In this consultation issued by the European Securities and Markets Authority (ESMA), ALFI’s response followed a targeted approach, focusing on high-level assessment and spotted industry-related consideration. The response covers the following four sets of proposed rules:

• Sustainability indicators for distributed ledgers;
• Disclosures of inside information;
• Technical requirements for white papers;
• Business continuity requirements for crypto-asset service providers

ALFI generally favours an alignment with the various regulations in place, streamlining the approach and regulatory framework with traditional asset management to the extent possible. Nevertheless, we raise concerns with regards to the specificities of the crypto assets’ management, the respective role of each actor, including the various types of crypto assets service providers and issuers, with particular view on the large diversity and heterogeneity of DLT technical solutions and protocols, while highlighting the central role of the CASP.

We encourage flexibility to allow the CASP to select the appropriate and most efficient approach and organisation model, taking into account the size (according to the proportionality principle), the internal resources and client needs/request.

ALFI’s response details the industry’s considerations and concerns with regards to data availability, reliability and comparability (for sustainability disclosures), clarity, completeness and consistency across definitions, as well as adequate use of communication media (with regards to disclosure of inside information).

View the ALFI response.