Systems thinking and regulatory governance (5): Epistemic and ethical challenges

We have reached the end of this series of blog posts on systems thinking and its application in regulatory governance scholarship.

If you are tuning in just now, then I strongly recommend reading the earlier posts first: a broad introduction to the series, an exploration of the history of systems thinking, examples of systems thinking in regulatory governance, and evidence and findings on how systems thinking helps to improve regulatory policy and practice. In this blog post, we will look at the epistemic and ethical challenges that come with applying systems thinking to regulatory governance.

All the blog posts in this series will appear as an open-access paper in the State of the Art in Regulatory Governance Research Paper series. In it, I will also present a more critical evaluation of the full set of literature reviewed than I have done thus far. Expect the paper to be available by the end of February 2020.

The epistemic challenges of systems thinking in regulatory governance

Many of the epistemic challenges discussed in the literature address the limits to and differences in knowing what constitutes a system and how to conceptualise it best. The challenges broadly revolve around two questions: is thinking in systems possible at all, and what knowledge is needed to change systems?

Is thinking in systems possible at all?

We have already seen that system thinking make a clear distinction between systematic thinking and systemic thinking. Systematic thinking is about breaking down the system in its constituent parts (in a structured manner) and study the parts individually. It assumes that adding up the insights on the parts will give insight into the behaviour and performance of the system. Systemic thinking takes as a starting point that the behaviour and performance of the system emerge from its constituent parts. To understand emergent-properties of the system, its constituent parts and their relations need to be understood—including feedback and non-linearity.

We have also seen that systems thinking make a clear distinction between complicated systems and complex systems. Complicated systems typically consist of a (very) large number of (interacting) constituent parts—sometimes of a highly technical nature. Still, the parts and their interactions show predictable behaviour and can be managed. In complicated systems, cause and effect operate linearly. In complex systems, cause-effect relationships are less visible, less predictable, and therefore less manageable.

Finally, we have seen that there are many ways of thinking in systems, with none being dominant or the ‘best’ way. Also, we have seen the difference between thinking of systems as something ‘being out there’ (an ontological approach to systems thinking) and systems thinking as a tool that helps us to think about reality (an epistemological approach to systems thinking). Thinking in and of systems comes quite naturally to people, and our worldviews strongly affect how we think in and of systems.

What knowledge is needed to change systems?

A main epistemic challenge for those interested in applying systems thinking to regulatory governance and practice is to embrace the different approaches to systems thinking. That gets us to one of the paradoxes of systems thinking. Systems thinking helps to reduce and give insight into complexity, but systems thinking itself is a highly complex activity. Mapping and analysing systems ask for collecting and processing considerable amounts of data and knowledge. So, can such knowledge help us changing the systems we are facing?

Systems thinkers are, generally, sceptical about our ability to influence the specific behaviour or direction of systems simply by ‘knowing’ the system. “Instead of trying to organize it in full detail, you organize it only somewhat; you then ride on the dynamics of the system in the direction you want to go”, Stafford Beer argues.[1] Or, to cite Donella Meadows once more, “one of the most frustrating aspects of systems is that the purposes of subunits may add up to an overall behavior that no one wants”.[2] Put differently, even if one is capable of knowing all the constituent parts of a system, the system may still be fully out of one’s control. Nevertheless, scholars point to various aspects of systems that are relevant to know and understand when seeking to change systems—such as stocks and flows, feedback, time delays, trigger points, and the mode of communication within a system.

The consensus among systems thinkers is that there is little point in just changing one of these elements of a system. A change of an element in one part of the system will likely trigger an unanticipated change elsewhere. Likewise, a lack of knowledge of or data on the system as a whole easily results in too forceful or speedy changes of such elements and may result in undesired outcomes or oscillation of the system. Finally, even when a system appears to be performing well, there still is a risk that it is stuck at a suboptimal performance peak. That is, any direct change to the system may make it perform less well immediately, but in the long run, more optimal performance may be possible. This asks for an ongoing critical assessment of the systems we work in and work with—both those that work well and those that do not.

The ethical challenges of systems thinking in regulatory governance

The ethical challenges discussed in the literature closely relate to these epistemic challenges. The first set of challenges is obvious. Because systems thinking acknowledges and calls for embracing different worldviews and different forms of knowledge, those practising systems thinking will face dilemmas of weighing, balancing and merging these worldviews and forms of knowledge. It is likely that, at some point in the systems thinking process, a decision must be made to give (a little) more weight to some worldviews and forms of knowledge than to others. Yet, doing so gives (more) power to some in the system and takes it away from others.

The second set of ethical challenges considers related choices. Different approaches to systems thinking ask different questions of systems and, thus, provide different solutions to deal with systemic challenges. The initial choice of which approach to follow may result in similar power imbalances as choices over what worldview and forms of knowledge to use. Likewise, the initial choice of a specific systems thinking approach will have impact on whether systemic solutions that result from it lean more towards collective or individual welfare, more towards long(er) or short(er) term gains and losses, more towards (vested) special or general interests, and so on. Systems thinking can easily be politicised.

A final set of ethical challenges identified in the literature revolves around the risk that people embrace systems thinking, its jargon and concepts to justify a lack of action to change matters. More problematically, systems thinking can quite easily be (ab)used to absolve oneself or one’s organisation from responsibility for a problem. To recap, systems thinking emphasises complex interactions of several parts of a system and how these affect the system’s behaviour and performance. That, ironically, leaves no individual (or organisation or group) to blame when the system malfunctions, yet everybody partially at fault.

Conclusion: What is the value of systems thinking for regulatory theory and practice?

We began this series of blog posts with observing that the term ‘regulatory system’ seems benign and hardly warrants attention. Over the last weeks, we have come to learn that the term can mean a whole lot of different things to different people. Likewise, we have come to learn that studying systems—or systems thinking—comes in different shapes and forms.

Throughout this series of blog posts, I have aimed to make clear that the term ‘regulatory system’ as well as the (increasing) call for systems thinking in regulatory reform are less benign than they seem at first glance. Yes, there is a great intuitive appeal to applying systems thinking to regulatory form. But we do not have many examples of how systems thinking is applied in regulatory reform, let alone have access to a strong evidence base of its performance in (improving) regulatory governance.

To a certain extent, practitioners of systems thinking must be reductionist and make choices that ultimately affect their findings of the holistic, dynamic, adaptive, and systemic issues they seek to address. That includes the approach to systems thinking, the knowledge and worldviews to include, the weight given to systems parts, and so on. All this asks for a good dose of realism and reflexivity when mapping, exploring and analysing regulation through a systems thinking lens.

All in all, it is not easy to think in systems and talk of systems. It is critical to be exceptionally clear about what you mean when talking in or of systems—and ask others what they mean when they use systems (thinking) jargon.


[1] Beer, S. (1995 [1972]). Brain of the firm – 2nd edition. Chichester: John Wiley & Sons.

[2] Meadows, D. (2008). Thinking in systems: A primer. White River Junction, VT: Chelsea Green Publishing.

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