QIS5 Consultation Feedback: Practicability Issues

The CRO Forum and CFO Forum are pleased to be able to provide comment on the QIS5 draft specification, as prescribed in the QIS5 consultation. We welcome the openness to cooperation between us and trust that this is merely a point in our continuous dialogue. We note the marked improvements evidenced in the European Commission’s draft QIS5 specifications, compared to the final advice for Level 2. Nevertheless, the CRO Forum and CFO Forum still believe that the draft specifications are too conservative and need improvement in a number of areas. In addition to our ‘high-level issues paper’, this document sets all our practicability issues in relation to the QIS 5 draft specification that list more detailed observations on the clarity of drafting.

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