EFAMA supports the European Commission's initiative to establish the European Single Access Point. We see it as a unique opportunity for the Capital Markets Union to centralise all publicly available ESG and financial transparency information data in one place.
In EFAMA's view, the overarching aim of the ESAP should be to improve access to publicly available information that is currently submitted under various national, EU or third-party information systems. The Platform should neither duplicate any existing reporting requirements, nor include information that is not subjected to public distribution, such as information communicated confidentially to investors.
The Platforms' scope should be carefully calibrated to ensure efficiency, data quality and bring an added value to investors. We recommend that the ESAP is built incrementally, differentiating the priority level attributed to ESG and financial information data. In light of the recently adopted transparency requirements under the EU sustainable finance framework, we believe that ESAP's immediate priority should be centralising access to ESG data, while financial information is added gradually as the Platform evolves. When completed, the ESAP should include both ESG and financial information.
The access to standardised sustainability data reported by investee companies is essential to enable Financial Market Participants to satisfy investors needs and demands, and comply with the sustainability disclosure obligations under the Taxonomy and Sustainable Finance Disclosure regulations. In this context, the development of ESAP should be closely aligned with the review of the Non-financial Reporting Directive (NFRD), which may extend the scope of reporting companies and establish European sustainability reporting standards. Company information disclosed under NFRD should be centralised in the ESAP on the principle of open access. As a result, the costs of retrieving and using companies' public information would be reduced, granting access to data that will allow asset managers to make better-informed investment decisions.
We are proposing that all information included in the ESAP should be comparable in terms of content and rendered in a structured, machine-readable format compatible with artificial intelligence. This would help in making the information easily consumable by cross-border investors, who could seamlesslyextract large amounts of data based on precise definitions of terms and concepts. The development and governance of the Platform should not only include EU authorities (ESMA, European Commission, Eurostat), national authorities, investors and reporting companies, but also the European Financial Reporting Advisory Group 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.
By acting as a tool to attract EU investors, the Platform should allow companies not subject to regulatory reporting obligations to provide voluntary disclosures. For this purpose, 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 voluntarily disclosed information is audited or not.
As information users, asset managers see the most significant potential of ESAP in:
i. Standardising and centralising the reporting of company sustainability data, resulting in better data availability and comparability.
ii. Reducing search costs for disclosed raw ESG data.
iii. Providing a transparent data source for ESG ratings, which are increasingly used to guide investment decisions.
iv. Incentivising voluntary reporting on pre-defined sustainability criteria for SME, non-EU and/or non-listed companies in a single platform.
As information providers, we believe the ESAP would:
i. Streamline some of the existing financial and non-financial disclosures and reducing the reporting burden to financial institutions.
ii. Reduce reporting and verification costs of financial market participants in compliance with the taxonomy and disclosure regulations.
iii. Reduce the degree of reliance of asset managers on sector-based coefficients and methodologies estimating Taxonomy alignment of companies outside the scope of NFRD.
As a public good serving the needs of stakeholders beyond the financial services industry, we believe that central EU budgets should primarily incur costs associated with the platforms' development and management. Nonetheless, we would not find it unreasonable to levy a small fee on those that report under and use the ESAP in the same manner as central company registers. However, the user's status should differentiate between end-users and data providers, whereby end-users should have access to the database for free.
