However, Insurance Europe does not support ESMA issuing these guidelines as Insurance Europe does not believe the current requirements have been proven to be inadequate. Moreover, Insurance Europe strongly believes that the use of APMs have an equally important role as financial statement figures to explain our business.

 

In particular, Insurance Europe has significant concerns that the scope of application of the ESMA draft guidelines is too broad in terms of the definition of APMs and also the application to public documents such as press announcements, interim financial statements and prospectuses. The latter category is especially unclear to us as a European Directive already covers specific guidelines.

 

Insurance Europe shares EFRAG’s view that ESMA has not provided evidence on why the existing CESR Recommendations on Alternative Performance Measures no longer provide adequate guidance. Furthermore, InsuranceEurope also shares EFRAG’s position that ESMA should clearly define the objective of the guidelines in a way that focuses on the usefulness of the resulting information for users.

 

InsuranceEurope has also the view that the ESMA draft guidelines if implemented would contradict the efforts of the IASB’s Disclosure Initiative which aims to make the disclosure requirements more effective.

 

Finally, InsuranceEurope would recommend for EFRAG to add more weight on the arguments used in its final comment letter, particularly in relation to ESMA’s Question 7 regarding reconciliation requirements. InsuranceEurope believes it would be beneficial to make ESMA fully aware of certain impracticalities. Especially, the general requirement to separately explain each reconciling item would lead to a significant increase in disclosure requirements.

 

Full letter