Category: Position papers

We very much welcome the very detailed consultation on the ESG rating market and on ESG factors in credit ratings. Since a high number of questions are addressed to users of ratings and companies subject to ESG ratings, we hereby provide our general views on both sections of this consultations only.

On November 25th, 2021, the European Commission tabled the Capital Markets Union Package[1], which includes amongst others a legislative proposal aiming at establishing the European Single Access Point (“ESAP”) for financial and non-financial information[2]. We note that ESAP is expected to have a very extensive scope, as it should cover 21 EU Regulations and 16 […]

Dear European Commission, EACRA welcomes the above consultation paper as well as the very detailed set of questions in the targeted consultation.   One of the main objectives of the capital markets union action plan “is to ensure that companies, and in particular small and medium-sized enterprises (SMEs), have unimpeded access to the most suitable […]

In this response letter, we are providing responses to all questions raised to CRAs. We hope that our views and comments will assist ESMA in developing a final guideline leading to a common and shared understanding between ESMA and all CRAs to the benefit of all stakeholders, including issuers and investors alike.

ESMA proposes a number of changes to the current Delegated Regulation on CRA Supervisory fees, the key elements being: 1) the introduction of a flat annual supervisory of EUR 20.000 for CRAs with aturnover between EUR 1 and 10 mln. 2) the calculation of fees based on total turnover. 3) the introduction of an endorsement […]