COMMUNITY On June 11, 2024, he sent his request to BSAG to answer in ESMA consultation on March 26, 2024 draft regulatory technical standards (RTS): connected registration and supervision of external auditorsaccording to EU Regulation 2023/2631 green link (EuGB).
For ICMA, in summary, the draft ESMA RTS on external auditors referred to in the Regulation; green link:
- should be accepted a an approach that is proportionate to the requirements of all external auditors (ER). The amount of documentation and information required by ESMA for ICMA is quite significant and in some cases seems to go beyond other regulatory regimes. In addition to requiring you to provide all relevant policies, procedures and organizational information, ESMA appears to require some grades are
- mecollective compliance of the board of directors and senior management
- me internal control
- that analyst knowledge
- It outsourcing contracts. in the latter case, there may be such elements for ICMA difficult to formalize for all providers. Given the voluntary nature of the EU GBS, reducing the overall administrative burden will help ensure that both potential and larger REs are ready to provide EU GBS-related services and thus enter the EU GBS regulatory regime.
- L:The interaction between the GGB Regulation and the ESG Ratings Regulation should be clear to avoid overlaps; as many external auditors will provide different services, including PSOs and ESG ratings, entity-level requirements should be developed to avoid unnecessary bureaucracy and paperwork; where possible, they should also be designed to take advantage of existing structural and governance arrangements and processes. Organizations intending to provide ESG ratings and external reviews must be able to be authorized and comply with both the ESG Ratings Regulation and the External Ratings Regulation.
- It intra-group agreements should be exempt from outsourcing rulesExternal auditors may obtain different expertise when issuing opinions through their parent, subsidiaries and affiliates, which should not trigger the outsourcing rules because that is not the purpose.
- Analyst knowledge and experienceESMA should consider requiring some knowledge from the external auditor EU Taxonomy and EU GBSshow itself-declaration; however, given that EU classification is a relatively new regime, the knowledge requirements they should not create an access barrierbut rather take a balanced approach, as businesses familiarize themselves with practical application and best practice guidance on EU classification and GBS.
