Although Accountancy Europe believes that all characteristics are relevant in an ESAP context, it would be
important to work with priorities in the beginning. For example: We support a wide scope of information in ESAP, but it would be good to start with certain information and add additional information at a later stage
(Please refer to our response to question 7, The scope of ESAP).

- Quality: High quality information (e.g. accuracy, completeness) on the ESAP is of utmost importance
considering that users, including investors, base their decisions upon the information provided. We suggest the following instruments to ensure data quality:
o Automated data quality system within the ESAP to ensure for example data consistency and
immutability
o Users should also be able to flag any data quality concerns
o Indicate and specify the involvement of auditors: Financial information of entities, except small entities
(and in some EU Member States also part of the small entities), is audited based on EU legislation. Non-
Financial Information is also increasingly assured. Auditors could also play a role when the data is
generated, uploaded and maintained within the ESAP.
o A feedback loop should be in place to report back actual errors to data sources and regulators

- Scope: We agree with a wide scope of information (see our response to question 7). Accountancy
Europe also strongly supports interconnected financial and non-financial information, please refer to our
thought leadership paper 'Core & More: An opportunity for smarter corporate reporting' (https://www.
accountancyeurope.eu/wp-content/uploads/170918-Publication-Core-More.pdf).

- Timeliness: Please refer to our response to question 13
- Source: Please refer to our response to question 14
- Immutability: Please refer to our response to question 14
- Information disclosed by non-listed entities, including SME’s on a voluntary basis: Please refer to our
responses to questions 17-21
- Information disclosed by financial market actors on a voluntary basis: We welcome all company
information meeting the quality criterion, disclosed on a voluntary basis, which might improve allocation of capital and promote market integration across the EU.

Downloads

• Response to the EC's Consultation on a European Single Access Point (ESAP) for financial and non-financial information publicly disclosed by companies