ESMA has updated the ESEF Reporting manual, which includes detailed technical and mark-up recommendations for the preparation of ESEF reports. We studied this document carefully and have summed up the main changes from the ESEF report preparer’s perspective.

We divided the updates into two groups:

Important updates with new requirements

Enhancing existing practice

Important updates with new requirements

The amendment for the ESEF RTS will be postponed to 2024; there are no significant changes in the preparation of the ESEF reporting process for the 2023 financial year and ESMA intends to focus on the improvement of this process for the 2023 year.

Presentation of extracted marked-up information.
In Guidance 2.2.6 ESMA has added a new requirement for the data extracted from XBRL markup on the XHTML document: “Information that is contained in tables in the human-readable report is meaningfully transcribed in the extracted tagged information.”
This gives a clear hint that table information has to be converted to an XHTML document as a table layout. In the previous version of the Reporting manual, the requirement for table layout was omitted.
It is an important issue because there can be inconsistency between expectations for the XHTML conversion of auditors, regulators, and XBRL software vendors.

ESMA has updated a set of Reporting package specifications (Guidance 2.6), the last update was in 2018.

Enhancing the existing practice

Extended taxonomy

According to Guidance 1.2.2. for extended taxonomy, the issuer has to check if the IFRS taxonomy includes an element that corresponds to an essence of the disclosed information for the Extended taxonomy label. If there are such elements, not only the name and label but also XBRL characteristics of the Extended taxonomy element have to be the same as in IFRS Taxonomy.
It will help to increase the comparability of the electronic reports and facilitate future updates to new ESEF taxonomies.

The Guidance 3.3.1 fixed the common practice that anchoring relationships has to be set only for concepts. For example, no anchors are allowed for member-type items.

Block tagging

In guidance 1.9.1 the ESMA commented that using additional non-mandatory elements from Annex II of the ESEF RTS is complementary to the mandatory elements from Annex VI of the ESEF RTS and does not prevail over the use of the elements from Annex VI.

Numeric markup

There is a clarification regarding the tagging of empty fields and dashes. ESMA emphasises the recommendation to mark up empty fields and dashes for numeric information (guidance 2.2.5). This is not a new approach, but a more detailed recommendation based on the best practice.

Stand-alone reporting

The inclusion of content other than XHTML is allowed for Stand-alone reporting, separately or as a zip archive (Guidance 4.1.1).

ESMA ESEF reporting manual update