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InsuranceEurope believes that it would be beneficial if ESMA should more clearly define the objective of the guidelines in a way that focuses on the usefulness of the resulting information for users.
Moreover, InsuranceEurope strongy believes that use of APMs have an equally importnat role as financial statement figures to explain business.
The scope of the guidelines is already partly covered by an EU Directive on Prospectuses and they could contradict the efforts of the IASB’s disclosure initiative, a broad-based initiative to explore how disclosures in IFRS financial reporting can be improved.
In addition, some of the proposed APMs are not always reconcilable with IFRS, specifically in the case of life insurers.