Key focus areas for 2026 reporting

Key dates

2026-10-13

ESMA published its European Common Enforcement Priorities for the 2026 annual financial reports of listed issuers.

2026-10-21

The AFM published its guidance identifying the ESMA priorities and continuing Dutch focus areas for 2026 reporting.

Suggested considerations

• Issuers should map the ESMA 2026 priorities against their 2026 IFRS financial statements, sustainability statement, annual report and ESEF package, documenting conclusions for each material issue.
• Finance and risk teams should assess how geopolitical developments affect assumptions, impairment testing, liquidity, going-concern assessments, provisions, commitments and other relevant IFRS disclosures, rather than relying only on generic risk-factor language.
• Companies undertaking restructurings or debt modifications should consider whether IAS 37 provisions, IFRS 9 derecognition or modification accounting, covenant effects, liquidity disclosures and related management judgments are complete and internally consistent.
• Sustainability reporting teams should retain evidence supporting the double materiality assessment and consider whether positive and negative impacts are presented with comparable granularity, including for ESRS E1 and ESRS S1 where relevant.
• Issuers should reconcile each material impact, risk and opportunity to the relevant policies, actions, targets and metrics, explain gaps where no policy, action or target exists, and ensure targets are measurable, time-bound and outcome-oriented.
• Reporting owners should perform a cross-document consistency review between the sustainability statement, management report, financial statements, risk disclosures and other parts of the annual report.
• ESEF specialists should validate the statement of changes in equity taxonomy selections, anchoring, sign conventions, extensions and completeness of tags, and should conduct technical validation before filing.
• Preparers should use the AFM’s cash-flow points of attention and self-assessment to test classification, non-cash transactions, reconciliation disclosures, consistency with the financial statements and clarity of significant judgments.

What changed

The AFM has stated that its 2026 supervisory work will focus on ESMA’s priorities for annual reports of issuers admitted to trading on EEA regulated markets. For IFRS financial statements, this covers geopolitical risks and uncertainties, restructuring provisions, and debt restructuring. For sustainability reporting under the ESRS, issuers should demonstrate a robust double materiality assessment and connected disclosures linking impacts, risks and opportunities with related policies, actions, targets and metrics, with market commentary indicating particular attention to balanced treatment of positive and negative impacts and more mature topics such as ESRS E1 Climate Change and ESRS S1 Own Workforce. For ESEF reporting, ESMA has identified recurring errors in the statement of changes in e

Who is affected

• Companies listed on EEA regulated markets and preparing 2026 annual financial reports
• Dutch issuers supervised by the AFM under the EU Transparency Directive framework
• Audit committees overseeing listed companies’ financial and sustainability reporting
• Audit firms auditing listed companies’ annual financial reports and ESEF filings

Related regulations

• IFRS Accounting Standards
• IAS 7 Statement of Cash Flows
• IAS 37 Provisions, Contingent Liabilities and Contingent Assets
• IFRS 8 Operating Segments
• IFRS 9 Financial Instruments
• European Sustainability Reporting Standards (ESRS)
• European Single Electronic Format (ESEF) Regulatory Technical Standards
• EU Transparency Directive
• ESMA Guidelines on Alternative Performance Measures