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FEE welcomes the Commission’s decision to assess the cumulative impact of the EU regulatory package on financial services introduced over the last six years. In response to the financial crisis, legislators were required to take immediate action in order to restore public confidence in the financial sector. Following this intense period of regulation, it is now important to look back and review any points which may have been overlooked or caused unintended effects and unnecessary constraints to the industry, to markets or to the public at large.
Over the last six years an important number of initiatives were agreed at EU level and handed to Member States for transposition at national level. Although a number of countries have already advanced with transposition, the deadlines for an important number of initiatives have not yet been reached. Therefore, it is essential to allow for further time to pass in order to be able to assess the transposition and implementation process in a comprehensive manner and conclude which parts possibly need to be reviewed, especially in the light of the numerous Member States options included in certain initiatives. This applies to most of the recently adopted financial services initiatives and particularly the Audit Directive (2014/56/EU), Audit Regulation for Public Interest Entities (PIEs) (537/2014) and Accounting Directive (2013/34/EU).
FEE provides some evidence and flag the profession’s concerns and views on the impact of the following legislative requirements:
• Audit Reform: Audit Directive (2014/56/EU) and Audit Regulation (537/2014);
• The Country by Country Reporting provisions;
• Evolution in corporate reporting and how to better serve market needs, starting from the Accounting Directive;
• Accounting Directive (2013/34/EU);
• The International Accounting Regulation (IAS) 1606/2002;
• Auditors’ involvement in regulatory reporting and public disclosure for banks and insurance undertakings: indications of inconsistencies.