CRA Market Share Report

20 December 2023

ESMA84-2037069784-2106

2023 edition

 
ESMA - 201-203 rue de Bercy - CS 80910 - 75589 Paris Cedex 12 - France - www.esma.europa.eu   2 
 
Table of Contents 
Legislative references, abbreviations and definitions .................................................... 3 
1  Legislative references ............................................................................................ 3 
2  Abbreviations ......................................................................................................... 3 
Executive Summary ...................................................................................................... 5 
Legal Basis .................................................................................................................... 5 
How to use this Document ............................................................................................ 6 
How CRAs’ Market Shares are calculated .................................................................... 6 
Applicability ................................................................................................................... 6 
Market Share Calculation for EU Registered CRAs ...................................................... 7 
Types of Credit Ratings offered by EU registered CRAs .............................................. 9 
Market Share of EU Registered CRAs by Rating Category ........................................ 10 
Supervisory Briefing for Article 8d ............................................................................... 13 
Questions and Feedback ............................................................................................ 13

1 Legislative references, abbreviations and definitions

1.1 Legislative references

CRA Regulation

Regulation (EC) No 1060/2009 of the European Parliament

and of the Council of 16 September 2009 on credit ratings

agencies as amended by Regulation (EU) No 513/2011 of

the European Parliament and of the Council of 11 May 2011,

Directive 2011/61/EU of the European Parliament and of the

Council of 8 June 2011, Regulation (EU) No 462/2013 of the

European Parliament and of the Council of 21 May 2013,

Directive 2014/51/EU of the European Parliament and of the

Council of 16 April 2014 and Regulation (EU) 2017/2402 of

the European Parliament and of the Council of 12 December

2017.

1.2 Abbreviations

Credit Rating

Credit rating means an opinion regarding the

creditworthiness of an entity, a debt or financial obligation,

debt security, preferred share or other financial instrument,

or of an issuer of such a debt or financial obligation, debt

security, preferred share or other financial instrument, issued

using an established and defined ranking system of rating

categories (Regulation 1060/2009 Article 3(1)(a)).

Credit Rating Agency

Credit rating agency means a legal person whose occupation

includes the issuing of credit ratings on a professional basis

(Regulation 1060/2009 Article 3(1)(b)).

Credit Rating Activities

Credit rating activities means data and information analysis

and the evaluation, approval, issuing and review of credit

ratings.

Group of Credit Rating

Agencies

‘group of credit rating agencies’ means a group of

undertakings established in the Union consisting of a parent

undertaking and its subsidiaries within the meaning of

Articles 1 and 2 of Directive 83/349/EEC as well as

undertakings linked to each other by a relationship within the

meaning of Article 12(1) of Directive 83/349/EEC and whose

occupation includes the issuing of credit ratings. For the

purposes of Article 4(3)(a), a group of credit rating agencies

shall also include credit rating agencies established in third

countries;(Regulation 1060/2009 Article 3(1)(m).

Ancillary Services

Ancillary services are not part of credit rating activities; they

comprise market forecasts, estimates of economic trends,

pricing analysis and other general data analysis as well as

distribution services.

Issuer

Issuer means a legal entity that issues or proposes to issue

securities as defined in Article 2(h) of Regulation (EU)

2017/1129 on the prospectus to be published when securities

are offered to the public or admitted to trading on a regulated

market and repealing Directive 2003/71/EC. (Regulation

1060/2009 Article 3(1)(s)).

Financial Instrument

Financial Instrument means any of the instruments listed in

Section C of Annex I to Directive 2004/39/EC. Regulation

1060/2009 Article 3(1)(k)).

Related Third Party

Related third party means the originator, arranger, sponsor,

servicer or any other party that interacts with a credit rating

agency on behalf of a rated entity including any person

directly or indirectly linked to that entity by control (Regulation

1060/2009 Article 3(1)(i)).

Sectoral Competent

Authority

Sectoral Competent Authority means the national competent

authorities designated under the relevant sectoral legislation

for the supervision of credit institutions, investment firms,

insurance undertakings, reinsurance undertakings,

institutions for occupational retirement provision,

management companies, investment companies, alternative

investment fund managers, central counterparties and

prospectuses (Regulation 1060/2009 Article 3(1)((r)).

2 Executive Summary

1. One of the objectives of the CRA Regulation is to increase competition in the markets

for credit ratings by encouraging issuers or related third parties to use smaller credit

rating agencies.

2. In this regard, Article 8d of the CRA Regulation requires issuers or related third parties,

who intend to appoint two or more CRAs to rate an issuance or entity, to consider

appointing at least one CRA with no more than 10% of the total market share in the

EU.

3. Where an issuer or related third party does not chose to appoint a CRA with a less than

10% total market share in such cases, the CRA Regulation (Article 8d) requires this

decision to be documented. The obligations of Article 8d are supervised and enforced

at national level by the relevant sectoral competent authorities.

4. In order to assist issuers or related third parties with this assessment, Article 8d of the

CRA Regulation requires the European Securities and Markets Authority (ESMA) to

publish annually a list of registered CRAs and the types of credit ratings they issue,

together with a calculation of CRAs’ revenues from credit rating activities and ancillary

services at group level.

3 Legal Basis

5. As set out in recital 11 of the CRA Regulation

, the purpose of Article 8d is to increase

competition in the credit rating industry by encouraging issuers or related third parties

to consider the appointment of smaller CRAs.

6. In this regard, Article 8d(1) states that where issuers or related third parties intend to

use two or more CRAs, they should consider appointing one CRA with less than 10%

market share in the EU. In the event that the issuer or related third party does not

appoint at least one CRA with less than a 10% market share, this decision shall be

documented.

7. The market share calculation is required to be published by ESMA on an annual basis

in accordance with Article 8d(2). Its purpose is to assist issuers or related third parties

in their identification of CRAs with a total market share of less than 10%.

8. Credit rating activities refer to the definition of credit ratings provided in Article 3(1)(a)

of the CRA Regulation. These activities involve giving opinions regarding the

creditworthiness of an entity, a debt or financial obligation, debt security, preferred

share or other financial instrument, or an issuer of such a debt or financial obligation,

debt security, preferred share or other financial instrument.

See recital 11 of 2013 amendments to the CRA Regulation, Regulation (EU) No 462/2013 of the European Parliament and of

the Council of 21 May 2013, OJ L 146, 31.5.2013, p. 1–33.

9. The term ancillary service is set out in the second paragraph of Point 4, Section B of

Annex I of the CRA Regulation, which states that ‘A credit rating agency may provide

services other than the issue of credit ratings (ancillary services). Ancillary services are

not part of credit rating activities; they comprise market forecasts, estimates of

economic trends, pricing analysis and other general data analysis as well as distribution

services.

10. As set out in Article 25a of the CRA Regulation, the supervision and enforcement of

Article 8d is the responsibility of national sectoral competent authorities. For further

details please refer to Section 9 of this document.

4 How to use this Document

11. In order to identify a CRA with less than 10% total market share, issuers or related third

parties should refer to Section 7, which provides a list of registered CRAs indicating

total market share for each.

12. In order to identify the different types of credit ratings offered by each CRA, issuers or

related third parties should refer to Section 8. For a breakdown of credit ratings by asset

class, issuers or related third parties should refer to Section 9. For more information on

Article 8d of the CRA Regulation, please refer to the Supervisory Briefing adopted by

ESMA in Section 10.

13. This Supervisory Briefing includes a Standard Form that can be used by issuers or

related third parties on a voluntary basis. This Standard Form is relevant for issuers or

related third parties who choose not to appoint a CRA with less than 10% total market

share and are required to document this decision.

5 How CRAs’ Market Shares are calculated

14. In accordance with Article 8d(3) of the CRA Regulation, the total market share for each

registered CRA is calculated with reference to annual turnover generated from credit

rating activities and ancillary services at group level in the EU for that CRA or group of

CRAs.

15. For the purpose of this exercise, total market share has been calculated based on

CRAs’ audited financial statements with reference to the annual turnover from the credit

rating activities and ancillary services for the year 2022.

16. Separately, the market shares by rating category included in Section 9 are based on

the proportion of instruments for which an EU-issued rating has been assigned by EU

registered CRAs.

6 Applicability

17. This market share calculation is valid for use from its date of publication and is

applicable until the date of publication of the next Market Share Calculation in 2024.In

order to ensure you are referring to the most recent Market Share Calculation please

visit the relevant section of ESMA’s CRA supervision webpage. For the most recent list

of EU Registered CRAs please visit the relevant section of ESMA’s CRA Supervision

Page

7 Market Share Calculation for EU Registered CRAs

18. The Table on page 6 (Table 1

) provides a list of all CRAs registered in the EU in

accordance with the CRA Regulation. In this regard, there are currently a number of

groups of CRAs operating in the EU

. For each CRA or group of CRAs, ESMA provides

the applicable total market share, calculated according to the process described in

Section 5. In order to provide information on the evolution of the market, ESMA also

provides information as to the year-on-year change in each CRA’s market share

Finally, ESMA provides an indicator as to whether a CRA has less than 10% total

market share.

19. This year, the deregistration of two CRAs has led to changes in the market share. The

two CRAs deregistered were Qivalio SAS (previously Spread Research) and Scope

Hamburg GmbH (previously Euler Hermes Rating GmbH).

CRAs are included in the market share table in order of decreasing market share.

Moody’s Investors Service: Moody’s Investors Service Cyprus Ltd. Moody’s France S.A.S. Moody’s Deutschland GmbH.

Moody’s Italia S.R.L. Moody’s Investor Service España S.A., Moody’s Investors Service (Nordics) AB.

CRIF Ratings and ICAP CRIF: CRIF S.p.A, ICAP CRIF S.A.

CRA’s market shares have been rounded to 2 decimal points. Indication of Year on Year Change is based on the underlying

unrounded figure.

Name of CRA

Market

Less than

10%

Total Market Share

2022

YoY Change vs

2022

S&P Global Ratings Europe Limited

48.63%

50.13%

↓

Moody's Investor Services

31.45%

32.79%

↓

Fitch Ratings Ireland Limited

10.26%

10.05%

↑

DBRS Ratings GmbH

1.81%

Yes

1.31%

↑

Scope Ratings GmbH

1.72%

Yes

1.31%

↑

Cerved Rating Agency S.p.A.

1.16%

Yes

1.03%

↑

Kroll Bond Rating Agency Europe Limited

0.72%

Yes

0.37%

↑

EthiFinance S.L.

0.69%

Yes

0.34%

↑

CRIF Rating S.r.l.

ICAP CRIF S.A.

0.66%

Yes

0.48%

↑

modeFinance S.r.l.

0.61%

Yes

0.42%

↑

A.M. Best (EU) Rating Services B.V.

0.49%

Yes

0.41%

↑

GBB-Rating Gesellschaft für

Bonitätsbeurteilung GmbH

0.44%

Yes

0.33%

↑

CreditReform Rating AG

0.42%

Yes

0.38%

↑

ASSEKURATA Assekuranz Rating-Agentur

GmbH

0.30%

Yes

0.25%

↑

Capital Intelligence Ratings Ltd

0.16%

Yes

0.11%

↑

Nordic Credit Rating

0.15%

Yes

0.11%

↑

ARC Ratings S.A.

0.13%

Yes

0.07%

↑

Inbonis S.A.

0.12%

Yes

0.06%

↑

BCRA-Credit Rating Agency AD

0.06%

Yes

0.03%

↑

EuroRating Sp. z o.o.

0.02%

Yes

0.01%

↑

TOTAL

100%

Moody’s Investors Service: Moody’s Investors Service Cyprus Ltd. Moody’s France S.A.S. Moody’s Deutschland GmbH.

Moody’s Italia S.R.L. Moody’s Investor Service España S.A., Moody’s Investors Service (Nordics) AB.

8 Types of Credit Ratings offered by EU registered CRAs

20. The Table below (Table 2) provides an overview of the different types of credit ratings

each EU CRA is registered to provide. This table is provided in order to enable issuers

or related third parties to evaluate whether a CRA with less than 10% total market share

is registered to provide the class of credit rating they require. The information contained

in this table is based on the data reported into ESMA’s supervisory database and ESMA

supervisory information.

CRA NAME

Corporate

non-financial

Financial

Institutions

Insurance

Sovereign

Structured

finance

S&P Global Ratings Europe

Moody's

Fitch Ratings

DBRS Ratings

Scope Ratings

Cerved Rating Agency

Kroll Bond Rating Agency Europe

EthiFinance

CRIF Ratings

ICAP CRIF

modeFinance

A.M. Best (EU) Rating Services

GBB-Rating

CreditReform

ASSEKURATA Assekuranz

Rating-Agentur

Capital Intelligence Ratings

Nordic Credit Rating

ARC Ratings

Inbonis

BCRA-Credit Rating Agency

EuroRating

TABLE 2: TYPES OF CREDIT RATINGS OFFERED BY EU REGISTERED CRAS. SOURCE: ESMA

SUPERVISORY INFORMATION AS PER 30/09/2023

9 Market Share of EU Registered CRAs by Rating Category

21. The Figures below (Figures 1-5) provide additional information to assist issuers or

related third parties in their evaluation of a CRA with less than 10% total market share.

These figures show the proportion of instruments

for which an EU-issued rating has

been assigned by EU registered CRAs (i.e. endorsed ratings are excluded),

irrespective of the domicile of the issuer, as of 30th September 2023.

22. This approach is coherent with the revenue-based market share described in the

previous sections, as the revenues generated by EU-registered CRAs may derive from

both EU and non-EU issuers. To provide further insight the figures included in the

Report reflect the ratio between solicited and unsolicited EU-issued ratings issued by

EU registered CRAs.

23. The Figures are based on data reported by CRAs to ESMA and do not take into account

ratings reported by a CRA where a unique identifier of the bond (ISIN) was not reported.

For ease of reading, only EU registered CRAs which have rated at least 0.1% of all

outstanding ISINs in a specific asset class have been included in the tables.

The definition of EU financial instrument is drawn from the Commission delegated Regulation 2015/2 of 30 September 2014

supplementing Regulation (EC) No 1060/2009 with regard to regulatory technical standards for the presentation of the information

that credit rating agencies make available to ESMA, available at: https://eur-lex.europa.eu/legal-

content/EN/TXT/?uri=uriserv:OJ.L_.2015.002.01.0024.01.ENG (the Delegated Regulation).

58.2%

44.0%

36.4%

24.6%

11.9%

1.2%

0.3%

0.2%

0.1%

S&P

Moodys

Scope

Fitch

Creditreform

Nordic Credit

Rating

DBRS

CERVED

CRIF S.p.A.

BCRA

EU-only issued ratings - Corporate non financial

Unsolicited Solicited

Figure 1: Percentage of the total number of outstanding non-financial

corporate instruments (ISINs) that have at least one rating assigned by a

CRA registered in the EU. Source: ESMA supervisory data as of

30/09/2023

61.1%

41.3%

27.2%

23.0%

19.1%

5.1%

0.3%

Moodys

S&P

Fitch

Creditreform

Scope

DBRS

Nordic Credit

Rating

EU-only issued ratings - Financial Institutions

Unsolicited Solicited

Figure 2: Percentage of the total number of outstanding financial

corporates (excl. insurance) instruments (ISINs) that have at least one

rating assigned by a CRA registered in the EU. Source: ESMA supervisory

data as of 30/09/2023

65.7%

27.8%

27.3%

6.8%

0.2%

S&P

Moodys

Fitch

DBRS

AM Best

EU-only issued ratings - Insurance

Unsolicited Solicited

Figure 3: Percentage of the total number of outstanding insurance

undertakings instruments (ISINs) that have at least one rating assigned by

a CRA registered in the EU. Source: ESMA supervisory data as of

30/09/2023

54.8%

38.3%

24.1%

19.3%

17.6%

S&P

Scope

Fitch

Moodys

DBRS

EU-only issued ratings - Sovereign and Public

Finance

Unsolicited Solicited

Figure 4: Percentage of the total number of sovereign and public entity

instruments (ISINs) that have at least one rating assigned by a CRA

registered in the EU. Source: ESMA supervisory data as of 30/09/2023

51.1%

30.8%

30.7%

21.7%

3.5%

2.3%

0.2%

0.1%

Moodys

Fitch

S&P

DBRS

Scope

KBRA

EthiFinance

ARC

Creditreform

EU-only issued ratings - Structured Finance

Unsolicited Solicited

Figure 5: Percentage of the total number of outstanding structured finance

instruments (ISINs) that have at least one rating assigned by a CRA

registered in the EU. Source: ESMA supervisory data as of 30/09/2023

10 Supervisory Briefing for Article 8d

24. As set out in Article 25a of the CRA Regulation, Article 8d is supervised and enforced

at Member State level by Sectoral Competent Authorities (SCAs). In this regard, it is

the role of ESMA to promote supervisory convergence by encouraging the SCAs to

adopt common approaches to the supervision and enforcement of this article.

25. On 6 April 2016 ESMA published a Supervisory Briefing which provided further

information on the implementation of Article 8d at a national level as well as a voluntary

template for documenting the non-appointment of a CRA with less than 10% market

share.

26. The purpose of this Supervisory Briefing is to provide guidance to SCAs in relation to

the application of Articles 8c and 8d of the CRA Regulation and promote a common

supervisory approach and enforcement of these Articles. In this regard, the Supervisory

Briefing includes the following:

o A Common Supervisory Approach as to which issuers or related third parties

are covered by Article 8c and 8d; and,

o A Standard Form for documenting the decision not to appoint a CRA with less

than 10% total market share in accordance with article 8d.

27. The purpose of the Common Supervisory Approach is to assist SCAs as well as issuers

or related third parties by clearly establishing who should be prioritised for supervision

and enforcement under these Articles.

28. The Standard Form assists SCAs by promoting standardised and consistent data

across different issuers or related third parties. It also assists issuers or related third

parties by providing clarity as to how they may meet their regulatory obligations under

these Articles and simplify their internal processes by removing the need to develop in-

house templates for documenting compliance under Article 8d.

29. For issuers or related third parties who would like to know more about the Common

Supervisory Approach and the Standard Form, both items are available on ESMA’s

website

11 Questions and Feedback

30. ESMA welcomes feedback on the information presented in this market share

calculation and invites market participants to send this by email to: CRA-

[email protected].

Common Supervisory Approach incl. Standard Form