33. Under the 2015 Guidelines, ESMA has encountered difficulties in cases where CRAs submit documents to ESMA in a language other than English in a format that cannot be translated by ESMA’s translation tools. Typically, this problem arises when a document is submitted in a protected or non-machine readable format.

34. To address this issue, and ensure that CRAs are clear as to the format in which such documents should be reported to ESMA, the proposed Guidelines are introducing a section setting out General Principles clarifying that any document that is provided in a language that is not English should be submitted in a machine readable format.