and attrition (with possible more focus on specific sample groups);  Establishing more rigorous monitoring of implementation of tracing rules (quality reports) including a revision of list of data collected on traced persons;  Considering ways of post-correcting of attrition bias, for example harmonised approach in creating weights;  Further support of exchange of information between NSIs and other experts (for example by means of workshops). The text of the Regulation in relation to the tracing rules presented in this document is therefore aiming to maintain the situation as it is defined in the old regulation. However the countries are invited to follow the improvement work. Further proposals on how the text should look like in the new SILC act will be presented following works to be covered by grants.

2. MAIN TEXT OF THE REGULATION

In this section the revised text of the Regulation is proposed whenever convenient in track changes and commented if necessary.

The WG members are requested to reflect on the proposal.

Article 1

Aim 1. The aim of this Regulation is to implement in the domain of income and living conditions the provisions of the article 6, 7 and 12 of the Regulation of the European Parliament and of the Council Deleted: 11 establishing a common framework for the production of European statistics relating to persons and households, based on data at individual level. Estat comment: The Article 11 of IESS refers to sampling frame. This is not followed up in the SILC Regulation, the reference is therefore deleted

Article 2

Definitions

For the purpose of this Regulation, the following definitions shall apply:

(a) ‘year of data collection’: means the year in which the data is collected;

(b) ‘fieldwork period’: means the period of time in which the data collection from respondents is conducted;

(d) ‘private household’: means add the reference to IESS or cross domain act;

(e) ‘cross-sectional data’: means the data pertaining to a given time or a certain time period; Comment [LA(1]: to be coherent with (f) ‘longitudinal data’: means the data pertaining to given subsequent reference periods, observed the definition of cross sectional data yearly over certain duration; Deleted: to individual or household level characteristics (g) 'initial sample': refers to the sample of households or persons at the time it is selected for Deleted: inclusion in EU-SILC; Deleted: over Deleted: time (h) 'achieved sample' means the sample that was successfully interviewed and the interview is accepted for the database;

(h') 'age' refers to the age at the end of the income reference period;

(i) 'sample persons' means members of the household in the initial sample aged at least 16 years minus half of duration of a panel (if applicable rounded upwards);

(j) 'sample households' means a household containing at least one sample person; Comment [LA(2]: Moved to the (k) ‘selected respondent model' means a particular way of sampling that is based on individuals Article 4. (aged at least 16 years minus half of duration of a panel -if applicable rounded upwards). The Deleted: A sample household shall be household to which the selected respondent belongs is the sample household. included in EU-SILC for the collection or compilation of detailed information when it contains at least one sample person (l) 'current household members' means current members of the sample household at the time of aged 16 or more; data collection or compilation; Deleted: ¶ Deleted: the (m) 'co-residents' all current members of a sample household other than those defined above as Comment [LA(3]: moved to the article sample persons; 3 Deleted: In this model only selected (n) ‘household split’: Sample household from wave x is said to have been ‘split’ if its sample persons respondents are subject to collection of from wave x reside at the time of wave x+1 in more than one private household within the national data by interview at individual level; territories included in the target population; when a household split occurs, there will be one and Deleted: residents only one initial household and one or more split-off household,

(o) 'initial households': If any sample person of the wave x still lives at the same address as the previous wave, then his/her household shall be defined as the ‘initial’ household. If no sample person lives at the address of the previous wave, then the household of the sample person who had the lowest person number for the previous wave shall be the initial household. Where this person is no longer alive or no longer in a private household within the national territory of the target population, the initial household shall be the household of the sample person with the next lowest person number.; Deleted: When a split has occurred, one (and only one) of the resulting households For the selected respondents model initial household means the household of the selected shall be defined as the ‘initial’ household respondent.

(p) 'split-off households': One or more households after household split that are not initial household are called ‘split-off’ households;

Deleted: S (q) 'fusion': All sample persons from different sample households from the previous wave join together to form a new household;

(r) 'imputation': refers to the generation of information, when it was missing, on the basis of statistical relationships which are mainly internal to the data set;

(s) 'modelling': refers to the generation of information, when it was missing, that makes use of substantive relationships and information external to the data set;

(t) 'collection unit': is the household or individual of certain characteristics to whom the collected information refers to;

(u) ‘substitution’ refers to replacement in the first wave by other units of the original units selected in the sample which do not supply the required information, either because the address cannot be located or is inaccessible, or because the household refuses to cooperate, the entire household is temporarily away or the household is unable to respond.

Estat: The text was edited following the comments received. Information related to the population being subject of data collection or to interview was moved from the Article 4. Most comments received on the Article 2 were related to the definition of sample person and sample household which also connected to the tracing rules defined in the Article 8. To remind, the rules described in the doc 65. are currently following: Children aged under 14 will not be traced if they move to a new household containing no sample person aged 14+. In this sense, they are not considered ‘sample persons’. Sample persons aged 14+ will be normally traced.

Detailed interviews will be conducted with those persons aged 16+, and in the case a sample of complete households is used, with all persons aged 16+ (whether sample persons or co-residents) in the household.

Sample persons aged 14+ who have moved to another private household within the country are traced to the new location. Those aged 16+ are interviewed.

Strictly, the reference here is to the territory of the country included in the target population. Those moving to certain small and specified excluded areas are dropped from the survey, as are persons moving out of the country.

Sample persons aged 14+ who reside temporarily in a collective household or institution but who are still considered as members of a private household are traced and, if aged 16+, are to be interviewed by proxy.

However, sample persons aged 14+ who have moved to a collective household, are institutionalised or moved abroad on a permanent or indefinite basis, for an actual or intended duration of twelve months or more, or for a short stay but who cannot be considered a member of any private household, are dropped from the survey. (In such cases, the following information should be recorded from someone who was a member of the person’s household at the previous wave: to where did the person move, date of movement, number of months spent in the household during the income reference period and main activity status during the income reference period). For sample persons who died, no information other than date of death, number of months spent in the household during the income reference period and main activity status during the income reference period will be collected. For sample persons aged 14+ who have not been contacted in the previous wave because of the impossibility to access the address (for atmospheric reasons) or because the whole household was temporary absent or unable to respond (illness, incapacitated,…) or for other reasons, a new contact will be attempted in the present wave. If the sample person has not been contacted the first year or two consecutive years due to the reasons mentioned above, the sample person may be dropped from the survey. Deleted: Sample persons aged 14+ will also be dropped if they have not been contacted because of the theyhave impossibility to locate the address or because the address was non-residential or unoccupied, lost (no information on what happened to the survey) and who (or whose household) refused to cooperate. Co-residents are included in EU-SILC as long as they continue to live with a sample person. Personal information is required, using normal procedures, if aged 16+. However, co-residents are not traced if they move to a household that does not contain a sample person (aged 14+). For former residents (‘‘the former household members’’), who spent at least three months in the household during the income reference period, the following information will be required (only initial households): number of months spent in the household during the income reference period and main activity status during the income reference period. The age cut-off of 14 years will be lowered if panels of duration longer than four years are used. Persons of all ages in the initial sample (including children born to sample women) should be treated as sample persons to be followed-up in panels of duration exceeding eight years. The age refers to the age that person is in the first wave of each panel.

Article 3

List and description of variables

1. Definitions of statistical concepts laid down in Annex 1 shall be used by the Member-States for the data collection. Deleted: and 2. The list of variables to be covered every year together with their codification, and reference period Deleted: characteristics and the characteristics of the population their concern is laid down in Annex 2 of the regulation.

3. The variables that shall be imputed or cannot be asked by proxies are identified in the Annex 2.

4. All household and personal data shall be linkable over the whole duration of the panel.

5. Member States shall transmit the data in electronic form, in conformity with an appropriate technical format as described in the Annex 2.

Article 4

Statistical populations, observation unit and mode of collection Deleted: aged 16 and over (at the end of 1. The statistical population shall pertain to private households and all persons composing the income reference period), household.

2. Individual level information is collected for all the sample persons aged 16 and more. In the selected respondent model only selected respondents aged 16 and more are subject to collection of data by interview at individual level.

Where a sample person is in the survey for more than one year, information shall be obtained on whether that person remained at the same address or moved to a different address from one year to the next.

3. A sample household shall be included in EU-SILC for the collection or compilation of detailed information when it contains at least one sample person aged 16 or more. Deleted: full 4. The information required at the household level and at the individual level for current household members, and the information on household members in the previous wave that are no longer Deleted: basic household members as well as mode of collection is set out in Annex 2.

5. In the initial household, the full information required for current household members and the full household level information as well as technical items, demography and main activity status Deleted: and the basic information on household members in the previous wave that are no longer household members shall be collected.

Basic information on household members in the previous wave that are no longer household members shall be collected in order to establish if the person is deceased, moved abroad or moved to a different address within the national territory.

6. In the split-off household, only the full information required for current household members and the full household level information shall be collected.

7. The proxy rate, where proxy is allowed, shall be kept as limited as possible for the income personal variables and for any variables required for at least one household member aged 16 or more. Deleted: In the case that a proxy interview is carried out, the identification of the person who has provided number the information must be recorded.

Estat:

The article was redrafted in order to identify the observation units of various situations and in relation to changes of the sample household composition. Some of the elements that were so far in the Annex 4 were incorporated here. The reference to persons aged 16 and more in par. 1 statistical population was removed to allow collection of the information on children in the household data (in particular on childcare, children deprivation and health).

Information to be collected from non-current household members is for now defined based on the subtopics.

Article 5

Reference periods and dates

1. The income reference period shall be a 12-month period, such as previous calendar or tax year.

Article 6

Sample characteristics

1. Only Member States that are using selected respondent model in the first year of implementation of this regulation are authorised to continue using the method in the following years. Deleted: Countries that can use the 2. In the first year of each panel controlled substitutions may be allowed only where the response selected respondent model are: Denmark, Finland, Sweden, Slovenia, Netherlands, rate falls below 60 % and one of the following situations arises: Norway, and Iceland. ¶

— address non-contacted because it cannot be located or is inaccessible,

— address contacted but interview not completed because the household refuses to cooperate, the whole household is temporarily away or the household is unable to respond.

3. The set for substitution shall be defined prior to data collection.

4. Procedures shall be followed to ensure that the process of substitution is controlled to the maximum extent possible. These include the use of a design which ensures that substitutes are selected so as to match the substituted units closely for important characteristics. The substitutions shall be allowed only after special efforts have been made to convince refusals, and properly scheduled call-backs have been made to other no respondents.

5. A household shall not be substituted by another non-sample household at the same address not belonging to the set of households for substitution.

6. Small parts of the national territory amounting to no more than 2 % of the national population and the national territories identified in Table 1 may be excluded from EU-SILC, after agreement of the Deleted: listed Commission (Eurostat). Deleted: between the Member States concerned and TABLE 1 Country Territories France French Overseas Departments and territories Ireland All offshore islands with the exception of Achill, Bull, Cruit, Gorumna, Inishnee, Lettermore, Lettermullan and Valentia Croatia All islands with the exception Krk, Pag, Murter, Čiovo and Vir

Estat

The countries using selected respondent model are listed as this method is considered not optimal for SILC and any possible changes towards this model will need to be followed by the Commission.

Only countries that are using selected respondent model in the first year of implementation of the IESS are authorised to continue using the method in the following years.

Article 7

Technical aspects of the fieldwork

1. For the data directly provided by the respondents, fieldwork period shall be as close as possible to the income reference period so as to minimise time lag between income and current variables.

2. The collection or compilation of data, for a given unit (household or person), between successive waves shall be kept as close as possible to 12 months.

3. Each Member State shall follow appropriate procedures to maximise the response rates achieved. At least three attempts to contact shall be made before a household or individual is accepted as non- Deleted: call-backs responding, unless there are conclusive reasons (such as a definite refusal to cooperate, circumstances endangering the safety of the interviewer, etc.) why this cannot be done. Deleted: and information to be collected 4. Details about identification of households and persons are defined in the Annex 4. in case of change of the household composition 5. The data directly provided by the respondents shall be collected by computer-assisted methods. Exceptions shall be duly justified.

Article 8

Rules for the follow-up

1. Sample persons, co-residents and sample households shall be followed over the duration of the panel in accordance to the rules in the Table 2.

TABLE 2

Sample persons To be

Moving to a private household within the national territory Followed to the new covered in the survey location of the household

Other persons temporarily away but who are still considered as Covered in the members of the household household they belong to

Persons no longer members of a private household, or those who Dropped from the survey have moved outside the national territory covered in the survey

Co-residents To be

Living in a household containing at least one sample person Followed

Living in a household not containing any sample person Dropped

Sample households To be

Non-enumerated a single year due to the impossibility of locating Dropped the address, the address being non-residential or unoccupied, lost (no information on what happened to the household), or the household refusing to co-operate

Non-contacted the first year of the panel or non contacted two Dropped consecutive years due to the impossibility of accessing the address, because the whole household is temporarily away or is unable to respond due to incapacity or illness or for other serious reasons

Estat:

If necessary the text of this article will be updated following the results of work granted in the 2018 SILC action and exchanges of experiences and proposals for improvements in the countries.

Article 9

Data editing, imputation and estimation

1. Imputation and modelling (which may be used in combination) could be applied to the data.

2. The procedure applied to the data should preserve variation of and correlation between variables. Methods that incorporate ‘error components’ into the imputed values shall be preferable to those that simply impute a predicted value.

3. Methods which take into account the correlation structure (or other characteristics of the joint distribution of the variables) shall be preferable to the marginal or univariate approach.

Article 10

Standards for transmission and exchange of information

1. Member States shall transmit to the Commission (Eurostat) in the form of micro-data files data (including appropriate weights) which has been fully checked and edited, using the statistical data and metadata exchange standard. The data shall be provided to Eurostat through the single entry point to allow the Commission (Eurostat) to retrieve the data by electronic means.

Article 11

Quality reporting

1. Quality evaluation criteria and the detailed content of the quality report to be produced by Member States shall be as laid down in Annex 3.

3. ANNEX 1-DEFINITIONS Following the suggestions of the TF in SILC revision in 2016 it was proposed to the WG to cover in the variable PY030G only compulsory contributions and abandon collecting variable PY031 Optional employer's social insurance contributions. However the definition proposed in the Annex 1 was the following:

1.1.1. Employers' social insurance mandatory (PY030G) Deleted: /legal contributions Employers' contributions are defined as payments made, during the income reference period, by employers for the benefits of their employees to insurers (social security funds and private funded schemes) covering statutory, conventional or contractual contributions in respect of insurance against social risks. They cover traditionally legal old age pension schemes, legal health insurance, unemployment. These contributions are common to most employed persons and can be deduced from wages received according to published rules; The variable includes:

— employers' contributions to private retirement (pension) plans,

— employers' contributions to private health insurance,

— employers' contributions to life insurance,

— employers' contributions to other employer insurance schemes (e.g. disability),

— employers' contributions to government insurance (social security) schemes (including payroll taxes levied for social insurance purposes).

As the definition covers contribution to the private insurance schemes, that could be either mandatory (e.g. II pension insurance pillar that in some countries could be either public or private), statutory (e.g. private health or pension insurance offered traditionally or based on the social agreement by all the employers in certain sectors) or voluntary (up to decision of individual employer); the real coverage of the variable is not clear.

Given the fact that for instance statutory or conventional contributions specific to certain sectors may not be possible to be collected as a separate information to be deduced from the variable PY030 in case it should cover exclusively compulsory government insurance those contributions to private system may be covered by the variable. Therefore, in order to clarify this, the following changes are proposed to the definition of the variable:

Employers' contributions are defined as payments made, during the income reference period, by employers for the benefits of their employees to insurers (social security funds and private funded schemes) covering statutory, conventional or contractual contributions in respect of insurance against social risks. They cover traditionally legal old age pension schemes, legal health insurance, unemployment. These contributions

11 are common to most employed persons and can be deduced from wages received according to published rules; The variable includes:

— employers' contributions to government insurance (social security) schemes (including payroll taxes levied for social insurance purposes).

— employers' contributions to private retirement (pension) plans, that are element of defined insurance system in a country (e.g. II pension insurance pillar),

— statutory employers' contributions to other private retirement (pension) plans,

— statutory or conventional employers' contributions to private health insurance,

— statutory or conventional employers' contributions to life insurance,

— statutory or conventional employers' contributions to other employer insurance schemes (e.g. disability),

The variable does not include contributions that are voluntary to the employer.

To mirror the changes in the variable PY030, the following changes to the variable PY080 are proposed:

Pensions received from individual optional plans (other than those covered under ESSPROS) Deleted: private (PY080). Regular pensions from private plans (other than those covered under ESSPROS) refer to pensions and annuities received, during the income reference period, in the form of interest or dividend income from individual private insurance plans, i.e. fully organised schemes where contributions are at the discretion of the contributor independently of their employers or government. It includes: Old age, survivors, sickness, disability and unemployment pensions received as interest or dividends from individual insurance private plans. It excludes: Pensions from mandatory government schemes; Pensions from mandatory, conventional or statutory employer-based schemes.

4. ANNEX 4- CODIFICATION OF HOUSEHOLD AND PERSONS Following movement of the types of information to be collected in case of change of the household composition to the article 4 the regulation the ANNEX 4 refers now only to the codification of households and persons.

Household number

1. The household identification number (ID) is composed of the household number and the split number. The household number is a sequential number. The split number for the first wave shall always take the value ‘00’.

2. In the case of a split-off, the initial household shall keep the household number and split number from one wave to the next. The split-off household(s) shall keep the same household number, but shall be assigned the next available unique split number in sequence.

3. In the case of a fusion of two sample households, if the new household is still at the previous address, it shall retain the household number and split number of the household that was at that address in the previous wave. If the new household is at a new address, the household number and split number of the household of the sample person who now has the lowest person number shall be used.

Personal number

1. The personal identification number is composed of the household ID and the person number.

2. The person number for any new person in the household shall be constructed by adding 1 to the highest person number used, for all the years of the survey and the household ID.

3. The household ID shall be the household identification number of the household where the person first appears in the panel.

4. The personal ID shall remain fixed over the length of time the person is in the survey. Deleted: 2. INFORMATION TO BE COLLECTED ¶ 1. In the initial and split-off household, the full information required for current household members as well as Further work membership status for previous wave household members and the household level information shall be collected. ¶ The regulation text is a draft that follows the internally agreed structure which will be applied to 2. In case of selected respondent model, for the split off-household, only the all social surveys specific Implementing Regulations, however it will be consulted with the legal information coming from registers shall be services of the Commission and further modifications may be needed. collected.¶ 3. Where a sample person is in the survey for more than one year, information shall Annex 1. Depending on the discussions on definition of the household that is planned to be in be obtained on whether that person remained at the same address or moved the cross surveys Regulation and the level of details on treating borderline cases, some more to a different address from one year to the SILC specific elements of the household member definition may be needed in the Annex 1. next.¶

Moreover, following the discussion on the variables PY030 and PY080 further modifications to the Annex 1 will be made.

Annex 2. Work on finalising the list of variables to be included in the first wave and yearly data collection takes place now and the subject is discussed under points 3.2b-e, of the agenda.

Annex 3 will need to be modified following the cross surveys legislation on quality reports once the latter is made available.

COMMENTS RECEIVED ON THE REGULATION FOLLOWING THE SILC WG MEETING IN NOVEMBER 2017

Article 1

Aim

1. The aim of this Regulation is to implement in the domain of income and living conditions the provisions of the article 6, 7, 11 and 12 of the Regulation of the European Parliament and of the Council establishing a common framework for the production of European statistics relating to persons and households, based on data at individual level.

Article 2

Definitions

For the purpose of this Regulation, the following definitions shall apply:

(a) ‘year of data collection’: means the year in which the data is collected;

(b) ‘fieldwork period’: means the period of time in which the data collection from respondents is conducted;

(d) ‘private household’: means add the reference to IESS or cross domain act;

(e) ‘cross-sectional data’: means the data pertaining to a given time or a certain time period;

(f) ‘longitudinal data’: means the data pertaining to individual or household level characteristics over time, observed yearly over certain duration; Change to: PT (f) ‘longitudinal data’: means the data pertaining to individual or household level characteristics over subsequent time periods, observed yearly over certain duration;

(g) 'initial sample': refers to the sample of households or persons at the time it is selected for inclusion in EU-SILC;

(h) 'achieved sample' means the sample that was successfully interviewed and the interview is accepted for the database;

(i) 'sample persons' means members of the household in the initial sample aged at least 16 years minus half of duration of a panel (if applicable rounded upwards);

PL Due to the need of simplifying we proposed to increase age of ‘sample persons’ from “16 years minus the half of duration of longitudinal panel” to 16 years. We do not support tracing children that are 15 or 16 years old (in the second or third wave) .

FI Finland prefers defining ‘sample person’ as it is in currently SILC regulation, i.e. as all or a subset of persons in the initial sample. That is, keeping the tracing rules as they are currently.

In the suggested approach, there is a lower age limit of at least 16 years minus half the duration of a panel SE for sample persons. In our opinion, it is not necessary to specify the lower age limit since some countries, i.e., those using the selected respondent model, may use a different approach. In this case, it is possible to add individuals to the sample in subsequent years from a recently updated sampling frame, which should facilitate better sample coverage compared to the suggested approach. For example, in Sweden we each year update the panels from the previous years by an additional sample of individuals that have become 16 year old during the year and immigrants which have entered the population during the year. Because the additional sample comes from a sampling frame of recent date and because immigrants are included in the additional sample, this facilitates a sample that is representative of the current population. This approach is preferable to the suggested one when applicable, i.e., for Sweden and other selected respondent model countries. Suggestion: PT ‘sample persons’ means all members of the households in the initial sample whose age at the first wave and at the end of the income reference period is greater or equal to 16 years less half the duration of the rotation

(j) 'sample households' means a household containing at least one sample person;

A sample household shall be included in EU-SILC for the collection or compilation of detailed information when it contains at least one sample person aged 16 or more;

BE We understand that a sample person is a member of the initial sample aged at least 16, minus half of the duration of the panel, and that a sample household is a household that contains at least one sample person. However, we do not understand why the next line has been added ‘a sample household shall be included… when in contains at least one sample person aged 16 or more’. If a sample person of 14 years old in wave 1, has a split in wave 2 – we do not have to trace that person in case he/she is the only person in the split, because we will not have a household with a least one sample person aged 16 as he/she is 15 at that time. However, if this same sample person has a split in wave 4, we do have to trace him/her, because he/she is 17 at that time, and the household contains at least one sample person aged 16 or older. If this is not what is meant with the additional sentence, and we only have to trace sample persons aged 16 or older, why bothering with the definition “minus half of the duration of the panel”? If this is not what is meant with the additional sentence, and we have to follow all sample persons, even those younger than 16, what is the implication of this sentence? Additionally, for the moment DB135 has the code ‘accepted’ if there is at least one of the personal interviews is completed. Does this mean that in the future this will be ‘if there is at least one of the personal interviews of a sample person completed’?

IT The inclusion of people below 16 years is useless because if such a sample person moves alone without other sample persons, because of the (j) statement the sample household shall not be included in the EU- Silc collection as it does not contain at least one sample person aged 16 or more. See: (j) 'sample households' means a household containing at least one sample person; A sample household shall be included in EU-SILC for the collection or compilation of detailed information when it contains at least one sample person aged 16 or more;

Proposal:

(i) 'sample persons' means members of the household in the initial sample aged at least 16 years In article 2 the definition of sample household and selected respondent model is not clear. Namely in SI item (i) is written that sample person are aged 16 minus half of duration of panel what means in praxis 14 years. As selected respondent is 16 years old this means for us confusion, because in the case that selected respondent will be 14 or 15 years old in these households nobody will answer to the questions for selected respondent (for example variables about health, ad hoc modules, in some countries even on material deprivation questions). We think that sample person in selected respondent countries must be aged 16, what is more logical. Considering that only households containing a sample person aged at least 16 are to be followed is PT contradictory with the specification of sample persons as those at least 16 less half the duration of the

panel (According to the proposal if a sample person is 14 years old in the 1st wave his/her chance to be followed in the 2nd wave is in fact null and he/she is in fact a co-resident; This leads to a difference vs. the selected respondent model) Correct to: ‘Sample household’ means a household containing at least one sample person.

(k) ‘selected respondent model' means the way of sampling that is based on individuals (aged at least 16 years minus half of duration of a panel -if applicable rounded upwards). The household to which the selected respondent belongs is the sample household. In this model only selected respondents are subject to collection of data by interview at individual level; minor drafting issue, but as the text is written now, it could imply that this applies to sample designs CZ based on individuals and for these sampling units, only selected respondents are subject to data collection -, which is not necessary true, S-R model is only a specific case of sampling designs based on individuals, adding ... means a particular way of sampling ... would perhaps help to make this clearer (that this does not necessarily apply to all samples based on individuals), or some other drafting modification

(l) 'current household members' means current members of the household at the time of data collection or compilation; Change to: PT (l) 'current household members' means current members of the sample households at the time of data collection or compilation;

(m) 'co-residents' all current residents of a sample household other than those defined above as sample persons;

IT We have no need to use the concept of residence

Proposal: (m) 'co-residents' (non-sample persons): all current members of a sample household other than those defined above as sample persons, (m) - for consistency, we recommend to replace "all current residents" with "all current household CZ members"

(n) ‘household split’: Sample household from wave x is said to have been ‘split’ if its sample persons from wave x reside at the time of wave x+1 in more than one private household within the national territories included in the target population;

IT adding at the end “when a household split occurs, there will be one and only one initial household and one or more split-off household” and delete this sentence “When a split has occurred, one (and only one) of the resulting households shall be defined as the ‘initial’ household;” from the (o) statement

(o) 'initial households': If any sample person of the wave x still lives at the same address as the previous wave, then his/her household shall be defined as the ‘initial’ household. If no sample person lives at the address of the previous wave, then the household of the sample person who had the lowest person number for the previous wave shall be the initial household. Where this person is no longer alive or no longer in a private household within the national territory of the target population, the initial household shall be the household of the sample person with the next lowest person number. When a split has occurred, one (and only one) of the resulting households shall be defined as the ‘initial’ household;

For the selected respondents model initial household means the household of the selected respondent.

As several households can live at the same adress, the definition of the initial household has to be FR changed. Indeed, the case of on an household that split off in several households still living at the same addresses is not treated (case of a young adult living with his parents that start working and thrn leave the household without leaving her parents dwelling for example). Here is a proposal :

" (o) 'initial households': If any sample person of the wave x still lives at the same address as the last wave, then the household of the sample person that had the lowest person number for the last wave among the sample persons still living at the same adress shall be the initial household. If no sample person lives at the address of the last wave, then the household of the sample person who had the lowest person number for the last wave shall be the initial household. Where this person is no longer alive or no longer in a private household within the national territory of the target population, the initial household shall be the household of the sample person with the next lowest person number. When a split has occurred, one (and only one) of the resulting households shall be defined as the ‘initial’ household "

Proposal:

Drop the definition or change the name to “Source household”

(p) 'split-off households': One or more households after household split that are not initial household are called ‘split-off’ households; Drop the definition or change to: PT (p) 'split-off households': One or more households after household split that are not a source household are called ‘split-off’ households;

(q) 'fusion': Sample persons from different sample households from the previous wave join together to form a new household; Correct to: PT Fusion: All sample persons from different sample households from the previous wave join together to form a new household.

Note: otherwise it’s a split

(r) 'imputation': refers to the generation of information, when it was missing, on the basis of statistical relationships internal to the data set; Change to: PT (r) 'imputation': refers to the generation of information, when it was missing, on the basis of statistical relationships which are mainly internal to the data set;

(s) 'modelling': makes use of substantive relationships and information external to the data set; Change to: PT (s) 'modelling': refers to the generation of information, when it was missing, that makes use of substantive relationships and information external to the data set;

(t) 'collection unit': is the household or individual of certain characteristics to whom the collected information refers to;

(u) ‘substitution’ refers to replacement by other units of the original units selected in the sample which do not supply the required information, either because the address cannot be located or is inaccessible, or because the household refuses to cooperate, the entire household is temporarily away or the household is unable to respond.

(u) ‘substitution’ refers to replacement in the first wave by other units of the original units selected in the IT sample which do not supply the required information

Article 3

List and description of variables

1. Definitions of statistical concepts laid down in Annex 1 shall be used by the Member-States for the data collection.

2. The list of variables to be covered every year together with their codification and characteristics is laid down in Annex 2 of the regulation.

3. The variables that shall be imputed or cannot be asked by proxies are identified in the Annex 2.

4. All household and personal data shall be linkable over the whole duration of the panel.

5. Member States shall transmit the data in electronic form, in conformity with an appropriate technical format as described in the Annex 2.

Article 4

Statistical populations, observation unit and mode of collection

1. The statistical population shall pertain to private households and all persons aged 16 and over (at the end of income reference period), composing the household. 1. The statistical population shall pertain to private households and all persons aged 16 and over (at the PT end of income reference period), composing the household.

2. The proxy rate, where proxy is allowed, shall be kept as limited as possible for the income personal variables and for any variables required for at least one household member aged 16 or more. In the case that a proxy interview is carried out, the identification number of the person who has provided the information must be recorded.

SE in the regulation and the inclusion of identification number” of proxy person – why is this important? Is this just a technical matter?

3. The collection unit, together with the mode of collection for household and personal information, shall be as laid down in Annex 2.

FI Children aged 15 or less need to be mentioned separately.

Article 5

Reference periods and dates

1. The income reference period shall be a 12-month period, such as previous calendar or tax year.

Article 6

Sample characteristics

1. Countries that can use the selected respondent model are: Denmark, Finland, Sweden, Slovenia, Netherlands, Norway, and Iceland. we would like to suggest defining not so strictly that only Denmark, Sweden, Slovenia, Netherlands and LV Iceland can use selected respondent model. It might be possible that also other countries implement this model.

2. In the first year of each panel controlled substitutions may be allowed only where the response rate falls below 60 % and one of the following situations arises:

— address non-contacted because it cannot be located or is inaccessible,

— address contacted but interview not completed because the household refuses to cooperate, the whole household is temporarily away or the household is unable to respond. Question: where a mixed technique survey is carried out, with very different response rate based on the IT technique, is it meaningful considering the overall response rate? Or could we allow substitutions only for a subsample?

3. The set for substitution shall be defined prior to data collection.

5. A household shall not be substituted by another non-sample household at the same address.

IT It can happen indeed that in the set of households for substitution there could be a household at the same address of the household to be substituted. The aim of the statement is avoiding only that substitutions are made randomly by the interviewer selecting the nearest household, that is one at the same address.

Proposal:

5. A household shall not be substituted by another nonsample household at the same address not belonging to the set of households for substitution

6. Small parts of the national territory amounting to no more than 2 % of the national population and the national territories listed in Table 1 may be excluded from EU-SILC, after agreement between the Member States concerned and the Commission (Eurostat).

TABLE 1 Country Territories France French Overseas Departments and territories Ireland All offshore islands with the exception of Achill, Bull, Cruit, Gorumna, Inishnee, Lettermore, Lettermullan and Valentia Croatia All islands with the exception Krk, Pag, Murter, Čiovo and Vir

FR Article 6 .Why the sub-article 6as not be changed as discussed at the october meeting from "6Small parts of the national territory amounting to no more than 2 % of the national population and the national territories listed in Table 1 may be excluded from EU-SILC, after agreement between the

Member States concerned and the Commission (Eurostat). " to "Small parts of the national territory amounting to no more than 2 % of the national population and the national territories listed in Table 1 may be excluded from EU-SILC".

Article 7

Technical aspects of the fieldwork

1. For the data directly provided by the respondents, fieldwork period shall be as close as possible to the income reference period so as to minimise time lag between income and current variables.

2. The collection or compilation of data, for a given unit (household or person), between successive waves shall be kept as close as possible to 12 months. Addresses are distributed during fieldwork according to interviewers burden, we are not able to ensure LT close to 12 months between successive waves. In practice it is 8- 10 months.

FI What is the purpose of 12 month period between waves? The text suggests that both shorter and longer time gaps are considered undesirable.

LV requirement that collection of data “…between successive waves shall be kept as close as possible to 12 months” is not realistic, considering the fact that several sequential data collection methods are applied – CAWI, CAPI and CATI.

3. Each Member State shall follow appropriate procedures to maximise the response rates achieved. At least three call-backs shall be made before a household or individual is accepted as non- responding, unless there are conclusive reasons (such as a definite refusal to cooperate, circumstances endangering the safety of the interviewer, etc.) why this cannot be done. How is this monitored? Should there be variables concerning number of contacts and reasons for less FI than 3 contacts? What does a call-back mean in a country conducting web surveys?

4. Details about identification of households and persons and information to be collected in case of change of the household composition are defined in the Annex 4.

5. The data directly provided by the respondents shall be collected by computer-assisted methods. Exceptions shall be duly justified.

Article 8

Rules for the follow-up

1. Sample persons, co-residents and sample households shall be followed over the duration of the panel in accordance to the rules in the Table 2.

TABLE 2

Sample persons To be

Moving to a private household within the national territory Followed to the new covered in the survey location of the household

Other persons temporarily away but who are still considered as Covered in the members of the household household they belong to

Persons no longer members of a private household, or those who Dropped from the survey have moved outside the national territory covered in the survey

Co-residents To be

Living in a household containing at least one sample person Followed

Living in a household not containing any sample person Dropped

Sample households To be

FI Article 8, table 2, sample households: Concepts of “non-enumerated” and “non-contacted” should be clarified. This part of text is difficult to interpret because of the way it has been written and we fear it will lead to confusion. In a telephone interview, most “non-contacted” are those who do not answer telephone. We may find in registers that they are still part of reference population but reason for non- contact is unknown. Are these households non-contacts or non-enumerated?

SE as mentioned during the WG meeting we would like to have a separate discussion regarding the SR model and tracing rules. It’s important to keep the representativeness over the panel duration and to have a known likelihood of selection for the selected respondent and hence the household over the whole length of the panel. The text suggested in the current draft would mean that we would have to produce less representative statistics than today – with no obvious benefit.

Article 9

Data editing, imputation and estimation

1. Imputation and modelling (which may be used in combination) could be applied to the data.

3. Methods which take into account the correlation structure (or other characteristics of the joint distribution of the variables) shall be preferable to the marginal or univariate approach.

Article 10

Standards for transmission and exchange of information

Article 11

Quality reporting

1. Quality evaluation criteria and the detailed content of the quality report to be produced by Member States shall be as laid down in Annex 3.

2. Member States shall transmit the quality-related reference metadata required by this Regulation, using the statistical data and metadata exchange standard. The metadata shall be provided to Eurostat through the single entry point to allow the Commission (Eurostat) to retrieve the data by electronic means. depending on the format of the foreseen implementing regulation on quality reporting for all domains, CZ this can perhaps be moved there and replaced by the reference to the general principles in that QR regulation

Other comments:

Country Comment NO We have previously commented on the draft implementing regulation, and refer to that for more detailed comments. We do not agree with the change in the definition of sample persons. The selected respondent should be the sample person in the selected respondent countries. It is better to follow up previous household members with register information than to interview them if a change occurs, as this will reduce the burden. It is nevertheless problematic as the households are different in administrative registers and interviews.

NL Regulation: The Netherlands is one of the counties which uses the selected respondent model. In the regulation which was presented in the WG in November, it is stated that selected respondents countries would deliver household information from registers for the split-off household members. We would like to keep our current design of selected respondent and we cannot deliver information about the split-off households. Further clarification is needed here.

IT Part of implementing act As it is IT Proposal IT Remarks Annex IV – Technical aspects of the fieldworks INFORMATION TO BE COLLECTED 1a. The full information required for current household members and the household level information shall be collected in the first wave. 2a. From the second wave onwards, the full information required for current household members, the basic information on household members in Annex IV – Technical the previous wave that aspects of the fieldworks are no longer household INFORMATION TO BE members and the COLLECTED household level 1. In the initial and split- information shall be off household, the full collected. information required for 2b. From the second current household wave onwards in the members as well as split-off household, only membership status for the full information Annex IV – previous wave required for current Technical aspects household members and household members and of the fieldworks the household level the household level INFORMATION TO information shall be information shall be BE COLLECTED 3. collected. collected

Annex IV – Technical aspects of the fieldworks INFORMATION TO BE COLLECTED 3. Basic information on 3. Where a sample household members in person is in the survey the previous wave that But for all non-current for more than one year, are no longer household household members information shall be members shall be (even if not sample obtained on whether collected in order to persons) information that person remained at estabilish if the person is shall be obtained the same address or decesead, moved whether deceased, moved to a different abroad o moved to a institutionalized, moved address from one year different address within abroad o moved within to the next. the national territory. the national territory.

ES Comments on the Annex 1: Statistical definitions

We think some clarification is needed in the ‘Annex 1 to the Regulation: Statistical definitions’ about the ‘optional employers’ social insurance contributions’, and the pensions that are counterpart to these contributions:

- Variable PY030 ‘Employers' social insurance mandatory/legal contributions’: The name of the variable says ‘mandatory/legal’. Nevertheless in the description of the variable it includes employers’ contributions to private plans, which normally correspond to optional contributions.

- Variable PY080 ‘Pensions received from individual private plans’: In the description of the variable, in the exclusions, it says that ’Pensions from mandatory employer-based schemes’ are excluded. The doubt is whether only ‘mandatory’ are excluded, or all employer-based schemes are excluded.

CZ Annex 4 - household number - we do not see the need that household numbers are necessarily sequential, and we ask to drop this requirement.

Nucleus (doc. 202 / item 3.6)

It should be mentioned that "first wave variables" are also part of the nucleus, and not a distinct category, it is not clear in the current description.

The issue of 3-years and 6-years rotating modules should be reformulated and cross-checked with the IESS regulation. I found the point on the need to align the list of detailed topics in annex I of the IESS with the periodicity of the modules and the content of the nucleus very important, and I think that this should be done without any delay. Any change in the list of detailed topics in the IESS annex should be well communicated and discussed with the Member States - WG ILC, perhaps also for information at the DSS, to avoid any confusion and unnecessary resistance at the Council WP - as any addition to the existing list of detailed topics is a sensitive issue, and could be viewed as increasing burden on the Member States. SI At the WG meeting we have already announced some remarks on the SILC Implementing Regulation with this letter we are going to elaborate more comments and clarifications to the regulation.

As we understand the proposal of regulation and annex 4 we should collect also some data for split-off households. At the beginning (after Task Force meeting in October 2017) we have understood that we will have to collect the data only for split-off households of which part of members remain in the same address, but from annex 4 it comes that it would be necessary to collect the data for all split off household members (also if somebody moves to another address). We understand that we would collect only the data from registers. At the same time, it is questionable quality of the data for split off the households, because it is impossible to compose

25 the right households with all members because register of households have limitations (updating, mistakes) and also different methodological background (data available for the permanent address only). We made analysis for households that remain on the same address and we found out that in 2017 we have approximately 35 such households. This means a lot of time consuming work with collection of these data for relatively small benefit. Additionally it is not clear what Eurostat (and users) would like to do with the data as only data on income for those households will be available. It is not clear what should be weights for persons in these households and also coherence with other SILC outputs could be questionable.

At the beginning the main aim of changing the regulation used to be simplification of data collection, but at the moment we are going into completely different direction. It is necessary to think about timeliness, with more complex rules it would be much more difficult achieve target to achieve timeliness. It is necessary to think if some households with partly data are enough large benefit in comparison with all costs which is made by new tracing rules.