Recital 5

(5)The necessary amendments to Implementing Regulation (EU) 2022/389 do not involve significant changes in substantive terms nor additional reporting burden on investment firms. In accordance with Article 15(1), second subparagraph, of Regulation (EU) No 1093/2010 of the European Parliament and of the Council ³ , the European Banking Authority has not conducted open public consultations, nor analysed the potential related costs and benefits, considering that it would be highly disproportionate in relation to the scope and impact of the draft implementing technical standards concerned,