Joint Proposal on the Prospectus Regulation Level II Measures

The co-signing organisations welcome the launch of the ESMA consultation on the Level II measures for Prospectus Regulation.

We would like to take this opportunity to communicate several guiding principles, which we hope will help improve prospectuses for companies and investors alike:

Simplify not complexify – The EU Growth Prospectus should be designed so that it truly enables companies wanting to enter public capital markets.
Ensure alignment with existing rules & avoid duplication – Clear rules are more likely to lead to clear reporting, thus ensuring that investors receive comprehensive and consistent information.
Further promote incorporation by reference and lighter prospectuses – In the paper we include a three tiers model to prioritise the disclosure of information.
Focus on relevant and material information for investors.
Keep it flexible – Flexibility is key to avoid duplication of information and make prospectuses more comprehensible.
Foster supervisory convergence – This is essential to avoid regulatory arbitrage, harmonise practices and ensure an efficient approval process.
Take advantage of digitalisation – New tech solutions could ease disclosure of information while ensuring it is useful for investors.