Delay to the implementation of the European Single Electronic Format (ESEF)

Delay to the implementation of European
Single Electronic Format and update on
Coronavirus-related measures
Policy Statement
PS20/14
November 2020

PS20/14 Financial Conduct Authority
Delay to the implementation of European Single Electronic Format and update on Coronavirus-related measures This relates to Consultation Paper 20/12 which is available on our website at www.fca.org.uk/publications Email:
cp20-12@fca.org.uk
Contents
1 Summary 3
2 Feedback to CP 20-12 7
3 Our decision 11
Annex 1
List of non-confidential respondents 13
Annex 2
Abbreviations used in this paper 14
Appendix 1
Made rules (legal instrument)
Appendix 2
Made rules (legal instrument)

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PS20/14 Financial Conduct Authority
Chapter 1 Delay to the implementation of European Single Electronic Format and update on Coronavirus-related measures
1 Summary
ESEF measures
1.1 This Policy Statement sets out our decision on our proposals to push back by 1 year
mandatory requirements related to the European Single Electronic Format (ESEF).
1.2 The ESEF initiative includes requirements for publication and filing of machine￾readable financial statements and the electronic tagging of basic financial statements
and notes to these financial statements. It will enhance the accessibility of issuers’ financial data and will make easier the process of evaluating corporate performance by investors across industry sectors and different jurisdictions.
1.3 Our proposals to push back implementation by 1 year aimed to relieve the burden on
issuers during the exceptional circumstances of the coronavirus pandemic. These proposals were set out in our Consultation on delay to the implementation of the European Single Electronic Format (ESEF) (CP 20/12).
1.4 This Policy Statement summarises the feedback we received and sets out our
response to it. It also gives an update on measures to extend deadlines for the publication by listed companies of financial statements. These measures were introduced in response to the coronavirus pandemic.
1.5 Feedback to CP 20/12 was supportive overall of a delay to ESEF implementation for
financial years starting on or after 1 January 2020, though some of the respondents, particularly a number of companies assisting issuers in implementing ESEF, opposed it. Feedback about whether we should delay requirements for tagging of notes to the annual financial statements was more balanced between those who supported a delay and those who did not feel that it was necessary.
1.6 In light of the feedback, we are going to proceed with our proposal to push back by 1
year ESEF requirements originally scheduled for financial years starting on or after 1 January 2020, which will now apply to financial years starting on or after 1 January
2021. Issuers will, however, still be able to publish and file their financial reports in ESEF
voluntarily for financial years starting on or after 1 January 2020, from January 2021 if they choose to do so.
1.7 However, we have adjusted our proposal in relation to implementation of mandatory
tagging of notes to the annual financial statements. In light of the mixed feedback to this proposal, and taking into account the views of those respondents who did not support any delay to the overall ESEF timetable, we have decided to keep this requirement to the existing timetable, and it will apply to financial years starting on or after 1 January 2022. Details of our decision are set out in Section 3 of this document and our new rules are set out in Appendix 1.

PS20/14 Financial Conduct Authority
Chapter 1 Delay to the implementation of European Single Electronic Format and update on Coronavirus-related measures
Coronavirus-related temporary policy measures on corporate reporting
1.8 Earlier this year we announced a series of measures aimed at assisting listed
companies through the coronavirus crisis. These included measures on the deadlines attached to both annual and half-yearly financial statements, as well as a package of other measures aimed principally at companies seeking to raise additional capital.
1.9 Those announcements were clear that those policy interventions were temporary
while the UK faces the extreme disruption of the coronavirus pandemic and its aftermath. We said at the time we will keep those interventions under review and when the disruption abates we will announce how we will end them in a fair, orderly and transparent way.
1.10 We repeat that commitment. At the moment, the disruption caused by the coronavirus
in our view has not abated sufficiently to justify removing any of the reliefs. So, we are confirming that our temporary relief for delayed publication of financial statements will, at a minimum, continue to be available to listed companies with financial periods ending before April 2021.
1.11 When we decide to bring any of these measures to an end we will give companies
notice so that they have time to plan for the change.
Who this affects
1.12 This Policy Statement affects issuers with transferable securities admitted to trading
on UK regulated markets, or who are considering admission to trading on a UK regulated market. It is also of interest to:

• Issuers with securities admitted to our Official List or considering a listing.
• Firms advising issuers or advising persons investing in their securities.
• Firms or persons investing or dealing in UK listed securities or securities admitted
  to trading on a UK regulated market.
• Firms providing research and analysis on issuers, and
• Accountants and other advisors and service providers helping issuers with the
  preparation and publication of their annual financial statements.
  The wider context of this policy statement
  1.13 The wider context of this Policy Statement includes the impact of the coronavirus
  crisis, which has put significant pressures on issuers, and the UK’s exit from the EU.
  1.14 To meet ESEF requirements issuers will need to devote potentially significant
  management and operational time for the rest of this year and continuing into 2021.
  1.15 In this context, and in line with our other recent actions to relieve burdens on issuers,
  our changes to the ESEF implementation timetable will allow issuers to focus on their more immediate and significant priorities.

PS20/14 Financial Conduct Authority
Chapter 1 Delay to the implementation of European Single Electronic Format and update on Coronavirus-related measures
1.16 The EU Regulatory Technical Standard (RTS) setting out the detailed requirements and
timetable for implementation is already in force and will be part of UK law under the EU Withdrawal Act. We can only change the RTS when we have the powers to do so at the end of the Implementation Period (IP completion day). We are therefore making these changes with effect from 1 January 2021, following the end of the Implementation Period.
1.17 We note that the European Council has proposed amending the Transparency
Directive in order to allow EU Member States to delay ESEF requirements starting on or after 1 January 2020 by one year if they choose to do so What we are changing
1.18 In our Consultation Paper, we proposed to push the ESEF mandatory requirements
back by 1 year. We have decided to continue with our proposal to push back by 1 year the mandatory requirements to publish and file machine-readable financial statements and tagging of basic financial information. But requirements for the tagging of notes to the annual financial statements will now run on their original timetable. This means that:

• The requirement for all issuers to publish and file their annual financial reports in
  XHTML web browser format, replacing the current PDF format, will be pushed back to financial years starting on or after 1 January 2021, for publication from 1 January 2022.
• The requirement for issuers who prepare consolidated annual financial statements
  in accordance with International Financial Reporting Standards (IFRS) to tag basic financial information will be pushed back to financial years starting on or after 1 January 2021, for publication from 1 January 2022.
• However, the requirement for issuers who prepare IFRS consolidated annual
  financial statements to tag notes to the financial statements will now be unchanged, applying to financial years starting on or after 1 January 2022, for publication from 1 January 2023. Outcome we are seeking
  1.19 We want to help issuers to focus their management and operational resources on
  their immediate and urgent needs in the exceptional circumstances caused by the coronavirus, without damaging the transparency and effectiveness of the UK’s capital markets. We also want to enable issuers to publish and file voluntarily their annual financial reports in the new ESEF in 2021 if they choose to do so.
  1.20 We also want to achieve a smooth and effective long-term implementation of the
  ESEF initiative, which should enhance the transparency and efficiency of the UK’s regulated markets.

PS20/14 Financial Conduct Authority
Chapter 1 Delay to the implementation of European Single Electronic Format and update on Coronavirus-related measures
How it links to our objectives
1.21 We support the ESEF initiative as it enhances the accessibility of issuers’ financial data
and will make easier the process of evaluating corporate performance by investors across industry sectors and different jurisdictions. This will help to improve the long￾term effectiveness of the UK capital market and reduce the cost of capital.
1.22 Our decision to delay by 1 year ESEF requirements for publication and filing of
machine-readable financial statements and for tagging of basic financial information should help market integrity by minimising burdens on issuers during the exceptional circumstances of the coronavirus crisis. Our decision not to delay the requirement for issuers who prepare IFRS consolidated financial statements to tag notes to the annual financial statements allows for consistency of implementation at a timetable in line with that of other markets. Measuring success
1.23 We will measure our success by feedback on the implementation of ESEF under our
proposal and on its effectiveness in avoiding excessive short-term costs and resource stretch for issuers. Equality and diversity considerations
1.24 We have considered the equality and diversity issues that may arise from the decision
set out in this Policy Statement. Overall, whilst we recognise that ESEF may improve the accessibility of data for investors and analysts, we do not consider that our decision materially impacts any of the groups with protected characteristics under the Equality Act 2010. Next steps
1.25 The new rules (which are set out in Appendix 1) will come into force on IP completion
day as defined in the European Union (Withdrawal Agreement) Act 2020 (that is, 31 December 2020 at 11.00pm).
1.26 To allow issuers to submit annual reports in the ESEF standard, the FCA is upgrading
our National Storage Mechanism facility, and our online archive of filings by companies who are subject to the Transparency Directive and Listing Rules.
1.27 We currently anticipate releasing the upgrade in January 2021, ready for those issuers
who wish to file reports in ESEF on a voluntary basis. More information will be available on the ESEF pages of FCA website as the project progresses.

PS20/14 Financial Conduct Authority
Chapter 2 Delay to the implementation of European Single Electronic Format and update on Coronavirus-related measures
Feedback to CP 20-12
2.1 This section summarises feedback to CP 20-12 and sets out our response.
Summary of responses
2.2 We had 21 substantive responses, from a range of stakeholders including companies
assisting issuers in ESEF implementation, issuers, investor groups, investment management companies, public bodies, consulting firms, trade associations and industry bodies. ESEF requirements for machine-readable publication and tagging of basic financial information
2.3 We asked the following questions in relation to a delay on ESEF requirements set for
publication and filing of machine-readable financial statements and tagging of basic financial information. Q1: Do you agree with our proposal to delay by 1 year the mandatory requirement for all issuers to publish their entire annual financial report in XHTML web browser format? Q2: Do you agree with our proposal to delay by 1 year the mandatory requirement for issuers who prepare consolidated annual financial statements in accordance with International Financial Reporting Standards (IFRS) to publish these statements with tagging of basic financial information in ESEF machine-readable format, as set out in the RTS? Feedback to Questions 1 and 2 and our response.
2.4 We had 21 responses to Questions 1 and 2, with 12 of these supportive of our proposal
for a delay, and 9 against.
2.5 The 3 accounting and consulting firms and 1 accounting professional body who
responded supported a delay to ESEF for the reasons we set out in CP 20/12, to relieve burdens on issuers and to assist an effective implementation.
2.6 We had 3 responses from larger issuers who responded supporting delay, arguing that
ESEF is a significant cost to bear when they are experiencing difficulties due to the coronavirus pandemic. However, the 1 smaller issuer who responded, drawn from the IT consulting and corporate reporting sector, said that ESEF is not an issue of concern

2.7
PS20/14
Chapter 2
2.8
2.9
Financial Conduct Authority
Delay to the implementation of European Single Electronic Format and update on Coronavirus-related measures for them and that they are ready for implementation. 1 professional body related to issuers also supported a delay. 9 companies assisting issuers in the implementation of ESEF or providing related IT and reporting advice responded. 7 of these did not support a delay to ESEF implementation. They questioned whether the costs to issuers of ESEF implementation are as high as set out in our cost benefit analysis (CBA). They also stated that, in their experience, issuers are ready to implement ESEF. 1 of these respondents commented that a delay to ESEF would put the UK market out of line with EU and other markets and that this could damage UK competitiveness. 1 of these respondents also stated that they did not see any reason to think that the situation would be any better in a year’s time. The 3 investors and investor groups who responded had contrasting views about the proposed delay. One argued that it is even more important that the market should have easier access to data in the ESEF during the current circumstances. An investment management company and a body representing issuers who responded argued for a delay to allow for a more effective implementation, and the first of these noted that for many issuers the current circumstances of remote working made training of staff and testing for ESEF difficult. Four of the total respondents emphasised the need for clarity as soon as possible on what the nature of any audit requirement on the ESEF might be. Our response We are grateful for all feedback provided. Whilst it was supportive overall of a delay to ESEF implementation, we recognise that a significant minority of respondents, particularly those who are assisting issuers in implementing ESEF, opposed a delay. We re-emphasise that we support ESEF and that any issuer who is ready, and who wants to, will be able to publish and file their annual financial reports in ESEF voluntarily with the FCA’s National Storage Mechanism from January 2021. We encourage those issuers who are able to do this from next year, to do so. However, we have decided to proceed with our proposal to push back implementation of these requirements by 1 year for the reasons set out below. The balance of responses was supportive of our proposal to delay. Larger issuers who responded indicate that ESEF implementation is a significant challenge for them in the current circumstances. This is also supported by the accounting and consulting firms who responded. In addition, recent evidence from a survey of issuers carried out by the Financial Reporting Council (FRC) indicates that many issuers are at a low stage of preparation. We note, however, that ESEF is not considered a difficulty by all, particularly by respondents who argue that the costs of implementation are low.

PS20/14 Financial Conduct Authority
Chapter 2 Delay to the implementation of European Single Electronic Format and update on Coronavirus-related measures
However, in relation to the costs of implementing ESEF now, even if the costs may be lower than those contained in our CBA, as argued by some respondents, we are confident that the benefits still outweigh costs in monetary terms i.e. there is still a net benefit from delaying these requirements. We also remain concerned about the opportunity costs for issuers in having to allocate scarce resources to ESEF at this time. It is not practicable for us to quantify these opportunity costs. We recognise that the situation for issuers may still be difficult in a year’s time. But, if this is the case, a delay will be more rather than less important so that issuers have more time to prepare and implementation is more effective. We note the concerns of some respondents over the impact of our proposals on the ability of investors to access more easily issuers’ financial statements and, more widely, on the competitiveness of the UK’s financial markets. As we explained in CP 20-12, the benefits of ESEF will accrue over the longer-term rather than immediately. In addition, rushed or ineffective implementation now is likely to result in less robust and reliable tagging, which could be damaging to market transparency overall. In the meantime, there will be no loss of existing transparency. We do not think that a short delay now to the ESEF requirements originally timetabled for financial years starting on or after 1 January 2020, will damage the attractiveness of the UK’s financial markets either now or in the longer￾term. We also note in this context the recently published proposal of the European Council to allow EU Member States the option of delaying implementation of ESEF by one year. We note the requests made by four respondents for greater clarity about the possible requirements for independent auditing of ESEF. This issue is not covered by this consultation and we understand the Department for Business, Energy and Industrial Strategy (BEIS) is continuing to consider whether any mandatory auditor reporting requirement should be introduced to apply after the end of the period of postponement of the ESEF requirements. Those interested should await further information from BEIS.

PS20/14 Financial Conduct Authority
Chapter 2 Delay to the implementation of European Single Electronic Format and update on Coronavirus-related measures
ESEF requirements for tagging notes to the annual financial statements
2.10 We asked the following question on our proposal to push back by one year ESEF
requirements for tagging of notes to the annual financial statements. Q3: Do you agree with our proposal to delay by 1 year the mandatory requirement for issuers who prepare consolidated annual financial statements in accordance with International Financial Reporting Standards (IFRS) to publish notes to the annual financial statements with tagging in ESEF machine-readable format, as set out in the RTS?
2.11 We had 21 responses to this question.
2.12 Eleven of the respondents supported a delay to this requirement for the same
reasons that they had supported a delay to the ESEF requirements considered in Q1 and Q2 and the nine respondents who did not support a delay to ESEF requirements considered in Q1 and Q2 also did not support a delay to requirements for tagging of notes to the annual financial statements.
2.13 However, one of the respondents who supported a delay to the requirements
covered by Q1 and Q2 took a different view on delaying the requirement for tagging of notes to the annual financial statements. This respondent argued that this delay was unnecessary as issuers will have had plenty of time by 2022 to prepare and as the pressures caused by the coronavirus crisis may have subsided. Our response We have decided to keep to the original timetable for the mandatory requirements for issuers who prepare annual financial statements in accordance with IFRS to tag notes to the annual financial statements. In doing so we took into account the desirability of putting the timetable for the implementation of ESEF overall back on to its original schedule. We think that this will help allay the concerns of those respondents who did not support a delay to the other ESEF requirements.

PS20/14 Financial Conduct Authority
Chapter 3 Delay to the implementation of European Single Electronic Format and update on Coronavirus-related measures
Our decision
3.1 In this section, we set out our decision and next steps
Our decision
3.2 Our decision following consultation is to proceed with our proposal to delay ESEF
requirements for the publication and filing of machine-readable financial statements and tagging by 1 year, but not to proceed with our proposal to push back ESEF requirements for the tagging of notes to the annual financial statements by 1 year.
3.3 The final requirements are set out in Table 1 below:
Table 1: Timeframe for ESEF implementation
Obligation
Annual financial reports for all issuers to be published and filed in ESEF machine￾readable format Original timetable Financial years starting on or after 1 January (publication from 1 January 2021) Timeframe proposed in CP 20-12 Financial years starting on or after 1 January 2021 (publication from 1 January 2022) Final timetable Financial years starting on or after 1 January (publication and filing from 1 January 2022) Mandatory tagging Financial years starting Financial years starting on Financial years starting requirements for issuers on or after 1 January or after 1 January 2021 on or after 1 January preparing IFRS consolidated 2020 (publication from 1 2021 financial statements (publication from 1 January 2021) January 2022) (publication from 1 January 2022) Requirements on issuers preparing IFRS consolidated financial statements to tag notes to the annual financial statements Financial years starting on or after 1 January (publication from 1 January 2023) Financial years starting on or after 1 January 2023 (publication from 1 January 2024) Financial years starting on or after 1 January (publication from 1 January 2023)
3.4 Under our decision:

• All issuers will be required to publish and file their annual financial reports in XHTML
  web browser format for financial years starting on or after 1 January 2021.
• Issuers preparing consolidated annual financial statements in accordance with IFRS
  will be required to tag basic financial information in their financial statements for financial years starting on or after 1 January 2021.
• However, the requirement for issuers who prepare IFRS consolidated annual
  financial statements to tag the notes to the annual financial statements will now be unchanged, applying to financial years starting on or after 1 January 2022, for publication from 1 January 2023.
  3.5 We have implemented our decision by amending the transitional provision in DTR TP 1
  32R and Article 8 and Annex II of the RTS.

PS20/14 Financial Conduct Authority
Chapter 3 Delay to the implementation of European Single Electronic Format and update on Coronavirus-related measures
Next steps
3.6 Our final rules, which come into effect on IP Completion day, are set out in Appendix 1.
3.7 To allow issuers to submit annual reports in the ESEF standard, the FCA is upgrading its
National Storage Mechanism facility, its online archive of filings by companies who are subject to the Transparency Directive and Listing Rules.
3.8 We currently anticipate releasing the upgrade in January 2021, ready for those issuers
who wish to file reports in ESEF on a voluntary basis. More information will be available on the ESEF pages of FCA website as the project progresses.

PS20/14
Annex 1
Financial Conduct Authority
Delay to the implementation of European Single Electronic Format and update on Coronavirus-related measures
Annex 1
List of non-confidential respondents
Amana Consulting Gmbh
Arkk Consulting Ltd
BAE Systems
Black and Callow Ltd
CTRLPRINT UK Ltd
Datatracks
Deloitte LLP
Ernst and Young LLP
Falcon Windsor
Friend Studio
Institute of Chartered Accountants in England and Wales ICSA The Chartered Governance Institute UK BP United Kingdom Share Society XBRL international

PS20/14 Financial Conduct Authority
Annex 2 Delay to the implementation of European Single Electronic Format and update on Coronavirus-related measures
Annex 2
Abbreviations used in this paper
ESEF European Single Electronic Format
EU European Union
IFRS International Financial Reporting Standards PDF Portable Document Format xHTML EXtensible Hyper Text Mark-up Language Sign up for our weekly news and publications alerts All our publications are available to download from www.fca.org.uk. If you would like to receive this paper in an alternative format, please call 020 7066 7948 or email: publications_graphics@fca.org.uk or write to: Editorial and Digital team, Financial Conduct Authority, 12 Endeavour Square, London, E20 1JN

PS20/14 Financial Conduct Authority
Appendix 1 Delay to the implementation of European Single Electronic Format and update on Coronavirus-related measures
Appendix 1
Made rules (legal instrument)

FCA 2020/66
TECHNICAL STANDARDS (ELECTRONIC REPORTING FORMAT) INSTRUMENT 2020 Powers exercised A. The Financial Conduct Authority (“the FCA”) makes this instrument in the exercise of the powers and related provisions in or under:
(1) regulation 72 (Transfer of directive functions to the FCA) of the Official Listing of Securities, Prospectus and Transparency (Amendment etc.) (EU Exit) Regulations 2019 (the “Regulations”), for the purposes specified in paragraph 31 (to specify the electronic reporting format for annual financial reports) of Schedule 2, Part 3 of the Regulations; and (2) the following sections of the Financial Services and Markets Act 2000 (“the Act”) as amended by the Financial Regulators’ Powers (Technical Standards etc.) (Amendment etc.) (EU Exit) Regulations 2018:
(a) section 138P (Technical standards);
(b) section 138Q (Standards instruments); and (c) section 138S (Application of Chapters 1 and 2). B. The rule-making powers listed above are specified for the purposes of section 138Q(2) (Standards instruments) of the Act. Pre-conditions to making
C. The FCA has consulted the Prudential Regulation Authority and the Bank of England
as appropriate in accordance with section 138P of the Act.
D. A draft of this instrument has been approved by the Treasury in accordance with
section 138R of the Act.
Modifications
E. The following EU Regulation is amended in accordance with the Annex to this instrument. Commission Delegated Regulation (EU) 2019/815 of 17 December 2018 supplementing Directive 2004/109/EC of the European Parliament and of the Council with regard to regulatory technical standards on the specification of a single electronic reporting format, which is part of UK law by virtue of the European Union (Withdrawal) Act 2018 Commencement F. This instrument comes into force on IP completion day as defined in the European Union (Withdrawal Agreement) Act 2020. Citation

FCA 2020/66
G. This instrument may be cited as the Technical Standards (Electronic Reporting Format) Instrument 2020. By order of the Board 22 October 2020

FCA 2020/66
Annex
In this Annex, underlining indicates new text and striking through indicates deleted text. COMMISSION DELEGATED REGULATION (EU) 2019/815 of 17 December 2018 supplementing Directive 2004/109/EC of the European Parliament and of the Council with regard to regulatory technical standards on the specification of a single electronic reporting format …
Article 8
Entry into force and application
…
It shall apply to annual financial reports containing financial statements for financial years beginning on or after 1 January 2020 1 January 2021. …
ANNEX II
Mandatory markups
…
2. Issuers shall mark up all disclosures made in IFRS consolidated financial statements or
made by cross-reference therein to other parts of the annual financial reports for financial years beginning on or after 1 January 2020 1 January 2021 that correspond to the elements in Table 1 of this Annex. …
Table 1
Mandatory elements of the core taxonomy to be marked up for financial years beginning on or after 1 January 2020 1 January 2021 …

PS20/14 Financial Conduct Authority
Appendix 2 Delay to the implementation of European Single Electronic Format and update on Coronavirus-related measures
Appendix 2
Made rules (legal instrument)

FCA 2020/65
DISCLOSURE GUIDANCE AND TRANSPARENCY RULES SOURCEBOOK (ELECTRONIC REPORTING FORMAT) INSTRUMENT 2020 Powers exercised A. The Financial Conduct Authority (“the FCA”) makes this instrument in the exercise of the following powers and related provisions in the Financial Services and Markets Act 2000 (“the Act”):
(1) section 73A (Part 6 Rules);
(2) section 89A (Transparency rules);
(3) section 89C (Provision of information by issuers of transferable securities); and (4) section 137A (The FCA’s general rules). B. The rule-making powers listed above are specified for the purposes of section 138G(2) (Rule-making instruments) of the Act. Commencement
C. This instrument comes into force on IP completion day as defined in the European
Union (Withdrawal Agreement) Act 2020.
Amendments to the Handbook
D. The Disclosure Guidance and Transparency Rules sourcebook (DTR) is amended in accordance with the Annex in this instrument. Citation E. This instrument may be cited as the Disclosure Guidance and Transparency Rules Sourcebook (Electronic Reporting Format) Instrument 2020. By order of the Board 22 October 2020

FCA 2020/65
Annex
Amendments to the Disclosure Guidance and Transparency Rules sourcebook (DTR) In this Annex, underlining indicates new text and striking through indicates deleted text. TP1 Disclosure and transparency rules Transitional Provisions (1) (2) Material to which the Transitional Provisions applies (3) (4) Transitional Provision (5) Transitional Provision:
dates in force
(6)
Handbook
Provision:
coming into force
…
32 DTR 4.1.14R R DTR 4.1.14R applies in relation to a financial year of an issuer beginning on or after 1 January 2020 1 January 2021. From 13 December 2019 IP completion day From 13 December …

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