Financial Supervisory Authority and Danish Business Authority Publish Results and Trends from Financial Statement Control 2025

1 Report on the Financial Supervisory Authority and the Danish Business Authority's Financial Statement Control 2025

2 Introduction The Financial Supervisory Authority (Finanstilsynet) and the Danish Business Authority (Erhvervsstyrelsen) verify that listed companies comply with the rules regarding financial and non-financial information in their annual and interim reports. Based on the previous year's controls, the Financial Supervisory Authority and the Danish Business Authority prepare a joint annual report. The authorities also participate in ESMA working groups to ensure a uniform understanding and application of the rules across the EU. The European Securities and Markets Authority (ESMA) publishes an annual report on supervisory work in the EU (Activity Report) on its website. The Financial Supervisory Authority publishes summaries of all orders and observations from the previous year on its website. The joint report on financial statement control has been published since 2005¹. This report contains the results of the Financial Supervisory Authority's and the Danish Business Authority's financial statement control of listed companies' annual and interim reports in 2025. The control covers both financial aspects of the companies' reporting and sustainability reporting. As of the end of 2025, there were 183 listed companies. Of these, 79 were financial companies, investment funds, securities funds, and capital companies subject to the Financial Supervisory Authority's regulations, and 104 companies subject to the Danish Financial Statements Act. Of these, 11% had their annual or interim reports selected for control. The report contains the results of financial statement control cases concluded in 2025, regardless of when the cases were initiated. In addition, the report includes comparative figures for financial statement control in 2024. The report is based on the scope and results of the financial statement control. This is followed by a description of specific individual cases, and finally, the focus areas for financial statement control in 2025 and 2026 are described. ¹ https://www.finanstilsynet.dk/tilsyn/regnskabskontrol ² The figure has been corrected due to an error in last year's report

2024 2025 Annual Reports Interim Reports Annual Reports Interim Reports Number of open cases at start of year 8 2 9 2 Number of cases initiated during the year 27 3 20 1 Number of cases concluded during the year 25 4 16 1

• Of which with errors 5 2 7 1
• Of which without errors or breaches (closed, possibly with guidance) 20 2 9 0 Number of open cases at end of year 10 1 13 1

17 cases, distributed across 16 annual reports and 1 interim report, were concluded in 2025, of which 9 were without errors or breaches. Among these, some companies received guidance. For 14 cases, distributed across 13 annual reports and 1 interim report, case processing continued into 2026. Of the concluded cases, 59% of the annual and interim reports were selected based on a risk assessment. The remaining 41% were drawn randomly or as part of a rotation scheme ensuring that all listed companies within a certain period are selected for financial statement control. The annual and interim reports selected after a risk assessment were chosen, among other things, based on a screening using a number of criteria that experience shows indicate an elevated risk of errors. The probability of finding errors is, all else being equal, higher in cases selected based on a risk assessment than in randomly drawn cases. Cases in which the Financial Supervisory Authority and the Danish Business Authority identify errors normally have longer processing times than cases that can be concluded without identified errors. Processing times will, of course, be further extended in cases where the authorities assess that treatment by the Financial Supervisory Authority's board or by ESMA is required. The sustainability area is in a transitional period between the current Danish reporting requirements (current ESRS), the taxonomy rules, and the upcoming simplified requirements in the sustainability standards (revised ESRS) as a result of efforts to reduce administrative burdens (Omnibus package). In view of the current transitional period and until the end of 2026, the Danish Business Authority's stock market control and the Financial Supervisory Authority therefore focus on analysis and guidance rather than actual control of sustainability reporting. In 2025 and 2026, the Danish Business Authority and the Financial Supervisory Authority will, as a general rule, not initiate actual control cases. However, if very serious and pervasive errors are identified, the authorities may still start a control case.

2. Concrete Examples from Financial Statement Control The Financial Supervisory Authority's board makes decisions in cases that are of a principled nature or have far-reaching significant consequences. Before the board decides on these cases, they are discussed in an accounting-savvy subcommittee consisting of members from the Financial Supervisory Authority's board and external accounting experts. In other cases, the Financial Supervisory Authority and the Danish Business Authority make decisions without processing by the board or the subcommittee. In 2025, the Danish Business Authority decided, among other things, on the following cases: IFRS 8 – Revenue disaggregated by geographic areas A company must present information on the geographical distribution of its revenue, unless the necessary information is not available and preparing it would involve disproportionate costs, in accordance with IFRS 8, paragraph 33. The disclosure requirement means, among other things, that a company must disclose revenue from external customers attributable to Denmark (the company's home country) and abroad. For some Danish companies, revenue in Denmark is insignificant compared to total revenue. Even if a company's revenue in Denmark is insignificant, the disclosure cannot be omitted, as it is material for financial statement users to be informed that the company is highly dependent on foreign customers. • A company that primarily sells on export markets and did not disclose revenue disaggregated between Denmark and abroad received an order to disclose that the overwhelming majority of the company's revenue could be attributed to abroad, in accordance with IFRS 8, paragraph 33(a). A company must also separately disclose revenue from a single foreign country if it is material. The disclosure requirement applies to revenue in specific countries, not regions or similar. Therefore, it is insufficient to disclose revenue from, for example, North America, if revenue from the USA is material in itself. • In two financial statement control cases, the companies had not separately disclosed revenue from the USA. Since revenue from the USA was material, in accordance with IFRS 8, paragraph 33(a), the Danish Business Authority raised the issue. It was therefore insufficient for the companies to have disclosed the total revenue for the regions "Americas" and "USA/Canada". The Danish Business Authority acknowledges that information on revenue by regions, etc., may be relevant for financial statement users, in accordance with IFRS 15, paragraph 114. Therefore, there is nothing preventing this information from being included in the accounts. However, it cannot replace the statutory disclosures of revenue by country. A company that shows revenue disaggregated by geographic regions, e.g., Europe, North America, and Asia in accordance with IFRS 15, paragraph 114, can therefore benefit from also paying attention to the disclosure requirement in IFRS 8, paragraph 33(a). To comply with the disclosure requirement in IFRS 8, paragraph 33(a), the company may indeed need to disclose revenue from individual material countries and revenue from Denmark and abroad separately.

3. Danish Business Authority's Sustainability Analysis In 2025, the Danish Business Authority prepared an analysis based on ESRS S1 on social matters for own workforce and on ESRS E1-6, which cover climate change. The purpose of the analysis was to identify central trends and challenges in companies' sustainability reporting and to support uniform implementation of the European Sustainability Reporting Standards (ESRS) in Denmark. The analysis was based on 2024 annual reports from 10 listed companies subject to the Danish Financial Statements Act. The companies were selected among reporting companies that were also expected to continue being subject to the ESRS reporting requirements in the future. The companies represented approximately 25% of listed companies with over 1,000 employees and revenue over €450 million. All companies had undergone limited assurance audit of their sustainability reporting, and none of the auditors found reason to make remarks on this. The Danish Business Authority did not engage in dialogue with the selected companies in connection with the analysis. This distinguishes the analysis from an actual financial statement control, where dialogue with companies is usually conducted before a decision in a case. The analysis showed that companies have taken a solid first step in implementing the new requirements in ESRS S1 and the selected elements of ESRS E1. Regarding standards on own workforce S1-1, S1-5, S1-6, and S1-9, the Danish Business Authority found no indications that the companies failed to meet the disclosure requirements regarding policies, processes, measures, and characteristics of their employees. The Danish Business Authority therefore considers that these sections provide a general understanding of the companies' objectives, processes, and results in these areas. The reporting generally appears structured and informative, particularly in the review of policies, processes, and the overarching descriptions of the workforce's characteristics. At the same time, the review revealed a number of areas where reporting can be improved, and where companies are expected to strengthen quality and precision over time. This applies, for example, to reporting on the characteristics of the company's employees in relation to cross-references to relevant figures in the annual accounts, appropriate remuneration in relation to benchmarks and remuneration parameters, and the total amount related to fines, sanctions, and damages for breaches of human rights, etc. Regarding the reporting on E1-6 on scope 3 emissions, the Danish Business Authority assesses that all investigated companies have included the mandatory disclosures in the sustainability report. It is the Danish Business Authority's overall impression that the companies have a structured and well-described approach to reporting that follows the specified structure and clearly indicates where the most material disclosure requirements are calculated. This helps make the reports clear and usable for readers. The analysis thus provides a current insight into companies' first experiences with ESRS requirements. The results can be used as inspiration and guidance for companies, auditors, and other stakeholders working with sustainability reporting, during a period of new requirements and simplifications on the horizon. Find the full analysis here: Sustainability Analysis 2025

4. Financial Supervisory Authority's Sustainability Investigation In 2025, the Financial Supervisory Authority conducted an investigation of the first sustainability reports under CSRD for the financial year 2024. The investigation had the same purpose as the Danish Business Authority's analysis, namely to identify central trends and challenges and to support uniform implementation of the ESRS in Denmark. The investigation covered the total of 21 financial companies (13 credit institutions and 8 pension and insurance companies) that submitted a sustainability report under CSRD for the financial year 2024. It was based on the companies' double materiality assessments, which form the basis for the entire sustainability reporting. In addition, 5 of the 21 companies (2 credit institutions and 3 insurance companies) were selected for a sample control focusing on ESRS 2 (general disclosures), ESRS E1 (climate change), and ESRS 2 IRO-1. The Financial Supervisory Authority has been in dialogue with the selected companies regarding the observations. The Financial Supervisory Authority concludes that the reports are generally readable and follow the overarching requirements for structure and content. The reports are further strengthened when they include references to avoid double reporting. Conversely, the overt use of standard formulations from the standards hinders readability. In the double materiality assessment, companies identified between five and seven topic-specific standards as material. All companies found E1 (climate change), S1 (own workforce), and G1 (business conduct) to be material. Some companies provide inadequate descriptions of the process for identifying IROs (impacts, risks, opportunities). This applies, for example, to thresholds for materiality, criteria and prioritization of sustainability risks in relation to other types of risks, integration into management processes, stakeholder engagement, and internal control procedures. In the investigation of reporting under ESRS E1, the Financial Supervisory Authority found deficiencies in descriptions of targets and measures to mitigate and adapt to climate change, as well as in disclosures on scope 3 greenhouse gas emissions. It is the Financial Supervisory Authority's impression that the deficiencies are mainly due to a limited data basis, or that data quality in the area was not yet sufficient. Find the full report here: Sustainability Reporting – Observations and Future Supervisory Priorities

5. Special Focus Areas for Financial Statement Control in the EU in 2025 (ECEP) ESMA sets annual focus areas for the financial statement control of European supervisory authorities. For the financial year 2024, ECEP was divided into three parts: Financial Information, Sustainability Disclosures, and European Single Electronic Format (ESEF). The financial part focused on liquidity and applied accounting practices, including Supplier Finance Arrangements (SFA) and the new requirements in IAS 7 as well as updates to IAS 1 and Statement of Cash Flows (SCF). In addition, companies were encouraged to focus on any long-term contracts. This included, among other things, whether these could be classified as customer contracts, and whether any macroeconomic factors could affect the assessment of the contracts' value and the overall security of the accounts. ECEP also contained a recommendation for companies to describe their considerations regarding relationships and connectivity to other non-group companies, in accordance with paragraphs 7-19 of IFRS 12. The part on sustainability disclosures was naturally shaped by the introduction of CSRD, focusing on a thorough and transparent double materiality assessment of relevant topics for the annual report's sustainability reporting. Similarly, the focus was on the internal processes within companies that enable thorough and faithful sustainability reporting, and on the correct use of the templates for the taxonomy regulation's Article 8. Finally, ECEP for 2024 focused on companies' reporting in relation to the European Single Electronic Format (ESEF). ESEF requires that annual reports be prepared in xHTML. Companies reporting under IFRS must also use InlineXBRL (iXBRL) to tag the accounting figures in the financial statements at the group level. Companies subject to CSRD or the size criteria under the taxonomy regulation's Article 8 will in the longer term have to prepare management reports in iXBRL and tag sustainability reporting under the taxonomy as established by the ESEF regulation. In addition to ECEP's focus areas for 2024, the focus in 2025, following previous years' ECEP focus areas, continued to be on the interplay between financial reporting and sustainability disclosures, and on the correct and transparent use of alternative performance measures (APMs).

6. Special Focus Areas for Financial Statement Control in the EU in 2026 (ECEP) ESMA's special focus areas for European supervisory authorities' financial statement control in 2026 (for the financial year 2025) are, like previous years, divided into financial information, sustainability disclosures, and European Single Electronic Format (ESEF). The financial focus areas address geopolitical risks and uncertainties, as well as segment reporting. Geopolitical risks and uncertainties are expected to result, among other things, in asset impairments and changes in the timing and recognition of deferred tax assets. ECEP specifically focuses on companies providing detailed, understandable, and company-specific information to financial statement users, so they understand the financial impact the uncertainty may have. For segment reporting, particular attention will be paid to the consistency across all segment information reported by companies, and to the material factors included in the segment breakdown. Due to uncertainty surrounding Omnibus I and the changes it has brought to CSRD reporting, ESMA has chosen to carry forward two of last year's priorities in this area: The double materiality assessment, and the scope and structure of the sustainability report. Given the uncertain regulatory environment in this area, the ECEP for 2026 also contains no special focus areas in relation to the taxonomy regulation. ESMA also refers to its letter on supervision of the European Sustainability Reporting Standards (ESRS), which states that in the first years after CSRD enters into force, the focus will be on guidance to support a harmonized approach to reporting under and supervision of the ESRS and CSRD. For the European Single Electronic Format (ESEF), this year's focus is on the correct use of taxonomies, so that accounting items are tagged correctly (especially with the correct granularity). ESMA has identified particularly many errors in tagging comparative figures and in the use of different currencies. ESMA also mentions recognition errors, incorrect use of signs and decimals for accounting items, and excessive use of extensions. Finally, ESMA, as in previous years, sets out some general points of attention. These are not part of the joint supervisory priorities and are therefore solely intended as information and inspiration for companies' considerations. Like the previous year, ESMA mentions here the interplay between financial information and sustainability reporting, as well as the correct and transparent use of alternative performance measures (APMs). Finally, ESMA reminds of the changes to IFRS 9 and IFRS 7 and encourages companies to begin familiarizing themselves now with the impact IFRS 18 will have on their accounts.