The Case for a Single-Document-Driven European Issuer-Disclosure Regime

The disclosure regime to which corporate equity issuers listed on European regulated markets are subject under the relevant European financial regulation have similar objectives whether or not the issuer is offering securities at the time of disclosure. From this premise, this article argues that the content and format of disclosure should be the same on primary and secondary markets, at least with respect to large and thickly traded issuers whose securities are traded in an efficient market. More specifically, a move to an integrated disclosure regime and to a company registration system is advocated. This includes the suppression of the separate drafting, dissemination and storage of periodic reports which should be replaced by a periodic update of the initial disclosure document. The suggested scheme should lower the costs for issuers and supervisory authorities. It should also make comparisons by investors easier.