European single access point (ESAP): access to information in relation to financial services, capital markets and sustainability

ESBG welcomes the opportunity to comment on the European Commission’s proposal for a Regulation establishing a European single access point (ESAP). The availability of quality, comparable, reliable and public ESG data is currently rather limited and insufficient to meet rising expectations and new legal requirements set to take effect soon.

EBF Key Messages on ESAP The EBF welcomes and supports the proposal to establish ESAP to provide investors with a common database for financial and sustainability information that EU companies are required to publish pursuant to EU regulation.

AMAFI welcomes the opportunity to comment on ESAP draft Regulation afforded by the Commission. However, AMAFI would like to raise the Commission's attention on two specific concerns AMAFI has with ESAP draft regulation: 1.

Paris, March 29th 2022 Paris EUROPLACE’s feedback to the European Commission’s proposal on Financial transparency – single EU access point for company information Paris EUROPLACE -which represents Paris International Financial Centre’s actors, French as well as international corporates, investors, banks, financial intermediaries and other financial services providers- welcomes the opportunity to contribute to the…

AFEP brings together over 110 large companies operating in France and worldwide which are in majority public interest entities and therefore subject to the disclosure requirements of several pieces of EU legislation listed in the Annex of the ESAP Regulation and in particular the Transparency Directive, the Accounting Directive – including the Non-financial Directive as well as the forthcoming Corporate…

General position Finance Denmark sees an advantage in gathering information that EU companies already today are required to disclose publicly into one single access point allowing investors, lenders etc. easy access to standardized, digital, machine-readable data.

The KNF supports the idea of a common information hub. However, we would like to point out the following key factors: • The deadline of establishment of ESAP is too short. Having in regard experiences related to ESEF implementation (postponement of deadlines) and complexity of the ESAP project, it seems that the date of establishment should be postponed for at least 2 years, i.e. for the end of December 2026.

The Bucharest Chamber of Commerce and Industry (CCIB) welcomes the creation of Financial transparency – single EU access point for company information and has a direct interest in making use of it. Better access to data helps decision usefulness aspect of information and hence improves investment decision making, builds up investors confidence, and increases comparability among companies, especially when data is…

The Deutsches Steuerberaterverband e.V. (DStV) represents some 36 500 professionals, representing more than 60 % of tax advisers, tax representatives, auditors, sworn accountants and professional companies in Germany. The DStV represents its interests in the professional law of tax advisors and accountants, tax law, accounting and auditing.

Filed in German · English published by the European Commission

The key position of European Insurance CFO Forum (“CFOF”) on the EU COM’s Legislative Proposal on a European Single Access Point (ESAP) is summarized below: AMBITIOUS TIMELINE FOR CSRD REPORTING: An ambitious timeline for reporting sustainability information under the Corporate Sustainability Reporting Directive (CSRD) in the ESAP is needed.

Common capital market Full implementation of ESAP should mean not only creating common data base, but also common market meaning possibility of making transactions based on these data. So ESAP should be complemented with allowing any EU investor to buy or sell any securities admitted to trading on any EU licensed stock exchange at a moderate fee.

ISDA and GFXD (‘The Associations’) welcome the opportunity to comment on the European Commission’s proposal to establish a European Single Access Point (ESAP) for financial and non-financial company information.

As part of its Sustainable Finance and Digital Finance strategies as well as of its Capital Markets Union Action Plan, the European Commission plans to establish an EU-wide mechanism offering easily accessible, comparable and digitally usable databases on the public reporting requirements of companies, including sustainability information: the European Single Access Point (ESAP).

On November 25th, 2021, the European Commission tabled the Capital Markets Union Package , which includes amongst others a legislative proposal aiming at establishing the European Single Access Point (“ESAP”) for financial and non-financial information .

Please find attached the comments from France Assureurs (brand name of Fédération Française de l’Assurance). France Assureurs represents the views of French insurance and reinsurance companies, totalling more than 99% of the premium income of the French insurance market.

Please find attached the comments from ACCIS. ACCIS is the voice of organisations responsibly managing data to assess the financial credibility of consumers and businesses. Established as an association in 1990, ACCIS brings together more than 40 members from countries all over Europe as well as associates and affiliates across the globe.

The French Banking Federation (FBF) welcomes the proposal of the European Commission (EC) establishing the European Single Access Point (ESAP). It will allow banks to access robust, comparable and reliable financial and ESG data in an electronic machine-readable format, and thus help to steer even more effectively their financing and investment portfolios towards sustainability objectives and comply with their…

Allianz highly welcomes the establishment of a European Single Access Point (ESAP) as it constitutes an important step to improve the availability and accessibility of data, facilitate their processing and analysis, and reduce fragmentation. The attached paper summarizes Allianz Group’s key positions on the EU COM legislative proposal.

The European insurance industry welcomes the European Commission’s proposal establishing a European Single Access Point (ESAP). It will allow insurers, Europe’s largest institutional investors, to access robust, comparable and reliable financial and ESG data in an electronic machine-readable format, steer their investment portfolios more effectively towards sustainability objectives and comply with their disclosure…

The German Insurance Association GDV greatly welcomes that ESAP will be established by no later than 31 December 2024 and will provide centralized access to publicly available financial and sustainability information of relevance to investors on capital markets and necessary to comply with sustainability reporting obligations.

The European Commission presented the ESAP Regulation on 25 November 2021, which MAIF welcomes. It has ambitious requirements: — Strengthen corporate reporting, both financial and non-financial — Increase comparability between this information — Summarise the choices made by the various stakeholders in the company — Fostering the integration of financial services and capital markets In particular, MAIF welcomes the…

Filed in French · English published by the European Commission

The idea of a central contact point for relevant information is understandable. However, due to the large volume of information, it can easily become confusing and not useful for market participants. Duplicate reporting or publication channels should be avoided but built on existing systems. The start date for ESAP is very ambitious.

ANIA, the Italian Insurance Association, fully supports the proposal of the European Commission (EC) for establishing the European Single Access Point (ESAP), an EU-wide platform, to provide financial and non-financial information. The availability of quality, reliable, comparable, easily accessible, digital information is in general very important, but it is essential for ESG data.

Please find attached the comments from FEBIS - the Federation of Business Information providers on the ESAP proposal. FEBIS stands for Federation of Business Information Services, the specialized and recognized industry body of providers of global B2B business intelligence services for managing trade risks.Today´s 140 plus members of our federation are present in nearly 60 countries throughout Europe, Asia, Africa…

The Association of German Public Insurers strongly welcomes the European Commission's initiative to strengthen the availability of sustainability data. The Sustainable Finance Disclosure Regulation (SFDR) requires insurers to disclose the sustainability data of their investments. The Taxonomy Regulation, specifically Art. 8, requires disclosure of additional sustainability indicators.

DUFAS supports the development of a European Single Access Point as it will improve data availability for asset managers and other stakeholders. We see most merit in additional data availability related to sustainability regulations/directives like NFRD, CSRD, the Taxonomy Regulation and the SFDR.

ABI supports the establishment of a European Single Access Point as we believe that the proposals for a voluntary contribution scheme open to all companies, the public management of the initiative, entrusted to ESMA, and the free and widespread access to the information will contribute to proceed in the right direction.

The Chamber of Tax Advisors and Accountants (KSW) is the umbrella organisation for all tax advisors and accountants in Austria. It represents more than 11 000 members. They are the specialists in tax advice and auditing and are responsible for over 95 % of Austrian companies.

Filed in German · English published by the European Commission

We believe the proposal for creating an European Single Access Point for financial and non-financial information publicly disclosed by companies is an essential component that will assist in our society’s future capacity to measure the value being generated and distributed across the open banking and open finance ecosystem as part of Europe’s Digital Single Market.

We firmly support this proposal to improve access to data relevant for investment decisions by building a European Single Access Point (ESAP). We agree with the European Commission’s considerations that investors in capital markets must have access to information about companies and financial products in order to make sound investment decisions.

The CCI for Munich and Upper Bavaria is grateful for the possibility of taking a position. Opinion on the EU consultation “Financial transparency — single EU access point for company information” The plan is to set up a single EU access point (ESAP) relating to corporate financial and non-financial information.

Filed in German · English published by the European Commission

Please find below a summary of Insurance Europe's comments on the EC inception impact assessment on a single EU access point for company information. Our detailed comments can be found in the attached position paper.

Deutsche Börse Group appreciates the opportunity to provide feedback on the roadmap for a European Single Access Point (ESAP) for financial and non-financial information publicly disclosed by companies as part of the CMU Action Plan. Progressing on the CMU is not only decisive for delivering Europe's New Green Deal and Digital Agenda, but also to support a healthy and sustainable post-pandemic recovery.

Finance Denmark welcomes the Commission's inception impact assessment regarding the establishment of a European Single Access Point (ESAP). Finance Denmark has three key messages for the proposed ESAP 1. Finance Denmark welcomes the establishment of a European Single Access Point. The first step and top priority should be to ensure access to ESG data.

ShareAction strongly supports the European Commission’s intention to present a legislative proposal to build a European single access point for corporate data. We see four key priorities for the single access points which will be essential for its success: 1) The single access point’s database must include small companies, non-listed companies, and the data provided must include sustainability data; 2) The public…

We fully support the EU initiative for establishing a single EU access point for company information. Such centralised point of access would be very helpful for asset managers in order to be able to easily obtain important information on their investee companies, in particular on ESG topics.

The German Insurance Association (GDV) welcomes the European Commission’s initiative to establish a European Single Access Point (ESAP) for financial and non-financial information publicly disclosed by companies.

Established nearly 40 years ago, France Invest brings together venture capital, private equity, infrastructure and private debt teams based in France, as well as the associated professions which support them. Its membership currently counts 340 management firms and 170 associate members.

The Association of German Public Insurers (www.voev.de) welcomes the initiative of the European Commission to create an EU-wide platform for company information, in particular for sustainability data. So far, the availability of high quality, reliable and comparable data is insufficient to comply with the increasing expectations and new regulatory requirements in the realm of sustainable finance.

FEBIS thanks the European Commission for putting forward an Impact Assessment on a proposal for a directive/regulation on a European single access point for financial and non-financial information publicly disclosed by companies. FEBIS Members represent business information providers all across Europe and worldwide.

The Bank for the Accounts of Companies Harmonized Working Group (BACH WG) welcomes the initiative for establishing a European Single Access Point (ESAP) for financial and non-financial data and considers this mechanism to be of outmost importance to centralize and harmonize financial data for firms across Europe.

• Finance Finland welcomes the European Commission’s plan to streamline company reporting (both financial and non-financial) in the EU. We have called for a centralized ESG data register and think that accessibility to sustainability data should be the priority in building ESAP.

European DataWarehouse (EDW) welcomes the EC consultation on its roadmap for the European Single Access Point (ESAP) for company information published on 18 December 2020. The attached document contains EDW’s feedback to the European Commission’s Inception Impact Assessment with regards to a Proposal for a Directive/Regulation of the European Parliament and of the Council for a European single access point for…

The Sustainability Accounting Standards Board (SASB) submits this letter in response to the Inception Impact Assessment regarding financial transparency via a single EU access point for company information (Ref. Ares(2020)7748392 - 18/12/2020).

XBRL International is pleased to see the Commission's work on ESAP commence. Clearly there are a number of threshold questions that need to be answered before it is possible to provide significant technical commentary on the plans.

Non-financial information on companies’ sustainability fed to the EU single access point (ESAP) should be made useful for policy makers, investors, consumers and the broad public. This could result in a more targeted legislative and better informed consumer behaviour and thus promote environmentally sustainable company business.

We regret that the consultation has been launched at the beginning of the Christmas break and that only 4 weeks have been attributed for sending comments, while the Commission offices were closed during 10 days. We are not able to send our comments by tomorrow 15th. We will send our comments with some delay. Many thanks for your understanding.

WWF strongly supports the European Commission’s intention to present a legislative proposal to build a European single access point for corporate data. This proposal will strengthen both the Capital Markets Union by improving cross-border investment opportunities as well as the Sustainable Finance Strategy by making sustainability information more easily accessible to interested stakeholders, including potential…

The European Commission’s initiative aims at setting up a single digital EU access point to, among others, non-financial company information. In the context of the current call for feedbacks, MAIF, as a mission driven company, would like the make the following remarks to the European Commission. 1.

The Division Bank and Insurance of the Austrian Federal Economic Chamber, as legal representative of the entire Austrian banking and insurance industry, appreciates the possibility to comment on the Inception Impact Assessment. We would like to note the following comments and remarks. In general, we support this initiative.

The Global Legal Entity Identifier Foundation (GLEIF) is pleased to provide comments to the European Commission's Initiative titled Proposal for a Directive/Regulation of the European Parliament and of the Council for a European single access point for financial and non-financial information publicly disclosed by companies.

As business information provider and reuser of public sector information Compass-Verlag welcomes any proposal that fosters transparency and facilitates access to disclosed company data. Up to now the proposal leaves a lot of questions open and those aspects like scope of the provision, accessibility to data, European wide standardisation and so on have to be tackled to determine the possible impact of this…

Given the competitive impact of financial information, namely for the purposes of controlling financial compensation and calculating compensation for public service obligations, national contact points should be regulators and independent administrative entities.