It’s not mandatory, but it is recommended to show the share based on company-reported data, and the share based on estimates, proxy data, or external sources.
Should financial market participants disclose what share of PAI impacts have been estimated and what have been calculated on the basis of reported information?
For the sake of clarity and to enable investors to assess the robustness of the indicators disclosed in the PAI disclosure, it would be a good practice, but not obligatory, for financial market participants to include, where relevant as part of the disclosures required by Article 7(1)(e) of the Delegated Regulation and for each PAI considered by the financial market participant: • The proportion of investments for which the financial market participant has relied on data obtained directly from investee companies, in order to calculate the corresponding indicator; and • The proportion of investments for which the financial market participant has relied on data obtained by carrying out additional research, cooperating with third party data providers or external experts or making reasonable assumptions, in order to calculate the corresponding indicator. These proportions could be expressed as a percentage of the current value of the investments included in the calculation of the indicator.
European Supervisory Authorities (ESAs)
