Response to the ESMA Consultation on ‘Guidelines on risk factors under the Prospectus Regulation’

FESE Members welcome the opportunity to respond to ESMA’s Consultation Paper on the guidelines on risk factors under the new Prospectus Regulation.

We support the work that ESMA is doing to provide clarification on Level 2. We believe that clear instructions will facilitate both issuers and investors. As indicated in our response, we would like to ask ESMA for more guidance on how these guidelines will apply in practice and whether they might result in a barrier to entry.