EFFAS reply to ESMA Consultation on draft ITS specifying certain tasks of collection bodies and certain functionalities of the ESAP (March 2024)
We do not agree with the preferred approach presented (in particular paragraph 14, chapter 4 “Background and analysis” of the Consultation paper JC 2023 78, hereinafter referred to as 4.14). We do not agree with the assessment of the alternative approach in paragraph 4.16.
We agree that a “Europe-wide uniform minimum data quality” is the central success criterion so that the EU parliament’s goals, which are associated with the European Central Access Point, can be achieved at all.