In our response, we highlight that the proposal offering a single point of access to public information about EU companies and EU investment products could potentially allow ACCIS members to retrieve and process data which is used for added value services (e.g., credit scores) more easily.
In our view, voluntary submission of information by any natural or legal person should be connected to objective criteria. Voluntary submission of information (Article 3(1)) should be opened to all entities which have to file annual accounts.
We also think that the draft Regulation should clarify the relationship and the differences between the ESAP and current Business Registers and what constitutes “very large volume of information or for frequently updated information” in Article 8.2 of the Regulation.