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ESEF Roundtable: Key takeaways from the FRC

Last month, we hosted our annual ESEF roundtable bringing together industry experts to discuss what they had learnt from ESEF filings to date and the impact of ESMA’s updated guidance. We were joined by Thomas Toomse-Smith and Kerlien Conings from the FRC, who were able to share their views on how to improve quality and usability of future filings.


Both encouraged all UK listed filers to take advantage of the FCA’s test facility to validate your ESEF filing against ESMA’s rules and guidance. We’ve seen first-hand how this has benefitted many of our clients and helped make their final AFR filing process seamless.  


The test facility will validate your report prior to submitting your final AFR, giving you the chance to fix any errors and investigate any warnings. It is expected that most filings will have warnings yet still be perfectly valid. However, each warning should still be reviewed to ensure it is acceptable within the result.  


ESMA has not yet released a conformance suite (something that defines tests for application of rules and guidance) for their new guidance. But some firms have taken the initiative to implement many of these changes already. ESMA’s conformance suite is expected to be released in December 2022. 


The FRC also strongly encouraged filers to take more responsibility for their report. The ESEF format has replaced the PDF as the official document that meets the Transparency Directive requirements. Partnering with a third party for your tagging requirements is an efficient way of complying to the new mandate. However, it is still the company’s responsibility to ensure the tagged ESEF report is a true and accurate reflection of what is being stated in the annual report. 


To read more about the points discussed in the roundtable and many of the FRC’s discussion points can also be found in their Lab report from September 2022: