FESE response to ESMA consultations on Guidelines on periodic information and supervisory expectations

FESE has some concerns about ESMA’s proposals to apply uniform expectations to all currently supervised entities and any future mandates ESMA may receive. Some of ESMA’s proposed reporting and governance expectations may go beyond what the specific regulations governing them foresee, introducing more granular and standardised requirements.

We emphasise the importance of proportionality based on the nature, scale and complexity of the supervised entity. For instance, a “one-size-fits-all” approach to governance arrangements cannot achieve this. Moreover, double reporting to both NCAs and ESMA, such as in the case of BMAs, should be avoided.

For more details on FESE’s concrete recommendations regarding periodic reporting and governance expectations, please refer to our consultation response.