EFFAS Comments to EFRAG on DCL Amendments to the Classification and Measurement of Financial Instruments IFRS 9 and IFRS 7 (June 2023)

The Commission supports in general EFRAG’s DCL comments on IASB ED IFRS-9 and IFRS-7 as it intends to contribute to the IASB due process. EFFAS also agrees with EFRAG’s proposal of clarifying the amendments proposed in the ED providing a good basis for evaluating whether contractual cash flows of financial assets with ESG-linked or similar features meet SPPI requirements.

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.