Luxembourg issuers preparing their 2025 annual reports face heightened regulatory scrutiny alongside new filing requirements taking effect mid-2026. This article summarises three developments for issuers subject to the law of 11 January 2008 on transparency requirements for issuers of securities, as amended (the "Transparency Law"):
- the CSSF's enforcement findings from 2024 reports (published 16 January 2026),
- enforcement priorities for 2025 reports (announced 12 December 2025), and
- mandatory changes to the filing process under the European Single Access Point (ESAP) framework from 10 July 2026.
CSSF enforcement results from 2025 Campaign: key findings from 2024 annual reports
On 16 January 2026, the CSSF published its findings from its review of 2024 annual reports. The CSSF examined financial statements, sustainability disclosures, EU Taxonomy reporting, alternative performance measures and electronic reporting format compliance.
Key findings included:
- Financial statement notes: issuers should provide disaggregation of material amounts
- Segment reporting: insufficient quality of disclosures (a recurring finding from previous years)
- Going concern: the CSSF observed significant variability in disclosure quality, particularly where material uncertainties exist
- Sustainability reporting: overall improvement in quality observed with better structured reports and more relevant information, particularly among voluntarily adopting ESRS
- EU Taxonomy & APMs: continued need for enhanced disclosure quality.
The CSSF also conducted a desktop examination of 53 issuers' ESEF markup of financial position and notes, identifying common tagging errors.
The CSSF identified that alternative performance measures ("APMs") used in press releases announcing annual earnings were often not properly defined, explained or reconciled. Issuers are reminded that the ESMA guidelines on APMs apply to all regulated information, including press releases presenting results. Common deficiencies identified included: lack of clear definitions, missing reconciliations of comparative data and inconsistent labelling of the same APMs.
CSSF enforcement priorities for its 2026 campaign: geopolitical risks, segment reporting & sustainability disclosures
On 12 December 2025, the CSSF published a press release setting out its enforcement priorities for the 2026 campaign. These priorities are relevant to issuers preparing their financial statements for the financial year ending 31 December 2025 (“FY2025”) in accordance with IFRS.
European common enforcement priorities (ECEPs)
As in previous years, ESMA together with European national accounting enforcers (including the CSSF) identified European Common Enforcement Priorities ("ECEPs") for 2025 annual reports, detailed in ESMA's public statement of 14 October 2025 (document reference ESMA32-2064178921-9254).
CSSF focus areas for 2025 reports
The CSSF will pay particular attention to the following:
Geopolitical risks and uncertainties
Issuers should provide clear disclosures on how geopolitical developments, including ongoing conflicts and trade tensions, affect their financial position and performance. This includes disclosures about key judgements and estimates, going concern assumptions, liquidity, asset valuations and provisions.
Segment reporting
The CSSF will review segment reporting disclosures, including whether income and expense items are appropriately disclosed in accordance with IFRS 8. Geographic and major customer disclosures are particularly relevant given current geopolitical conditions.
Sustainability reporting: materiality and structure
For sustainability reporting, the CSSF will focus on how issuers conduct and disclose their materiality assessments, including the methodology used to identify material impacts, risks and opportunities. The CSSF will also review the scope and structure of sustainability statements.
Sustainability reporting: policies and actions
Issuers should describe the policies they have adopted to address material sustainability matters, including the scope of those policies and any third-party standards they follow. Issuers should also disclose key actions taken and planned, along with the resources allocated to those actions.
Other areas of focus
The CSSF will also focus on common errors in the electronic tagging of cash flow statements. Looking ahead, issuers should begin preparing for IFRS 18 presentation and disclosure in financial statements, which is expected to be endorsed in the course of 2026 and will be effective from 1 January 2027. The CSSF recommends that issuers start assessing its impact on their financial statements, communication and reporting systems.
European Single Access Point (ESAP): new filing requirements from 10 July 2026
The European Single Access Point ("ESAP") framework will enter into force on 10 July 2026. This will affect all issuers subject to the Transparency Law, as the storage of regulated information with the Officially Appointed Mechanism (OAM) will be subject to new requirements.
The Luxembourg Stock Exchange (LuxSE), acting as the OAM, has published an FAQ highlighting the following key requirements:
- File format: regulated information must be submitted in a data-extractable format (for example, PDFs must not be scanned documents). Where applicable, information must be machine-readable and comply with ESEF requirements.
- Additional information: when filing, users must provide information about the issuer's size, industry sector and whether the submission contains personal data. Information must be organised into structured categories.
- Automated checks: the OAM will perform automated checks on submissions, including verification of file format compliance and LEI validity.
- Non-compliant submissions: submissions that do not comply with the new requirements will be rejected. Users who believe a rejection was made in error may contact OAM support for assistance. Information submitted on a voluntary basis is not transmitted to ESAP.
Some upcoming key dates
- 10 July 2026: ESAP framework enters into force. All regulated information must comply with new format and metadata requirements.
- 1 January 2027: IFRS 18 effective date (subject to EU endorsement in 2026).
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