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BPFI position paper on the proposal to establish a European Single Access Point (ESAP)

Banking and Payments Federation Ireland (BPFI) welcomes the European Commission (EC) proposal to establish a European Single Access Point (ESAP), which we believe can help develop EU capital markets by providing investors, analysts and market participants with access to standardized and machine-readable public data.

In particular, we are of the opinion that by publishing/standardizing publicly available information, EU companies will get substantially more visibility from potential investors, supporting the wider EU economy, while contributing to the development of the Capital Markets Union (CMU).

From our perspective it is key that for the project to be successful, it should “start small” and become operational before expanding. Against this backdrop, we support the voluntary contribution elements of the package but would point out that the current timeline is rather ambitious and could be challenging to operationalise. To ensure that the proposal supports the development of EU capital markets in the most effective and efficient manner, we would highlight the following key priorities to EU policymakers:

  • The ability of firms to voluntarily report/disclose information into the ESAP needs to be retained and any proposal to remove this option rejected
  • We believe the current draft proposal is too board, which risks undermining the effectiveness of ESAP. As such, we would suggest the removal of MiFID RTS 27 & 28 reports, as well as PRIIPs and UCITS key information documents.
  • As a way to ensure costs on market participants are proportionate, we would urge that the proposals to place an obligation on collection bodies to ensure additional metadata is kept to an absolute minimum.
  • It is vital that all relevant technical standards and guidelines have been finalized well in advance of any go-live date, and as such, we would urge the removal of fixed implementation dates in the Level 1 text, with these to be set instead as relative dates, for instance applying such dates 6-12 months after all relevant secondary and tertiary rules have been finalized.
  • We would also recommend a staged approach where the go live date for subsequent phases of reports is only finalized when there is certainty around the success of the prior phase. In our view, the data that should be given priority are:
  • Regular financial reports and statements
  • Sustainability risk disclosures
  • Finally, we believe that, as recommended by High-Level Forum (HLF) on the CMU, the ESAP should provide access to information “freely accessible to the public and free of fees or license use.”