The EACB welcomes the possibility to comment on the European Commission consultation on the establishment of a European single access point (ESAP) for financial and non-financial information publicly disclosed by companies.
The EACB first and foremost supports the proposal of the Commission to broaden the scope of the ESAP to both financial and non-financial information, as getting updated financial and non-financial data on companies is key for the proper functioning of the banking sector from a risk management perspective. At the same time we think this wider scope can be achieved by using a phased approach which can be set up in a roadmap by the European Commission which could also be evaluated by a certain frequency (e.g. annually), as recommended by the High Level Forum on the CMU. Our members believe that ESAP should have an immediate focus on certain regulation and infrastructures where public information is already being made available, and then eventually phase-in the various financial and non-financial data as the regulation is published or updated. The scope should be determined based on the prevention of any additional reporting burdens and based on building upon existing infrastructure.
In terms of non-financial information, we believe that the ESAP should collect first and foremost the entity-related information needed for the EU Taxonomy and SFDR compliance (especially those requested by level 2 implementation), together with disclosures required by NFRD (once developed), the information needed to fulfil obligations under the CRR/CRD mandates on ESG risks.
In terms of financial information, the annual accounts are the basis for every investment and every loan. Therefore, we would propose a phased approach whereby annual accounts are included within the scope of ESAP as a first step. At a later stage, ESAP could also consider product related securities markets regulations (such as PRIIPs, MiFID, UCITS). Moreover, with regard to prudentially sensitive data, we believe that as ESAP will be public, FINREP/COREP prudential reporting for banks must not qualify for ESAP, as this information is only produced for the supervisors’ scrutiny.
The integration of ESG and financial data in the same repository also shows advantages from different perspectives: 1) financial reporting is standardized already and so it should not present so much of a technical difficulty; 2) there is a need for interlinking ESG - and financial reporting in the longer term. These two are natural parts of one whole. Moreover, there is an additional need to cope with the limited availability of good quality ESG data which banks are currently facing. The EACB vocalised this urgent need for ESG data in June 2020 when it called the EU to build a centralised electronic European ESG data register to increase the availability of raw harmonized ESG data. We believe that the development of ESAP on the collection of non-financial data would represent a very important and strategic project to solve the ESG data gap issue at the European level.
For ESG data, the NFRD review shall determine whether non-listed companies including SMEs should provide mandatory non-financial information. Furthermore, should SMEs be included in the scope in a mandatory manner (i.e. also in the scope of the NFRD) this inclusion should be based on simplified reporting obligations for SMEs, but on a voluntary basis for micro-enterprise. For financial information, it is hard to impose a mandatory reporting regime for non-listed companies including SMEs.
Our Members believe that National Competent Authorities (NCAs) and EU authorities (i.e. ESMA) should be involved in the governance of ESAP. A particular attention should be provided to the involvement of different stakeholders in terms of non-financial information. It was proposed that a stakeholders’ committee (similar to that of the ESAs) should be set up, composed of investors, reporting companies and ESG services & products providers.
Given the fact that the ESAP should be regarded as a European strategic infrastructure project, it should be funded by the EU. Moreover, with regards to the users’ access to data in the ESAP, in principle we advocate for free usage of the data for all.
A deeper analysis is included in the EACB position paper here attached and in the key messages document.
For further information or questions please contact:
Ms. Elisa Bevilacqua, Head of Department (firstname.lastname@example.org)
Ms Marieke van Berkel, Head of Department (Marieke.vanBerkel@eacb.coop)
Ms Tamara Chetcuti, Senior Adviser, Financial markets (Tamara.Chetcuti@eacb.coop)
Mr. Giovanni Betti, Adviser; Sustainable Finance (email@example.com)