ESMA had published the proposed guidelines in February 2014 with the aim of improving the transparency and comparability of financial information, reducing information asymmetry among the users of financial statements, contributing to coherent use and presentation of alternative performance measures (APMs), and restoring confidence in the accuracy and usefulness of financial information.

In our comment letter, we note that we see the need to address the presentation of alternative performance measures (APMs) in various types of communications by issuers to the investors' community but we also point out that the debate is not restricted to Europa alone and especially mention the IFAC's draft guide on the use of supplementary financial measures also published in February 2014 and IASB's April 2014 decision to undertake a research project, as part of the disclosure initiative project, on the matter.

Regarding the proposed guidelines, our most significant concerns relate to the scope of documents to which the APM guidelines would apply as well as the type of APMs that would be captured in the proposed scope.

• We understand that the proposed guidelines may apply to a scope of documents larger than those that National Competent Authorities (NCAs) would usually review and we question how their application could be enforced if the scope of documents to which they apply goes beyond the reach of NCAs.
• We also believe that the scope of the guidelines is too broad regarding the types of APMs that would be captured. We suggest that the guidelines are limited to the presentation of, and information about, APMs that are financial measures that have been prepared using financial data underlying the preparation of an entity's historic, current or future financial statements.

In addition, we also believe that it is essential that users have transparent information on the level of external assurance, if any, attached to APMs presented.

Please click for access to the full comment letter.