This response was developed with input from our members in GDF’s MICA Working Group, and we were pleased to provide a constructive assessment and technical analysis of the templates, identifying key areas of the templates that may require further consideration. The core areas identified are:
- Proportionality for Reasonable Reporting Encouraged,
- Further Alignment to Global and EU Standards Supported,
- Concerns Noted for Unprecedented Reporting Requirements,
- Identification of Competition Concerns, and
- Proposal of Adjustments to Reporting Requirements to Mitigate Risks.