The European Securities and Markets Authority (ESMA) published its 2026 European Common Enforcement Priorities on October 13, 2026, setting out areas of focus for reviewing annual financial reports of issuers admitted to trading on EEA regulated markets.
The priorities cover financial statements, sustainability statements, and European Single Electronic Format (ESEF) reporting. Alongside the statement, ESMA published seven enforcement decisions illustrating the application of existing requirements.
The publications establish supervisory priorities and explain case-specific enforcement outcomes; they do not introduce a new reporting standard.
What Are ESMA’s Main Priorities?
The 2026 enforcement statement identifies these areas:
| Reporting area | Focus |
|---|---|
| Financial statements | Geopolitical uncertainty; restructuring provisions and debt restructuring |
| Sustainability statements | Materiality assessments and connected information |
| ESEF reporting | Errors in tagging the statement of changes in equity |
For sustainability reporting, ESMA emphasizes balanced assessment of positive and negative impacts, clear impact materiality thresholds, and coverage of operations and the value chain. The “entity-specific” category should be used only after exhausting ESRS classifications.
Disclosures should connect impacts, risks, and opportunities with policies, actions, targets, and metrics, particularly for climate and own workforce. Consistency should extend across the wider annual financial report.
Which ESRS Version Should Issuers Identify?
FY2026 is transitional. Issuers should state whether they use amended ESRS Set 1, ESRS Set 2, or amended Set 1 with specifically permitted Set 2 reliefs.
Although the statement includes no specific EU Taxonomy recommendations, enforcers will continue supervising Taxonomy disclosures.
Broader reminders, including IFRS 18 preparation, are distinguished from the selected enforcement priorities.
What Do the Accompanying Enforcement Decisions Show?
The 31st extract of enforcement decisions covers seven decisions taken between October 2024 and January 2026.
The cases address revenue recognition, fair value measurement, climate-related disclosures, borrowing costs, deferred tax assets and government assistance, and alternative performance measures. They are case-specific outcomes, rather than general IFRS interpretations.
In one case, an oil and gas company provided extensive climate reporting outside its financial statements without explaining why climate matters had no material financial effect. The enforcer required that explanation in the circumstances. This does not establish a universal requirement for every company to provide a negative confirmation.
Another case concerned disclosure of the nature of the evidence supporting deferred tax asset recognition and the nature and extent of government assistance.
The alternative performance measure cases challenged hypothetical adjustments and inconsistent treatment of gains and losses. The borrowing-cost decision supported the issuer’s treatment, so the report should not be characterized as seven reporting failures.
What This Means for Reporting Teams
Reporting teams can use the priorities to organize their year-end review and the enforcement decisions to identify relevant disclosure questions.
Extensive climate reporting outside the financial statements can raise user expectations that climate matters are addressed within them. Teams should review whether explanations across financial and sustainability reporting are consistent and sufficiently clear.
A practical review should connect disclosures with their underlying data, assumptions, supporting evidence, and approval decisions. This gives reviewers the context needed to assess completeness and resolve inconsistent explanations before publication.
How EcoActive Supports Connected Disclosure Management
EcoActive’s AI-native disclosure management platform connects financial disclosure management and ESG disclosure management, helping teams manage data, disclosures, supporting evidence, reviews, and approvals within a governed reporting process.
Native AI supports analysis and insights, while Agentic AI supports workflow actions and repeatable reporting activities. Interpretation, materiality judgments, and final approval remain under human control.
For teams preparing 2026 reports, this supports coordination between financial and sustainability disclosures and the evidence behind them.
Read ESMA’s complete 2026 reporting package, including the enforcement priorities and accompanying enforcement decisions.
See Connected Disclosure Management in Action
