EuropeanIssuers very much welcomes the call for evidence as they aim to ensure that EU policy creates an environment in which companies can raise capital through the public markets and can deliver growth over the longer-term.
Over the years, EU financial regulation has become extremely complex. As a result, the costs to companies are increasingly higher. This has a negative impact on all quoted companies, although often smaller ones are affected disproportionately due to a lack of available resources. Regulation is thus not designed for the needs of all the approximately 13,000 quoted companies across Europe.
EuropeanIssuers therefore believe that the call for evidence on the EU regulatory framework for financial services measuring the possible impact and interaction of financial legislation is an important step forward in order to fully understand burdens on companies.
To go one step further and to avoid inconsistencies as well as incoherencies in the future, EuropeanIssuers recommends for future initiatives of the EU Commission to consider new proposal only when absolutely necessary and following conducting well-grounded and well-designed impact assessment studies (following the “Better regulation” approach).
Consequently, they think that EU institutions should spend more time on deep and thorough impact assessments, including scrutiny of consequences and interactions of new proposals with the existing legislation. Impact assessments should be especially carried out by the Commission but – pursuant to the Better Regulation Guidelines - also by European Parliament and Council, in advance of substantial amendments.
Moreover, the consultation of various stakeholders should be enhanced. For instance, EuropeanIssuers would appreciate to see a higher representation of issuers within various stakeholder and expert groups, maybe even by establishing a dedicated ‘issuers experts group’.
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