EFRAG believes that Alternative Performance Measurement (‘APMs’) can provide useful information when properly used and presented, and therefore, supports the idea that APMs should be clearly defined and explained by preparers, and presented consistently over time to improve the understanding of the performance by users of financial information.

However, EFRAG observes that ESMA has not provided clear evidence on why the existing CESR Recommendation is no longer considered to provide adequate guidance and is in need of replacement. Further EFRAG would recommend that the scope of the requirements be supported by an underlying principle so as to target the requirements more narrowly and hence contribute to effective disclosures.


Comment Letter