GDF Response to EBA Consultation on Guidelines on templates to assist competent authorities in performing their supervisory duties regarding issuers’ compliance under MiCA
This response was developed with input from our members in GDF’s MICA Working Group, and we were pleased to provide a constructive assessment and technical analysis of the templates, identifying key areas of the templates that may require further consideration. The core areas identified are:
- Proportionality for Reasonable Reporting Encouraged,
- Further Alignment to Global and EU Standards Supported,
- Concerns Noted for Unprecedented Reporting Requirements,
- Identification of Competition Concerns, and
- Proposal of Adjustments to Reporting Requirements to Mitigate Risks.