...Our position is clear: convergence on a standard approach to reporting meaningful, material data across the different reporting jurisdictions - in a manner that avoids commercial harm to companies - would improve the quality and comparability of the information provided...we would welcome convergence on the definition of a ‘project’ for the purposes of disclosing project-level payments: defining extractive projects in a consistent manner across all countries would foster improved transparency and support accountability in practice...

BP believes that the adoption of an implementing Rule 13q under the Dodd Frank Act should aim to maintain a level playing field among oil and gas companies and encourage convergence on a standard approach by seeking alignment with EU rules and consistency with the new EITI Standard to the greatest extent possible...BP will continue to engage contructively with public debate in this area, to support the EITI Principles and to promote transparency of payments to governments. Accordingly, we will respond directly to the SEC during the current public comment period, to give BP’s view of the proposed Rule 13q.