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Disclosure Management - ESEF / ESRS in 2025

Marc_Kuipers
Product and Topic Expert
Product and Topic Expert
‎2025 Jan 09 8:34 PM
2,304

Here is an update related to ESEF / ESRS reporting for Fiscal Years 2024 and 2025:

1) For FY 2024, companies preparing ESEF reports in iXBRL format have two options regarding the taxonomy to use:

  • they can continue with the 2022 ESEF taxonomy (version 1.1 including the support of XBRL dtr-types 2020-01-21) based on the 2022 IFRS taxonomy
  • or they can adopt the 2024 ESEF taxonomy (including the support of XBRL dtr-types 2022-03-31), based on the 2024 IFRS taxonomy. The mandatory application of the 2024 IFRS taxonomy will start for fiscal years beginning on or after January 1, 2025, allowing early adopters to use it from 2024 reports.

Issuers are strongly encouraged by the ESMA to engage in early education and implementation of the 2024 ESEF taxonomy, particularly if one or more core taxonomy elements included in the 2024 ESEF taxonomy better captures the accounting meaning of the disclosure being marked up compared to the 2022 ESEF taxonomy. The banking institutions should adopt the 2024 ESEF taxonomy to reduce the number of their extensions, but this is not mandatory.

The list of the ESEF taxonomies published by the ESMA is available from this link: https://www.esma.europa.eu/electronic-reporting/esef-taxonomy (you may need to force the refresh of the page by the browser ; press <CTRL> <F5> to get the updated list including the ESEF 2024 taxonomy)

Warning : for now, the .zip file and taxonomy guides of ESEF 2024 are not publicly available for download from the ESMA website: https://www.esma.europa.eu/document/esef-taxonomy-2024 (page with restricted access) whereas the 2022 ESEF taxonomy is fully documented, the .zip of all its taxonomy files and taxonomy guides can be downloaded from the ESMA website:  https://www.esma.europa.eu/document/esef-taxonomy-2022,

For the above reasons, as of today, it might be risky to migrate already to ESEF 2024, knowing that all FY 2024 filings based on ESEF 2022 will be accepted by the national authorities. Only if you find extensions in the 2024 IFRS taxonomy (go to https://bigfoot.corefiling.com/yeti/resources/yeti-gwt/Yeti.jsp) that can significantly improve your ESEF reporting, then it could be useful to run the migration script to 2024 ESEF taxonomy.

The 2024 IFRS taxonomy (extended by the 2024 ESEF taxonomy) introduces significant changes in the management of XBRL dimensions. Those updates are automatically performed by the migration script to ESEF 2024 and SEC 2024.

 2) According to the latest Regulatory Technical Standards amending Delegated Regulation (EU) 2019/815 as regards the 2024 updat...:

  • the mandatory text blocks to be tagged remain unchanged for FY 2024 reporting, the number of concepts are still 252 (like last year) including the 3 Dividends… perShare and monetary items.
  • Next year for FY 2025 reporting (for FY beginning on or after 1 January 2025 – see in Annex II), the mandatory elements of the core taxonomy to be marked up for financial years will be decreased from 252 to 245. You will find in this Sharepoint folder the 2025 ESEF template taxonomy files by SAP to reflect those changes.

7 elements are going to be removed for FY 2025 by the ESMA from the list of tags that must be applied if corresponding information is present in a report:

  • Disclosure of assets and liabilities with significant risk of material adjustment [text block]
  • Disclosure of available-for-sale financial assets [text block]
  • Disclosure of significant accounting policies [text block]
  • Description of accounting policy for available-for-sale financial assets [text block]
  • Description of accounting policy for held-to-maturity investments [text block]
  • Description of accounting policy for loans and receivables [text block]
  • Description of other accounting policies relevant to understanding of financial statements [text block] (deprecated)

On request, we can integrate in the Definition linkbase of customers’ taxonomies the “[000000] Tags that must be applied if corresponding information is present in a report” temporary role to be used for 2024 year-end reporting – like we did last year.

As a reminder: since last year, you should not tag the Disclosure of notes and other explanatory information [text block] root text block tag anymore (which includes all the notes). Indeed, since the IFRS 2023 taxonomy, it is replaced by the Notes and other explanatory information [abstract] element, which is now defined as an abstract, therefore it is no longer a text block (that used to be the parent of all disclosures) and not a tag.

 3) The latest versions 2024 and 2023 of the ESEF Reporting Manual have introduced the main following changes through theses guidances:

  • 2.2.5 Tagging of dashes or empty fields – For better readability and greater comparability between companies, it is recommended to tag all the cells in the financial statement tables including where no data is entered (especially in the statement of changes in equity).  A cell that has a value in one period should not have an empty cell in the other period, rather 0 or dash for instance.
  • 2.2.6 Readability of the information extracted from a block tag – It is mandatory that the underlying html tags allow to extract data from tables to external tool. In the case of information presented in a tabular format, the XHTML document would contain relevant HTML table tags such as <table>, <th>, <tr>, etc. to ensure that the extracted tagged data includes the presentation of the fact values in a tabular format.
    In SAP DM, go to the Configuration tab of the iXBRL ESEF report and set the Add table structure parameter to Yes:

Marc_Kuipers_0-1736453986549.png

  • 2.2.7 Technical construction of a block tag – Text facts with datatypes different from dtr-types:textBlockItemType , such as xbrli:stringItemType MUST use the @escape attribute set to “false”. SAP DM 10.1 Stack 2200 is now supposed to set it to “false” explicitly although this is the default value.
  • 2.2.8 Use of the ID attribute on facts – For better analysis, ESMA recommends that the software should include an ID attribute with a unique value for each tagged fact in the iXBRL report. This could be a GUID for instance. This is not yet supported in SAP DM 10.1 Stack 2200.
  • 2.5.1 Inclusion of content other than XHTML and XBRL in the Inline XBRL document - SVG image format is now accepted in the report. This new feature is effective provided that the tag present in the source code is of type <img> and not <svg>. The JPG image format is no longer supported (but JPEG is still accepted).
  • 2.6.1 Including Inline XBRL document in taxonomy report packages – ESMA recommends that issuers prepare their ESEF submissions according to the Report Package 1.0 specification now published by XBRL International. Theoretically, the new template to be applied for packages would be:

 

 

 

META-INF/
     reportPackage.json
     taxonomyPackage.xml
     catalog.xml
xbrl.example.com/
     v1/
        taxonomy.xsd
        taxonomy-linkbase.xml
reports/
     report-1.html
     report-1-graph.svg
     css/
        report-1.css

 

 

 

  • 2.6.3 Naming convention for report packages and report file – The package name should include the version (v0 for first submitted version to the relevant authority) and have the .xbri extension (instead of .zip previously): {base}-{date}-}-{version}-{lang}.xbrl

The filename of the report inside the package should indicate the version of the ESEF report package {base}-{date}-}-{version}-{lang}.html or .xhtml

Practically, based on the ESEF 2.6.1 and 2.6.3 guidances, from the early feedback we get from Customers having already uploaded test ESEF filings to their National Authorities and according to the information I got from the AMF (French Market Authority), zip file is still expected for the ESEF package, but .xbri extension (in lowercase) could also be supported. Here is the detailed description of the ESEF package:

Marc_Kuipers_1-1736453986552.jpeg

 

As you can see, the expected package format for this year is very similar to last year except the version must be added in the package name, in the root directory and in the instance document. According to the XBRL Report Package specifications: when zip file is provided, then the reportPackage.json is not required.

In SAP DM, go to the Configuration tab of the iXBRL ESEF report and add the version accordingly to the above parameters, for instance:

Marc_Kuipers_2-1736453986553.png

…

Marc_Kuipers_3-1736453986553.png

 

  •  3.4.1 Documenting arithmetical relationships in the calculation linkbase – Although a new calculation specification has been published by XBRL International (Calculation 2.0), ESMA indicates that the formal specification will be Calculation 1.1 which is more relevant to calculations in reports. Especially for the Changes in Equity statement, the calculations of the line items should be clearly defined between parent and son accounts, and a hierarchy of the dimension members should be clearly defined. Arithmetical relationships defined in the calculation linkbase of an issuer’s taxonomy MUST use the https://www.xbrl.org/2023/arcrole/summation-item arcrole as defined in the Calculation 1.1 specification. In case of violation, the following violation message might be displayed during validation: “IncorrectSummationItemArcroleUsed”.

Although stated in the ESEF reporting manual of July 2024, in practice: the upgrade to XBRL Calculations 1.1 is not mandatory this year.

There are 3 supported scenarios for FY 2024 reporting:

i) You can stay with 2022 ESEF taxonomy and XBRL Calculations 1.0. In that case, you do not need to run any migration script.
In SAP DM, go to the Configuration tab of the iXBRL ESEF instance report, then set the CalculationMode parameter to xbrl21-dedup, which means XBRL Calculation 1.0 with deduplication of iXBRL facts:

.Marc_Kuipers_4-1736453986554.png

ii) If you stay with 2022 ESEF taxonomy but need to upgrade to XBRL Calculations 1.1, then download the upgrade_2024_ESEF.zip from here. Unzip it into the folder where your corporate taxonomy files are located and simply run the upgrade.bat command file.

 

iii) If you upgrade to 2024 ESEF taxonomy and XBRL Calculations 1.1, then download the upgrade_2024_ESEF.zip from here. Unzip it into the folder where your corporate taxonomy files are located and rename the ESEF2022.txt to ESEF2024.txt. Finally, run the upgrade.bat command file.

 

If you apply XBRL Calculations 1.1 with 2022 or 2024 ESEF taxonomy - above cases ii) and iii) – then you need also to install Calculations 1.1 patch XWAND_TK_CALC11.zip for Fujitsu Interstage XWand Toolkit v13.7.2 (from here).

 

To validate ESEF filing with XBRL Calculations 1.1 activated, you should set in SAP DM the CalculationMode parameter to round-to-nearest or truncation

Marc_Kuipers_7-1736453986554.png

Marc_Kuipers_8-1736453986555.png

 

As tolerance is introduced by XBRL Calculations 1.1 through round-to-nearest or truncation rounding mode, all remaining Calculation inconsistencies returned by the XBRL engine during validation would be errors [calc11e:inconsistentCalculationUsingTruncation] and [calc11e:inconsistentCalculationUsingRounding], and no more warnings.

4) Customers need to upgrade Arelle to recent version for ESEF validation of FY 2024 report (at least version 2.35.17). Please note that the name of the ESEF plugin of Arelle comes back to “ESEF” (instead of “ESEF 2022” last year), to be set to the DM parameter “Validation Level”, and there is now a new parameter “RuleSet” to specify the Disclosure System. As for now, it should be set to “esef-2024-draft”.

This is customizable in the Configuration tab of the iXBRL instance report in SAP DM 10.1 Stack 2200:

Marc_Kuipers_3-1736547116879.png

 5) Tagging requirements in iXBRL format based on the ESRS taxonomy is expected for FY 2026 as the standard format for Annual Report is becoming iXBRL / xHTML instead of PDF. In a few countries like Sweden, the national regulators are introducing new requirement, so the board must sign the instance report with an advanced electronic signature like for bank and insurance reporting already in Europe. Since the auditor’s review assignment will also encompass the tagging (markup), it is therefore the electronic version in iXBRL / xHTML format which will be subject to the auditor’s review and certification.

For FY 2024 reporting, only the paper version in PDF format is expected to comply with the CSRD requirements. But most of the European Countries have not yet adopted CSRD in local law as they should have done by July 6, 2024 (the mandatory transposition deadline).

The European Commission decided to open infringement procedures by sending a letter of formal notice to 17 Member States [among 27] (Belgium, Czechia, Germany, Estonia, Greece, Spain, Cyprus, Latvia, Luxembourg, Malta, the Netherlands, Austria, Poland, Portugal, Romania, Slovenia and Finland) for failing to notify their national measures transposing fully the Accounting Directive (Directive 2013/34/EU), the Transparency Directive (Directive 2004/109/EC) and the Audit Directive (Directive 2014/56/EU), as amended by the Corporate Sustainability Reporting Directive (CSRD) (Directive (EU) 2022/2464).

To date, the CSRD has been fully transposed in 11 countries (10 EU member states + 1 country in the EEA): Bulgaria, Croatia, Finland, France, Denmark, Ireland, Italy, Norway, Romania, Slovakia and Sweden. Many of the remaining countries are still in the parliamentary process or have made no progress in Parliament towards meeting the transposition requirements.

As a reminder, the Phase-in adoption of the CSRD regulation (entry into force of the first reporting - excluding XBRL) is the following:

- 2025 (for Fiscal Year starting at or after January 1, 2024): companies already subject to the NFRD directive on the publication of non-financial information in force since 2018. That is to say, companies meeting two of the following criteria: more than 500 employees, more than €50 million in turnover, more than €25 million in total balance sheet.

- 2026 (for Fiscal Year starting at or after January 1, 2025): companies meeting two of the following criteria: more than 250 employees, more than €50 million in turnover, more than €25 million in total balance sheet

- 2027 (for Fiscal Year starting at or after January 1, 2026): listed SMEs (except micro-enterprises: companies with fewer than 10 employees whose balance sheet total does not exceed €450,000 or whose net turnover does not exceed €900,000)

 

 

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