ASCG submits comment letter regarding consultation paper 2015/ESMA/1463

Yesterday, the ASCG submitted its comment letter to the European Securities and Markets Authority (ESMA) on their Consultation Paper 2015/ESMA/1463 on the Regulatory Technical Standards on the European Single Electronic Format (ESEF) of annual financial reports.

According to the amendments to the Transparency Directive 2004/109/EC brought about by Directive 2013/50/EU, all annual financial reports shall be prepared in a single electronic reporting format beginning 1 January 2020. The same document charges ESMA to develop draft regulatory technical standards to specify the electronic reporting format, with due reference to current and future technological options, and submit those draft regulatory technical standards to the European Commission by 31 December 2016 at the latest. Before the adoption of the draft regulatory technical standards, ESMA shall carry out an adequate assessment of possible electronic reporting formats and conduct appropriate field tests.

In its comment letter, the ASCG discusses particularly the usefulness of structured financial reporting and ESMA’s proposed implementation concept in this regard. ESMA proposes, for the time being, to subject only financial statements – prepared in accordance with the IAS regulation (EC) No 1606/2002 – as one part of the annual financial report to the structured format.

The ASCG agrees with ESMA that it is sensible and appropriate to consider the taxonomy of the IFRS Foundation as a starting-point for the content of a structured format of these financial statements. As the endorsement process for the taxonomy has not yet been defined, the ASCG is unable to comment on the appropriateness as to the content of the taxonomy though. This is because the content is highly dependent on the answer to the question as to how compatible the information submitted in structured format with the annual financial report in non-structured format should be