105. In addition to clarifying the approach to reporting for material changes to initial conditions of registration, the proposed revised Guidelines also introduce some additional areas which ESMA does not consider as constituting material changes to the conditions of registration but which are still significant enough to be notified to ESMA on an "as soon as" basis.

106. These are all areas where CRAs are expected to report on an as "As soon As" basis regardless of their reporting categorisation, using the reporting templates provided. The information required under each of these items is highly relevant for ESMA’s supervisory processes and in all cases are being introduced in these Guidelines in response to an identified supervisory need to receive this information on a more formalised basis than is currently the case.

Item 37 - Identification of errors in methodologies / model processes **New**

107. Under the 2015 Guidelines, there is no guidance provided to CRAs as to the content or format of the information to be reported in the event of the identification of an error in a CRAs methodologies or models. As a result the information currently received by ESMA can lack sufficient detail or be insufficiently comparable across CRAs, to be of significant value to ESMA’s supervision.