Feasibility Study for a pan-european storage system for information disclosed by issuers of securities - Final Report

Save this PDF as:
 WORD  PNG  TXT  JPG

Size: px
Start display at page:

Download "Feasibility Study for a pan-european storage system for information disclosed by issuers of securities - Final Report"

Transcription

1 Feasibility Study for a pan-european storage system for information disclosed by issuers of securities - Final Report ACTICA/PB318D Keith Thomas Steve Gilbert 18 October 2011

2 Executive Summary This document has been prepared by Actica Consulting Ltd as the final report of the study into a pan- European storage system for regulated information disclosed by issuers of securities. It has been prepared for Internal Market and Services DG of the European Commission in delivery of Contract No. MARKT/2010/17/F. The European Commission (EC) Directive 2004/109/EC, the Transparency Directive, requires issuers of securities in regulated markets within the European Union (EU) to ensure appropriate transparency for investors. Article 21(1) of the Transparency Directive requires such information to be immediately available to investors and Article 21(2) requires each Member State to officially appoint at least one mechanism for the central storage of regulated information. The Directive encourages the establishment of some kind of interconnection of these officially appointed storage mechanisms (OAMs) across Member States. The purpose of this study is to identify and technically assess possible options for interconnecting the disclosed regulated information about issuers of securities at a pan-european level, beyond the existing situation which results from the implementation of the Directive rules on storage. In pursuit of the above, the Commission have specified the following objectives for the current study: examine the technical feasibility of an electronic storage system (dataset service) providing public access to pan-european regulated information about issuers of securities; evaluate the cost of such a system considering the different solutions available; provide analytical conclusions. In accordance with the expectations of the Commission, this study includes the following elements: examination of the technical characteristics of the existing national OAMs, including: how they are technically structured, including how the filing of documents is organised, how filers are identified, which types of documents are filed, and the facilities available to end users etc.; whether the OAMs comply with the quality standards in paragraphs 5 to 20 of the Commission Recommendation of 2007; how the national OAMs are supervised by the national competent authorities. examination of the technical feasibility of a storage system providing public access to pan- European regulated information about issuers of securities disclosed pursuant to the obligations of Directive 2004/109/EC and other Directives applicable to issuers of securities. The Commission have specified the characteristics required of such a system. The Commission has also required the examination of at least the three options below: o o o a central data set fed by the existing national OAMs; a network of harmonised national datasets; a single EU dataset; analysis of the costs of the storage system, including: o the costs involved in creating and running the existing national OAMs; Page ii Actica/PB318D

3 o o the expected development and on-going running costs and benefits associated with the options for the pan-european service; the expected sunk investments of national OAMs if a single EU dataset is created; analytical conclusions based on the technical examinations and cost analysis. A number of previous studies have been conducted to examine the options for creating a pan-european database of regulated information submitted by issuers of securities. The following points from these studies are relevant to the technical and cost assessment of feasible options to be undertaken here: The provisions of the Directive for the storage of regulated information are generally well understood and accepted by stakeholders. The 2007 Recommendations have defined, at a high level, common operational standards for all OAMs. A full or interim OAM service based on and, to varying levels, compliant with these standards is in place in all Member States. At the more detailed level, common standards have not been set covering the implementation of the OAM solution (for example covering technical architecture, common coding structures, and detailed process areas). As a result OAMs have developed independent solutions in these areas. Usage of OAMs by end users is limited. Most retail and institutional investors, analysts and other stakeholders traditionally use the issuers web site as their first source of information. Whilst the studies indicate that the OAM service is well regarded, market and issuer demand for increased services is limited. A light integration of information held by OAMs has been provided through the use of CESR s MiFID database but this does not fully meet the expectations of even the light integration model proposed by CESR in A number of options have been put forward to progress the pan-european network by both CESR and Mazars 2009 external study, but to date no consensus on a firm direction has been agreed and no progress has been made on moving forward from the current light integration position. There is no central list of issuers of all securities, a central list of issuers of shares only is available as part of the MiFID database. The development of a central database of issuers, with appropriate coding structures, is a prerequisite for development of an integrated OAM network; There is a view that an OAM based approach offers benefits compared to solutions based on a reliance on issuers web sites or purely relying on commercial data vendors. Summary of the current status quo position OAMs are operating in all Member States, although the types of services offered vary considerably, with some still operating interim solutions with limited facilities for end users. (Although some of these are due for imminent replacement at the time of this report.) The OAMs supplement, and are often closely integrated with, stock exchange and regulatory information filing services and systems. The OAM has not typically acted as a replacement repository for regulated information, and filings continue to be stored and disseminated through multiple channels. Issuers in several Member States make use of intermediaries or commercial data disseminators to manage their filings to both the OAM and other agencies. In these cases there are system-to-system interfaces to support the filing process. Actica/PB318D Page iii

4 Almost universally, the OAMs support the filing and storage of unstructured document formats. They provide user tools to search for and download documents, based on a limited set of descriptive metadata describing the nature of the document but not its detailed contents. (Some OAMs also provide full text search of the contents of documents.) The OAMs manage the filing process and ensure the safe storage of documents provided by issuers. Their role is to transparently present information provided by issuers. They are not involved in the interpretation, analysis or presentation of the information contained within the documents they manage. Commercial providers of financial information are typically seen as the providers of structured and analytical information regarding issuers. These providers make use of information typically obtained from regulatory filings but tend to have their own information channels and do not rely on the OAMs to source their data. There is very limited pan-european integration available through the ESMA (CESR) MiFID database. Neither this nor the national OAM services appear to be actively promoted or marketed to potential users. Most OAMs report very low volumes of end user/investor access to their services. Typically, such users either use the analytical tools and information available from the commercial providers or directly access information from issuers websites. The OAM acts as a repository of record for professionals to obtain official versions of key documents on an exception basis. Approach In order to meet the objectives of the study as set out above, the approach has included: desk research, including a review of the user facilities offered by the current OAM network; multi-stage online information gathering surveys of the OAM operators supplemented by follow up interviews; structured interviews with both representative OAMs and central bodies with a stakeholder interest, including Eurostat, ESMA and ECB; structured development and assessment of cost and benefit models for technical options for the development of a pan-european solution, compared to maintaining the status quo. Key findings for options analysis Although there are OAM services operating in all Member States, there exist varying degrees of readiness to begin further integration. Except in a few cases where interim solutions still exist this is not predominantly a technical issue, rather it reflects the varying interpretations of the Directive in business process, coding and detailed filing practices: OAMs have implemented different arrangements for the creation and storage of metadata, there are no common standards; OAM filing processes in several Member States are closely coupled with other exchange disclosure, regulatory and news dissemination processes and systems in these cases many issuers do not file direct to the OAM; Information held by the OAMs is often duplicated in other exchange or regulatory systems; OAMs do not have existing structured processes for handling notification of changes to voting rights. Page iv Actica/PB318D

5 Few end users make use of the OAM service in most Member States. The quality of the user experience offered to end users is good overall, but the services offered vary considerably: o o o o Web sites for OAMs can be difficult to find using commercial search engines; Users of the information held in the OAM repositories are mainly professional advisors and researchers; Individual investors tend to access commercial information services or the issuers web sites rather than OAMs, mainly due to the extra information and analysis available; The OAM service is of limited value to central bodies such as Eurostat and ECB because there is no structured or analytical data stored by the OAM that can be used by these organisations for statistical and analysis purposes. Technically, the OAMs are in a good position to respond to changes and extensions to the service they provide: Options o o o o Documents and metadata held by the OAMs are mainly stored in flexible SQL databases so can be updated relatively easily (although the contents of the documents is not structured); Similarly, OAMs can provide access to their back end databases in order to facilitate a central search tool relatively easily, although the scope and activities required would need to be agreed; OAM operators agree with the requirement for pan-european interconnections but are seeking clear long term direction on the way forward as they do not see market demand driving such an initiative; OAM operators have highlighted potential issues with significant change to current operations and processes. The options for implementing a pan-european database of securities information have been developed from a baseline that consists of the existing options as identified by previous studies conducted by CESR (now ESMA) and Mazars. The initial step in the options identification was to assess these options against the EC specified requirements of this study, and discard any options that do not meet the requirements. The remaining options were then reviewed to assess whether there were any gaps, including areas where new technologies could provide an option or areas where a different combination of local and central services provided a different option. The review also ensured that all options proposed by the EC in the scope of this review were included. There were eight options considered: a. Option 1: Single European OAM - Replace all national OAMs with one central OAM that stores all European data and provides all search facilities. b. Option 2: Central database for all data - Create a central European database for securities information which holds copies of all information stored by the national OAMs. c. Option 3: Central database for metadata - Create a central European database that holds metadata for all information held by the national OAMs d. Option 4: OAM web-ring - Standardise data storage across all national OAMs to enable all information to be searched by current national search tools Actica/PB318D Page v

6 Key requirements e. Option 5: Harmonised OAM network - Standardise data storage/metadata as for Option 4 above together with a central search capability searching all national datasets. f. Option 6: Central intelligent search - Make use of intelligent search tool to provide central search facility without using central database. g. Option 7: Combine current OAM operations with national business registers - Create a combined OAM and national business registers database and its operations to make use of the planned central access point for the business registers by linking it to the national OAM databases. This leverages economies of scale and the existing business registers European network to also provide OAM data centrally. h. Option 8: Maintain status quo - Continue to provide national OAM services using multiple different databases, with few interconnections. The external study, CESR s consultation and report and other work performed by the Commission have identified a number of elements required to be in place in order to build an effective pan-european storage network. The findings from the surveys and interviews conducted allow a number of key requirements to be identified. These are: Common filing standards and formats; Harmonised methods of classification and indexing; Interconnection with national company registers; Multiple country search from a single query; Standardisation of telecoms and database solutions. Initial options analysis A number of the options identified in Section 5 can be discounted at this stage on the basis that they clearly do not meet one or more of the requirements. The discounted options, and reasons for disqualification are listed below. Option 4: OAM web-ring - discounted at this stage because the EC requirements specify that a single, central search tool is required, that allows users to conduct pan-european searches from a single, central point. This option does not meet that requirement as no additional portals are created users would be able to use any of the existing OAM portals rather than being directed to a single, central portal. Option 6: Central search and index engine - discounted at this stage because use of an intelligent tool to index the data is seen as interpretation and carries a risk that data could be incorrectly or inappropriately indexed. Users conducting a search of information indexed in this fashion could therefore be presented with incorrect or inaccurate results which could be seen as the responsibility of the owner and supplier of the search tool. This could lead to complaints or more serious action being taken against the EC (or other central body that is responsible for the central search tool) to recover monies lost as a result of incorrect data being supplied. Option 7: Combine current OAM operations with national business registers - discounted at this stage for two reasons: The effort required to integrate OAM databases with the Business Registers to enable the existing international linkages to be used to share OAM information is likely to be prolonged. This extra effort is not likely to deliver additional benefits over the previous options; Page vi Actica/PB318D

7 The option does not increase the efficiency of the two separate databases due to a lack of synergy between them. The information held in the national business registers is different to that held in the OAMs, the only point of commonality is financial reports. It is therefore unlikely that a combined database would deliver any tangible savings and it is also unlikely that the combined database would be able to make use of the existing international linkages to search OAM data as these exist to share business register data rather than the different OAM data. Option 8: Maintain status quo - discounted as it does not meet the requirement for a single European access point and does not enable a pan-european search. Further options analysis A set of criteria by which the four options taken forward (Options 1,2,3 and 5) can be assessed has been developed based on assessing the overall suitability of each option to fulfil the requirement of enabling users to conduct pan-european searches of regulated information held on issuers of securities. These criteria are listed below: ability to meet the EC requirements as described in the ITT (Annex A); deliverability how easy is it to move from the current situation to that proposed by the option; ability to address concerns identified in previous reports; timescale how long is the option likely to take to be fully implemented; Cost; governance and resourcing How much will current governance and resourcing arrangements need to change to implement the option; standardisation to what level will the current national arrangements need to be standardised to implement the option; flexibility - how easily can the proposed system be changed to include new data, storage arrangements or processes (such as moving to XBRL); benefits and user experience what are the quantifiable and unquantifiable benefits of the option, including any improvements to the user experience; impact on other organisations, including 3rd party providers; impact on other government services such as information registers; risk the likely risk of implementing the option. Each option has been assessed against these criteria individually in order to understand how well that option is likely to meet the overall need. Cost model The table below summarises the full cost model for the options and shows the additional costs incurred centrally and the total costs associated with all four options, detailed over a 5 year period. Actica/PB318D Page vii

8 Year 1 Year 2 Year 3 Year 4 Year 5 Central costs Option 1 2,070, , , , ,000 Option 2 1,240, , , , ,000 Option 3 1,880, , , , ,000 Option 5 1,090, , , , ,000 Total costs Option 1 4,090,000 2,060,000 1,560,000 1,050, ,000 Option 2 3,260,000 2,320,000 2,320,000 2,320,000 2,320,000 Option 3 3,900,000 2,360,000 2,360,000 2,360,000 2,360,000 Option 5 3,110,000 2,280,000 2,280,000 2,280,000 2,280,000 Recommendation Cost model summary The options analysis does not identify a clear preferred option. All of the options identified are able to meet the majority of the requirements, have similar costs and similar timescales. It is clear that Option 1 best satisfies the requirements, but it is also clear that this option has the highest overall impact on users, issuers and existing OAMs, and thus is highly likely to take the longest time to implement. However, this option also presents the best opportunity to save costs based on the reduction of the number of national OAMs over time. The recommendation is therefore that Option 1 should be the long term solution, and that the EC seeks to evolve the current situation into a single, European OAM over time. Options 2 and 3 can then be used as steps which support this evolution and allow the costs and impact on stakeholders to be borne over time, and thus the impact and difficulty of change is reduced. It is recognised that the implementation of a pan-european OAM network meeting all the functional requirements specified will require progress through a number of steps and take some considerable time to deliver and manage transition. In order to maintain focus, and to show the market there is strong commitment to the longer term vision, we strongly recommend that a clear strategic roadmap and vision is agreed and published showing the proposed end target model, the proposed steps for moving towards this from the current position and the principles that will underpin this development. The other key activities that are needed to support the implementation of this roadmap are: Set up a central standards and protocol body to agree and implement standards Define a unique pan-european issuer code Standardise metadata held for issuers and filings, and harmonise coding Harmonise other key aspects of national OAM data and processes, including time stamping and version control Specify a standardised format for filing structured information Page viii Actica/PB318D

9 List of Contents Executive Summary ii 1 Introduction General Overall study context Purpose of the study Objectives of the study Key outcomes of the study Scope Acknowledgements Status Disclaimer: Structure of this report 3 2 Background Introduction The Transparency Directive rules on disclosure of regulated information Dissemination and storage of regulated information Progress on creating a pan-european network Commission 2007 Recommendation and standards The current position Recommendations and findings of the 2009 External Study Cross-border access to regulated information on SMEs Interconnection with company registers and unique company identifier EC 2010 consultation on the Transparency Directive CESR 2010 consultation and report on development of pan-european access Summary 12 3 Methodology Introduction Review of user facilities offered by current OAM network Online information gathering surveys and follow up interviews Structured interviews for impact assessment of options Assessment of options 14 4 Findings Introduction Overview of the national OAM network Technical structure of the national OAMs Common code for identification of issuers Consolidation of information on voting rights Visibility of small listed companies Alert systems Integration with business registers Compliance with quality standards End user access to OAMs Current pan-european integration Use of issuers web sites as a source of information The role of the OAM and interpretation of data Relationship between OAMs and third party vendors 28 Actica/PB318D Page ix

10 4.15 Summary of the current status quo position Key findings for options analysis 29 5 Options Identification Introduction Methodology Options identified Option descriptions 33 6 Options Analysis Introduction Key requirements Initial analysis Further analysis methodology Cost model Detailed analysis Other considerations 51 7 Recommendation Introduction Recommendation Other recommendations Summary of recommendations 56 A Characteristics of a pan-european storage system 59 Page x Actica/PB318D

11 INTENTIONALLY BLANK Actica/PB318D Page xi

12

13 1 Introduction 1.2 General This document has been prepared by Actica Consulting Ltd as the final report of the study into a pan-european storage system for regulated information disclosed by issuers of securities. It has been prepared for Internal Market and Services DG of the European Commission in delivery of Contract No. MARKT/2010/17/F. 1.3 Overall study context The European Commission (EC) Directive 2004/109/EC, the Transparency Directive, requires issuers of securities in regulated markets within the European Union (EU) to ensure appropriate transparency for investors. This is achieved through a regular flow of information by disclosing periodic and on-going regulated information and by disseminating such information to the public throughout the Community Article 21(1) of the Transparency Directive requires such information to be immediately available to investors and Article 21(2) requires each Member State to officially appoint at least one mechanism for the central storage of regulated information. The Directive encourages the establishment of some kind of interconnection of these officially appointed storage mechanisms (OAMs) 1 across Member States. The Directive does not however make such networks compulsory The transposition deadline of the Transparency Directive was 20 January On 27 May 2010 the Commission published its report on the application of the Transparency Directive, which included a review of the operation of the OAM network. In the report, the Commission indicated that progress towards the establishment of a pan-european system of storage of regulated information had been slow and the impact of the Directive in this area had been insufficient. 1.4 Purpose of the study The purpose of this study is to identify and technically assess possible options for interconnecting the disclosed regulated information about issuers of securities at a pan- European level, beyond the existing situation which results from the implementation of the Directive rules on storage. 1.5 Objectives of the study In pursuit of the above, the Commission have specified the following objectives for the current study: a. examine the technical feasibility of an electronic storage system (dataset service) providing public access to pan-european regulated information about issuers of securities; 1 The acronym OASM is also used. Actica/PB318D Page 1

14 b. evaluate the cost of such a system considering the different solutions available; c. provide analytical conclusions. 1.6 Key outcomes of the study In accordance with the expectations of the Commission, the study includes the following elements: 1.7 Scope a. examination of the technical characteristics of the existing national OAMs, including: 1. how they are technically structured, including how the filing of documents is organised, how filers are identified, which types of documents are filed, and the facilities available to end users etc.; 2. whether the OAMs comply with the quality standards in paragraphs 5 to 20 of the Commission Recommendation of ; 3. how the national OAMs are supervised by the national competent authorities. b. examination of the technical feasibility of a storage system providing public access to pan-european regulated information about issuers of securities disclosed pursuant to the obligations of Directive 2004/109/EC and other Directives applicable to issuers of securities. The Commission have specified the characteristics required of such a system. These are summarised in Appendix A of this report. The Commission has also required the examination of at least the three options below: 1. a central data set fed by the existing national OAMs; 2. a network of harmonised national datasets; 3. a single EU dataset; c. analysis of the costs of the storage system, including: 1. the costs involved in creating and running the existing national OAMs; 2. the expected development and on-going running costs and benefits associated with the options for the pan-european service; 3. the expected sunk investments of national OAMs if a single EU dataset is created; d. analytical conclusions based on the technical examinations and cost analysis The OAMs in scope for this study are those run by all 27 EU Member States plus Iceland and Norway, making a total of 29 OAMs. Three of those OAMs are managed by a single operator and there are therefore 27 OAM operators in total. 2 Commission Recommendation 2007/657/EC of 11 October Page 2 Actica/PB318D

15 1.8 Acknowledgements Actica would like to thank all representatives from national OAMs and operators, the EU, Eurostat and the ECB who contributed to this study. 1.9 Status This is the final version of this report Disclaimer: The views expressed in this document are purely those of the writer and may not, in any circumstances, be interpreted as stating an official position of the European Commission The European Commission does not guarantee the accuracy of the information included in this study, nor does it accept any responsibility for any use thereof. Reference herein to any specific products, specifications, process, or service by trade name, trademark, manufacturer, or otherwise, does not necessarily constitute or imply its endorsement, recommendation, or favoring by the European Commission All care has been taken by the author to ensure that he has obtained, where necessary, permission to use any parts of manuscripts including illustrations, maps, and graphs, on which intellectual property rights already exist from the titular holder(s) of such rights or from his or their legal representative Structure of this report The remainder of this report is structured as follows: a. Section 2 details background information; b. Section 3 outlines the methodology used to conduct this study; c. Section 4 details the findings from the information gathering stage; d. Section 5 provides information on the options identified; e. Section 6 analyses the options; f. Section 7 presents the recommendations and next steps Details of the surveys carried out as part of the study, together with tabulations and analyses of the responses to the survey questions, are presented in the Survey Analysis Annex to this report and issued as a separate document. Actica/PB318D Page 3

16 INTENTIONALLY BLANK Page 4 Actica/PB318D

17 2 Background 2.1 Introduction This section details the background to this study. It outlines the EC Transparency Directive as it applies to issuers of securities and how this requirement is being met by the current situation. It also summaries a number of previous studies that have been conducted in this area, including their conclusions. Lastly, this section contains a summary of the relevant information that is carried forward to the findings and analysis stage of this report. 2.2 The Transparency Directive rules on disclosure of regulated information Directive 2004/109/EC (the "Transparency Directive") requires issuers of securities in regulated markets within the EU to ensure appropriate transparency for investors. This is achieved through a regular flow of information by disclosing periodic and on-going regulated information and by disseminating such information to the public throughout the Community. Regulated information consists of financial reports, information on major holdings of voting rights and information disclosed pursuant to the Market Abuse Directive (2003/6/EC). Shareholders, or natural persons or legal entities holding voting rights or financial instruments that result in an entitlement to acquire existing shares with voting rights, should also inform issuers of the acquisition of, or other changes in, major holdings in companies so that issuers are in a position to keep the public informed The Transparency Directive contains rules on: g. disclosure of information (such as deadlines, content, formats, language etc); h. dissemination of information to the public and the competent authorities; i. storage of disclosed information by the officially appointed storage mechanisms (OAMs); j. liability of issuers regarding disclosed information; k. supervision by competent authorities and penalties for lack of compliance The Directive determines which national law is applicable; the home/host Member State rule is irrespective of the place of listing of the issuer. The Directive also contains provision for the treatment of issuers whose registered office is in a third country. The transposition deadline of the Transparency Directive was 20 January Dissemination and storage of regulated information The Directive requires issuers to disclose regulated information in a manner ensuring fast access to such information on a non-discriminatory basis and without charging investors any specific cost. According to the Directive, the home Member State shall require the issuer to use an appropriate media that may reasonably be relied upon for the effective dissemination of the information to the public throughout the EU, but may not impose an obligation to use only media whose operators are located in the home Member State With respect to regulated information access over time, the Transparency Directive has established a specific regime providing for a publicly accessible registry on disclosed Actica/PB318D Page 5

18 information. Article 21(2) of the Transparency Directive requires each Member State to officially appoint at least one "mechanism for the central storage of regulated information" an OAM. The Directive tries to establish some centralisation at Member State level, not at European level. The Directive is not prescriptive as to the practical solutions In addition to the creation of national OAMs, the Directive encourages the establishment of an interconnection across Member States: l. electronic networks at national level connecting OASMs to existing national business registers; m. the connection of those national electronic networks at European level However, the Directive is neutral as regards the architecture of OAMs and it does not directly make those networks compulsory. 2.4 Progress on creating a pan-european network Upon request of the Commission, CESR (the Committee of European Securities Regulators) prepared, in 2005, a Progress Report 3 on the implementation of the network of national OAMs. This Progress Report was followed by a Report on cost issues in 2006 which provides estimates in relation to the cost of setting up a national OAM and the cost of setting up a European network of national OAMs. Finally, later in 2006, CESR delivered formal advice on the possibility of implementing measures on storage of regulated information and filing with the competent authority 4. In its advice, CESR: n. presents 4 alternative models (A to D) for the European network with varying degree of centralisation; o. suggests the minimum standards to be respected by each national OAM; p. describes the funding implications of setting up and operating a national OAM; q. evaluates the role of the Competent Authority in the supervision of the OAM and in adopting the standards; r. provides an opinion in relation to the filing of regulated information by electronic means with the Competent Authorities The alternative models proposed by CESR in its advice were as follows: a. Model A proposes that there is a "Central Access Point" ("CAP") application that is used by end users to search the OAM network. The CAP is an application that sits on a central server outside all OAMs that allows end users to search the OAM network. b. Model B proposes that the end users use the software application of any one OAM to search the entire OAM network. In this model, each OAM implements a common search engine. An end user may choose to use the OAM that he or she prefers to search the network. 3 4 CESR (March 2005), Progress Report regarding possible implementing measures of the Transparency Directive on the role of the Officially Appointed Mechanism and the setting up of a European Electronic Network of information about Issuers and electronic filing. CESR (June 2006) Final technical advice on possible implementing measures concerning the Transparency Directive Storage of regulated information and filing of regulated information Page 6 Actica/PB318D

19 c. Model C proposes that there is a central server hosting an application, containing a complete list of issuers and the links to the OAM(s) holding information on that issuer. The list is used by end users to access the OAM that stores information related to the selected issuer. d. Model D proposes that each competent authority carry a list of links to all the national OAMs on its website. An end user must then select the appropriate OAM and access it directly through the web link In its advice, CESR expressed a preference for the Model C option, a simple network model. In accordance with the preliminary cost estimates made by CESR in 2006, the model was considered to have adequate functionalities with lower costs than other options. Under Model C, the pan-european network would consist of a common single interface for end users (e.g. a website) containing a central list of all EU issuers with, for each issuer, a hyperlink to the relevant national storage system in which regulated information can be found. By clicking on the name of the relevant issuer, the user would be directed to the site of the relevant storage mechanism to carry out a detailed search for the document(s) required. All data and documents would remain at national level and the only common element would be the list of issuers. 2.5 Commission 2007 Recommendation and standards Building on the CESR advice, in 2007 the Commission adopted a non-binding Recommendation 5 on the network of national mechanisms storing regulated information. The main aim of the recommendation was to give support to work undertaken by CESR regarding the pan-european network, and to its suggested way forward. Hence, this recommendation suggests that Member States should take steps to set up the network model proposed by CESR and requested CESR to draw up guidelines regarding the future development of the electronic network. The Recommendation also contains suggestions regarding the minimum quality standards with which OAMs should comply. Paragraphs 5 to 20 of the Recommendation include standards covering: a. security; b. certainty as to information source; c. time recording; d. ease of access by end users. 2.6 The current position CESR has set up an initial network of OAMs using CESR s MiFID database on shares admitted to trading on EU regulated markets. Clicking on the share s name displayed on the database search screen directs users to the corresponding national OAM. The MiFID database is designed with a focus on the issued instrument rather than the issuer and excludes issuers of securities other than shares. Currently a list of issuers of securities other than shares is not available centrally. As a result, the solution does not fully meet the expectations of the original Model C and is referred to by CESR as Model C-. 5 Commission Recommendation 2007/657/EC of 11 October Actica/PB318D Page 7

20 2.7 Recommendations and findings of the 2009 External Study The application of the Transparency Directive was evaluated by an external study undertaken by Mazars in Concerning the dissemination and storage of regulated information, the study outlined the objective of the Directive to ensure that such information can be: a. rapidly accessed by investors; b. provided on a non-discriminatory basis; c. provided at no cost to investors The review noted that the new elements introduced by the Directive were the requirements for an EU wide dissemination of information and for filing to the appointed OAM as well as the regulator of the issuers market. As a result, the role of Supervisors and/or Exchanges in the overall dissemination of this information was changing and was not stable Relevant findings from the extensive survey carried out as part of the external study were as follows: a. The vast majority (85%) of stakeholders consider the storage of historical information to be useful, with 70% agreeing it should be stored for a minimum of 5 years. 50% of stakeholders consider that the information stored is relevant and investors would be in favour of storing more information. b. 70% of stakeholders using the information believed issuers used the appropriate media to disseminate the information they produce and 45% did not believe the Directive had changed the way it is made public. c. Half of the users of information feel the information easily reached both the retail and institutional investor, not only intermediaries. d. Almost two thirds (60%) of users believed the Supervisor or Exchange should be the central access point for stored information, with a preference for the Supervisor, but in general these bodies are reticent to play such a role. e. Issuers continue to use data disseminators to ensure a wide distribution of regulated information. There are electronic systems available in some Member States to facilitate this, and the integration of the OAM. f. SMEs expressed the view that posting the information on their website should be sufficient to comply with the dissemination obligation of the Directive. g. While many stakeholders did not express an opinion on the effectiveness of the national OAMs, when an opinion was expressed it was clearly positive. h. The current national OAMs are not well known. Only 5% of users resort to them as a primary source of information regarding a specific company, with 68% of users indicating their first source of information was the company web site, although 38% of investors have more confidence in the information available through an OAM. i. Almost two thirds (63%) of stakeholders who expressed an opinion would be in favour of a central EU storage system to facilitate cross-market searches for information The external study concluded that, two years after the introduction of the Directive, there appeared to be no stable and consensual vision emerging on the manner in which stored Page 8 Actica/PB318D

21 information may be accessed on a national and EU level. The study derived three possible scenarios from the opinions expressed by stakeholders: a. rely exclusively on the issuers websites, with harmonised publication in a specific section of the issuers website made compulsory at EU level; b. improve the functioning and visibility of national OAMs through more streamlined and harmonised technical requirements to allow efficient interconnection, and more flexibility in the way in which such systems are run to improve their business case; c. create an EU single entry point, possibly by CESR maintaining a list of EU listed companies with direct links to the specific section of each company s website storing the regulated information As a result, the study suggested the following improvement A single EU access to Regulated Information: The time has come for the EU to set up a single access point for stored information, based on a serious cost benefit analysis while taking into account recent advances in technology The study goes on to suggest progressing the third option above, noting that the storage of regulated information on the issuers website is already compulsory in several Member States. 2.8 Cross-border access to regulated information on SMEs The Mazar s external study in 2009 highlighted the poor cross-border dissemination of regulated information by SMEs, and the low interest shown by analysts and investors in those companies (the black hole ). The majority of issuers and users of financial information either thought the Directive had had no effect or had no opinion. There appears to be a Catch 22 situation SMEs regret the low level of cross-border interest, so are unwilling to spend money to ensure wider dissemination (e.g. by translation of their information into English) whilst the analysts and investors believe they do not receive sufficient information from non-domestic SMEs, and so are reluctant to invest in them The study suggested that only a change in the behaviour of the markets participants would fill this gap. The specific initiatives suggested by the study to effect this change in behaviour are outside the scope of this work. 2.9 Interconnection with company registers and unique company identifier The 2010 CESR report and consultation also considered interconnection with the network developed by national company registers. Whilst considering the link to such registers not to be of the highest priority (a view endorsed by the proposed amendments to the Directive on the interconnection of these registers) CESR recognised the value of defining a common company identifier for both networks (for example the REID code developed by the BRITE project) EC 2010 consultation on the Transparency Directive The 2010 Commission report on the application of the Transparency Directive 6 also addressed the development of the OAM network. The report states that progress towards the establishment 6 COM(2010)243 final Actica/PB318D Page 9

22 of a pan-european network of OAMs has been slow, and the impact of the Directive in this area has been insufficient The issue was further addressed in the Commission s consultation on the modernisation of the Transparency Directive held between 28 May 2010 and 23 August Question 9.3 of the consultation paper asks: a. Do you think that the development of an EU database storing regulated information on all issuers of securities in the EU will facilitate research and create interest/result in greater attention in small listed companies by financial analysts, financial intermediaries and investors? of the responses received to the consultation included comments regarding the development of an EU database. Responses were mixed as to the market demand for such a database and the relative cost and value to be derived from such a development. Some respondents favoured solutions providing a portal to issuers websites or national databases CESR 2010 consultation and report on development of pan-european access In response to the request in the 2007 Commission Recommendation asking CESR to draw up appropriate guidelines for the future development of the network, in 2010 CESR produced a report to the European Commission 7 setting out its proposals for the onward development required to address the features described in the Recommendation The final CESR report was based on a public consultation held between 2 August 2010 and 24 September CESR received 34 responses to the consultation which were considered generally supportive of the proposals put forward in the consultation paper, and specifically to the two proposed models for the integration of the OAM network: a. Option 1 - A network model which would gradually develop the functionality of the current linked model in a 3 step approach. Step 1 would extend the current solution to cover all issuers of securities; Step 2 would enhance searching capabilities by storing more items of metadata on issuers and filings at the Central Access Point (CAP). National OAMs would provide harmonised metadata to the CAP and the CAP would provide end users with a hyperlink to the stored documents in the OAMs. Finally Step 3 would allow searching of information from documents filed in the OAM network and assumes the need for harmonised filing formats across the network. (Note Steps 2 and 3 above reflect the revised proposals in the report following analysis of the consultation responses.) b. Option 2 A single European OAM replacing the national OAM network. All issuers would be expected to file regulated information to this single point in a standardised way In the consultation paper, CESR preferred Option 1 and the responses to the consultation broadly supported this. 7 CESR/ December 2010 Development of Pan-European Access to Financial Information Disclosed by Listed Companies. Page 10 Actica/PB318D

23 In analysing the two options CESR made the following observations: a. The creation of a database of the home member state of all issuers is a prerequisite for the development of either option; as such a database does not currently exist. b. Both options require amendments to the Transparency Directive before a fully integrated network could be created. The network model of Option 1 does however allow development to begin before such changes are made, as it is based on the existing provision. c. The network model has a closer connection to local markets. Most of the national OAMs are operated by institutions with which issuers are in any case required to file regulated information (e.g. competent authorities and stock exchanges). Filing with a single, central OAM would need to be aligned with these national institutions to avoid increased administrative burdens for issuers required to file the information twice. d. Should future large scale development projects be anticipated, the aggregated costs of changes to all OAMs would be more than for a single OAM, increasing the benefits of the latter approach. Conversely, the initial implementation costs of a single European OAM would be high and consideration would need to be taken of the aggregated investments already made in the national OAMs In the report, CESR considered that an OAM based approach offered added value when compared with options reliant on issuer s websites. The relative merits of the OAM approach included: a. OAMs provide comprehensive, free of charge coverage of historical information; b. the information remains publicly available even if an issuer ceases to exist; c. OAMs enforce non-repudiation and information cannot be changed after it has been filed; d. OAMs provide easier access to regulated information for some issuers who may not have their own websites (e.g. Special Purpose Vehicles and corporate subsidiaries) The report also recognised the benefits of the OAM as a source of regulated data compared to commercial data vendors, considering the approach to be: a. non-discriminatory; b. independent; c. providing full coverage; d. at no cost to end users CESR did however share the conclusion made in the 2009 external study that the OAMs seem to lack visibility. While national OAMs may be widely used at national level, CESR considered that they are not always easy to access for investors in another country Despite suggestions from some respondents to the consultation paper, CESR did not consider that issuers should be required to disclose information in English. They did, however, state that where issuers voluntarily disclose information in more than one language the OAMs should make all language versions available Overall, CESR considered that the attractiveness and visibility of the national OAMs and the OAM network could be enhanced through developing search facilities at both national and network level. Actica/PB318D Page 11

THE COMMITTEE OF EUROPEAN SECURITIES REGULATORS CESR S CONSULTATION PAPER ON POSSIBLE IMPLEMENTING MEASURES CONCERNING THE TRANSPARENCY DIRECTIVE

THE COMMITTEE OF EUROPEAN SECURITIES REGULATORS CESR S CONSULTATION PAPER ON POSSIBLE IMPLEMENTING MEASURES CONCERNING THE TRANSPARENCY DIRECTIVE THE COMMITTEE OF EUROPEAN SECURITIES REGULATORS Ref: CESR /06-025 CESR S CONSULTATION PAPER ON POSSIBLE IMPLEMENTING MEASURES CONCERNING THE TRANSPARENCY DIRECTIVE STORAGE OF REGULATED INFORMATION AND

More information

Consultation Paper. ESMA Guidelines on Alternative Performance Measures. 13 February 2014 ESMA/2014/175

Consultation Paper. ESMA Guidelines on Alternative Performance Measures. 13 February 2014 ESMA/2014/175 Consultation Paper ESMA Guidelines on Alternative Performance Measures 13 February 2014 ESMA/2014/175 Date: 13 February 2014 ESMA/2014/175 Responding to this paper The European Securities and Markets Authority

More information

SUMMARY OF THE IMPACT ASSESSMENT

SUMMARY OF THE IMPACT ASSESSMENT EN EN EN EUROPEAN COMMISSION Brussels, 12.7.2010 SEC(2010) 846 COMMISSION STAFF WORKING DOCUMENT SUMMARY OF THE IMPACT ASSESSMENT Accompanying document to the Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT

More information

DETAILED TABLE OF CONTENTS

DETAILED TABLE OF CONTENTS DETAILED TABLE OF CONTENTS Table of Cases Table of Legislation List of Abbreviations xxii xxv lxi I. Introduction 1 1.1 EU Securities and Markets Regulation 1 1.2 Securities and Markets Regulation and

More information

Recent developments in the disclosure regime for economic interest in shares

Recent developments in the disclosure regime for economic interest in shares Recent developments in the disclosure regime for economic interest in shares by Peter Green and Jeremy Jennings-Mares, Morrison & Foerster (UK) LLP Most jurisdictions impose obligations requiring the disclosure

More information

COMMISSION STAFF WORKING DOCUMENT SUMMARY OF THE IMPACT ASSESSMENT. Accompanying the document

COMMISSION STAFF WORKING DOCUMENT SUMMARY OF THE IMPACT ASSESSMENT. Accompanying the document EUROPEAN COMMISSION Brussels, 7.3.2012 SWD(2012) 23 final COMMISSION STAFF WORKING DOCUMENT SUMMARY OF THE IMPACT ASSESSMENT Accompanying the document Proposal for a Regulation of the European Parliament

More information

CP ON TECHNICAL ADVICE ON CRITERIA AND FACTORS FOR INTERVENTION POWERS CONCERNING STRUCTURED DEPOSITS. Contents

CP ON TECHNICAL ADVICE ON CRITERIA AND FACTORS FOR INTERVENTION POWERS CONCERNING STRUCTURED DEPOSITS. Contents EBA/CP/2014/20 5 August 2014 Consultation Paper Draft Technical advice on possible delegated acts on criteria and factors for intervention powers concerning structured deposits under Article 41 and Article

More information

LONDON STOCK EXCHANGE HIGH GROWTH SEGMENT RULEBOOK 27 March 2013

LONDON STOCK EXCHANGE HIGH GROWTH SEGMENT RULEBOOK 27 March 2013 LONDON STOCK EXCHANGE HIGH GROWTH SEGMENT RULEBOOK 27 March 2013 Contents INTRODUCTION... 2 SECTION A ADMISSION... 3 A1: Eligibility for admission... 3 A2: Procedure for admission... 4 SECTION B CONTINUING

More information

Annex 1: Detailed outline

Annex 1: Detailed outline Annex 1: Detailed outline Key issues Possible text for proposal for a directive/regulation Comments/Explanations on ongoing and periodic transparency requirements for issuers, and holders, of securities

More information

COMMISSION STAFF WORKING PAPER EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT. Accompanying the document. Proposal for a

COMMISSION STAFF WORKING PAPER EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT. Accompanying the document. Proposal for a EUROPEAN COMMISSION Brussels, XXX SEC(2011) 1227 COMMISSION STAFF WORKING PAPER EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT Accompanying the document Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT

More information

Facilitating debt raising

Facilitating debt raising REGULATORY GUIDE 213 Facilitating debt raising May 2012 About this guide This guide is for listed entities, their advisers and investors involved in offers of quoted corporate bonds or convertible notes.

More information

Guidelines. on the applicable notional discount rate for variable remuneration EBA/GL/2014/01. 27 March 2014

Guidelines. on the applicable notional discount rate for variable remuneration EBA/GL/2014/01. 27 March 2014 GUIDELINES ON THE APPLICABLE NOTIONAL DISCOUNT RATE FOR VARIABLE REMUNERATION EBA/GL/2014/01 27 March 2014 Guidelines on the applicable notional discount rate for variable remuneration Contents 1. Executive

More information

DISCLOSURE OF CONTRACTS FOR DIFFERENCES

DISCLOSURE OF CONTRACTS FOR DIFFERENCES DISCLOSURE OF CONTRACTS FOR DIFFERENCES The United Kingdom Financial Services Authority ("FSA") has recently announced that its regime for disclosure of major shareholdings will be expanded to include

More information

General Protocol relating to the collaboration of the insurance supervisory authorities of the Member States of the European Union March 2008

General Protocol relating to the collaboration of the insurance supervisory authorities of the Member States of the European Union March 2008 CEIOPS-DOC-07/08 General Protocol relating to the collaboration of the insurance supervisory authorities of the Member States of the European Union March 2008 CEIOPS e.v. - Westhafenplatz 1 60327 Frankfurt

More information

Impact Assessment (IA)

Impact Assessment (IA) Title: UK implementation of the EU Accounting Directive: Chapters 1-9: Annual financial statements, consolidated financial statements, relatied reports of certain types of undertakings and general requirements

More information

Consultation: Auditing and ethical standards

Consultation: Auditing and ethical standards Consultation Financial Reporting Council December 2014 Consultation: Auditing and ethical standards Implementation of the EU Audit Directive and Audit Regulation The FRC is responsible for promoting high

More information

Guidelines. on the data collection exercise regarding high earners EBA/GL/2014/07. 16 July 2014

Guidelines. on the data collection exercise regarding high earners EBA/GL/2014/07. 16 July 2014 EBA/GL/2014/07 16 July 2014 Guidelines on the data collection exercise regarding high earners Contents 1. Executive summary 3 2. Background and rationale 4 3. EBA Guidelines on the data collection exercise

More information

GUIDE AND INSTRUCTIONS. Listed Companies. listedcompanies@fi.se 2013-10-16

GUIDE AND INSTRUCTIONS. Listed Companies. listedcompanies@fi.se 2013-10-16 GUIDE AND INSTRUCTIONS Listed Companies listedcompanies@fi.se 2013-10-16 October 16, 2013 Ref. 11-1971 TABLE OF CONTENTS Abbreviations and terms 4 Stock exchange information 7 Regulated market 7 Home Member

More information

Best execution under MIFID

Best execution under MIFID THE COMMITTEE OF EUROPEAN SECURITIES REGULATORS Ref: CESR/07-050b Best execution under MIFID Public consultation February 2007 11-13 avenue de Friedland - 75008 PARIS - FRANCE - Tel.: 33.(0).1.58.36.43.21

More information

Mandatory Provident Fund Schemes Authority COMPLIANCE STANDARDS FOR MPF APPROVED TRUSTEES. First Edition July 2005. Hong Kong

Mandatory Provident Fund Schemes Authority COMPLIANCE STANDARDS FOR MPF APPROVED TRUSTEES. First Edition July 2005. Hong Kong Mandatory Provident Fund Schemes Authority COMPLIANCE STANDARDS FOR MPF APPROVED TRUSTEES First Edition July 2005 Hong Kong Contents Glossary...2 Introduction to Standards...4 Interpretation Section...6

More information

Corporate Policy. Data Protection for Data of Customers & Partners.

Corporate Policy. Data Protection for Data of Customers & Partners. Corporate Policy. Data Protection for Data of Customers & Partners. 02 Preamble Ladies and gentlemen, Dear employees, The electronic processing of virtually all sales procedures, globalization and growing

More information

Council Conclusions on Finance for Growth and the Long-term Financing of the European Economy. ECOFIN Council meeting Brussels, 9 December 2014

Council Conclusions on Finance for Growth and the Long-term Financing of the European Economy. ECOFIN Council meeting Brussels, 9 December 2014 Council of the European Union PRESS EN COUNCIL CONCLUSIONS Brussels, 9 December 2014 Council Conclusions on Finance for Growth and the Long-term Financing of the European Economy ECOFIN Council meeting

More information

Recommended Acquisition of Networkers International plc Presentation to Analysts & Investors

Recommended Acquisition of Networkers International plc Presentation to Analysts & Investors Recommended Acquisition of Networkers International plc Presentation to Analysts & Investors 28 January 2015 Disclaimer THIS PRESENTATION IS NOT AN OFFER OR SOLICITATION OF AN OFFER TO BUY OR SELL SECURITIES.

More information

Green Paper of the European Commission on Long-Term Financing of the Economy

Green Paper of the European Commission on Long-Term Financing of the Economy June 2013 Green Paper of the European Commission on Long-Term Financing of the Economy Reply of NASDAQ OMX The NASDAQ OMX Group, Inc. delivers trading, exchange technology and public company services across

More information

Chapter 10 EQUITY SECURITIES RESTRICTIONS ON PURCHASE AND SUBSCRIPTION

Chapter 10 EQUITY SECURITIES RESTRICTIONS ON PURCHASE AND SUBSCRIPTION Chapter 10 EQUITY SECURITIES RESTRICTIONS ON PURCHASE AND SUBSCRIPTION Restrictions on Preferential Treatment of Purchase and Subscription Applications 10.01 Normally no more than ten per cent. of any

More information

PROVISIONAL REQUEST TO CESR FOR TECHNICAL ADVICE

PROVISIONAL REQUEST TO CESR FOR TECHNICAL ADVICE Ref. Ares(2010)892960-02/12/2010 PROVISIONAL REQUEST TO CESR FOR TECHNICAL ADVICE ON POSSIBLE LEVEL 2 MEASURES CONCERNING THE FUTURE DIRECTIVE ON ALTERNATIVE INVESTMENT FUND MANAGERS Table of Contents

More information

GUIDELINE ON THE APPLICATION OF THE INVESTMENT RESEARCH REQUIREMENTS UNDER THE FSA RULES IMPLEMENTING MIFID IN THE UK

GUIDELINE ON THE APPLICATION OF THE INVESTMENT RESEARCH REQUIREMENTS UNDER THE FSA RULES IMPLEMENTING MIFID IN THE UK GUIDELINE ON THE APPLICATION OF THE INVESTMENT RESEARCH REQUIREMENTS UNDER THE FSA RULES IMPLEMENTING MIFID IN THE UK This Guideline does not purport to be a definitive guide, but is instead a non-exhaustive

More information

Deutsche Schutzvereinigung für Wertpapierbesitz e.v. (DSW): Response to the Green Paper "Building a Capital Markets Union" (CMU) General remarks

Deutsche Schutzvereinigung für Wertpapierbesitz e.v. (DSW): Response to the Green Paper Building a Capital Markets Union (CMU) General remarks (DSW): Response to the Green Paper "Building a Capital Markets Union" (CMU) General remarks DSW, Germany s largest association for private investors and other financial services users very much welcomes

More information

Consultation Paper. Draft Regulatory Technical Standards

Consultation Paper. Draft Regulatory Technical Standards EBA/CP/2015/24 08 December 2015 Consultation Paper Draft Regulatory Technical Standards on separation of payment card schemes and processing entities under Article 7 (6) of Regulation (EU) 2015/751 Contents

More information

Setting up a Gibraltar Asset Management Company

Setting up a Gibraltar Asset Management Company Setting up a Gibraltar Asset Management Company 1. Why choose Gibraltar as a jurisdiction in which to set up an asset management company Gibraltar is within the European Union Regulated in accordance with

More information

DELEGATED REGULATION (EU)

DELEGATED REGULATION (EU) RTS 15: Draft regulatory technical standards on market making, market making agreements and marking making schemes COMMISSION DELEGATED REGULATION (EU) No /.. of [date] supplementing Directive 2014/65/EU

More information

Questions and Answers Application of the AIFMD

Questions and Answers Application of the AIFMD Questions and Answers Application of the AIFMD 30 September 2014 ESMA/2014/1194 Date: 30 September 2014 ESMA/2014/1194 Contents Section I: Remuneration 5 Section II: Notifications of AIFs 7 Section III:

More information

FEE DISCUSSION PAPER Reporting Issues in relation to Endorsed IFRS and Possible Implications for the Audit Report

FEE DISCUSSION PAPER Reporting Issues in relation to Endorsed IFRS and Possible Implications for the Audit Report Fédération des Experts Comptables Européens FEE DISCUSSION PAPER Reporting Issues in relation to Endorsed IFRS and Possible Implications for the Audit Report FOR COMMENT AND RESPONSE BY 31 MAY 2005 CONTENTS

More information

Guidelines on operational functioning of colleges

Guidelines on operational functioning of colleges EIOPA-BoS-14/146 EN Guidelines on operational functioning of colleges EIOPA Westhafen Tower, Westhafenplatz 1-60327 Frankfurt Germany - Tel. + 49 69-951119-20; Fax. + 49 69-951119-19; email: info@eiopa.europa.eu

More information

Market claims in T2S

Market claims in T2S Market claims in T2S Introduction This document aims at clarifying the market claim models in the context of the T2S implementation and recommending a course of actions. Much has been discussed in various

More information

REFORM OF STATUTORY AUDIT

REFORM OF STATUTORY AUDIT EU BRIEFING 14 MARCH 2012 REFORM OF STATUTORY AUDIT Assessing the legislative proposals This briefing sets out our initial assessment of the legislative proposals to reform statutory audit published by

More information

Specific amendments to the Capacity Allocation and Congestion Management Network Code

Specific amendments to the Capacity Allocation and Congestion Management Network Code Annex: Specific amendments to the Capacity Allocation and Congestion Management Network Code I. Amendments with respect to entry into force and application The Network Code defines deadlines for several

More information

7 IX. Equity (EEA Prospectus Directive) this is provisionally deleted pending review

7 IX. Equity (EEA Prospectus Directive) this is provisionally deleted pending review ICMA PRIMARY MARKET HANDBOOK (IPMA HANDBOOK) Section Seven Standard Documentation & Standard Language 7 IX Standard Form Selling Restrictions A B Debt (UK) Equity (EEA Prospectus Directive) this is provisionally

More information

Having regard to the Charter of Fundamental Rights of the European Union, and in particular Articles 7 and 8 thereof,

Having regard to the Charter of Fundamental Rights of the European Union, and in particular Articles 7 and 8 thereof, Opinion of the European Data Protection Supervisor on the Commission Proposal for a Directive of the European Parliament and of the Council amending Directive 2007/36/EC as regards the encouragement of

More information

(Legislative acts) REGULATIONS

(Legislative acts) REGULATIONS 24.3.2012 Official Journal of the European Union L 86/1 I (Legislative acts) REGULATIONS REGULATION (EU) No 236/2012 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 14 March 2012 on short selling and

More information

Terms of Business. 03 March 2014. Authorised and regulated by the Financial Conduct Authority

Terms of Business. 03 March 2014. Authorised and regulated by the Financial Conduct Authority Terms of Business 03 March 2014 Authorised and regulated by the Financial Conduct Authority Our Particulars The full name of our firm is Winterflood Securities Limited ( Wins ) The address of our registered

More information

European Securities Markets Expert Group

European Securities Markets Expert Group ESME read-across working group DP 1 November 2008 European Securities Markets Expert Group Differences between the Definitions of Qualified investor in the Prospectus Directive and Professional Client

More information

Mapping of outsourcing requirements

Mapping of outsourcing requirements Mapping of outsourcing requirements Following comments received during the first round of consultation, CEBS and the Committee of European Securities Regulators (CESR) have worked closely together to ensure

More information

Registration must be carried out by a top executive or a number of executives having the power to commit the whole company in the EU.

Registration must be carried out by a top executive or a number of executives having the power to commit the whole company in the EU. Questions and answers 1- What is the purpose of The Initiative? Why are we doing this? The purpose of the Supply Chain Initiative is to promote fair business practices in the food supply chain as a basis

More information

To this end ERCI fully endorses and adheres to the Principles of Personal Data Protection Act (2012). 1. The Purpose:

To this end ERCI fully endorses and adheres to the Principles of Personal Data Protection Act (2012). 1. The Purpose: Data Protection Policy: Policy Statement: ERC Institute (ERCI) collects and uses information about people with whom it communicates. As stipulated by the Personal Data Protection Act (2012) (hereinafter

More information

Response to FSA Consultation on Disclosure of Contracts for Differences

Response to FSA Consultation on Disclosure of Contracts for Differences Response to FSA Consultation on Disclosure of Contracts for Differences Introduction Hermes is one of the largest pension fund managers in the City of London and is wholly owned by the BT Pension Scheme.

More information

A. Document repository services for EU policy support

A. Document repository services for EU policy support A. Document repository services for EU policy support 1. CONTEXT Type of Action Type of Activity Service in charge Associated Services Project Reusable generic tools DG DIGIT Policy DGs (e.g. FP7 DGs,

More information

Insurance Europe response to Joint Committee consultation on guidelines for cross-selling practices

Insurance Europe response to Joint Committee consultation on guidelines for cross-selling practices Insurance Europe response to Joint Committee consultation on guidelines for cross-selling practices Our reference: COB-DIS-15-038 Date: 20 March 2015 Contact person: Arthur Hilliard, Policy Advisor, Conduct

More information

INSIDE AIM Issue 1- December 2009

INSIDE AIM Issue 1- December 2009 INSIDE AIM Issue 1- December 2009 WELCOME TO INSIDE AIM Welcome to this first edition of Inside AIM, a periodic newsletter from the AIM Regulation team. Inside AIM is designed to keep the AIM adviser community,

More information

Code of Practice on Electronic Invoicing in the EU

Code of Practice on Electronic Invoicing in the EU CEN/WS einvoicing Phase 3 Date: 2011-11 CEN Workshop AgreementTC WI Secretariat: NEN Code of Practice on Electronic Invoicing in the EU Status: for public review (23 November 2011-23 January 2012) ICS:

More information

SERIES A : GUIDANCE DOCUMENTS. Document Nr 3

SERIES A : GUIDANCE DOCUMENTS. Document Nr 3 DATRET/EXPGRP (2009) 3 - FINAL EXPERTS GROUP "THE PLATFORM FOR ELECTRONIC DATA RETENTION FOR THE INVESTIGATION, DETECTION AND PROSECUTION OF SERIOUS CRIME" ESTABLISHED BY COMMISSION DECISION 2008/324/EC

More information

Payment Factories: different ways of achieving payment efficiency. Jonathan Jordan EMEA Payments Market Manager, Citi Transaction Services

Payment Factories: different ways of achieving payment efficiency. Jonathan Jordan EMEA Payments Market Manager, Citi Transaction Services Payment Factories: different ways of achieving payment efficiency Jonathan Jordan EMEA Payments Market Manager, Citi Transaction Services The term Payment Factory is becoming increasingly talked about

More information

UCITS IV: Management Companies, and passports. February 2011

UCITS IV: Management Companies, and passports. February 2011 February 2011 This briefing paper sets out the new provisions which will apply to UCITS Management Companies, explains how the passport is now designed to work, and summarises the changes made to the long

More information

EUROPEAN COMMISSION CONSULTATION ON THE FUTURE OF EUROPEAN COMPANY LAW

EUROPEAN COMMISSION CONSULTATION ON THE FUTURE OF EUROPEAN COMPANY LAW 14/05/12 EUROPEAN COMMISSION CONSULTATION ON THE FUTURE OF EUROPEAN COMPANY LAW London Stock Exchange Group s additional responses to the consultation on the future of European company law. The London

More information

Shareholder Communication Policy. Spotless Group Holdings Limited ACN 154 229 562

Shareholder Communication Policy. Spotless Group Holdings Limited ACN 154 229 562 Shareholder Communication Policy Spotless Group Holdings Limited ACN 154 229 562 Adopted by the Company board on 26 March 2014 Contents Page 1 Purpose 1 2 Methods of communication 1 3 ASX releases 1 4

More information

General Corporate Social Responsibility Policy 20/10/15

General Corporate Social Responsibility Policy 20/10/15 General Corporate Social Responsibility Policy 20/10/15 CONTENT GENERAL CORPORATE SOCIAL RESPONSIBILITY POLICY 3 OBJECTIVES 3 1. Objectives of the General Corporate Social Responsibility Policy 3 PRINCIPLES

More information

COMMISSION OF THE EUROPEAN COMMUNITIES. Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

COMMISSION OF THE EUROPEAN COMMUNITIES. Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL COMMISSION OF THE EUROPEAN COMMUNITIES Brussels, 16.3.2004 COM(2004) 177 final 2004/0065 (COD) Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on statutory audit of annual accounts

More information

COMMUNICATION FROM THE COMMISSION TO THE COUNCIL, THE EUROPEAN PARLIAMENT AND THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE

COMMUNICATION FROM THE COMMISSION TO THE COUNCIL, THE EUROPEAN PARLIAMENT AND THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE EN EN EN EUROPEAN COMMISSION Brussels, COM(2010) COMMUNICATION FROM THE COMMISSION TO THE COUNCIL, THE EUROPEAN PARLIAMENT AND THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE Removing cross-border tax obstacles

More information

Streamline Financial Consolidation and Reporting for a Faster Close

Streamline Financial Consolidation and Reporting for a Faster Close SAP Brief SAP s for Enterprise Performance Management SAP Financial Consolidation Objectives Streamline Financial Consolidation and Reporting for a Faster Close Balancing speed and accuracy in financial

More information

RECOMMENDATIONS by THE COMPANY LAW SLIM WORKING GROUP on THE SIMPLIFICATION OF THE FIRST AND SECOND COMPANY LAW DIRECTIVES

RECOMMENDATIONS by THE COMPANY LAW SLIM WORKING GROUP on THE SIMPLIFICATION OF THE FIRST AND SECOND COMPANY LAW DIRECTIVES RECOMMENDATIONS by THE COMPANY LAW SLIM WORKING GROUP on THE SIMPLIFICATION OF THE FIRST AND SECOND COMPANY LAW DIRECTIVES Conclusions submitted by the Company Law Slim Working Group I. FIRST COUNCIL DIRECTIVE

More information

EBA FINAL draft Regulatory Technical Standards

EBA FINAL draft Regulatory Technical Standards EBA/RTS/2015/03 03 July 2015 EBA FINAL draft Regulatory Technical Standards on resolution colleges under Article 88(7) of Directive 2014/59/EU Contents 1. Executive summary 3 2. Background and rationale

More information

FX & MIFID ECB FX Contact Group

FX & MIFID ECB FX Contact Group FX & MIFID ECB FX Contact Group Richard Haynes Fixed Income Sales & Trading Compliance Department Citigroup 21 November 2007 FX & MIFID Introduction MiFID Overview What FX instruments are within scope

More information

Consultation document on the Review of the Insurance Mediation Directive (IMD) Commission Staff Working Paper

Consultation document on the Review of the Insurance Mediation Directive (IMD) Commission Staff Working Paper Consultation document on the Review of the Insurance Mediation Directive (IMD) Commission Staff Working Paper This document is a working document of the Internal Market and Services Directorate General

More information

of2o July of Transmission System Operators for Electricity

of2o July of Transmission System Operators for Electricity Energy Regulators OPINION OF THE AGENCY FOR THE COOPERATION OF ENERGY REGULATORS No 06/2015 2O July 2015 ON THE ENT$O-E IMPLEMENTATION PLAN 2016-2018 OF THE RESEARCH AND DEVELOPMENT ROADMAP 2013-2022 THE

More information

EXPLANATORY MEMORANDUM TO THE DATA RETENTION (EC DIRECTIVE) REGULATIONS 2007. 2007 No. 2199

EXPLANATORY MEMORANDUM TO THE DATA RETENTION (EC DIRECTIVE) REGULATIONS 2007. 2007 No. 2199 EXPLANATORY MEMORANDUM TO THE DATA RETENTION (EC DIRECTIVE) REGULATIONS 2007 2007 No. 2199 1. This explanatory memorandum has been prepared by the Home Office and is laid before Parliament by Command of

More information

COMMISSION STAFF WORKING DOCUMENT. Executive Summary of the Impact Assessment. Accompanying the document

COMMISSION STAFF WORKING DOCUMENT. Executive Summary of the Impact Assessment. Accompanying the document EUROPEAN COMMISSION Brussels, 11.9.2013 SWD(2013) 332 final COMMISSION STAFF WORKING DOCUMENT Executive Summary of the Impact Assessment Accompanying the document Proposal for a Regulation of the European

More information

LSEG Response to Consultation Paper: ESMA s technical advice on possible delegated acts concerning the Prospectus Directive 2010/73/EU

LSEG Response to Consultation Paper: ESMA s technical advice on possible delegated acts concerning the Prospectus Directive 2010/73/EU LSEG Response to Consultation Paper: ESMA s technical advice on possible delegated acts concerning the Prospectus Directive 2010/73/EU 15 July 2011 Submitted online at: www.esma.europa.eu Executive Summary

More information

Equity Sponsors. Eligibility Criteria, Application Process and Other Regulations. Release 2

Equity Sponsors. Eligibility Criteria, Application Process and Other Regulations. Release 2 Equity Sponsors Eligibility Criteria, Application Process and Other Regulations Release 2 14 April 2014 1 INTRODUCTION 1.1 This paper sets out the Irish Stock Exchange s requirements for applications from

More information

DBA response to CESR s Consultation Paper MiFID 2 nd Set of Mandates

DBA response to CESR s Consultation Paper MiFID 2 nd Set of Mandates DANISH BANKERS ASSOCIATION CESR DBA response to CESR s Consultation Paper MiFID 2 nd Set of Mandates Introduction The Danish Bankers Association appreciates this opportunity to provide comments on CESR

More information

Data controllers and data processors: what the difference is and what the governance implications are

Data controllers and data processors: what the difference is and what the governance implications are ICO lo : what the difference is and what the governance implications are Data Protection Act Contents Introduction... 3 Overview... 3 Section 1 - What is the difference between a data controller and a

More information

Final report. Guidelines on the minimum list of qualitative and quantitative recovery plan indicators EBA-GL-2015-02. 6 May 2015

Final report. Guidelines on the minimum list of qualitative and quantitative recovery plan indicators EBA-GL-2015-02. 6 May 2015 EBA-GL-2015-02 6 May 2015 Final report Guidelines on the minimum list of qualitative and quantitative recovery plan indicators 1 Contents 1. Executive Summary 3 2. Background and rationale 5 3. EBA Guidelines

More information

COMMISSION STAFF WORKING DOCUMENT. on the implementation of the definitive VAT regime for intra-eu trade

COMMISSION STAFF WORKING DOCUMENT. on the implementation of the definitive VAT regime for intra-eu trade EUROPEAN COMMISSION Brussels, 29.10.2014 SWD(2014) 338 final COMMISSION STAFF WORKING DOCUMENT on the implementation of the definitive VAT regime for intra-eu trade EN EN 1. INTRODUCTION In international

More information

EUROPEAN COMMISSION INFORMATION SOCIETY AND MEDIA DIRECTORATE-GENERAL. [title of the project] Grant Agreement No ICT PSP GRANT AGREEMENT

EUROPEAN COMMISSION INFORMATION SOCIETY AND MEDIA DIRECTORATE-GENERAL. [title of the project] Grant Agreement No ICT PSP GRANT AGREEMENT EUROPEAN COMMISSION INFORMATION SOCIETY AND MEDIA DIRECTORATE-GENERAL [title of the project] Grant Agreement No ICT PSP GRANT AGREEMENT Version 3, 20/01/2012 GRANT AGREEMENT NO The European Union ( the

More information

Repeal of Short Sale Tagging

Repeal of Short Sale Tagging REGULATION IMPACT STATEMENT Repeal of Short Sale Tagging July 2014 About this Regulation Impact Statement This Regulation Impact Statement (RIS) addresses ASIC s proposal to repeal the ASIC market integrity

More information

Questions & Answers clarifying key aspects of the SEPA Cards Framework

Questions & Answers clarifying key aspects of the SEPA Cards Framework Doc. EPC075-08 (Version 10.0) 11 June 2008 Questions & Answers clarifying key aspects of the SEPA Cards Framework Circulation: Publicly available Restricted: No SEPA a Guide to the Single Euro Payments

More information

COMMISSION STAFF WORKING PAPER EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT. Accompanying the document. Proposal for

COMMISSION STAFF WORKING PAPER EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT. Accompanying the document. Proposal for EUROPEAN COMMISSION Brussels, XXX SEC(2011) 1385 COMMISSION STAFF WORKING PAPER EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT Accompanying the document Proposal for a Directive of the European Parliament

More information

COMMISSION OF THE EUROPEAN COMMUNITIES

COMMISSION OF THE EUROPEAN COMMUNITIES EN EN EN COMMISSION OF THE EUROPEAN COMMUNITIES Brussels, 28.11.2008 COM(2008) 798 final COMMUNICATION FROM THE COMMISSION TO THE COUNCIL, THE EUROPEAN PARLIAMENT, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE

More information

Financial Services Guidance Note Outsourcing

Financial Services Guidance Note Outsourcing Financial Services Guidance Note Issued: April 2005 Revised: August 2007 Table of Contents 1. Introduction... 3 1.1 Background... 3 1.2 Definitions... 3 2. Guiding Principles... 5 3. Key Risks of... 14

More information

GUIDANCE NOTE ON THE CONCEPT OF RELIANCE

GUIDANCE NOTE ON THE CONCEPT OF RELIANCE Final version of 23/02/2009 COCOF 09/0002/01-EN EUROPEAN COMMISSION DIRECTORATE-GENERAL REGIONAL POLICY GUIDANCE NOTE ON THE CONCEPT OF RELIANCE ON THE WORK OF OTHER AUDITORS DISCLAIMER This is a Working

More information

(Legislative acts) DIRECTIVES

(Legislative acts) DIRECTIVES 1.7.2011 Official Journal of the European Union L 174/1 I (Legislative acts) DIRECTIVES DIRECTIVE 2011/61/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 8 June 2011 on Alternative Investment Fund

More information

COMMUNIQUÉ ON PRINCIPLES FOR INTERNET POLICY-MAKING OECD HIGH LEVEL MEETING ON THE INTERNET ECONOMY,

COMMUNIQUÉ ON PRINCIPLES FOR INTERNET POLICY-MAKING OECD HIGH LEVEL MEETING ON THE INTERNET ECONOMY, COMMUNIQUÉ ON PRINCIPLES FOR INTERNET POLICY-MAKING OECD HIGH LEVEL MEETING ON THE INTERNET ECONOMY, 28-29 JUNE 2011 The Seoul Declaration on the Future of the Internet Economy adopted at the 2008 OECD

More information

Consultation Paper. Proposed rules for recognised clearing houses and approved operators

Consultation Paper. Proposed rules for recognised clearing houses and approved operators Consultation Paper Proposed rules for recognised clearing houses and approved operators February 2013 Consultation Paper Proposed rules for recognised clearing houses and approved operators February 2013

More information

18 Square de Meeûs B-1050 Bruxelles +32 2 513 39 69 Fax +32 2 513 26 43 e-mail : info@efama.org www.efama.org

18 Square de Meeûs B-1050 Bruxelles +32 2 513 39 69 Fax +32 2 513 26 43 e-mail : info@efama.org www.efama.org EFAMA REPLY TO THE CONSULTATION PAPER ON CESR S TECHNICAL ADVICE TO THE EUROPEAN COMMISSION ON LEVEL 2 MEASURES RELATING TO MERGERS OF UCITS, MASTER-FEEDER UCITS STRUCTURES AND CROSS- BORDER NOTIFICATION

More information

EASYWAY ES5 RULES OF PROCEDURE FOR CHANGE CONTROL AND RELEASE MANAGEMENT OF DATEX II. Page 1 of 21. March 2011

EASYWAY ES5 RULES OF PROCEDURE FOR CHANGE CONTROL AND RELEASE MANAGEMENT OF DATEX II. Page 1 of 21. March 2011 EASYWAY ES5 RULES OF PROCEDURE FOR CHANGE CONTROL AND RELEASE MANAGEMENT OF DATEX II March 2011 European Commission Directorate General for Mobility and Transport Copyright 2011 Page 1 of 21 Document Control

More information

Capital Adequacy: Advanced Measurement Approaches to Operational Risk

Capital Adequacy: Advanced Measurement Approaches to Operational Risk Prudential Standard APS 115 Capital Adequacy: Advanced Measurement Approaches to Operational Risk Objective and key requirements of this Prudential Standard This Prudential Standard sets out the requirements

More information

Application of Data Protection Concepts to Cloud Computing

Application of Data Protection Concepts to Cloud Computing Application of Data Protection Concepts to Cloud Computing By Denitza Toptchiyska Abstract: The fast technological development and growing use of cloud computing services require implementation of effective

More information

CONSULTATION PAPER. Insurance (Fees) Regulations 2013 Registered Schemes Administrators (Fees) Order 2013

CONSULTATION PAPER. Insurance (Fees) Regulations 2013 Registered Schemes Administrators (Fees) Order 2013 CONSULTATION PAPER Insurance (Fees) Regulations 2013 Registered Schemes Administrators (Fees) Order 2013 This document is relevant to all entities regulated by the Insurance and Pensions Authority under

More information

FEEDBACK STATEMENT Responses to the Discussion Paper Separate Financial Statements 15 April 2015

FEEDBACK STATEMENT Responses to the Discussion Paper Separate Financial Statements 15 April 2015 FEEDBACK STATEMENT Responses to the Discussion Paper Separate Financial Statements 15 April 2015 Introduction In September 2014, the European Financial Reporting Advisory Group (EFRAG), the Spanish Instituto

More information

(Legislative acts) REGULATIONS

(Legislative acts) REGULATIONS 28.8.2014 Official Journal of the European Union L 257/1 I (Legislative acts) REGULATIONS REGULATION (EU) No 909/2014 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 23 July 2014 on improving securities

More information

ALFI Code of Conduct for Luxembourg Investment Funds

ALFI Code of Conduct for Luxembourg Investment Funds ALFI Code of Conduct for Luxembourg Investment Funds Introduction The purpose of the ALFI Code of Conduct is to provide boards of directors with a framework of high-level principles and best practice recommendations

More information

5439/15 PT/ek 1 DG E

5439/15 PT/ek 1 DG E Council of the European Union Brussels, 20 January 2015 5439/15 Interinstitutional File: 2013/0309 (COD) TELECOM 17 COMPET 12 MI 28 CONSOM 13 CODEC 70 NOTE from: Presidency to: Delegations No. Cion prop.:

More information

EBF response to ESMA consultation on the exemption for market making activities and primary market operations under Regulation (EU) 236/2012

EBF response to ESMA consultation on the exemption for market making activities and primary market operations under Regulation (EU) 236/2012 EBF Ref.: D1758E-2012 Brussels, 5 October 2012 Launched in 1960, the European Banking Federation is the voice of the European banking sector from the European Union and European Free Trade Association

More information

CESR Consultation Paper Standardisation and exchange trading of OTC derivatives FBF S RESPONSE

CESR Consultation Paper Standardisation and exchange trading of OTC derivatives FBF S RESPONSE 16th August 2010 CESR Consultation Paper Standardisation and exchange trading of OTC derivatives FBF S RESPONSE General remarks: The French Banking Federation (FBF) represents the interests of the banking

More information

Option Table - Directive on Statutory Audits of Annual and Consolidated Accounts

Option Table - Directive on Statutory Audits of Annual and Consolidated Accounts Option Table - Directive on Statutory Audits of Annual and Consolidated Accounts The purpose of this document is to highlight the changes in the options available to Member States and Competent Authorities

More information

ROADMAP. A. Context and problem definition

ROADMAP. A. Context and problem definition ROADMAP TITLE OF THE INITIATIVE PARTIAL REVISION OF REGULATIONS (EC) NOS 883/2004 and 987/2009 LEAD DG RESPONSIBLE UNIT EMPL/B4 DATE OF ROADMAP 12/03/2013 This indicative roadmap is provided for information

More information

UNOFFICIAL CONSOLIDATION AND TRANSLATION OF LAWS 128(I) OF 2009 AND 52(I) OF 2010 THE PAYMENT SERVICES LAWS OF 2009 TO 2010

UNOFFICIAL CONSOLIDATION AND TRANSLATION OF LAWS 128(I) OF 2009 AND 52(I) OF 2010 THE PAYMENT SERVICES LAWS OF 2009 TO 2010 UNOFFICIAL CONSOLIDATION AND TRANSLATION OF LAWS 128(I) OF 2009 AND 52(I) OF 2010 THE PAYMENT SERVICES LAWS OF 2009 TO 2010 This translation and consolidation of laws is not official. It has been prepared

More information

Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL. on insider dealing and market manipulation (market abuse)

Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL. on insider dealing and market manipulation (market abuse) EUROPEAN COMMISSION Brussels, 20.10.2011 COM(2011) 651 final 2011/0295 (COD) Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on insider dealing and market manipulation (market abuse)

More information

Supplementary Appendix Table A DESCRIPTION OF THE DIRECTIVES OF THE FINACIAL SERVICES ACTION PLAN (FSAP)

Supplementary Appendix Table A DESCRIPTION OF THE DIRECTIVES OF THE FINACIAL SERVICES ACTION PLAN (FSAP) Supplementary Appendix Table A DESCRIPTION OF THE DIRECTIVES OF THE FINACIAL SERVICES ACTION PLAN (FSAP) Directive Name Directive No. Deadline Implementation of the Settlement Finality Directive 1998/26/EC

More information

Making tax easier, quicker and simpler for small business

Making tax easier, quicker and simpler for small business Making tax easier, quicker and simpler for small business Response to the Office of Tax Simplification s Small business tax review: Final report HMRC administration March 2012 Introduction At Budget 2012

More information

2015 EDUCATION PAYROLL LIMITED STATEMENT OF INTENT

2015 EDUCATION PAYROLL LIMITED STATEMENT OF INTENT 2015 EDUCATION PAYROLL LIMITED STATEMENT OF INTENT Published in August 2015 Education Payroll Limited 2015 EDUCATION PAYROLL LIMITED STATEMENT OF INTENT CONTENTS Foreword 3 Who We Are 4 What We Do 5 How

More information