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1. Is the principle, whereby a prospectus is required whenever securities are admitted to trading on a regulated market or offered to the public, still valid? In principle, should a prospectus be necessary for:(prospectus-required)
Please describe which different treatment should be granted to the two purposes:(specify-different-prospectus-required)
Please describe what other possible reasons why a prospectus is necessary:(specify-other-prospectus-required)
Additional comments on the principle whereby a prospectus is required whenever securities are admitted to trading on a regulated market or offered to the public:(comments-prospectus-required)
a) Please estimate the cost of producing a prospectus (between how many euros and how many euros for a total consideration of how many euros): Equity prospectus(cost-equity-prospectus) : Minimum cost (in €)([ID8])
a) Please estimate the cost of producing a prospectus (between how many euros and how many euros for a total consideration of how many euros): Equity prospectus(cost-equity-prospectus) : Maximum cost (in €)([ID9])
a) Please estimate the cost of producing a prospectus (between how many euros and how many euros for a total consideration of how many euros): Equity prospectus(cost-equity-prospectus) : For a total consideration of (in €)(cost-total-consideration)
a) Please estimate the cost of producing a prospectus (between how many euros and how many euros for a total consideration of how many euros): Non-equity prospectus(cost-non-equity prospectus) : Minimum cost (in €)([ID8])
a) Please estimate the cost of producing a prospectus (between how many euros and how many euros for a total consideration of how many euros): Non-equity prospectus(cost-non-equity prospectus) : Maximum cost (in €)([ID9])
a) Please estimate the cost of producing a prospectus (between how many euros and how many euros for a total consideration of how many euros): Non-equity prospectus(cost-non-equity prospectus) : For a total consideration of (in €)(cost-total-consideration)
a) Please estimate the cost of producing a prospectus (between how many euros and how many euros for a total consideration of how many euros): Base prospectus(a) : Minimum cost (in €)([ID8])
a) Please estimate the cost of producing a prospectus (between how many euros and how many euros for a total consideration of how many euros): Base prospectus(a) : Maximum cost (in €)([ID9])
a) Please estimate the cost of producing a prospectus (between how many euros and how many euros for a total consideration of how many euros): Base prospectus(a) : For a total consideration of (in €)(cost-total-consideration)
a) Please estimate the cost of producing a prospectus (between how many euros and how many euros for a total consideration of how many euros): Initial public offer (IPO) prospectus(cost-ipo-prospectus) : Minimum cost (in €)([ID8])
a) Please estimate the cost of producing a prospectus (between how many euros and how many euros for a total consideration of how many euros): Initial public offer (IPO) prospectus(cost-ipo-prospectus) : Maximum cost (in €)([ID9])
a) Please estimate the cost of producing a prospectus (between how many euros and how many euros for a total consideration of how many euros): Initial public offer (IPO) prospectus(cost-ipo-prospectus) : For a total consideration of (in €)(cost-total-consideration)
a) Please estimate the cost of producing a prospectus (between how many euros and how many euros for a total consideration of how many euros): Don’t know (add an X in the next three fields)(cost-dont-know) : Minimum cost (in €)([ID8])
a) Please estimate the cost of producing a prospectus (between how many euros and how many euros for a total consideration of how many euros): Don’t know (add an X in the next three fields)(cost-dont-know) : Maximum cost (in €)([ID9])
a) Please estimate the cost of producing a prospectus (between how many euros and how many euros for a total consideration of how many euros): Don’t know (add an X in the next three fields)(cost-dont-know) : For a total consideration of (in €)(cost-total-consideration)
Additional comments on the cost of producing a prospectus:(comments-cost-of-production)
b) What is the share, in per cent, of the following in the total costs of a prospectus: Issuer’s internal costs(issuers-share-in-cost) : Share in the total costs (in %)([ID8])
b) What is the share, in per cent, of the following in the total costs of a prospectus: Audit costs(cost-non-equity prospectus) : Share in the total costs (in %)([ID8])
b) What is the share, in per cent, of the following in the total costs of a prospectus: Legal fees(a) : Share in the total costs (in %)([ID8])
b) What is the share, in per cent, of the following in the total costs of a prospectus: Competent authorities’ fees(cost-ipo-prospectus) : Share in the total costs (in %)([ID8])
b) What is the share, in per cent, of the following in the total costs of a prospectus: Other costs (please specify which)(cost-dont-know) : Share in the total costs (in %)([ID8])
b) What is the share, in per cent, of the following in the total costs of a prospectus: Don’t know (add an X in the next three fields)(dont-know-share-in-cost) : Share in the total costs (in %)([ID8])
Additional comments on the share in the total costs of a prospectus:(comments-share-in-cost)
c. What fraction of the costs indicated above would be incurred by an issuer anyway, when offering securities to the public or having them admitted to trading on a regulated market, even if there were no prospectus requirements, under both EU and national law? Please estimate this fraction.(incurred-costs)
Please specify which fraction of the costs above would be incurred anyway (in %):(yes-incurred-costs)
Additional comments on the fraction of the costs indicated above that would be incurred by an issuer anyway:(comments-incurred-costs)
3. Bearing in mind that the prospectus, once approved by the home competent authority, enables an issuer to raise financing across all EU capital markets simultaneously, are the additional costs of preparing a prospectus in conformity with EU rules and getting it approved by the competent authority outweighed by the benefit of the passport attached to it?(costs-outweighed)
Additional comments on the possibility that additional costs are outweighed by the benefit of the passport attached to the prospectus:(comments-costs-outweighed)
a) the EUR 5 000 000 threshold of Article 1(2)(h):(5m-threshold)
Please specify from EUR 5 000 000 up to how many euros:(yes-5m-threshold)
Please justify your answer on the EUR 5 000 000 threshold:(comments-5m-threshold)
b) the EUR 75 000 000 threshold of Article 1(2)(j):(75m-threshold)
Please specify from EUR 75 000 000 up to how many euros:(yes-75m-threshold)
Please justify your answer on the EUR 75 000 000 threshold:(comment-75m-threshold)
c) the 150 persons threshold of Article 3(2)(b):(150-persons-threshold)
Please specify from 150 persons up to how many persons:(yes-150-persons-threshold)
Please justify your answer on the 150 persons threshold:(comments-150-persons-threshold)
d) the EUR 100 000 threshold of Article 3(2)(c) & (d):(100000-threshold)
Please specify from EUR 100 000 up to how many euros:(yes-100000-threshold)
Please justify your answer on the EUR 100 000 threshold:(comment-100000-threshold)
5. Would more harmonisation be beneficial in areas currently left to Member States’ discretion, such as the flexibility given to Member States to require a prospectus for offers of securities with a total consideration below EUR 5 000 000?(harmonisation)
Please specify what other area:(other-harmonisation)
Please justify your answer on whether more harmonisation be beneficial:(comment-harmonisation)
6. Do you see a need for including a wider range of securities in the scope of the Directive than transferable securities as defined in Article 2(1)(a)?(wider-range)
Please justify your answer on the possibility of including a wider range of securities in the scope of the Directive:(comments-wider-range)
7. Can you identify any other area where the scope of the Directive should be revised and if so how? Could other types of offers and admissions to trading be carried out without a prospectus without reducing consumer protection?(other-area)
Please specify what other area:(yes-other-area)
Please justify your answer on possible other area:(comments-other-area)
8. Do you agree that while an initial public offer of securities requires a full-blown prospectus, the obligation to draw up a prospectus could be mitigated or lifted for any subsequent secondary issuances of the same securities, provided that relevant information updates are made available by the issuer?(mitigation)
Please justify your answer on the possible mitigation of the obligation to draw up a prospectus:(comments-mitigation)
9. How should Article 4(2)(a) be amended in order to achieve this objective?(article-4-2)
Please specify to what extent the 10% threshold should be raised:(threshold-raised-article-4-2)
Please justify your answer on the amendment of Article 4(2):(comments-article-4-2)
10. If the exemption for secondary issuances were to be made conditional to a full-blown prospectus having been approved within a certain period of time, which timeframe would be appropriate?(exemption-period)
Please specify the lenght of the ideal timeframe (in years):(years-exemption-period)
Please justify your answer on the convenience of having a timeframe for the exemption:(comments-exemption-period)
11. Do you think that a prospectus should be required when securities are admitted to trading on an MTF?(mtf)
Please justify your answer on whether a prospectus should be required when securities are admitted to trading on an MTF:(comments-mtf)
12. Were the scope of the Directive extended to the admission of securities to trading on MTFs, do you think that the proportionate disclosure regime (either amended or unamended) should apply?(proportionate-disclosure)
Please justify your answer on the possible application of the proportionate disclosure regime:(comments-proportionate-disclosure)
13. Should future European long term investment funds (ELTIF), as well as certain European social entrepreneurship funds (EuSEF) and European venture capital funds (EuVECA) of the closed-ended type and marketed to non-professional investors be exempted from the obligation to prepare a prospectus under the Directive, while remaining subject to the bespoke disclosure requirements under their sectorial legislation and to the PRIIPS key information document?(eltifs-exemption)
Please state your reasoning, if necessary by drawing comparisons between the different sets of disclosure requirements which cumulate for these funds:(comments-eltifs-exemption)
14. Is there a need to extend the scope of the exemption provided to employee shares schemes in Article 4(1)(e) to non-EU, private companies?(non-eu-companies)
Please explain your answer on the possible extension of the scope of the exemption provided to employee shares schemes in Article 4(1)(e) to non-EU, private companies and provide supporting evidence:(comments-non-eu-companies)
15. Do you consider that the system of exemptions granted to issuers of debt securities above a denomination per unit of EUR 100 000 under the Prospectus and Transparency Directives may be detrimental to liquidity in corporate bond markets?(100000-detrimental)
If so, what targeted changes could be made to address this without reducing investor protection?(yes-100000-detrimental)
Please justify your answer on whether the system of exemptions may be detrimental to liquidity in corporate bond markets:(comments-100000-detrimental)
a) Do you then think that the EUR 100 000 threshold should be lowered?(threshold-lowered-yes-100000-detrimental)
Please specify to which amount (in euro) the EUR 100 000 threshold should be lowered:(yes-threshold-lowered-yes-100000-detrimental)
Please justify your answer on whether the EUR 100 000 threshold should be lowered:(comments-threshold-lowered-yes-100000-detrimental)
b) Do you then think that some or all of the favourable treatments granted to the above issuers should be removed?(treatments-removed-yes-100000-detrimental)
Please indicate to what extent the favourable treatments granted to the above issuers should be removed:(yes-treatments-removed-yes-100000-detrimental)
Please justify your answer on whether the favourable treatments granted to the above issuers should be removed:(comments-treatments-removed-yes-100000-detrimental)
c) Do you then think that the EUR 100 000 threshold should be removed altogether and the current exemptions should be granted to all debt issuers, regardless of the denomination per unit of their debt securities?(threshold-removed-yes-100000-detrimental)
Please justify your answer on whether the EUR 100 000 threshold should be removed altogether and the current exemptions should be granted to all debt issuers, regardless of the denomination per unit of their debt securities:(comments-threshold-removed-yes-100000-detrimental)
16. In your view, has the proportionate disclosure regime (Article 7(2)(e) and (g)) met its original purpose to improve efficiency and to take account of the size of issuers? If not, why?(original-purpose)
Please justify your answer on whether the proportionate disclosure regime has met its original purpose:(comments-original-purpose)
a) Proportionate regime for rights issues(issuers-proportionate-regime)
Please justify your answer on the proportionate regime for rights issues:(comments-issuers-proportionate-regime)
b) Proportionate regime for small and medium-sized enterprises and companies with reduced market capitalisation(sme-proportionate-regime)
Please justify your answer on the proportionate regime for small and medium-sized enterprises and companies with reduced market capitalisation:(comments-sme-proportionate-regime)
c) Proportionate regime for issues by credit institutions referred to in Article 1(2)(j) of Directive 2003/71/EC(credit-institutions-proportionate-regime)
Please justify your answer on the proportionate regime for issues by credit institutions referred to in Article 1(2)(j) of Directive 2003/71/EC:(comments-credit-institutions-proportionate-regime)
a) Proportionate regime for rights issues:(issues-proportionate-regime-modification)
b) Proportionate regime for small and medium-sized enterprises and companies with reduced market capitalisation:(sme-proportionate-regime-modification)
c) Proportionate regime for issues by credit institutions referred to in Article 1(2)(j) of Directive 2003/71/EC:(credit-institutions-proportionate-regime-modification)
19. If the proportionate disclosure regime were to be extended, to whom should it be extended?(extention-to-whom)
Please specify which types of issuers or issues not yet covered:(issuers-extention-to-whom)
Please specify which admissions of securities to trading on an MTF:(mtf-extention-to-whom)
Please specify which other possibilities:(other-extention-to-whom)
Please justify your answer on to whom the proportionate disclosure regime should be extended:(comments-extention-to-whom)
20. Should the definition of “company with reduced market capitalisation” (Article 2(1)(t)) be aligned with the definition of SME under Article 4(1)(13) of Directive 2014/65/EU by raising the capitalisation limit to EUR 200 000 000?(reduced-market-capitalisation)
Please justify your answer on the possible alignment of “company with reduced market capitalisation” (Article 2(1)(t)) with the definition of SME under Article 4(1)(13) of Directive 2014/65/EU by raising the capitalisation limit to EUR 200 000 000:(comments-reduced-market-capitalisation)
21. Would you support the creation of a simplified prospectus for SMEs and companies with reduced market capitalisation admitted to trading on an SME growth market, in order to facilitate their access to capital market financing?(sme-simplified-prospectus)
Please justify your answer on the possible creation of a simplified prospectus for SMEs and companies with reduced market capitalisation admitted to trading on an SME growth market:(comments-sme-simplified-prospectus)
22. Please describe the minimum elements needed of the simplified prospectus for SMEs and companies with reduced market capitalisation admitted to trading on an SME growth market:(content-simplified-prospectus)
23. Should the provision of Article 11 (incorporation by reference) be recalibrated in order to achieve more flexibility?(recalibrated-flexibility)
Please please indicate how this could be achieved (in particular, indicate which documents should be allowed to be incorporated by reference):(yes-recalibrated-flexibility)
Please justify your answer on the possible recalibration of the provision of Article 11 (incorporation by reference) in order to achieve more flexibility:(comments-recalibrated-flexibility)
24. a) Should documents which were already published/filed under the Transparency Directive no longer need to be subject to incorporation by reference in the prospectus (i.e. neither a substantial repetition of substance nor a reference to the document would need to be included in the prospectus as it would be assumed that potential investors have anyhow access and thus knowledge of the content of these documents)?(documents-incorporated-by-reference)
Please justify your answer on whether documents which were already published/filed under the Transparency Directive should no longer need to be subject to incorporation by reference in the prospectusr:(comments-documents-incorporated-by-reference)
b) Do you see any other possibilities to better streamline the disclosure requirements of the Prospectus Directive and the Transparency Directive?(better-streamline-disclosure-requirements)
Please justify your whether you see any other possibilities to better streamline the disclosure requirements of the Prospectus Directive and the Transparency Directive:(comments-better-streamline-disclosure-requirements)
25. Article 6(1) Market Abuse Directive obliges issuers of financial instruments to inform the public as soon as possible of inside information which directly concerns the said issuers; the inside information has to be made public by the issuer in a manner which enables fast access and complete, correct and timely assessment of the information by the public. Could this obligation substitute the requirement in the Prospectus Directive to publish a supplement according to Article 17 without jeopardising investor protection in order to streamline the disclosure requirements between Market Abuse Directive and Prospectus Directive?(obligation-substitute-supplement-requirement)
Please justify your whether the above-mentioned obligation could substitute the requirement in the Prospectus Directive to publish a supplement according to Article 17 without jeopardising investor protection in order to streamline the disclosure requirements between Market Abuse Directive and Prospectus Directive:(comments-obligation-substitute-supplement-requirement)
26. Do you see any other possibility to better streamline the disclosure requirements of the Market Abuse Directive and the Prospectus Directive?(other-possibility-better-streamline-disclosure-requirements)
Please justify your whether you see any other possibility to better streamline the disclosure requirements of the Market Abuse Directive and the Prospectus Directive:(comments-other-possibility-better-streamline-disclosure-requirements)
27. Is there a need to reassess the rules regarding the summary of the prospectus?(reassess-rules)
Please provide suggestions for re-assessment of the concept of key information and its usefulness for retail investors:(key-info-reassess-rules)
Please provide suggestions for re-assessment of the comparability of the summaries of similar securities:(comparability-reassess-rules)
Please provide suggestions for re-assessment of the interaction with final terms in base prospectuses:(final-terms-reassess-rules)
Please justify your answer on the possibility to reassess the rules regarding the summary of the prospectus:(comments-reassess-rules)
28. For those securities falling under the scope of both the packaged retail and insurance-based investment products (PRIIPS) Regulation, how should the overlap of information required to be disclosed in the key investor document (KID) and in the prospectus summary, be addressed?(address-overlap)
Please indicate which redundant information would be concerned:(no-duplication-address-overlap)
Please specify which other ways you would consider to addressing the overlap of information required to be disclosed:(other-address-overlap)
Please justify your answer on the possible ways to address the overlap of information required to be disclosed:([ID27])
29. Would you support introducing a maximum length to the prospectus? If so, how should such a limit be defined?(maximum-length)
What should be the maximum number of pages?(pages-maximum-length)
What other criteria could be used to set the maximum length of the prospectus:(other-maximum-length)
Please justify your answer on the possible introduction of a maximum length to the prospectus:(comments-maximum-length)
30. Alternatively, are there specific sections of the prospectus which could be made subject to rules limiting excessive lengths? How should such limitations be spelled out?(sections-limiting-length)
31. Do you believe the liability and sanctions regimes the Directive provides for are adequate? : The overall civil liability regime of Article 6 (article-6-liability-regimes-adequate)
31. Do you believe the liability and sanctions regimes the Directive provides for are adequate? : The specific civil liability regime for prospectus summaries of Article 5(2)(d) and Article 6(2) (article-5-6-liability-regimes-adequate)
31. Do you believe the liability and sanctions regimes the Directive provides for are adequate? : The sanctions regime of Article 25 (article-25-liability-regimes-adequate)
If not, how could they be improved?(if-not-liability-regimes-adequate)
Please justify your answer on the adequacy of the liability and sanctions regimes the Directive provides for:(comments-liability-regimes-adequate)
32. Have you identified problems relating to multi-jurisdiction (cross-border) liability with regards to the Directive?(cross-border-liability)
If you have identified problems relating to multi-jurisdiction (cross-border) liability, please give details:(yes-cross-border-liability)
Please justify your answer on possible problems relating to multi-jurisdiction (cross-border) liability:(comments-cross-border-liability)
33. Are you aware of material differences in the way national competent authorities assess the completeness, consistency and comprehensibility of the draft prospectuses that are submitted to them for approval?(national-auth-assess)
If you aware of material differences, please provide examples/evidence:(yes-national-auth-assess)
Please justify your answer on possible material differences in the way national competent authorities assess the completeness, consistency and comprehensibility of the draft prospectuses:(comments-national-auth-assess)
34. Do you see a need for further streamlining of the scrutiny and approval procedures of prospectuses by NCAs?(scrutiny-streamlining)
If you think there is a need for further streamlining of the scrutiny and approval procedures of prospectuses by NCAs, please specify in which regard:(yes-scrutiny-streamlining)
Please justify your answer on the possible need for further streamlining of the scrutiny and approval procedures of prospectuses by NCAs:(comments-scrutiny-streamlining)
35. Should the scrutiny and approval procedure be made more transparent to the public?(scrutiny-transparent)
If you think the scrutiny and approval procedure should be made more transparent to the public, please indicate how this should be achieved:(yes-scrutiny-transparent)
Please justify your answer on the opportunity to make the scrutiny and approval procedure more transparent to the public:(comments-scrutiny-transparent)
36. Would it be conceivable to allow marketing activities by the issuer in the period between the first submission of a draft prospectus and the approval of its final version, under the premise that no legally binding purchase or subscription would take place until the prospectus is approved?(allow-marketing-activities)
If you think it is conceivable to allow marketing activities by the issuer in the period between the first submission of a draft prospectus and the approval of its final version, please provide details on how this could be achieved:(yes-allow-marketing-activities)
Please justify your answer on the possibility to allow marketing activities by the issuer in the period between the first submission of a draft prospectus and the approval of its final version:(comments-allow-marketing-activities)
37. What should be the involvement of national competent authorities (NCA) in relation to prospectuses? Should NCA:(national-authorities-involvement)
Please describe the possible consequences of your favoured approach, in particular in terms of market efficiency and invest protection:(comments-national-authorities-involvement)
38. Should the decision to admit securities to trading on a regulated market (including, where applicable, to the official listing as currently provided under the Listing Directive), be more closely aligned with the approval of the prospectus and the right to passport?(securities-regulated-market)
Please explain your reasoning and the benefits (if any) this could bring to issuers:([ID34])
39. a) Is the EU passporting mechanism of prospectuses functioning in an efficient way?(passporting-mechanism-efficient)
What improvements could be made to the EU passporting mechanism of prospectuses?(improvements-passporting-mechanism-efficient)
Please justify your answer on whether the EU passporting mechanism of prospectuses is functioning in an efficient way:(comments-passporting-mechanism-efficient)
b) Could the notification procedure between NCAs of home and host Member States set out in Article 18 be simplified (e.g. limited to the issuer merely stipulating in which Member States the offer should be valid, without any involvement from NCAs) without compromising investor protection?(notification-procedure-simplified)
Please justify your answer on whether the notification procedure set out in Article 18 between NCAs of home and host Member States could be simplified:(comments-notification-procedure-simplified)
a) The use of the base prospectus facility should be allowed for all types of issuers and issues and the limitations of Article 5(4)(a) and (b) should be removed:(base-prospectus-support-changes)
Please justify your answer on whether or not you support the possibility for the use of the base prospectus facility to be allowed for all types of issuers and issues, and for the limitations of Article 5(4)(a) and (b) to be removed:(comments-base-prospectus-support-changes)
b) The validity of the base prospectus should be extended beyond one year:(above-1-year-support-changes)
Please indicate the appropriate validity length:(yes-above-1-year-support-changes)
Please justify your answer on whether or not you support the possibility for the validity of the base prospectus to be extended beyond one year:(comments-above-1-year-support-changes)
c) The Directive should clarify that issuers are allowed to draw up a base prospectus as separate documents (i.e. as a tripartite prospectus), in cases where a registration document has already been filed and approved by the NCA:(separate documents-support-changes)
Please justify your answer on whether or not you support the possibility for the Directive to clarify that issuers are allowed to draw up a base prospectus as separate documents (i.e. as a tripartite prospectus), in cases where a registration document has already been filed and approved by the NCA:(comments-separate documents-support-changes)
d) Assuming that a base prospectus may be drawn up as separate documents (i.e. as a tripartite prospectus), it should be possible for its components to be approved by different NCAs:(components-approved-support-changes)
Please justify your answer on whether it should be possible for the  components of a tripartite prospectus to be approved by different NCAs:(comments-components-approved-support-changes)
e) The base prospectus facility should remain unchanged:(base-unchanged-support-changes)
Please justify your answer on whether the base prospectus facility should remain unchanged:(comments-base-unchanged-support-changes)
f) Other possible changes or clarifications to the base prospectus facility (please specify):(other-support-changes)
41. How is the “tripartite regime” (Articles 5 (3) and 12) used in practice and how could it be improved to offer more flexibility to issuers?(tripartite-regime)
42. Should the dual regime for the determination of the home Member State for non-equity securities featured in Article 2(1)(m)(ii) be amended?(amend-dual-regime)
Please explain how this dual regime should be amended:(yes-amend-dual-regime)
Please justify your answer on the possibility for the dual regime for the determination of the home Member State for non-equity securities to be amended:(comments-amend-dual-regime)
43. Should the options to publish a prospectus in a printed form and by insertion in a newspaper be suppressed (deletion of Article 14(2)(a) and (b), while retaining Article 14(7), i.e. a paper version could still be obtained upon request and free of charge)?(printed-prospectus)
Please justify your answer on the possible supression of the options to publish a prospectus in a printed form and to be inserted in a newspaper:(comments-printed-prospectus)
44. Should a single, integrated EU filing system for all prospectuses produced in the EU be created?(single-filing-system)
Please give your views on the main benefits (added value for issuers and investors) and drawbacks (costs) of the creation of a single, integrated EU filing system for all prospectuses produced in the EU?(comments-single-filing-system)
45. What should be the essential features of such a filing system to ensure its success?(features-single-filing-system)
46. Would you support the creation of an equivalence regime in the Union for third country prospectus regimes?(harmonised-equivalence-regime)
Please describe on which essential principles the creation of an equivalence regime in the Union for third country prospectus regimes should be based:(comments-harmonised-equivalence-regime)
47. Assuming the prospectus regime of a third country is declared equivalent to the EU regime, how should a prospectus prepared by a third country issuer in accordance with its legislation be handled by the competent authority of the Home Member State defined in Article 2(1)(m)(iii)?(equivalence-third-country)
Please specify in which other way should a prospectus prepared by a third country issuer in accordance with its legislation be handled by the competent authority of the Home Member State defined in Article 2(1)(m)(iii):(other-equivalence-third-country)
Please justify your answer on how a prospectus prepared by a third country issuer in accordance with its legislation should be handled by the competent authority of the Home Member State:(comments-equivalence-third-country)
a) “Offer of securities to the public”?(offer-better-defined)
Please justify your answer on the need for “offer of securities to the public” to be better defined:(cmments-offer-better-defined)
b) “primary market” and “secondary market”?(markets-better-defined)
Please justify your answer on the need for “offer of securities to the public” to be defined:(comments-markets-better-defined)
49. Are there other areas or concepts in the Directive that would benefit from further clarification?(further-clarification)
What according to you should still be clarified:(yes-further-clarification)
Please justify your answer on whether there are other areas or concepts in the Directive that would benefit from further clarification?:(comments-further-clarification)
50. Can you identify any modification to the Directive, apart from those addressed above, which could add flexibility to the prospectus framework and facilitate the raising of equity or debt by companies on capital markets, whilst maintaining effective investor protection?(modification-flexibility)
Please explain your reasoning and provide supporting arguments for other possible modification to the Directive which could add flexibility to the prospectus framework:(comments-modification-flexibility)
51. Can you identify any incoherence in the current Directive’s provisions which may cause the prospectus framework to insufficiently protect investors?(incoherence)
Please explain your reasoning and provide supporting arguments for identifying incoherence(s) in the current Directive’s provisions:(comments-incoherence)
Should you wish to provide additional information (e.g. a position paper, report) or raise specific points not covered by the questionnaire, you can upload your additional document(s) here:(file-upload)
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a private individual
an organisation or a company
a public authority or an international organisation
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Academic institution
Company, SME, micro-enterprise, sole trader
Consultancy, law firm
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Industry association
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International or European organisation
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Accounting
Auditing
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Market infrastructure operation (e.g. CCPs, CSDs, Stock exchanges)
Social entrepreneurship
Other
Not applicable
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a company listed on a regulated market of the European Economic Area (EU, Iceland, Liechtenstein and Norway)
a company whose securities are admitted to trading on a multilateral trading facility (MTF) of the EEA
none of the above
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a company with a market capitalisation below 200M€ (“small and medium-sized enterprise” under the meaning of Art. 4(1)(13) of Directive 2014/65/UE)
a company meeting at least 2 of the following 3 criteria: 1. an average number of employees during the financial year of less than 250, 2. a total balance sheet not exceeding 43M€ 3. an annual net turnover not exceeding 50M€ (“small and medium-sized enterprise” under the meaning of Art. 2(1)(f) of Directive 2003/71/EC)
none of the above
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Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)
No, I do not want my response to be published
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Admission to trading on a regulated market
An offer of securities to the public
Should a different treatment should be granted to the two purposes (i.e. different types of prospectus for an admission to trading and an offer to the public)
Other
Don’t know / no opinion
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Yes, a percentage of the costs above would be incurred anyway
No
Don’t know / no opinion
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Yes
No
Don’t know / no opinion
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Yes, from EUR 5 000 000 to more
No
Don’t know / no opinion
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Yes, from EUR 75 000 000 to more
No
Don’t know / no opinion
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Yes, from 150 persons to more
No
Don’t know / no opinion
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Yes, from EUR 100 000 to more
No
Don’t know / no opinion
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Yes
No
Other areas
Don’t know / no opinion
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Yes
No
Don’t know / no opinion
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Yes
No
Don’t know / no opinion
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Yes
No
Don’t know / no opinion
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The 10% threshold should be raised
The exemption should apply to all secondary issuances of fungible securities, regardless of their proportion with respect to those already issued
No amendment
Don’t know / no opinion
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One or several years
There should be no timeframe (i.e. the exemption should still apply if a prospectus was approved ten years ago)
Don’t know / no opinion
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Yes, on all MTFs
Yes, but only on those MTFs registered as SME growth markets
No
Don’t know / no opinion
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Yes, the amended regime should apply to all MTFs
Yes, the unamended regime should apply to all MTFs
Yes, the amended regime should apply but not to those MTFs registered as SME growth markets
Yes, the unamended regime should apply but not to those MTFs registered as SME growth markets
Yes, the amended regime should apply but only to those MTFs registered as SME growth markets
Yes, the unamended regime should apply but only to those MTFs registered as SME growth markets
No
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Yes, such an exemption would not affect investor/consumer protection in a significant way
No, such an exemption would affect investor/consumer protection
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Yes
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Yes
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Yes
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To types of issuers or issues not yet covered
To admissions of securities to trading on an MTF, supposing those are brought into the scope of the Directive
Other
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Yes
No
Don’t know / no opinion
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Yes
No, the higher risk profile of SMEs and companies with reduced market capitalisation justifies disclosure standards that are as high as for issuers listed on regulated markets
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Yes
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Yes
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Yes
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Yes, regarding the concept of key information and its usefulness for retail investors
Yes, regarding the comparability of the summaries of similar securities
Yes, regarding the interaction with final terms in base prospectuses
No
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By providing that information already featured in the KID need not be duplicated in the prospectus summary
By eliminating the prospectus summary for those securities
By aligning the format and content of the prospectus summary with those of the KID required under the PRIIPS Regulation, in order to minimise costs and promote comparability of products
Other
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Yes, it should be defined by a maximum number of pages
Yes, it should be defined using other criteria
No
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Yes
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Yes
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Yes
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review all prospectuses ex ante (i.e. before the offer or the admission to trading takes place)
review only a sample of prospectuses ex ante (risk-based approach)
review all prospectuses ex post (i.e. after the offer or the admission to trading has commenced)
review only a sample of prospectuses ex post (risk-based approach)
Other
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Yes
No
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Yes
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I support
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I support
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I support
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No, status quo should be maintained
Yes, issuers should be allowed to choose their home Member State even for non-equity securities with a denomination per unit below EUR 1 000
Yes, the freedom to choose the home Member State for non-equity securities with a denomination per unit above EUR 1 000 (and for certain non-equity hybrid securities) should be revoked
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Such a prospectus should not need approval and the involvement of the Home Member State should be limited to the processing of notifications to host Member States under Article 18
Such a prospectus should be approved by the Home Member State under Article 13
Other
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No
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Yes
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No, legal certainty is ensured
Yes, the following should be clarified:
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Are you replying as:
First name and last name:
Name of your organisation:
Name of the public authority:
Contact email address:
Is your organisation included in the Transparency Register?
(If your organisation is not registered, we invite you to register here, although it is not compulsory to be registered to reply to this consultation. Why a transparency register?)
If so, please indicate your Register ID number:
Type of organisation:
Please specify the type of organisation:
Type of public authority
Please specify the type of public authority:
Where are you based and/or where do you carry out your activity?
Please specify your country:
Field of activity or sector (if applicable):
Please specify your activity field(s) or sector(s):
Please indicate if you are:
Please indicate if you are:
Contributions received are intended for publication on the Commission’s website. Do you agree to your contribution being published?
(see specific privacy statement PDF)
1. Is the principle, whereby a prospectus is required whenever securities are admitted to trading on a regulated market or offered to the public, still valid? In principle, should a prospectus be necessary for:
Please describe which different treatment should be granted to the two purposes:
Please describe what other possible reasons why a prospectus is necessary:
Additional comments on the principle whereby a prospectus is required whenever securities are admitted to trading on a regulated market or offered to the public:

a) Please estimate the cost of producing a prospectus (between how many euros and how many euros for a total consideration of how many euros):

Don’t know (add an X in the next three fields)

Minimum cost (in €)

Maximum cost (in €)

For a total consideration of (in €)

Equity prospectus

Non-equity prospectus

Base prospectus

Initial public offer (IPO) prospectus

Don’t know (add an X in the next three fields)

Additional comments on the cost of producing a prospectus:

b) What is the share, in per cent, of the following in the total costs of a prospectus:

Don’t know (add an X in the next three fields)

Share in the total costs (in %)

Issuer’s internal costs

Audit costs

Legal fees

Competent authorities’ fees

Other costs (please specify which)

Don’t know (add an X in the next three fields)

Additional comments on the share in the total costs of a prospectus:

c. What fraction of the costs indicated above would be incurred by an issuer anyway, when offering securities to the public or having them admitted to trading on a regulated market, even if there were no prospectus requirements, under both EU and national law? Please estimate this fraction.

Please specify which fraction of the costs above would be incurred anyway (in %):

Additional comments on the fraction of the costs indicated above that would be incurred by an issuer anyway:

3. Bearing in mind that the prospectus, once approved by the home competent authority, enables an issuer to raise financing across all EU capital markets simultaneously, are the additional costs of preparing a prospectus in conformity with EU rules and getting it approved by the competent authority outweighed by the benefit of the passport attached to it?
Additional comments on the possibility that additional costs are outweighed by the benefit of the passport attached to the prospectus:

a) the EUR 5 000 000 threshold of Article 1(2)(h):

Please specify from EUR 5 000 000 up to how many euros:

Please justify your answer on the EUR 5 000 000 threshold:

b) the EUR 75 000 000 threshold of Article 1(2)(j):

Please specify from EUR 75 000 000 up to how many euros:

Please justify your answer on the EUR 75 000 000 threshold:

c) the 150 persons threshold of Article 3(2)(b):

Please specify from 150 persons up to how many persons:

Please justify your answer on the 150 persons threshold:

d) the EUR 100 000 threshold of Article 3(2)(c) & (d):

Please specify from EUR 100 000 up to how many euros:

Please justify your answer on the EUR 100 000 threshold:

5. Would more harmonisation be beneficial in areas currently left to Member States’ discretion, such as the flexibility given to Member States to require a prospectus for offers of securities with a total consideration below EUR 5 000 000?
Please specify what other area:
Please justify your answer on whether more harmonisation be beneficial:
6. Do you see a need for including a wider range of securities in the scope of the Directive than transferable securities as defined in Article 2(1)(a)?
Please justify your answer on the possibility of including a wider range of securities in the scope of the Directive:
7. Can you identify any other area where the scope of the Directive should be revised and if so how? Could other types of offers and admissions to trading be carried out without a prospectus without reducing consumer protection?
Please specify what other area:
Please justify your answer on possible other area:
8. Do you agree that while an initial public offer of securities requires a full-blown prospectus, the obligation to draw up a prospectus could be mitigated or lifted for any subsequent secondary issuances of the same securities, provided that relevant information updates are made available by the issuer?
Please justify your answer on the possible mitigation of the obligation to draw up a prospectus:
9. How should Article 4(2)(a) be amended in order to achieve this objective?
Please specify to what extent the 10% threshold should be raised:
Please justify your answer on the amendment of Article 4(2):
10. If the exemption for secondary issuances were to be made conditional to a full-blown prospectus having been approved within a certain period of time, which timeframe would be appropriate?
Please specify the lenght of the ideal timeframe (in years):
Please justify your answer on the convenience of having a timeframe for the exemption:
11. Do you think that a prospectus should be required when securities are admitted to trading on an MTF?
Please justify your answer on whether a prospectus should be required when securities are admitted to trading on an MTF:
12. Were the scope of the Directive extended to the admission of securities to trading on MTFs, do you think that the proportionate disclosure regime (either amended or unamended) should apply?
Please justify your answer on the possible application of the proportionate disclosure regime:
13. Should future European long term investment funds (ELTIF), as well as certain European social entrepreneurship funds (EuSEF) and European venture capital funds (EuVECA) of the closed-ended type and marketed to non-professional investors be exempted from the obligation to prepare a prospectus under the Directive, while remaining subject to the bespoke disclosure requirements under their sectorial legislation and to the PRIIPS key information document?
Please state your reasoning, if necessary by drawing comparisons between the different sets of disclosure requirements which cumulate for these funds:
14. Is there a need to extend the scope of the exemption provided to employee shares schemes in Article 4(1)(e) to non-EU, private companies?
Please explain your answer on the possible extension of the scope of the exemption provided to employee shares schemes in Article 4(1)(e) to non-EU, private companies and provide supporting evidence:
15. Do you consider that the system of exemptions granted to issuers of debt securities above a denomination per unit of EUR 100 000 under the Prospectus and Transparency Directives may be detrimental to liquidity in corporate bond markets?
If so, what targeted changes could be made to address this without reducing investor protection?
Please justify your answer on whether the system of exemptions may be detrimental to liquidity in corporate bond markets:

a) Do you then think that the EUR 100 000 threshold should be lowered?

Please specify to which amount (in euro) the EUR 100 000 threshold should be lowered:

Please justify your answer on whether the EUR 100 000 threshold should be lowered:

b) Do you then think that some or all of the favourable treatments granted to the above issuers should be removed?

Please indicate to what extent the favourable treatments granted to the above issuers should be removed:

Please justify your answer on whether the favourable treatments granted to the above issuers should be removed:

c) Do you then think that the EUR 100 000 threshold should be removed altogether and the current exemptions should be granted to all debt issuers, regardless of the denomination per unit of their debt securities?

Please justify your answer on whether the EUR 100 000 threshold should be removed altogether and the current exemptions should be granted to all debt issuers, regardless of the denomination per unit of their debt securities:

16. In your view, has the proportionate disclosure regime (Article 7(2)(e) and (g)) met its original purpose to improve efficiency and to take account of the size of issuers? If not, why?
Please justify your answer on whether the proportionate disclosure regime has met its original purpose:

a) Proportionate regime for rights issues

Please justify your answer on the proportionate regime for rights issues:

b) Proportionate regime for small and medium-sized enterprises and companies with reduced market capitalisation

Please justify your answer on the proportionate regime for small and medium-sized enterprises and companies with reduced market capitalisation:

c) Proportionate regime for issues by credit institutions referred to in Article 1(2)(j) of Directive 2003/71/EC

Please justify your answer on the proportionate regime for issues by credit institutions referred to in Article 1(2)(j) of Directive 2003/71/EC:

a) Proportionate regime for rights issues:

b) Proportionate regime for small and medium-sized enterprises and companies with reduced market capitalisation:

c) Proportionate regime for issues by credit institutions referred to in Article 1(2)(j) of Directive 2003/71/EC:

19. If the proportionate disclosure regime were to be extended, to whom should it be extended?
Please specify which types of issuers or issues not yet covered:
Please specify which admissions of securities to trading on an MTF:
Please specify which other possibilities:

Please justify your answer on to whom the proportionate disclosure regime should be extended:

20. Should the definition of “company with reduced market capitalisation” (Article 2(1)(t)) be aligned with the definition of SME under Article 4(1)(13) of Directive 2014/65/EU by raising the capitalisation limit to EUR 200 000 000?
Please justify your answer on the possible alignment of “company with reduced market capitalisation” (Article 2(1)(t)) with the definition of SME under Article 4(1)(13) of Directive 2014/65/EU by raising the capitalisation limit to EUR 200 000 000:
21. Would you support the creation of a simplified prospectus for SMEs and companies with reduced market capitalisation admitted to trading on an SME growth market, in order to facilitate their access to capital market financing?
Please justify your answer on the possible creation of a simplified prospectus for SMEs and companies with reduced market capitalisation admitted to trading on an SME growth market:
22. Please describe the minimum elements needed of the simplified prospectus for SMEs and companies with reduced market capitalisation admitted to trading on an SME growth market:
23. Should the provision of Article 11 (incorporation by reference) be recalibrated in order to achieve more flexibility?
Please please indicate how this could be achieved (in particular, indicate which documents should be allowed to be incorporated by reference):
Please justify your answer on the possible recalibration of the provision of Article 11 (incorporation by reference) in order to achieve more flexibility:
24. a) Should documents which were already published/filed under the Transparency Directive no longer need to be subject to incorporation by reference in the prospectus (i.e. neither a substantial repetition of substance nor a reference to the document would need to be included in the prospectus as it would be assumed that potential investors have anyhow access and thus knowledge of the content of these documents)?

Please justify your answer on whether documents which were already published/filed under the Transparency Directive should no longer need to be subject to incorporation by reference in the prospectusr:

b) Do you see any other possibilities to better streamline the disclosure requirements of the Prospectus Directive and the Transparency Directive?

Please justify your whether you see any other possibilities to better streamline the disclosure requirements of the Prospectus Directive and the Transparency Directive:

25. Article 6(1) Market Abuse Directive obliges issuers of financial instruments to inform the public as soon as possible of inside information which directly concerns the said issuers; the inside information has to be made public by the issuer in a manner which enables fast access and complete, correct and timely assessment of the information by the public. Could this obligation substitute the requirement in the Prospectus Directive to publish a supplement according to Article 17 without jeopardising investor protection in order to streamline the disclosure requirements between Market Abuse Directive and Prospectus Directive?
Please justify your whether the above-mentioned obligation could substitute the requirement in the Prospectus Directive to publish a supplement according to Article 17 without jeopardising investor protection in order to streamline the disclosure requirements between Market Abuse Directive and Prospectus Directive:
26. Do you see any other possibility to better streamline the disclosure requirements of the Market Abuse Directive and the Prospectus Directive?
Please justify your whether you see any other possibility to better streamline the disclosure requirements of the Market Abuse Directive and the Prospectus Directive:
27. Is there a need to reassess the rules regarding the summary of the prospectus?
Please provide suggestions for re-assessment of the concept of key information and its usefulness for retail investors:
Please provide suggestions for re-assessment of the comparability of the summaries of similar securities:
Please provide suggestions for re-assessment of the interaction with final terms in base prospectuses:
Please justify your answer on the possibility to reassess the rules regarding the summary of the prospectus:
28. For those securities falling under the scope of both the packaged retail and insurance-based investment products (PRIIPS) Regulation, how should the overlap of information required to be disclosed in the key investor document (KID) and in the prospectus summary, be addressed?
Please indicate which redundant information would be concerned:
Please specify which other ways you would consider to addressing the overlap of information required to be disclosed:
Please justify your answer on the possible ways to address the overlap of information required to be disclosed:
29. Would you support introducing a maximum length to the prospectus? If so, how should such a limit be defined?
What should be the maximum number of pages?
What other criteria could be used to set the maximum length of the prospectus:
Please justify your answer on the possible introduction of a maximum length to the prospectus:
30. Alternatively, are there specific sections of the prospectus which could be made subject to rules limiting excessive lengths? How should such limitations be spelled out?
31. Do you believe the liability and sanctions regimes the Directive provides for are adequate?

The overall civil liability regime of Article 6

The specific civil liability regime for prospectus summaries of Article 5(2)(d) and Article 6(2)

The sanctions regime of Article 25

If not, how could they be improved?
Please justify your answer on the adequacy of the liability and sanctions regimes the Directive provides for:
32. Have you identified problems relating to multi-jurisdiction (cross-border) liability with regards to the Directive?
If you have identified problems relating to multi-jurisdiction (cross-border) liability, please give details:
Please justify your answer on possible problems relating to multi-jurisdiction (cross-border) liability:
33. Are you aware of material differences in the way national competent authorities assess the completeness, consistency and comprehensibility of the draft prospectuses that are submitted to them for approval?
If you aware of material differences, please provide examples/evidence:
Please justify your answer on possible material differences in the way national competent authorities assess the completeness, consistency and comprehensibility of the draft prospectuses:
34. Do you see a need for further streamlining of the scrutiny and approval procedures of prospectuses by NCAs?
If you think there is a need for further streamlining of the scrutiny and approval procedures of prospectuses by NCAs, please specify in which regard:
Please justify your answer on the possible need for further streamlining of the scrutiny and approval procedures of prospectuses by NCAs:
35. Should the scrutiny and approval procedure be made more transparent to the public?
If you think the scrutiny and approval procedure should be made more transparent to the public, please indicate how this should be achieved:
Please justify your answer on the opportunity to make the scrutiny and approval procedure more transparent to the public:
36. Would it be conceivable to allow marketing activities by the issuer in the period between the first submission of a draft prospectus and the approval of its final version, under the premise that no legally binding purchase or subscription would take place until the prospectus is approved?
If you think it is conceivable to allow marketing activities by the issuer in the period between the first submission of a draft prospectus and the approval of its final version, please provide details on how this could be achieved:
Please justify your answer on the possibility to allow marketing activities by the issuer in the period between the first submission of a draft prospectus and the approval of its final version:
37. What should be the involvement of national competent authorities (NCA) in relation to prospectuses? Should NCA:
Please describe the possible consequences of your favoured approach, in particular in terms of market efficiency and invest protection:
38. Should the decision to admit securities to trading on a regulated market (including, where applicable, to the official listing as currently provided under the Listing Directive), be more closely aligned with the approval of the prospectus and the right to passport?
Please explain your reasoning and the benefits (if any) this could bring to issuers:
39. a) Is the EU passporting mechanism of prospectuses functioning in an efficient way?

What improvements could be made to the EU passporting mechanism of prospectuses?

Please justify your answer on whether the EU passporting mechanism of prospectuses is functioning in an efficient way:

b) Could the notification procedure between NCAs of home and host Member States set out in Article 18 be simplified (e.g. limited to the issuer merely stipulating in which Member States the offer should be valid, without any involvement from NCAs) without compromising investor protection?

Please justify your answer on whether the notification procedure set out in Article 18 between NCAs of home and host Member States could be simplified:

a) The use of the base prospectus facility should be allowed for all types of issuers and issues and the limitations of Article 5(4)(a) and (b) should be removed:

Please justify your answer on whether or not you support the possibility for the use of the base prospectus facility to be allowed for all types of issuers and issues, and for the limitations of Article 5(4)(a) and (b) to be removed:

b) The validity of the base prospectus should be extended beyond one year:

Please indicate the appropriate validity length:

Please justify your answer on whether or not you support the possibility for the validity of the base prospectus to be extended beyond one year:

c) The Directive should clarify that issuers are allowed to draw up a base prospectus as separate documents (i.e. as a tripartite prospectus), in cases where a registration document has already been filed and approved by the NCA:

Please justify your answer on whether or not you support the possibility for the Directive to clarify that issuers are allowed to draw up a base prospectus as separate documents (i.e. as a tripartite prospectus), in cases where a registration document has already been filed and approved by the NCA:

d) Assuming that a base prospectus may be drawn up as separate documents (i.e. as a tripartite prospectus), it should be possible for its components to be approved by different NCAs:

Please justify your answer on whether it should be possible for the  components of a tripartite prospectus to be approved by different NCAs:

e) The base prospectus facility should remain unchanged:

Please justify your answer on whether the base prospectus facility should remain unchanged:

f) Other possible changes or clarifications to the base prospectus facility (please specify):

41. How is the “tripartite regime” (Articles 5 (3) and 12) used in practice and how could it be improved to offer more flexibility to issuers?
42. Should the dual regime for the determination of the home Member State for non-equity securities featured in Article 2(1)(m)(ii) be amended?
Please explain how this dual regime should be amended:
Please justify your answer on the possibility for the dual regime for the determination of the home Member State for non-equity securities to be amended:
43. Should the options to publish a prospectus in a printed form and by insertion in a newspaper be suppressed (deletion of Article 14(2)(a) and (b), while retaining Article 14(7), i.e. a paper version could still be obtained upon request and free of charge)?
Please justify your answer on the possible supression of the options to publish a prospectus in a printed form and to be inserted in a newspaper:
44. Should a single, integrated EU filing system for all prospectuses produced in the EU be created?
Please give your views on the main benefits (added value for issuers and investors) and drawbacks (costs) of the creation of a single, integrated EU filing system for all prospectuses produced in the EU?
45. What should be the essential features of such a filing system to ensure its success?
46. Would you support the creation of an equivalence regime in the Union for third country prospectus regimes?
Please describe on which essential principles the creation of an equivalence regime in the Union for third country prospectus regimes should be based:
47. Assuming the prospectus regime of a third country is declared equivalent to the EU regime, how should a prospectus prepared by a third country issuer in accordance with its legislation be handled by the competent authority of the Home Member State defined in Article 2(1)(m)(iii)?
Please specify in which other way should a prospectus prepared by a third country issuer in accordance with its legislation be handled by the competent authority of the Home Member State defined in Article 2(1)(m)(iii):
Please justify your answer on how a prospectus prepared by a third country issuer in accordance with its legislation should be handled by the competent authority of the Home Member State:

a) “Offer of securities to the public”?

Please justify your answer on the need for “offer of securities to the public” to be better defined:

b) “primary market” and “secondary market”?

Please justify your answer on the need for “offer of securities to the public” to be defined:

49. Are there other areas or concepts in the Directive that would benefit from further clarification?
What according to you should still be clarified:
Please justify your answer on whether there are other areas or concepts in the Directive that would benefit from further clarification?:
50. Can you identify any modification to the Directive, apart from those addressed above, which could add flexibility to the prospectus framework and facilitate the raising of equity or debt by companies on capital markets, whilst maintaining effective investor protection?
Please explain your reasoning and provide supporting arguments for other possible modification to the Directive which could add flexibility to the prospectus framework:
51. Can you identify any incoherence in the current Directive’s provisions which may cause the prospectus framework to insufficiently protect investors?
Please explain your reasoning and provide supporting arguments for identifying incoherence(s) in the current Directive’s provisions:

Should you wish to provide additional information (e.g. a position paper, report) or raise specific points not covered by the questionnaire, you can upload your additional document(s) here:

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