European DataWarehouse GmbH
EDW
European DataWarehouse GmbH (EDW) is the first central repository in Europe for collecting, validating and making available for download standardised and asset class specific loan level data (LLD) for Asset-Backed Securities (ABS) and Additional Credit Claims (ACC).
ID: 781559916266-15
Lobbying Activity
Meeting with Gilles Boyer (Member of the European Parliament, Shadow rapporteur)
23 Sept 2025 · Securitisation
Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union) and
15 Jan 2025 · Securitisation
30 Jan 2024
European DataWarehouse GmbH (EDW) welcomes European Commissions feedback request on the draft delegated regulation for harmonising and simplifying fees charged to securitisation repositories and would like to contribute to it from its standpoint as a European Securities and Markets Authority (ESMA) designated securitisation repository. EDW welcomes the European Commission´s decision to review the ESMAs fees funding system and the initiative to harmonise and simplify technical aspects of ESMAs fee collection system so that fee collection is less complex and more uniform across sectors. EDW generally agrees with the provisions of the draft delegated regulation for harmonising and simplifying fees charged to securitisation repositories. However, EDW is of the opinion that the introduction of the undefined terms direct and especially, indirect in Article 1 could lead to further discretion and ambiguity in the calculation of supervisory costs. In this context, EDW considers that the definition of indirect costs should be included in the draft delegated regulation.
Read full responseResponse to Open finance framework
27 Oct 2023
Dear Sirs, please see attached the European DataWarehouse GmbH response. Kind regards Marco Angheben
Read full responseMeeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)
25 Jan 2023 · European securitization market
Meeting with Frances Fitzgerald (Member of the European Parliament, Shadow rapporteur)
24 Oct 2022 · European Single Access Point (Assistant on behalf of MEP)
Response to Implementing act on a list of High-Value Datasets
21 Jun 2022
European DataWarehouse GmbH (EDW) hereby advocates for the making of sustainable and green datasets open access in a machine-readable format through application processing interfaces (APIs) and bulk download.
EDW was founded in 2012 as part of the implementation of the European Central Bank (ECB) ABS Loan Level Initiative to restore investors’ and supervisors’ confidence in European securitisation markets following the financial market crisis. EDW is the first central data repository in Europe for collecting, validating and making available for download detailed, standardised and asset class specific loan-level data (LLD) for Asset-Backed Securities (ABS) transactions. Developed, owned and operated by the market, EDW helps to facilitate risk assessment and to improve transparency standards for European ABS deals. EDW has been involved over the last few years in a number of sustainable finance initiatives like the Energy Efficiency Protocol and Portal under Horizon 2020 with the EMF-ECBC and is a founding member of the Energy Efficiency Mortgage Hub in the Netherlands. EDW is a designated securitisation repository by ESMA under Regulation (EU) 2017/2402 (hereinafter, the “Securitisation Regulation”), as well as a repository for the Eurosystem ABS and pools of additional credit claims (PACC) collateral framework across the Eurozone. In its remit as an ESMA designated securitisation repository, EDW has detected that the energy performance certificate (EPC) related fields of the disclosure technical standards under the Securitisation Regulation are usually not completed given the general lack of availability of EPC information in electronic format.
The unavailability of EPC information constitutes, in our view, an obstacle for the achievement of the European Green Deal goals. From the financial sector perspective, this is because the lack of sustainable-related information on products stalls the promotion of financial incentives for the Renovation Wave. In this context, Article 2 (10) of Directive (EU) 2019/1024 of the European Parliament and of the Council of 20 June 2019 on open data and the re-use of public sector information (the “Open Data Directive”) defines the term “High-value datasets” as documents the re-use of which is associated with important benefits for society, the environment and the economy, in particular because of their suitability for the creation of value-added services, applications and new, high-quality and decent jobs, and of the number of potential beneficiaries of the value-added services and applications based on those datasets.
The Draft Implementing Regulation object of the present consultation establishes the list of high-value datasets and the means through which these should be made available, i.e., in machine-readable formats via APIs and, where applicable, ready for bulk download.
EDW considers that EPC data should be included as a high-value dataset according to the definition of the Open Data Directive, since:
1. The availability of EPC information would have important benefits for the environment, namely, facilitating the improvement of the energy efficiency of EU building stock .
2. In this sense, the availability of EPC information in a machine-readable format via APIs and ready for bulk upload and download would enable the effective implementation and usage of value-added services already tested by EDW, i.e., the matching of loan-level data with EPC data . This matching helps the disclosure of the energy performance information of the underlying assets of loans and would therefore have a positive impact on the development of the EU sustainable finance strategy, boosting the Renovation Wave.
3. The availability open access of EPC information would be beneficial not only for the achievement of the European Green Deal objectives, but also, for the different participants in financial markets, such as borrowers and officers.
Read full responseResponse to Revision of the Energy Performance of Buildings Directive 2010/31/EU
31 Mar 2022
European DataWarehouse (EDW) has extensive expertise in data gathering, validating, standardisation and quality
restitution -for both financial and non-financial data-, as well as in operating a European Union (EU)
central database with appropriate human and IT resources under EU supervision. More recently
the European Banking Authority underlined the importance of “Developing a Framework for Sustainable
Securitisation” in a report published on 2 March 2022. The need for additional disclosure
requirements is important to ensure that investors are made aware of the green characteristics of
the underlying mortgage portfolios. We firmly believe that EDW could significantly and vey positively
contribute to the enforcement of the Energy Performance of Buildings Directive thanks to its
technical and regulatory knowledge and its wide experience acting as a data repository.
As such, EDW welcomes the European Commission’s proposal for the revision of the Energy Performance
of Buildings Directive that would provide citizens, investors, and other relevant parties
with seamless access to energy efficiency-related dwellings information.
The EU Building Stock Observatory (BSO) will become a key component of the “Fit for 55” objectives,
as envisaged by the common vision for a zero-emission building stock by 2050. The BSO should
become de facto the key source of EPC information for financial institutions enriching their collateral
information with cadastral data that is generally not collected and available openly for mortgage
or loan providers. Additionally, there are currently barriers to the access to the EPC information
due to the inconsistent interpretation of the General Data Protection Regulation (GDPR).
This hampers the debt financing for buildings renovations due to the lack of publicly open access
EPC data and limit the overall objective of reducing energy poverty.
Below we set out the data-related requirements that we believe are essential to ensure that the
BSO is effective in delivering on its policy objectives.
1. Ensuring a successful BSO
In EDW’s view, this common publicly accessible data space for buildings’ EPC information,
combining data reported under different regulatory reporting requirements such as the Energy
Efficiency Directive (EED) and other EPC related reporting requirements (Renewable Energy
Directive (RED) etc.), should be expanded based on the following key principles:
• Centralisation – all EPC documentation should be collected into one European centralised
database for all European dwellings. A centralised platform solution facilitates the
access and eventually the use of the information. From this perspective the BSO represents
an important step forward collecting all relevant information from the various
national and regional EPC databases;
• Proportionality – the concept of proportionality should aim to strike the right balance
between the costs and benefits of such disclosures especially for lower efficiency
dwellings that are typically older buildings. It has to be noted that the EPC information
is not available for all the dwellings in Europe and therefore incentives should be built
for homeowners to lessen their EPC expense (for example by making the EPC document
expense fiscally deductible when it needs to be issued or updated after a specific
period of time).
• Comparability – a centralised repository facilitates the comparison of EPC and other
related information across data submissions and sectors should be regularly updated
(semi-annually or annually) in an open access manner to facilitate queries.
• Data harmonisation and standardisation – the EPC data and documentation should
be based on a common European minimum performance standards and scale taking
into consideration the national specificities.
• Data digitisation - The use of a structured machine-readable format is a necessity... (the complete letter in PDF is attached)
Read full response29 Mar 2022
Ensuring a successful ESAP
In EDW’s view, this common publicly accessible data space for companies’ financial and non-financial data including ESG information, combining data reported under different regulatory re-porting requirements such as the Non-Financial Reporting Directive (NFRD) and other ESG related reporting requirements (Sustainable Finance Disclosure Regulation (SFDR) etc.) should be built on the following key principles:
• Centralisation – We strongly support the Commission’s approach for a centralised plat-form to collect all relevant information from the national appointed mechanisms, which will facilitate the access and eventually the use of the information. This is all the more important considering the voluminous amount of data and documentation that can be expected to be provided across the almost entire Financial Services and Sustainable Finance legislative acquis. The centralisation of ESG company information is particularly important for investors to be able to support the sustainable finance transition, and should there-fore be a priority, while financial data can be collected incrementally later, or in parallel. Additionally, both financial and non-financial data reported in the ESAP should also dis-close if such information has been audited or not.
• Proportionality – The concept of proportionality should aim to strike the right balance between the costs and benefits of disclosures, especially for smaller companies (for more information on the ESAP estimated costs please see the section below). This is particularly relevant with respect to the formats of the data to be reported as well as to reporting entities with presence in multiple countries, for which the process should be streamlined as much as possible. For example, the XML format currently required under the Securitisation Regulation should also be required as part of the ESAP reporting framework. Further, to avoid additional burdens on SMEs, SMEs should also be able to delegate the re-porting obligations to appropriate third parties.
• Comparability – We support the proposal of a centralised repository that facilitates the comparison of ESG and other information across data submissions, jurisdictions and sec-tors, but this should be open access to facilitate queries. The ability to have open access bulk data is critical for data users to build their analytical tools to monitor the information flow and derive meaningful insights. We support the Commission’s proposal to have power users pay a premium for ongoing access to open data and the regular updates. However, we believe that the ESAP centralised solution may not fully deliver on its comparability function without adequate support for clients onboarding the information as well as using the data. Having a qualified team of multilingual speakers across relevant jurisdictions is invaluable in light of divergences in accounting principles, practices, fiscal regimes, fiscal incentives and data formats across Member States.
• Data harmonisation and standardisation – The ESG data and documentation should be based on a common reporting framework. Such framework should include minimum re-porting technical standards developed by the European Supervisory Authorities such as reporting templates with taxonomies and KPIs, like in the EU Taxonomy. In an ideal scenario, the goal would be to have an adjusted dataset whereby it would be possible to compare reporting submissions across time series taking into consideration the previous-ly available data and upcoming reporting requirements.
• Data digitisation – The use of a structured machine-readable format as proposed is a deminimis necessity and consistent with other regulatory disclosure obligations, espe-cially with respect to financial data reporting. The digitisation of the information would al-low the enhancement of the non-financial information with other public corporate information. (Please read more in the PDF response attached)
Read full responseResponse to EU single access point for financial and non-financial information publicly disclosed by companies
15 Jan 2021
European DataWarehouse (EDW) welcomes the EC consultation on its roadmap for the European Single Access Point (ESAP) for company information published on 18 December 2020. The attached document contains EDW’s feedback to the European Commission’s Inception Impact Assessment with regards to a Proposal for a Directive/Regulation of the European Parliament and of the Council for a European single access point for financial and non-financial information publicly disclosed by companies.
Read full response