Information that is incorporated pursuant to Article 19(1b) of the Prospectus Regulation will not have been considered by an NCA during the prospectus scrutiny and approval process. How will that interact with the NCA’s approval statement which will be included in the base prospectus at the time of approval?

How should issuers comply with the requirement to include a hyperlink to new annual or interim financial information that will be incorporated by reference if such information is not yet available at the time of approval of the base prospectus?

Article 19(1b) of the Prospectus Regulation states that issuers may incorporate new annual or interim financial information by reference that has been published electronically.
If an issuer plans to use this facility how should this fact be reflected in the base prospectus?

Please clarify the scope of ‘financial information’ to which Article 19(1b) of the Prospectus Regulation applies.

Article 14 of Regulation (EU) 2023/2631 on European green bonds (‘EuGB Regulation’) requires certain issuers to publish a prospectus approved under Regulation (EU) 2017/1129 (the ‘Prospectus Regulation’) in order to use the designation of ‘European Green Bond’ or ‘EuGB’. Article 10 of the EuGB Regulation sets out the requirements relating to the completion of an EuGB factsheet, while Article 15 sets out requirements relating to the publication of the EuGB factsheet.

In this regard, is it possible to publish the EuGB factsheet prior to the publication of a prospectus approved under the Prospectus Regulation? Moreover, is it possible to advertise a European Green Bond prior to the approval and publication of the prospectus? Please clarify the meaning ‘use of the designation’ in this context.