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However, due to the limited consultation period - two months instead of the usual three - Accountancy Europe cannot be expected to bring together all the planned input and therefore opted to submit comments on key topics relating to financial reporting and auditing instead of a detailed response to all aspects of the consultation. In addition, the consultation paper is scarce on problem analysis regarding key issues as well as on the arguments for some of the proposals, making it difficult to discuss and assess their various respective merits. As ESAs have moved convergence of supervision forward, it is not the time now to change their mandate and role significantly.
In theory, Accountancy Europe can consider different scenarios for financial supervision in the EU and Accountancy Europe remains committed to contribute to an informed discussion in this area but a thorough analysis of the pros and cons of the available models is key before taking any decisions.
The transfer of supervisory competences to the ESAs should also be assessed in the light of the current political climate in the EU (Brexit, national elections, etc.). There is an increasing scrutiny by EU citizens on centralization initiatives or the transfer of powers and any move in this regard should be sufficiently clear and duly justified. Accountancy Europe suggests the Commission to rethink this approach when structural issues – as is the case of the European System of Financial Supervisors - are at stake.