Accountancy Europe supports overall the draft guidance on prospectus risk factors published by ESMA. We have additional minor recommendations to propose in order to render the draft guidance even better and clearer for both investors and issuers.

Moreover, we propose future work in two areas:

• further alleviations on risk factor disclosures for SME Growth Market issuers
• clarifications on risk factor disclosures between prospectuses, financial statements and management reports

Our comment letter to the draft guidance should be seen in conjunction with our previous prospectus work, including our Simplified prospectus paper, our Model prospectus and our response to ESMA’s prospectus consultation.