The European Fund and Asset Management Association (EFAMA) has published its response to the European Commission's consultation on the establishment of a European Single Access Point (ESAP) for financial and non-financial information publicly disclosed by companies.
Tanguy van de Werve, Director General of EFAMA, commented: "EFAMA sees the establishment of the ESAP as a unique opportunity for advancing the Capital Markets Union, centralising all publicly available ESG and financial information in one place. The information to be included on the platform has to reflect investor's needs and should build on existing EU and national reporting infrastructures without duplicating existing reporting requirements.”
In its response, EFAMA provides six key recommendations for the development of the platform:
‘File only once’ principle: The platform should neither duplicate existing reporting requirements, nor include information that is not subject to public distribution, such as information communicated confidentially to investors.
Scope and timeline: The platform should be built incrementally, differentiating between the priority levels attributed to ESG and financial information. The platform's immediate priority should be centralising ESG company data, while financial information can be added gradually as the platform evolves.
ESG data: The cost for retrieving and using companies' public ESG information is high, owing to the lack of consistency and the fragmented disclosure architecture. Public access to standardised sustainability data reported by investee companies is essential to unleashing the impact of sustainable finance. Therefore, the ESAP must establish synergies with the revision of the NFRD and the preparatory work of EFRAG, so that data following European sustainability reporting standards (ESS) is directly channelled into the platform. To better integrate ESG considerations in investment decisions, a possible regulatory framework for ESG data providers should mandate the disclosure of ESG ratings in the ESAP.
SMEs and non-EU companies: By acting as a tool to attract EU investors, the platform should allow companies not subject to the NFRD reporting obligations to provide voluntary disclosures. For this purpose, the ESAP should incorporate a set of pre-defined sustainability data for companies choosing to disclose their information voluntarily, regardless of their size or geographic location. It would be also important for the platform users to know whether such voluntarily disclosed information is audited or not.
Data infrastructure: All information included in the ESAP should be comparable in terms of content and rendered in a structured, machine-readable and AI-compatible format.
Governance: The platform's governance should include EU authorities (ESMA, European Commission, Eurostat), national authorities, investors, reporting companies, EFRAG and the working group on data and usability of the Platform on Sustainable Finance. EFAMA would also support a public-private partnership governing the platform.
Dominik Hatiar, Regulatory Policy Advisor at EFAMA, commented: "Currently, issuing entities report information to different authorities, public databases or stock exchanges, and in different jurisdictions. Investors would benefit from a publicly accessible database, that would address the lack in quality, standardisation and availability of sustainability and financial information. To meet the new transparency requirements under the EU sustainable finance regime, ESAP's immediate priority should be the centralisation of ESG company data, while financial information can be added gradually. The ESAP should also allow for voluntary submissions of ESG disclosures by companies not subject to the NFRD, which could help attract EU investors to SMEs and non-EU companies".
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About the European Fund and Asset Management Association (EFAMA)
EFAMA, the voice of the European investment management industry, represents 28 Member Associations, 57 Corporate Members and 23 Associate Members. At end Q4 2020, total net assets of European investment funds reached EUR 18.8 trillion. These assets were managed by more than 34,350 UCITS (Undertakings for Collective Investments in Transferable Securities) and almost 29,650 AIFs (Alternative Investment Funds). At the end of Q2 2020, assets managed by European asset managers as investment funds and discretionary mandates amounted to an estimated EUR 24.9 trillion. More information is available at www.efama.org