ICMA responds to draft EU prospectus regulation amendments on sequencing and ESG disclosure
The International Capital Market Association (ICMA) has published its feedback on the draft amendments to Commission Delegated Regulation (EU) 2019/980 under the EU Listing Act. The feedback specifically addresses the prospectus format sequencing and ESG disclosure requirements. ICMA welcomes the alleviations provided for base prospectuses and 144A offerings. However, it requests broader exemptions for standalone prospectuses and the reinstatement of explicit alleviation wording. The response also covers issues related to mandatory sequencing rules, the categorisation of ESG disclosures for non-EU Green Bond securities and various technical drafting corrections.