In early January 2024, the European Supervisory Authorities (ESAs) presented the draft of their technical implementing standards outlining certain tasks of collection bodies and functionalities of the central European Access Portal (ESAP) for consultation. With the establishment of ESAP as a central hub for corporate data and documents across various regulatory frameworks, the information contained therein is set to be gradually made publicly accessible.
The German Banking Industry Committee (GBIC) responded to the draft and expressed strong concerns about the creation of new bureaucratic hurdles or duplicative burdens. No double reporting obligations must be introduced for the purposes of the ESAP. This also applies to the obligation to use an electronic seal. To avoid unnecessary burdens on market participants, GBIC advocates for the continued use of PDFs in line with the ESAP Regulation's definition for data-extractable or machine-readable formats. Any additional requirements beyond existing regulations would overshoot the goal. Furthermore, readability and comprehensibility of the data and documents to be published must take precedence over technical specifications, as these documents primarily serve the purpose of informing people.