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Writer's pictureJames Ross
Oct 43 min read

ESMA's 2025 Agenda: A Deep Dive into Issuer Disclosure and Beyond - Part 3

The European Securities and Markets Authority (ESMA) has unveiled its 2025 work program, setting a demanding agenda for financial firms across the EU. Part three of this series delves into the program's critical aspects, focusing on issuer disclosure and its broader implications for listed companies.



ESMA Issuer Disclosure: Transparency Takes Center Stage


ESMA's 2025 plan emphasises enhancing transparency and accountability in issuer disclosure. This means listed companies must prepare for more stringent requirements and evolving standards, particularly in financial and sustainability reporting.


ESMA's core objectives for issuer disclosure include:


  • Supporting broader goals: Ensuring effective markets, robust supervision, investor protection, sustainable finance, and technological innovation.

  • Harmonising rules: Developing clear and consistent rules for financial and sustainability reporting, significant holdings, prospectuses, corporate governance, and takeover bids.

  • Promoting supervisory convergence: Ensuring consistent supervisory practices across the EU.

  • I contribute by participating in international standard-setting activities through EFRAG and the ISSB.

  • Monitoring and enforcing: Publishing European Common Enforcement Priorities on corporate reporting and assessing issuer compliance.


To achieve these objectives, ESMA's action plan for 2025 includes:


  • Ongoing support: Offering guidance and tools to promote supervisory convergence in issuer disclosure.

  • I am updating ESEF reporting: I am updating technical standards and guidance related to the European Single Electronic Format (ESEF) to reflect new requirements, including those related to the Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS).

  • Enhancing ESEF usability: Leveraging ESEF data provides NCAs and investors with better tools to analyse and utilise reported information.

  • Monitoring SRD2 implementation: This involves monitoring the implementation of Shareholder Rights Directive 2 (SRD2) and providing input on potential challenges.

  • Implementing the Listing Act: Initiating work related to the Listing Act's implementation, including providing advice and developing technical standards on prospectuses.

  • Monitoring CSRD application: Closely monitor and support the application of the new CSRD requirements and coordinate the work of national authorities supervising sustainability disclosures.

  • We are updating the Takeover Bid Directive Whitelist and potentially updating the Allowlist to ensure that acting in concert with rules does not hinder investors' collective engagement with sustainability goals.


Key Implications for Issuers


  • Enhanced ESG Reporting: Prepare for increased scrutiny and new requirements for sustainability reporting under the CSRD and ESRS, including tagging sustainability information in ESEF reports.

  • ESEF Compliance: Ensure compliance with updated ESEF requirements and leverage ESMA's tools to improve the usability of reported data.

  • Prospectus Disclosures: Stay informed about upcoming changes to prospectus requirements under the Listing Act, including those related to ESG disclosures and the universal registration document (URD).

  • SRD2 Implementation: Address any challenges related to SRD2's implementation and prepare for potential directive updates.

  • Corporate Governance: Maintain high standards of corporate governance and comply with relevant regulations as ESMA continues to promote supervisory convergence in this area.

  • Takeover Bids: Be aware of potential updates to the Takeover Bid Directive Whitelist, which may impact investors' collective engagement with sustainability goals.


Beyond Issuer Disclosure: ESMA's Broader Priorities


ESMA's 2025 agenda extends beyond issuer disclosure, focusing on several key areas:


1. Effective Markets and Financial Stability:


  • Developing a single, clear rulebook.

  • It is enhancing international cooperation.

  • We monitor and mitigate retail investors, ESG, and climate change risks.

  • Overseeing Central Counterparties (CCPs).


2. Effective Supervision:


  • Promoting a common supervisory approach.

  • We are enhancing direct supervision of CRAs, TRs, and CCPs.

  • We are fostering supervisory convergence.

  • They are leveraging technology for risk identification and data analysis.


3. Investor Protection:


  • Ensuring consistent supervisory approaches to investor protection.

  • We are developing a robust regulatory framework for retail investors.

  • I am creating a single rulebook for investment services, crowdfunding, and crypto-assets.

  • We are monitoring retail investor trends and risks.

  • We are promoting financial education.


4. Sustainable Finance:


  • Facilitating sustainable investment.

  • We are integrating sustainability factors into supervisory and regulatory activities.

  • They are combating greenwashing.

  • We are monitoring ESG risks.


5. Technological Innovation:


  • Adapting to digitalisation.

  • We are implementing cybersecurity requirements under DORA.

  • I am supervising crypto-asset markets under MiCA.

  • We are analysing the impact of digital innovation, including AI.

  • We are identifying emerging risks related to technological innovation.


6. Data and Technology:


  • Enhancing its data hub and improving data access and quality.

  • We are increasing public data usability through machine-readable formats and innovative data-sharing methods.

  • Maximising data value for intelligence and regulatory frameworks.

  • We are promoting data-driven supervision through SupTech projects.


Conclusion


ESMA's 2025 work program significantly shifts the EU financial landscape. By understanding and adapting to these priorities, firms can ensure compliance, enhance investor confidence, and contribute to a more resilient, transparent, and sustainable financial ecosystem.



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