9. One of the main changes introduced by the proposed Guidelines is the basis on which CRAs reporting requirements are determined. As mentioned, the approach of the 2015 Guidelines was for a CRA’s reporting requirements to be determined by whether or not that CRA is exempted from the requirement to pay supervisory fees.

10. While this approach is a clear and objective basis for distinguishing between the reporting requirements of different entities, it is no longer aligned with ESMA’s risk-based approach to supervision, nor does it enable ESMA to adjust its reporting requirements in response to changes in ESMA’s risk assessment of an entity.

11. ESMA has established a risk assessment framework in order to support the determination of its work plan and allocation of its supervisory resources. According to this framework, ESMA supervision will focus its resources on entities that pose the most risk.