AFEP responded to the European Commission’s consultation (“Have your say”) on a proposal for a regulation establishing a single access point to financial information. In its contribution, AFEP stresses the fact that ESAP should not generate additional costs for companies or increase their liability. AFEP further elaborates on the following points :
- Supervisory reporting should not fall within the scope of ESAP as well as KIDs/KIIDs published under the PRIIPS Regulation and UCITS Directive, disclosures of significant net short positions and reports on the quality of the execution of client orders and on the top five execution venues published pursuant to MIFID/MIFIR.
- ESAP should not impact current dissemination and storage rules of regulated information in France. AFEP therefore puts forward amendments to allow Member States to choose and appoint the collection body.
- Finally, AFEP considers that whenever ESMA is empowered with the task to develop implementing technical standards regarding the metadata to be included, the structuring of the data and the use of machine-readable formats, a minimum period of 12 months before the application of the new requirements should be explicitly included in the technical standards. Furthermore the definition of technical standards and the choice of reporting formats, should be based on a robust cost-benefit analysis and stakeholders’ consultation.