We are generally in favour of standardised, uniform and database-based reporting which is readable for both humans and machines.
We also
welcome the associated aims, especially that of creating comparability
across businesses. However, we consider it vitally important that ESAP
introduces no additional information requirements compared to the status
quo. Also, the technical implementation of the ESAP must not restrict
the legal possibilities provided for in current legislation: We
therefore advocate, that in the further legislative process and in the
development of the technical implementation standards, care must be
taken to ensure that the additional efforts are as low as possible.
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© BDB - Bundesverband Deutscher Banken
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