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Grab your camera and good mood and dive in a romantic underwater dance with the statues. Show how brave you are by inviting a white tip reef shark juvenile or a baby for a photo. That would create the ultimate Insta buzz, right? Are you ready to make some new sharky friends? Do you want to share a special moment with the cutie Nemo? This is the perfect dive site to encounter not only anemonefish like Nemo, but also beautiful green sea turtles and octopuses.

Ready for the challenge? In terms of machine readability, the EU has undertaken to digitise an increasing part of the information to be published with various levels of ambition. Whereas users report that machine readability is the primary issue is relation to formats, there are various degrees and steps in reaching full machine readab ility Annex I ntermediate steps having to do with machine readability include for instance data portability or data extractability.

Nowadays, full machine readability requires in addition data structuring. Stakeholders may have had different views on the level and extent of issues when report ing problems in connection with machine-readability during consultation : focus could be with varying degrees depending on the respondent on standardised formats, data extractability or underlying data structuring Whereas consultation outlined the need for accurate and high quality data, this is largely driven in terms of content — and should remain the prerogative — of sectoral legislation.

These problems are in the scope of this initiative, from the angle of compliance with IT specifications, in other words, outline the general need for digital validation checks on information.

Other barriers, include varied or inadequate terms of use and re-use. These are generally not addressed by the EU sectoral or other legislation in the area of financial services and capital markets. Terms of use, if any, are therefore largely left to Member States , access points or private entities to define. As observed on the basis a limited survey, national or specific own terms of use are introduced as regards national repositories.

Companies may introduce their own terms o f use The terms of use are varied and sometimes rely on open licenses designed at national level or building on Creative Commons type In addition they sometimes limit the reuse of information by introducing copyrights, database rights, limits to commercial reuse or specific obligations. Nowadays, the EU legislation in the financial services and capital markets offer limited directions or provisions in this regard Timeliness should be understood from the perspective of information being made available once a company makes it public, as otherwise the frequency and delays of reporting obligations depends on each sectoral legislation and is not covered by this initiative.

However depending on how information was embedded e. PDF based on scanned images , this format may not always allow for simple data extraction and it is generally not suitable as a machine readable format As seen in consultation activities, stakeholders report as a common practice the use of paid services from data aggregators to access information.

This market led solution enables to alleviate the problems identified however come with a price tag for the service and other drawbacks such as own non-interoperable formats and standards and digested information.

Difficulties in comparing information due a lack of semantic interoperability observed among the various sectoral legislation is out of the scope of this initiative. Whereas there is no reason to downplay the importance of this problem in enabling the digital use of information, semantic interoperability has to do with the inner building of the information, the design and content of which has largely to do with the objectives and design of sectoral legislation, including by ways of own definitions and concepts underlying the content.

The Commission has undertaken to advance on this front in a separate initiative with the development of a common data dictionary under its supervisory data strategy, to ensure data consistency and standardisation across financial sectors. This dictionary will describe the content and format of all data collected under various reporting frameworks in a structured, comprehensive, consistent and unambiguous manner, using terms anchored in legislation to establish a clear link between collected data items and the relevant legislative requirements.

While this initiative will address primarily supervisory reporting, it will also aim to coordinate the data specifications with public disclosures. Therefore it is expected to have ramifications over public reporting. Nevertheless, the development of a common data dictionary will have little impact on the design of this initiative, in particular its scope and costs.

This is because the data dictionary is a longer term initiative, and it aims to describe the reported and disclosed information, whereas this initiative focuses on making the disclosed information more accessible and more easily readable by machines.

The two initiatives are complementary as, the development of a common dictionary has the potential to aid the interpretation and comparability of disclosed information and hence facilitate its use. Fragmentation as regards the information flows on the European markets and financial service s drives the costs up for discovering, accessing and processing the information users need.

This is also a det e rr ent to research, and cross border analysis About half of stakeholders consulted find that costs for retrieving and processing information are generally high. Retail investors and civil society tend to find this source quite costly or even unaffordable. The problems identified drive the significant search and processing costs experienced by stakeholders to get information and compare it.

The situation is also a hindrance for users to compare 38 information , either directly or indirectly. About half of respondents to our consultation find that costs for retrieving and processing information are high. C osts to acquire data and bring it in a stage where it can be digitally used generally require human intervention: scanning and recognition software, rekeying, etc. Such costs are comprised mainly of staff costs, licensing or access fees, software, translations. As a result, on average respondents find that costs for retrieving and processing information that is mandatorily published in the area of financial services and capital markets are high, either with licenses acquired from data vendors or without such licenses.

This is particularly acute as regards sustainability-related data which is currently more difficult and costly to obtain than standardised financial information publicly disclosed by listed entities.

A large insurance company estimated its own costs reached millions of euros. Another consequence is that the increasing demand for ESG information by market participants is not met. A vast majority of respondents to the ESAP targeted consultation 39 underlined their difficulties to easily access and digitally use ESG and other types of information published by entities. The European Green Deal aims to place sustainable finance at the heart of the financial system.

Introduction of new disclosure obligations, such as those related to EU Taxonomy, SFDR and recently proposed CSRD, will on one hand increase transparency on sustainability impacts and risks, but also further increase demand for access to reliable sustainability, related data. Continued uneasy access to sustainability-related data and barriers to their digital use hinder the ability of investors to reflect sustainability-related risks and impacts in their decisions and hence to effectively contribute to the Green Deal via sustainable investments.

This reduces as well the ability of investors, governments and civil society to hold companies accountable for negative environmental, social and human rights impacts, resulting in lower incentive for companies to become more sustainable and resilient. Different types of users report that they experience similar problems, however on a different scale. Users are varied e. As a result, the impacts of the problems are of different scale and nature for different user types.

One aspect that illustrates this is the different scale and frequency of data that stakeholders need to access: while professional investors seek frequent access to large volumes of information, retail investors typically find smaller volumes of information and occasional access sufficient. National and EU public bodies have shared their interest in accessing information notably for statistical, supervisory or other public-interest purposes. Correspondingly, the magnitude of search costs or impairments to decision making due to missing or difficult to use data that different users bear also differs.

Data aggregators interviewed or consulted, despite being in the business of disseminating information, report similarly that these issues are an annoyance for them in harvesting raw data for their business, and a driver for loss of productivity. During the workshop with users Annex 4 , there was a strong message that access to information is not optimal. The prevailing fragmentation in access to data is one of the long-standing barriers to the integration of financial markets across the EU By making it difficult and costly for investors to find, analyse and ultimately compare relevant information including for retail investors and financial advisors to compare financial product information , this situation also presents a barrier to optimal allocation of capital.

As such, this problem undermines the functioning of the internal market. For instance, it has been noted that it makes SME research more difficult As a result, their attractiveness to investors is not optimal, especially from a cross border perspective Home bias is in the EU a natural barrier to integration for cultural, historical and linguistic reasons. In finance, the fragmented European market affects in particular SMEs, which can in turn hamper their ability to expand beyond their own borders Due to home bias , SMEs and non-listed entities often have to rely on national markets.

As seen during the examination of barriers to the single market 49 , risk capital continues to be scarce for high-growth SMEs. As echoed by business organisations, the difficulty in accessing funding affects both domestic and non-domestic businesses alike. However, it would affect disproportionately those businesses that are trying to expand in the markets with limited access to capital, compared to already established businesses. In the wake of the covid crisis, the prospects for SME finance have become bleaker still.

The Netherlands stands out negatively in the euro area, with SME finance having shrunk as a percentage of GDP since the financial crisis. Fragmentation of capital markets is detrimental to a smooth functioning of the market and drives higher cost of capital, especially for listed companies which in turn makes becoming or staying listed less attractive The situation is also a hindrance to developing new digital services, such as services around the digital comparison of EU wide complete sets of data for a given sector, which is key for investment decisions.

Companies in the rating business ESG or creditworthiness report that the lack of digitalisation and easy access are barriers to their ability to develop complete, reliable and forward looking service offers. During consultation, some stakeholders contended that the emergence of new technologies such as artificial intelligence AI and machine learning ML combined for instance with Optical Character Recognition OCR could in the future improve the digital use of documents that contain non-structured data in any IT format, with the potential of solving, at least partly, the problem.

I t is difficult to predict whether such emerging technologies would enable any user to obtain reliable results at a reasonable cost in the foreseeable future , absent any intervention T here are nevertheless reasons to believe that this hypothetical scenario will not solve the problem. Building solutions based on artificial intelligence or machine learning would require that vast amounts of available data are readily available, accessible and usable.

For this purpose, the Commission aims precisely to build common data spaces, recognising that easier access and usability are a premise to the emergence of such new technologies In addition, the problems noted on harmonization in several dimension like document metadata, data structuring and semantic interoperability would impinge negatively on the quality of the output information that would be based on a fully automated interpretation of data.

Addressing t hese inefficiencies from the market angle would require huge investment s in not only technologies 54 but also human resources and gathering of data. As a result the total cost of investment would be high 55 , raising doubts whether this would result economically more efficient in the medium term than services offered by data aggregators. Given the persistence of the problem and absent new impetus, it is unlikely that EU markets and financial services would start integrating naturally , in a coordinated move , overcoming , for instance , the home bias observed on information flows A number of ongoing initiatives at regulatory level may nevertheless modify slightly the landscape.

Company Law mandates that by August , all documents and information submitted as part of the formation of a company, the registration of a branch, or a filing by a company or a branch, is stored by the registers in a machine-readable and searchable format or as structured data The impact of this initiative would remain limited for the objectives of ESAP, given the very limited overlap of information covered between Company law and this initiative , whilst other problems noted are not addressed.

An implementing Regulation on High Value Datasets will ensure an open data approach at national level as regards information delivered by certain national bodies where public offering access to on companies and company ownership, that is an estimated three reporting obligations within the scope of this intervention.

This policy builds on national systems, hence access would remain scattered on this basis. The ESEF i s an important stepping stone — not yet fully implemented in the markets — that will d eliver on the objective of increased digital use of information, however for a limited number of reporting obligations and market participants.

As regards ESG information , the European Commission adopted on 21 April a legal proposal as regards corporate sustainable reporting 59 which will cater for the need of structured and machine readable corporate sustainability reporting 60 , addressing one of the key concerns on ESG information raised during consultations. This Commission proposal for sustainability reporting concerns 37 listed regardless of size and large non-listed entities publishing corporate sustainability reports If adopted by the Union, this would represent undeniable progress but would not solve the problem globally.

Furthermore, the EEAP does not address problems such as terms of use, quality, integrity of information, etc. For these reasons, the EEAP cannot solve the problem in an extensive way. The European Parliament has long been stress ing the need for deepening European capital markets in order to ensure access to financing from sources other than banks and to address barriers to cross border investments Adding to this, the shift towards sustainable investment and digital finance drive this initiative where information has a key role to play in the wider dimension of financial services area.

Data should be more easily accessible and ready for digital use for investors, including on a cross border basis. An EU intervention to reduce fragmentation, by ways of e. The objectives of this initiative cannot be sufficiently achieved by the Member States individually. The Member States have currently certain leeway for the design of rules on mechanisms and formats of corporate reporting obligations set out by the EU legislation, with heavy reliance on national systems.

The resulting geographical and thematic fragmentation of disclosure mechanisms and formats is pervasive in the Union and increases costs for users of corporate information. Further individual actions by Member States would not reduce this fragmentation unless they move in the same direction to build a single access point and address a number of barriers, which is unlikely without a coordinated approach. Enabling better access to information at the EU level, considering the scale and the effects of such a project, is an objective that can be better achieved at Union level.

In addition, the design of suitable formats, terms of use, language specifications, etc. There is widespread support for such initiative from governments, regulators, regional or national market participants, users, civil society, etc.

Therefore, the Union may adopt measures, in accordance with the principle of subsidiarity as set out in Article 5 of the Treaty on European Union. In accordance with the principle of proportionality, this initiative should not go beyond what is necessary in order to develop and operate the ESAP. This intervention will not add to, or modify existing reporting obligations in terms of content, as this is the prerogative of sectoral legislation.

In order to minimise the burden on entities and national authorities, it would be appropriate for the ESAP to build as much as possible on the existing data reporting channels and infrastructure. Nevertheless, the EU intervention will add value by streamlining in an efficient way the delivery of usable information to users on a cross border basis which would not be possible through different national access points.

In response to the problems identified, the overall objective of the European Single Access Point is to contribute to integrating the European capital markets and the financial services including a cross border s within the Union and to foster a more efficient allocation of capital across the EU. In addition, the intervention supports better access to sustainability-related data.

O ther types of users may see an interest in obtaining the information, f or instance civil society , p ublic authorities, law-makers or economists and this also contributes to an efficient functioning of the internal market.

Barriers to access and use of information published by entities in the financial services and capital markets area will therefore have to be examined, as well as the numerous existing channels and lack of interconnection of existing national or EU repositories.

The intervention would not create any new reporting obligation in terms of content, but build on existing requirements. It would address information that is relevant in the financial services, capital markets and sustainable finance areas, pursuant to the overall EU strategy for data in these areas.

Two major specific objectives are identified in relation to public reporting obligations would contribute to the general objective set out above, as seen in Table 1. Reporting requirements with different channels as regards information to be published.

Data repositories channelling a small portion of information are not interconnected. Increasing the flows i. Language and other barriers insufficiently addressed.

Machine readable formats specified for only for a few datasets. No prevailing market standard for disclosure format s. Increasing digital use and re-use of data. The first specific objective is to enable a seamless and integrated access to data published by entities subject to disclosure obligations in the area of financial services and capital markets, including sustainability related data, whilst avoiding disproportionate administrative costs for entities, in order to increase the circulation of information within the Union.

Increasing the circulation of information published in relation to financial services is necessary both within Member States and cross-border to support, at least in part, the general objective s of integration. The intervention should remove barriers to access, and improve discovery. This should be addressed keeping in mind the need to keep costs to a minimum 68 and alleviate other additional constraints, such as multiple filings The intervention should have regard to ongoing actions facilitating access to data at national level 70 and at EU level The second specific objective is to increase the digital use and re-use of data, addressing barriers or hurdles currently in place.

From the digital use angle, the ESAP should seek to standardise the way in which information is drawn up in order to make it easier digitally use, analyse and possibly compare , thus reducing processing costs for users.

The intervention should remov e barriers such as unnecessary restrictions to re-use , linguistic barriers , etc. This should be consistent with actions which will facilitate use of data at national level and at EU level A minimum viable product should be implemented by end The intervention should also ensure that these measures enable the EU framework to remain dynamic in order to be able to accommodate future technological progress and remain evolutionary Considering how the problem will evolve, the main characteristics of the baseline scenario i.

As part of the baseline, other existing pan EU interconnection systems or databases are considered. Business registers under EU law 76 are in charge of the disclosure of limited liability company information to ensure publicity of such information towards third parties.

As regards information in the financial services area, OAMs and NCA collect only a small portion of the available information. Without a proper EU dissemination system for information stored by OAMs and NCA, the information they collect remains not easily available to end users.

This is also valid for companies willing to disclose voluntari ly information relevant for financial services There are however a number of factors that prevent retaining the BRIS in the baseline.

The main reasons are this initiative and BRIS have different intended users, consuming different information in a different way. In addition, there are different collection bodies with limited overlap on the data collected. In particular:. By contrast, BRIS covers the company information to be disclosed under EU Company Law to the general public such as citizens, professionals and companies in order to provide legal certainty of such information.

Th e vast majority of information otherwise offered in the BRIS, based on the Company Law Directive, would have no immediate interest to investors for the purpose of this initiative. While a maximum of 12 months is allowed by the EU law for filing financial statements with a business register, the delay is reduced to 4 month for an issuer i.

This overlap concerns currently up to around 12 companies depending on the type of document, and in the future possibly up to 49 companies, should the Commission proposal of 21 April for a corporate sustainability reporting Directive be endorsed by the co-legislators. Therefore, considering the above, BRIS is not relevant in the baseline scenario. And this is only for one reporting obligation.

Therefore despite significant progress over the last years, the widespread digital use of information would remain hampered by the situation. As a result, in the baseline scenario, discovery and processing costs would remain significant for users.

Reduced flow and digital use of information represent a barrier to integrated financial services and capital markets at the Union level, leading to losses of funding or investment opportunities, sub-optimal allocation and higher costs of capital, hampering the full potential of the internal market in the financial sector.

The main message during consultation is the emerging need for access to ESG information. This information is increasingly demanded, notably by investors, fund managers, intermediates, advisors, as well as civil society and public authorities due to recent regulatory evolutions in the Union 79 , but also by the public at large for various purposes out of the general fight against climate change.

This bottleneck may become a significant barrier to achieving the sustainable finance angle of the Green Deal. From the market side, extant registers other than data aggregators are not satisfactory solutions as none can fully solve all the problems identified Annex One can expect that technologies relevant to this problem will continue to emerge but there is no clear indication that they would resolve a substantial part of the problem in a timely manner.

The policy options focus on how to establish a single access point in order to achieve the specific policy objectives outlined in section 4, rather than considering a single access point as one possibility among others to tackle the problems. T his is because a vast majority could support an EU single access point as a wa y of improving access , even though some recognised that there could be other avenues to improve access on the basis of numerous sources of information or other ways — however providing no clear alternative efficient direction.

There is a strong support 80 among all stakeholders for a single access point at the EU level as the best solution to address the problems. Asked during the public consultation on the Renewed sustainable finance strategy April-July if EU policy action is needed to help maximise the potential of digital tools for integrating sustainability into the financial sector, most respondents indicated that digital tools have a role to play to ensure access ible, reliable data e.

Only some suggested other ways such as promote innovation, create new instruments e. T here was a strong support during workshops Annex 4 for a single access point confirmed by survey on the spot, including for users. A few users believed that having access to the information in a centralized manner was not key — however not providing a clear description what other solutions might consist of.

The European economy has historically suffered from a lack of divers ified sources of funding for companies, hence the need to tackle the barriers to the flow of capital, to remove regulatory and non-regulatory barriers to the free movement of capital across borders.

Hence, members have stressed that the EU suffered from a market competition disadvantage and insufficient EU market-based financing compared to e. To tackle these issues, members of the HLF saw merit in mirroring in th e EU solutions in place in comparable markets of third countries , that is a single access point to information however with a broader scope to also capture sustainability-related and other information.

A single access point is consistent with the European strategy for data and on digital finance which both herald common data spaces in the financial sector for enhanced access to data and data sharing.

This section presents the different policy options for the following five main dimensions that are crucial to ensure relevant objectives are met: 1 scope of the information accessible via ESAP; 2 format of the information accessible via ESAP; 3 collection of the information accessible via ESAP and interconnection of existing collection points; 4 open data, and 5 governance. This is called inter-cell dependency. Hermite data is used to solve the problem of topological ambiguity. However, the resulting speed only comparable to our CPU implementation.

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Table of contents 15 chapters Search within book Search. Page 1 Navigate to page number of 2. Front Matter Pages i-xxix. The Mobile and Device Landscape Pages Flash Lite Platform Fundamentals Pages Flash Lite 3 Pages Adopting Flex for Multiple Devices Pages

 
 

 

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This is a summary of key elements of the Privacy Rule including who is covered, what information is protected, and how protected health information can be used and disclosed. Because it is an overview of the Privacy Rule, it does not address every detail of each provision. The U. The Rule strikes a balance that permits important uses of information, while protecting the privacy of people who seek care and healing.

Given that the health care marketplace is diverse, the Rule is designed to be flexible and comprehensive to cover the variety of uses and disclosures that need to be addressed. This is a summary of key elements of the Privacy Rule and not a complete or comprehensive guide to compliance. Entities regulated by the Rule are obligated to comply with all of its applicable requirements and should not rely on this summary as a source of legal information or advice.

To make it easier for entities to review the complete requirements of the Rule, provisions of the Rule referenced in this summary are cited in the end notes. Visit our Privacy Rule section to view the entire Rule, and for other additional helpful information about how the Rule applies. In the event of a conflict between this summary and the Rule, the Rule governs.

Collectively these are known as the Administrative Simplification provisions. HIPAA required the Secretary to issue privacy regulations governing individually identifiable health information, if Congress did not enact privacy legislation within three years of the passage of HIPAA. Because Congress did not enact privacy legislation, HHS developed a proposed rule and released it for public comment on November 3, The Department received over 52, public comments.

The final regulation, the Privacy Rule, was published December 28, In March , the Department proposed and released for public comment modifications to the Privacy Rule.

The Department received over 11, comments. The final modifications were published in final form on August 14, For help in determining whether you are covered, use CMS’s decision tool. Health Plans. Individual and group plans that provide or pay the cost of medical care are covered entities. Health plans also include employer-sponsored group health plans, government and church-sponsored health plans, and multi-employer health plans.

There are exceptions—a group health plan with less than 50 participants that is administered solely by the employer that established and maintains the plan is not a covered entity. Two types of government-funded programs are not health plans: 1 those whose principal purpose is not providing or paying the cost of health care, such as the food stamps program; and 2 those programs whose principal activity is directly providing health care, such as a community health center, 5 or the making of grants to fund the direct provision of health care.

If an insurance entity has separable lines of business, one of which is a health plan, the HIPAA regulations apply to the entity with respect to the health plan line of business. Health Care Providers. Every health care provider, regardless of size, who electronically transmits health information in connection with certain transactions, is a covered entity.

These transactions include claims, benefit eligibility inquiries, referral authorization requests, or other transactions for which HHS has established standards under the HIPAA Transactions Rule. The Privacy Rule covers a health care provider whether it electronically transmits these transactions directly or uses a billing service or other third party to do so on its behalf.

Health Care Clearinghouses. Health care clearinghouses are entities that process nonstandard information they receive from another entity into a standard i. Business Associate Defined. In general, a business associate is a person or organization, other than a member of a covered entity’s workforce, that performs certain functions or activities on behalf of, or provides certain services to, a covered entity that involve the use or disclosure of individually identifiable health information.

Business associate functions or activities on behalf of a covered entity include claims processing, data analysis, utilization review, and billing.

However, persons or organizations are not considered business associates if their functions or services do not involve the use or disclosure of protected health information, and where any access to protected health information by such persons would be incidental, if at all. A covered entity can be the business associate of another covered entity. Business Associate Contract. When a covered entity uses a contractor or other non-workforce member to perform “business associate” services or activities, the Rule requires that the covered entity include certain protections for the information in a business associate agreement in certain circumstances governmental entities may use alternative means to achieve the same protections.

In the business associate contract, a covered entity must impose specified written safeguards on the individually identifiable health information used or disclosed by its business associates. Covered entities that had an existing written contract or agreement with business associates prior to October 15, , which was not renewed or modified prior to April 14, , were permitted to continue to operate under that contract until they renewed the contract or April 14, , whichever was first.

Protected Health Information. The Privacy Rule protects all “individually identifiable health information” held or transmitted by a covered entity or its business associate, in any form or media, whether electronic, paper, or oral. The Privacy Rule excludes from protected health information employment records that a covered entity maintains in its capacity as an employer and education and certain other records subject to, or defined in, the Family Educational Rights and Privacy Act, 20 U.

De-Identified Health Information. There are no restrictions on the use or disclosure of de-identified health information. Basic Principle. Required Disclosures. A covered entity must disclose protected health information in only two situations: a to individuals or their personal representatives specifically when they request access to, or an accounting of disclosures of, their protected health information; and b to HHS when it is undertaking a compliance investigation or review or enforcement action.

A covered entity may disclose protected health information to the individual who is the subject of the information. A covered entity may use and disclose protected health information for its own treatment, payment, and health care operations activities. Treatment is the provision, coordination, or management of health care and related services for an individual by one or more health care providers, including consultation between providers regarding a patient and referral of a patient by one provider to another.

Payment encompasses activities of a health plan to obtain premiums, determine or fulfill responsibilities for coverage and provision of benefits, and furnish or obtain reimbursement for health care delivered to an individual 21 and activities of a health care provider to obtain payment or be reimbursed for the provision of health care to an individual.

Health care operations are any of the following activities: a quality assessment and improvement activities, including case management and care coordination; b competency assurance activities, including provider or health plan performance evaluation, credentialing, and accreditation; c conducting or arranging for medical reviews, audits, or legal services, including fraud and abuse detection and compliance programs; d specified insurance functions, such as underwriting, risk rating, and reinsuring risk; e business planning, development, management, and administration; and f business management and general administrative activities of the entity, including but not limited to: de-identifying protected health information, creating a limited data set, and certain fundraising for the benefit of the covered entity.

Most uses and disclosures of psychotherapy notes for treatment, payment, and health care operations purposes require an authorization as described below. Informal permission may be obtained by asking the individual outright, or by circumstances that clearly give the individual the opportunity to agree, acquiesce, or object.

Where the individual is incapacitated, in an emergency situation, or not available, covered entities generally may make such uses and disclosures, if in the exercise of their professional judgment, the use or disclosure is determined to be in the best interests of the individual.

Facility Directories. It is a common practice in many health care facilities, such as hospitals, to maintain a directory of patient contact information. Members of the clergy are not required to ask for the individual by name when inquiring about patient religious affiliation. For Notification and Other Purposes. In addition, protected health information may be disclosed for notification purposes to public or private entities authorized by law or charter to assist in disaster relief efforts.

The Privacy Rule does not require that every risk of an incidental use or disclosure of protected health information be eliminated. Specific conditions or limitations apply to each public interest purpose, striking the balance between the individual privacy interest and the public interest need for this information. Required by Law. Covered entities may use and disclose protected health information without individual authorization as required by law including by statute, regulation, or court orders.

Public Health Activities. Victims of Abuse, Neglect or Domestic Violence. In certain circumstances, covered entities may disclose protected health information to appropriate government authorities regarding victims of abuse, neglect, or domestic violence. Health Oversight Activities. Covered entities may disclose protected health information to health oversight agencies as defined in the Rule for purposes of legally authorized health oversight activities, such as audits and investigations necessary for oversight of the health care system and government benefit programs.

Judicial and Administrative Proceedings. Covered entities may disclose protected health information in a judicial or administrative proceeding if the request for the information is through an order from a court or administrative tribunal.

Such information may also be disclosed in response to a subpoena or other lawful process if certain assurances regarding notice to the individual or a protective order are provided. Law Enforcement Purposes. Covered entities may disclose protected health information to funeral directors as needed, and to coroners or medical examiners to identify a deceased person, determine the cause of death, and perform other functions authorized by law.

Cadaveric Organ, Eye, or Tissue Donation. Covered entities may use or disclose protected health information to facilitate the donation and transplantation of cadaveric organs, eyes, and tissue. Serious Threat to Health or Safety. Covered entities may disclose protected health information that they believe is necessary to prevent or lessen a serious and imminent threat to a person or the public, when such disclosure is made to someone they believe can prevent or lessen the threat including the target of the threat.

Covered entities may also disclose to law enforcement if the information is needed to identify or apprehend an escapee or violent criminal. Essential Government Functions. An authorization is not required to use or disclose protected health information for certain essential government functions. Such functions include: assuring proper execution of a military mission, conducting intelligence and national security activities that are authorized by law, providing protective services to the President, making medical suitability determinations for U.

State Department employees, protecting the health and safety of inmates or employees in a correctional institution, and determining eligibility for or conducting enrollment in certain government benefit programs.

A limited data set is protected health information from which certain specified direct identifiers of individuals and their relatives, household members, and employers have been removed.

An authorization must be written in specific terms. It may allow use and disclosure of protected health information by the covered entity seeking the authorization, or by a third party.

All authorizations must be in plain language, and contain specific information regarding the information to be disclosed or used, the person s disclosing and receiving the information, expiration, right to revoke in writing, and other data.

The Privacy Rule contains transition provisions applicable to authorizations and other express legal permissions obtained prior to April 14, Psychotherapy Notes Marketing is any communication about a product or service that encourages recipients to purchase or use the product or service. Marketing also is an arrangement between a covered entity and any other entity whereby the covered entity discloses protected health information, in exchange for direct or indirect remuneration, for the other entity to communicate about its own products or services encouraging the use or purchase of those products or services.

No authorization is needed, however, to make a communication that falls within one of the exceptions to the marketing definition. See additional guidance on Marketing. Minimum Necessary. A covered entity must make reasonable efforts to use, disclose, and request only the minimum amount of protected health information needed to accomplish the intended purpose of the use, disclosure, or request.

When the minimum necessary standard applies to a use or disclosure, a covered entity may not use, disclose, or request the entire medical record for a particular purpose, unless it can specifically justify the whole record as the amount reasonably needed for the purpose. See additional guidance on Minimum Necessary.

Access and Uses.

 
 

Quy trình thực hiện đăng ký hóa đơn điện tử theo Thông tư 78 |

 
 

As observed on the basis a limited survey, national or specific own terms of use are introduced as regards national repositories. Companies may introduce their own terms o f use The terms of use are varied and sometimes rely on open licenses designed at national level or building on Creative Commons type In addition they sometimes limit the reuse of information by introducing copyrights, database rights, limits to commercial reuse or specific obligations.

Nowadays, the EU legislation in the financial services and capital markets offer limited directions or provisions in this regard Timeliness should be understood from the perspective of information being made available once a company makes it public, as otherwise the frequency and delays of reporting obligations depends on each sectoral legislation and is not covered by this initiative.

However depending on how information was embedded e. PDF based on scanned images , this format may not always allow for simple data extraction and it is generally not suitable as a machine readable format As seen in consultation activities, stakeholders report as a common practice the use of paid services from data aggregators to access information.

This market led solution enables to alleviate the problems identified however come with a price tag for the service and other drawbacks such as own non-interoperable formats and standards and digested information. Difficulties in comparing information due a lack of semantic interoperability observed among the various sectoral legislation is out of the scope of this initiative.

Whereas there is no reason to downplay the importance of this problem in enabling the digital use of information, semantic interoperability has to do with the inner building of the information, the design and content of which has largely to do with the objectives and design of sectoral legislation, including by ways of own definitions and concepts underlying the content. The Commission has undertaken to advance on this front in a separate initiative with the development of a common data dictionary under its supervisory data strategy, to ensure data consistency and standardisation across financial sectors.

This dictionary will describe the content and format of all data collected under various reporting frameworks in a structured, comprehensive, consistent and unambiguous manner, using terms anchored in legislation to establish a clear link between collected data items and the relevant legislative requirements.

While this initiative will address primarily supervisory reporting, it will also aim to coordinate the data specifications with public disclosures. Therefore it is expected to have ramifications over public reporting. Nevertheless, the development of a common data dictionary will have little impact on the design of this initiative, in particular its scope and costs.

This is because the data dictionary is a longer term initiative, and it aims to describe the reported and disclosed information, whereas this initiative focuses on making the disclosed information more accessible and more easily readable by machines. The two initiatives are complementary as, the development of a common dictionary has the potential to aid the interpretation and comparability of disclosed information and hence facilitate its use.

Fragmentation as regards the information flows on the European markets and financial service s drives the costs up for discovering, accessing and processing the information users need. This is also a det e rr ent to research, and cross border analysis About half of stakeholders consulted find that costs for retrieving and processing information are generally high. Retail investors and civil society tend to find this source quite costly or even unaffordable.

The problems identified drive the significant search and processing costs experienced by stakeholders to get information and compare it. The situation is also a hindrance for users to compare 38 information , either directly or indirectly. About half of respondents to our consultation find that costs for retrieving and processing information are high.

C osts to acquire data and bring it in a stage where it can be digitally used generally require human intervention: scanning and recognition software, rekeying, etc.

Such costs are comprised mainly of staff costs, licensing or access fees, software, translations. As a result, on average respondents find that costs for retrieving and processing information that is mandatorily published in the area of financial services and capital markets are high, either with licenses acquired from data vendors or without such licenses. This is particularly acute as regards sustainability-related data which is currently more difficult and costly to obtain than standardised financial information publicly disclosed by listed entities.

A large insurance company estimated its own costs reached millions of euros. Another consequence is that the increasing demand for ESG information by market participants is not met. A vast majority of respondents to the ESAP targeted consultation 39 underlined their difficulties to easily access and digitally use ESG and other types of information published by entities. The European Green Deal aims to place sustainable finance at the heart of the financial system. Introduction of new disclosure obligations, such as those related to EU Taxonomy, SFDR and recently proposed CSRD, will on one hand increase transparency on sustainability impacts and risks, but also further increase demand for access to reliable sustainability, related data.

Continued uneasy access to sustainability-related data and barriers to their digital use hinder the ability of investors to reflect sustainability-related risks and impacts in their decisions and hence to effectively contribute to the Green Deal via sustainable investments.

This reduces as well the ability of investors, governments and civil society to hold companies accountable for negative environmental, social and human rights impacts, resulting in lower incentive for companies to become more sustainable and resilient.

Different types of users report that they experience similar problems, however on a different scale. Users are varied e. As a result, the impacts of the problems are of different scale and nature for different user types. One aspect that illustrates this is the different scale and frequency of data that stakeholders need to access: while professional investors seek frequent access to large volumes of information, retail investors typically find smaller volumes of information and occasional access sufficient.

National and EU public bodies have shared their interest in accessing information notably for statistical, supervisory or other public-interest purposes.

Correspondingly, the magnitude of search costs or impairments to decision making due to missing or difficult to use data that different users bear also differs. Data aggregators interviewed or consulted, despite being in the business of disseminating information, report similarly that these issues are an annoyance for them in harvesting raw data for their business, and a driver for loss of productivity.

During the workshop with users Annex 4 , there was a strong message that access to information is not optimal. The prevailing fragmentation in access to data is one of the long-standing barriers to the integration of financial markets across the EU By making it difficult and costly for investors to find, analyse and ultimately compare relevant information including for retail investors and financial advisors to compare financial product information , this situation also presents a barrier to optimal allocation of capital.

As such, this problem undermines the functioning of the internal market. For instance, it has been noted that it makes SME research more difficult As a result, their attractiveness to investors is not optimal, especially from a cross border perspective Home bias is in the EU a natural barrier to integration for cultural, historical and linguistic reasons. In finance, the fragmented European market affects in particular SMEs, which can in turn hamper their ability to expand beyond their own borders Due to home bias , SMEs and non-listed entities often have to rely on national markets.

As seen during the examination of barriers to the single market 49 , risk capital continues to be scarce for high-growth SMEs. As echoed by business organisations, the difficulty in accessing funding affects both domestic and non-domestic businesses alike. However, it would affect disproportionately those businesses that are trying to expand in the markets with limited access to capital, compared to already established businesses. In the wake of the covid crisis, the prospects for SME finance have become bleaker still.

The Netherlands stands out negatively in the euro area, with SME finance having shrunk as a percentage of GDP since the financial crisis. Fragmentation of capital markets is detrimental to a smooth functioning of the market and drives higher cost of capital, especially for listed companies which in turn makes becoming or staying listed less attractive The situation is also a hindrance to developing new digital services, such as services around the digital comparison of EU wide complete sets of data for a given sector, which is key for investment decisions.

Companies in the rating business ESG or creditworthiness report that the lack of digitalisation and easy access are barriers to their ability to develop complete, reliable and forward looking service offers. During consultation, some stakeholders contended that the emergence of new technologies such as artificial intelligence AI and machine learning ML combined for instance with Optical Character Recognition OCR could in the future improve the digital use of documents that contain non-structured data in any IT format, with the potential of solving, at least partly, the problem.

I t is difficult to predict whether such emerging technologies would enable any user to obtain reliable results at a reasonable cost in the foreseeable future , absent any intervention T here are nevertheless reasons to believe that this hypothetical scenario will not solve the problem. Building solutions based on artificial intelligence or machine learning would require that vast amounts of available data are readily available, accessible and usable.

For this purpose, the Commission aims precisely to build common data spaces, recognising that easier access and usability are a premise to the emergence of such new technologies In addition, the problems noted on harmonization in several dimension like document metadata, data structuring and semantic interoperability would impinge negatively on the quality of the output information that would be based on a fully automated interpretation of data.

Addressing t hese inefficiencies from the market angle would require huge investment s in not only technologies 54 but also human resources and gathering of data. As a result the total cost of investment would be high 55 , raising doubts whether this would result economically more efficient in the medium term than services offered by data aggregators. Given the persistence of the problem and absent new impetus, it is unlikely that EU markets and financial services would start integrating naturally , in a coordinated move , overcoming , for instance , the home bias observed on information flows A number of ongoing initiatives at regulatory level may nevertheless modify slightly the landscape.

Company Law mandates that by August , all documents and information submitted as part of the formation of a company, the registration of a branch, or a filing by a company or a branch, is stored by the registers in a machine-readable and searchable format or as structured data The impact of this initiative would remain limited for the objectives of ESAP, given the very limited overlap of information covered between Company law and this initiative , whilst other problems noted are not addressed.

An implementing Regulation on High Value Datasets will ensure an open data approach at national level as regards information delivered by certain national bodies where public offering access to on companies and company ownership, that is an estimated three reporting obligations within the scope of this intervention.

This policy builds on national systems, hence access would remain scattered on this basis. The ESEF i s an important stepping stone — not yet fully implemented in the markets — that will d eliver on the objective of increased digital use of information, however for a limited number of reporting obligations and market participants.

As regards ESG information , the European Commission adopted on 21 April a legal proposal as regards corporate sustainable reporting 59 which will cater for the need of structured and machine readable corporate sustainability reporting 60 , addressing one of the key concerns on ESG information raised during consultations. This Commission proposal for sustainability reporting concerns 37 listed regardless of size and large non-listed entities publishing corporate sustainability reports If adopted by the Union, this would represent undeniable progress but would not solve the problem globally.

Furthermore, the EEAP does not address problems such as terms of use, quality, integrity of information, etc. For these reasons, the EEAP cannot solve the problem in an extensive way.

The European Parliament has long been stress ing the need for deepening European capital markets in order to ensure access to financing from sources other than banks and to address barriers to cross border investments Adding to this, the shift towards sustainable investment and digital finance drive this initiative where information has a key role to play in the wider dimension of financial services area.

Data should be more easily accessible and ready for digital use for investors, including on a cross border basis.

An EU intervention to reduce fragmentation, by ways of e. The objectives of this initiative cannot be sufficiently achieved by the Member States individually. The Member States have currently certain leeway for the design of rules on mechanisms and formats of corporate reporting obligations set out by the EU legislation, with heavy reliance on national systems. The resulting geographical and thematic fragmentation of disclosure mechanisms and formats is pervasive in the Union and increases costs for users of corporate information.

Further individual actions by Member States would not reduce this fragmentation unless they move in the same direction to build a single access point and address a number of barriers, which is unlikely without a coordinated approach. Enabling better access to information at the EU level, considering the scale and the effects of such a project, is an objective that can be better achieved at Union level.

In addition, the design of suitable formats, terms of use, language specifications, etc. There is widespread support for such initiative from governments, regulators, regional or national market participants, users, civil society, etc.

Therefore, the Union may adopt measures, in accordance with the principle of subsidiarity as set out in Article 5 of the Treaty on European Union. In accordance with the principle of proportionality, this initiative should not go beyond what is necessary in order to develop and operate the ESAP. This intervention will not add to, or modify existing reporting obligations in terms of content, as this is the prerogative of sectoral legislation.

In order to minimise the burden on entities and national authorities, it would be appropriate for the ESAP to build as much as possible on the existing data reporting channels and infrastructure. Nevertheless, the EU intervention will add value by streamlining in an efficient way the delivery of usable information to users on a cross border basis which would not be possible through different national access points.

In response to the problems identified, the overall objective of the European Single Access Point is to contribute to integrating the European capital markets and the financial services including a cross border s within the Union and to foster a more efficient allocation of capital across the EU.

In addition, the intervention supports better access to sustainability-related data. O ther types of users may see an interest in obtaining the information, f or instance civil society , p ublic authorities, law-makers or economists and this also contributes to an efficient functioning of the internal market.

Barriers to access and use of information published by entities in the financial services and capital markets area will therefore have to be examined, as well as the numerous existing channels and lack of interconnection of existing national or EU repositories.

The intervention would not create any new reporting obligation in terms of content, but build on existing requirements. It would address information that is relevant in the financial services, capital markets and sustainable finance areas, pursuant to the overall EU strategy for data in these areas.

Two major specific objectives are identified in relation to public reporting obligations would contribute to the general objective set out above, as seen in Table 1. Reporting requirements with different channels as regards information to be published. Data repositories channelling a small portion of information are not interconnected. Increasing the flows i.

Language and other barriers insufficiently addressed. Machine readable formats specified for only for a few datasets. No prevailing market standard for disclosure format s. Increasing digital use and re-use of data. The first specific objective is to enable a seamless and integrated access to data published by entities subject to disclosure obligations in the area of financial services and capital markets, including sustainability related data, whilst avoiding disproportionate administrative costs for entities, in order to increase the circulation of information within the Union.

Increasing the circulation of information published in relation to financial services is necessary both within Member States and cross-border to support, at least in part, the general objective s of integration. The intervention should remove barriers to access, and improve discovery. This should be addressed keeping in mind the need to keep costs to a minimum 68 and alleviate other additional constraints, such as multiple filings The intervention should have regard to ongoing actions facilitating access to data at national level 70 and at EU level The second specific objective is to increase the digital use and re-use of data, addressing barriers or hurdles currently in place.

From the digital use angle, the ESAP should seek to standardise the way in which information is drawn up in order to make it easier digitally use, analyse and possibly compare , thus reducing processing costs for users. The intervention should remov e barriers such as unnecessary restrictions to re-use , linguistic barriers , etc. This should be consistent with actions which will facilitate use of data at national level and at EU level A minimum viable product should be implemented by end The intervention should also ensure that these measures enable the EU framework to remain dynamic in order to be able to accommodate future technological progress and remain evolutionary Considering how the problem will evolve, the main characteristics of the baseline scenario i.

As part of the baseline, other existing pan EU interconnection systems or databases are considered. Business registers under EU law 76 are in charge of the disclosure of limited liability company information to ensure publicity of such information towards third parties. As regards information in the financial services area, OAMs and NCA collect only a small portion of the available information. Without a proper EU dissemination system for information stored by OAMs and NCA, the information they collect remains not easily available to end users.

This is also valid for companies willing to disclose voluntari ly information relevant for financial services There are however a number of factors that prevent retaining the BRIS in the baseline. The main reasons are this initiative and BRIS have different intended users, consuming different information in a different way. In addition, there are different collection bodies with limited overlap on the data collected.

In particular:. By contrast, BRIS covers the company information to be disclosed under EU Company Law to the general public such as citizens, professionals and companies in order to provide legal certainty of such information. Th e vast majority of information otherwise offered in the BRIS, based on the Company Law Directive, would have no immediate interest to investors for the purpose of this initiative. While a maximum of 12 months is allowed by the EU law for filing financial statements with a business register, the delay is reduced to 4 month for an issuer i.

This overlap concerns currently up to around 12 companies depending on the type of document, and in the future possibly up to 49 companies, should the Commission proposal of 21 April for a corporate sustainability reporting Directive be endorsed by the co-legislators.

Therefore, considering the above, BRIS is not relevant in the baseline scenario. And this is only for one reporting obligation.

Therefore despite significant progress over the last years, the widespread digital use of information would remain hampered by the situation. As a result, in the baseline scenario, discovery and processing costs would remain significant for users. Reduced flow and digital use of information represent a barrier to integrated financial services and capital markets at the Union level, leading to losses of funding or investment opportunities, sub-optimal allocation and higher costs of capital, hampering the full potential of the internal market in the financial sector.

The main message during consultation is the emerging need for access to ESG information. This information is increasingly demanded, notably by investors, fund managers, intermediates, advisors, as well as civil society and public authorities due to recent regulatory evolutions in the Union 79 , but also by the public at large for various purposes out of the general fight against climate change.

This bottleneck may become a significant barrier to achieving the sustainable finance angle of the Green Deal. From the market side, extant registers other than data aggregators are not satisfactory solutions as none can fully solve all the problems identified Annex One can expect that technologies relevant to this problem will continue to emerge but there is no clear indication that they would resolve a substantial part of the problem in a timely manner.

The policy options focus on how to establish a single access point in order to achieve the specific policy objectives outlined in section 4, rather than considering a single access point as one possibility among others to tackle the problems. T his is because a vast majority could support an EU single access point as a wa y of improving access , even though some recognised that there could be other avenues to improve access on the basis of numerous sources of information or other ways — however providing no clear alternative efficient direction.

There is a strong support 80 among all stakeholders for a single access point at the EU level as the best solution to address the problems.

Asked during the public consultation on the Renewed sustainable finance strategy April-July if EU policy action is needed to help maximise the potential of digital tools for integrating sustainability into the financial sector, most respondents indicated that digital tools have a role to play to ensure access ible, reliable data e.

Only some suggested other ways such as promote innovation, create new instruments e. T here was a strong support during workshops Annex 4 for a single access point confirmed by survey on the spot, including for users. A few users believed that having access to the information in a centralized manner was not key — however not providing a clear description what other solutions might consist of.

The European economy has historically suffered from a lack of divers ified sources of funding for companies, hence the need to tackle the barriers to the flow of capital, to remove regulatory and non-regulatory barriers to the free movement of capital across borders. Hence, members have stressed that the EU suffered from a market competition disadvantage and insufficient EU market-based financing compared to e.

To tackle these issues, members of the HLF saw merit in mirroring in th e EU solutions in place in comparable markets of third countries , that is a single access point to information however with a broader scope to also capture sustainability-related and other information. A single access point is consistent with the European strategy for data and on digital finance which both herald common data spaces in the financial sector for enhanced access to data and data sharing.

This section presents the different policy options for the following five main dimensions that are crucial to ensure relevant objectives are met: 1 scope of the information accessible via ESAP; 2 format of the information accessible via ESAP; 3 collection of the information accessible via ESAP and interconnection of existing collection points; 4 open data, and 5 governance.

These are considered to be the core aspects in terms of addressing the identified problems and they are also the principal determinants of costs. An overview of which policy options can serve the objectives is provided in Table 2.

Table 3 provides a summary of the options presented in this section. Key dimensions. Scope of the information. Collection of the information and interconnection of existing. Increased digital use and re-use of information. Core information: Only entity-related info mandatorily published by listed entities.

No product-related nor other mandatory info. No voluntary info accepted. Option 2. No other mandatory info. Certain voluntary info accepted. Option 3. All info published by entities in the scope of EU financial markets legislation to be included progressively.

All relevant voluntary info accepted. Certain info to be in an open and widely used data extractable format see annex Entities submit the information to a collection point that is interconnected with the ESAP at the same time as they make the information public. Option 1.

This section presents the policy options for the information that would be accessible via ESAP. The scope and related options is driven by the objectives. This confines the scope to be examined to information that is relevant for use in the financial services and capital markets area , as well as in relation to sustainability. On the basis of a wide encompassing mapping of EU law, the Commission services identified the Directives and Regulations potentially serving this purpose During the mapping exercise it appeared that certain market participants had reporting obligations that confine to being a register, in relation to transaction based information, and not always for the purpose of making that information primarily available to the public.

By nature, this information does not respond to the objectives of this initiative. For instance, some requirements may imply an obligation for timely disclosure 15 minutes after the event , others require specific access means with the ability to address massive amounts of data with high frequency. For that matter, these transaction-related reporting obligations should remain out of the scope of the ESAP.

Nevertheless, any low frequency entity-related or product-related reporting obligations impinging on these bodies, such as governance reports, would represent relevant information for the ESAP. Some reporting obligations may pertain to several categories.

Third countries entities whose securities are traded on an EU regulated market will have to mandatorily make available via the ESAP any information required by EU law. No voluntary information. In this option focusing on essential core information demanded by investors , t he ESAP would provide access only on entity-related information financial and sustainability-related that has to be published under EU law by issuers with securities admitted to trading on the EU regulated markets i.

No other mandatory information , such as financial and sustainability information by large non-listed entities , would be accessible via the ESAP.

Certain voluntary information. In addition to the information disclosed under Option 1, t he ESAP would provide access to key entity-related information 95 required under the EU law the access to which is overall highly supported by users i.

Adding 21 more information that is related to both entity and product the option would address altogether around 79 reporting obligations. All relevant voluntary information. The ESAP would progressively 97 provide access to all entity , product and other information that has to be published by any entity under the EU financial markets legislation see the list of relevant EU legal acts in Annex 9 , representing around reporting obligations This section presents the policy options for the format of the information accessible via ESAP.

Formats such as PDF can be considered as data extractable if the file contains the characters, i. Making information machine readable on a systematic basis may be envisaged as an option.

In such a setting, the information published by entities would have to be mandatorily drawn-up and submitted in one or a few predetermined specific single machine-readable format s in order to be accepted by the ESAP. This option is however discarded at an early stage for the following reasons:. I Machine readability depends to a great extent on the preliminary existence of structured data on the basis of, for instance , layouts, taxonom ies , template s , form s associated with certain information , and a format.

If the template or taxonomies are missing the information will not be truly machine readable even if a machine readable format is adopted , because the machine will not recognise the nature of information it is dealing with. D ata structuring is therefore a prerogative of the sectoral legislation , having to d o with its inherent objectives, which is beyond the objectives of the ESAP initiative addressing the accessibility and digital use of information.

III Based on our consultation activities, most stakeholders except retail investors and data aggregators could cope with different formats for different types of information They did not necessarily support a single format and could live with different formats. In fact, with tools such as viewers, readers, software etc. IV As machine readable formats come with their own characteristics, co nstraints and benefits, a tailor- made approach is necessary to assess which format, if any, is the most appropriate for a given information depending on the content, perceived importance or needs of the users for each reported information, as well as costs and benefits.

An analysis has to be conducted at the level of each sectoral legislation rather than on a central basis to ensure proportional approach. Nevertheless, aiming for machine readability is key to reach the objective of increased digital use and re-use of data consultation. Hence as an overarching principle for all the options examined below, it is considered that the intervention will confer powers on the Commission to adopt machine readable formats by ways of level 2 measures secondary law such as Commission Decision in each relevant sectoral legislation concerned.

This would allow to examine the case for machine readability on a wide scale, yet possibly on a case by case basis, not pre-empting any solution or having any impacts at this stage. The following options were identified as regards formats:. This would effectively mean that most information available through ESAP would not be data extractable or machine readable. The ESAP would specify a common minimum set of metadata for all the information to be disclosed including a legal entity iden t ifier.

In addition, the Commission would be provided with delegated powers to define via delegated acts specific metadata for each type of document where the existing required format is not machine-readable. The Commission would have delegated powers to specify a machine readable format.

The ESAP would accept only documents prepared in a n open and widely used data extracta ble format The ESAP would specify a common minimum set of metadata for all the information to be disclosed including a l egal e ntity i dentifier.

In the absence of a collection point specified under EU law , the entities would submit the information including voluntary information directly to the OAMs.

In the absence of a collection point specified under EU law, the entities would submit the information including voluntary information directly to a collection point interconnected with the ESAP at the same time as they make such information public. Entities submit the information including voluntary information only to the OAMs. The ESAP will contain information that is of high value for users in the financial services and capital markets area. Many end users will re-use information in a way or another, for personal consumption or commercial purposes.

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