Consultation response

13 May 2014

FEE comments on ESMA consultation on Alternative Performance Measures (APMs)

 

On 13 May 2014, FEE issued a comment letter to ESMA on the ESMA consultation on Alternative Performance Measures (APMs).

FEE supports the acknowledgement from ESMA that APMs fulfil an important role in Corporate Reporting. We believe that APMs play an important role in Corporate Reporting as they can improve the communication between the entity and its stakeholders as long as they are reported in a transparent and unbiased manner.

FEE identifies six main areas that the [draft] guidelines should address regarding the reporting of APMs. These are:

1. The definition of APMs

2. The calculation of APMs,

3. Their reconciliation to financial information,

4. Their consistent application,

5. Benchmarking and industry comparisons, and

6. The “management’s interpretation” of APMs.

FEE supports the effort of producing this framework on the European level as it would contribute to enhancing the reliability, relevance and understandability of APMs. We note that in accordance with the ESMA regulation, National Competent Authorities (“NCAs”) should make every effort to comply with the [draft] guidelines and are expected to incorporate these guidelines into their supervisory procedures and practices, and monitor compliance. However FEE underlines that the ultimate enforcement of the [draft] guidelines lies with NCAs.

However, FEE believes that the scope of the [draft] guidelines and the definition of APMs are too wide and need to be revised. In addition, FEE suggests that the [draft] guidance should clarify how it would interact with other principles, guidance and rules that exist and govern the preparation and presentation of financial and non-financial information, for example accounting standards (i.e. IFRS) or local legislation.

For our detail comments please refer to the attached FEE comment letter.

Related files:

FEE Comment Letter

Related links:

ESMA consultation on APMs

 

Related content

Consultation responseLetter to Commissioner McGuinness on EFRAG’s draft ESRS

29 July 2022

Consultation responseEFRAG PTF-ESRS exposure drafts on European sustainability reporting standards

29 July 2022

Consultation responseISSB’s Climate Exposure Draft

28 July 2022

Consultation responseISSB’s General Requirements Exposure Draft

28 July 2022

NewsEU reaches agreement on the CSRD: a historic moment for corporate reporting

30 June 2022

PublicationPublic audit oversight

29 June 2022

EventESG & Corporate Governance: the evolving role of audit committees

20 June 2022

Consultation responseUS SEC’s climate-related disclosures proposed rule

17 June 2022

PublicationStronger internal controls to reduce corporate risks

17 June 2022

PublicationSustainability assurance under the CSRD

10 May 2022

PublicationAudit Quality Indicators: a global overview of initiatives

5 May 2022

Consultation responseLetter to Commissioner McGuinness on European sustainability reporting standards

21 April 2022

EventCSRD: state of play before the final EU negotiations

30 March 2022

NewsStronger corporate reporting in Europe – solutions by the accountancy profession

2 February 2022

Consultation responseEC’s consultation on corporate reporting – improving its quality and enforcement

2 February 2022

NewsSustainability will never do without governments

26 November 2021

Consultation responseEU Taxonomy and Article 8 Delegated Act implementation need clarity

17 November 2021

Consultation responseIASB’s Exposure Draft: Management Commentary and EFRAG’s Draft Comment Letter

15 November 2021

NewsTime to deliver on high quality sustainability reporting

12 November 2021

PublicationOrganisation of the public oversight of the audit profession in 30 European countries

8 November 2021

Sign up for our newsletter

* indicates required
Would you like to subscribe to our newsletter?
On which topics would you like to receive news?