ESEF is here!

Aug 13, 2020

The European Single Electronic Format (ESEF) is a new single electronic reporting format for the issuance of annual financial reports that was introduced pursuant to Article 4(7) of the Transparency Directive. On the 29th May 2019, the European Commission published a Delegated Regulation on use of ESEF, hereinafter referred to as the “ESEF Regulation”.

The Transparency Directive includes requirements and specific timelines for issuers to make public an annual financial report which includes the audited financial statements. The objective of the ESEF provisions that are integrated in the Transparency Directive are to improve the transparency of this financial reporting. It aims to make reporting easier and facilitate accessibility, analysis and comparability of annual financial reports.

Scope 

The ESEF Regulation applies to annual financial reports published by issuers whose securities are admitted to trading on a regulated market in the European Union, for example a company with equity listed shares on the EuroNext Dublin.

Effective Date  

The mandatory ESEF requirements are applicable to annual financial reports for financial years beginning on or after 1 January 2020. Note below, there are 2 phases to the iXBRL tagging requirements.

Requirements 

  1.  XHTML format 

All issuers in scope will be required to prepare the annual financial report in Extensible Hypertext Mark-up Language (XHTML). This single report will include, in particular, the financial statements, the management report and the responsibility statements of the persons responsible within the company. This format will make a company’s annual financial report machine readable and will replace the current PDF format.

     2.  iXBRL

As an additional obligation, if the issuer prepares consolidated financial statements on the basis of International Financial Reporting Standards (IFRS), financial information will also have to be marked up in accordance with the ESEF taxonomy (which is based on the IFRS Taxonomy) using mark-ups (known as inline Extensible Business Reporting Language (iXBRL) tags) and the inline XBRL technology. The mark-ups (also called “tags”) embedded in the report will make the financial statements machine-readable.

The implementation of these additional iXBRL tagging requirements is a phased approach. Issuers who prepare consolidated IFRS annual financial statements:

  • for financial years beginning on or after 1 January 2020 - must tag certain disclosures in the annual financial statements using digital tags; and
  • for financial years beginning on or after 1 January 2022 - must also tag notes in the annual financial statements using digital tags

Auditor involvement 

The nature and extent of auditor involvement is currently unclear. There have been some publications at an EU level on this matter, yet local implementation guidance for Ireland will be needed.

The European Commission has interpreted that the ESEF Regulation is a binding legal instrument and falls under statutory requirements for annual financial reports meaning that statutory auditors would have to provide an audit opinion stating: 

  • whether the financial statements included in the annual financial report gives a true and fair view in accordance with the relevant financial reporting framework; and
  • whether these financial statements comply with the requirements set out in the ESEF Regulation.

The Committee of European Auditing Oversight Bodies (CEAOB) has also published a guidelines document with broad proposed implementation guidance but additional implementation details are required at a local level, as noted above. 

Implementation

The required implementation date is fast approaching on ESEF, issuers must publish annual financial reports in the ESEF format from the start of 2021. To meet these requirements, it is likely that significant management and operational time will be required. Some filers may also decide to use service organisations to assist them with the creation of the iXBRL filing document including the tagging of the relevant financial statements. 

The Financial Conduct Authority in the UK  published a consultation paper at the end of July on a proposal to delay the implementation of these requirements in light of the impact of the Covid pandemic on financial reporting timelines.

Links to relevant publications

 

European Commission


ESMA


CEAOB


Accountancy Europe