CSSF: Enforcement of 2025 Annual Reports
CSSF
These reports include both financial statements prepared under IFRS and sustainability reports—either under the Non-Financial Reporting Directive (NFRD) or, voluntarily, the European Sustainability Reporting Standards (ESRS) as part of the Corporate Sustainability Reporting Directive (CSRD) transition.
The CSSF emphasizes that:
It is monitoring compliance with applicable reporting frameworks and will conduct an enforcement campaign in 2026 based on the quality of the published 2025 reports.
The ESRS reporting framework is complex and evolving; the CSSF expects issuers’ sustainability disclosures to continue improving over time.
Issuers should consider the European Common Enforcement Priorities (ECEPs) identified by ESMA and national enforcers, which focus on key areas of financial and sustainability reporting quality.
Key areas highlighted for special attention include:
IFRS Financial Statements
Issuers must ensure accurate disclosures, particularly in areas affected by economic uncertainty (e.g., asset valuations, liquidity, and revenue recognition).Sustainability Reporting (ESRS/NFRD)
Priorities include:
Materiality assessments and detailed explanations of how sustainability matters were determined as material.
Scope and structure of sustainability reports, ensuring they cover the same entity as the financial statements.
Clear disclosure of policies and actions taken to address material sustainability impacts, risks, and opportunities.
Additional Focus Points
The communiqué also highlights attention to common technical reporting issues such as ESEF tagging errors and encourages issuers to prepare for upcoming standards and taxonomy disclosure changes.
Overall, the CSSF’s enforcement approach aims to support improved transparency and comparability of issuer reporting in line with evolving EU reporting standards.