ESMA’s choices in the Guidelines are of pure technical nature and do not imply strategic decisions or policy choices.
ESMA’s options are limited to the approach it took to drafting these Guidelines and the need to ensure clarity, consistency or reporting and uniformity of formats.
The main policy decisions have already been analysed and published by the European Commission under the primary legislation, i.e. Regulation (EU) No 201/2365 of the European Parliament and of the Council of 25 November 2015, as well as by ESMA when submitting the draft technical and implementing standards to the European Commission on 31 March 2017.