FCA has published its response to the Commission’s now-closed call for evidence on the EU regulatory framework for financial services (see FReD 2 October 2015). FCA gives examples of areas where regulatory policy objectives could be achieved in a more efficient or more effective way, including:
- whilst the principle of proportionality is often embedded in legislation, it has been done in ways which leaves it unclear as to the intended practical impact;
- there is an increasing need for all measures to be considered in the light of technological developments, to ensure that legislation is appropriately future proof and technology neutral;
- requirements for a specific policy outcome must be proportionate, as targeted as possible, and developed in ways that minimise costs and complexity;
- co-ordination of implementation dates across legislation to minimise the costs and administrative burdens associated with the advent of each new set of rules; and
- suggesting a review of how disclosure and reporting obligations might better be aligned across different EU measures.