Date last updated: July 2017

Question: What are the limits for the compliance by reference principle included in paragraph 45 of the APMs Guidelines?

Answer: Paragraphs 45 and 46 provide a practical relief to issuers who may comply with the principles included in the APMs Guidelines if they include a direct reference to other documents previously published which contain the disclosures required by the APMs Guidelines.

Issuers may use the compliance by reference in order to avoid repetition of information in regulated information documents (e.g. ad-hoc disclosures presented in accordance with article 17 of MAR). However, the reference principle cannot be used when complying with the following requirements:

• Comparatives (paragraph 46 of the APMs Guidelines)

• Meaningful labels to the APMs used (paragraph 22 of the APMs Guideline

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