Call for Evidence on the restricted subscription and private credit ratings

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Responding to this paper 

ESMA invites comments on all matters in this paper and in particular on the specific questions summarised in Annex 1. Comments are most helpful if they:

  1. respond to the question stated;
  2. indicate the specific question to which the comment relates;
  3. contain a clear rationale; and
  4. describe any alternatives ESMA should consider.

ESMA will consider all comments received by 31 May 2026.

All contributions should be submitted online under the relevant consultation. All respondents should use the relevant reply form in docx format.

Publication of responses

All contributions received will be published following the close of the consultation, unless you request otherwise. Please clearly and prominently indicate in your submission any part you do not wish to be publicly disclosed. A standard confidentiality statement in an email message will not be treated as a request for non-disclosure. A confidential response may be requested from us in accordance with ESMA’s rules on access to documents. We may consult you if we receive such a request. Any decision we make not to disclose the response is reviewable by ESMA’s Board of Appeal and the European Ombudsman.

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Personal data contained in the file will be published as submitted. If you don't wish such personal data to be publicly available, you should not include personal data within the document you upload to a public consultation. Alternatively, you may choose the option to not have your response published on the ESMA website. For further details on data processing, please refer to the record register.

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Who should read this paper?

This paper is addressed to all financial market participants and, in particular, credit rating agencies, issuers, investors and competent authorities involved in the issuance and use of credit ratings for regulatory purposes.

Activity Institution Download
Others Advisense OSIS
  • 220424
Credit Rating Agencies MFR Credit Ratings
  • 220672
Credit Rating Agencies EthiFinance Ratings SL
  • 220789
Credit Rating Agencies Fitch Ratings
  • 220838
Others Alternative Investment Management Association (AIMA) and Alternative Credit Council (ACC)
  • 220849
Credit Rating Agencies Scope Ratings GmbH
  • 220866
  • 220867
Credit Rating Agencies Scope Ratings GmbH
  • 220873
  • 220874
Banking AFME
  • 220880
Credit Rating Agencies Morningstar DBRS
  • 220883
Asset Management MFA
  • 220886
  • 220887
Credit Rating Agencies KBRA
  • 220889
  • 220890
Others Loan Market Association ("LMA") and Private Placement Investors Association ("PPIA")
  • 220893
  • 220894
Credit Rating Agencies European Association of Credit Rating Agencies (EACRA)
  • 220921
Credit Rating Agencies S&P Global Ratings Europe Ltd
  • 220950
Credit Rating Agencies Moody’s Ratings
  • 221347