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disclosure regimes · European Union

What ESAP will make measurable in Europe, and when

ESAP was established by Regulation (EU) 2023/2859 of 13 December 2023. Article 1(1) requires ESMA to establish and operate it by 10 July 2027. It centralises information already made public under the Union acts listed in its Annex; it creates no new publication obligation.

the dates

  1. 20 December 2023Regulation (EU) 2023/2859 is published in the Official Journal, together with the two omnibus acts that carry the phasing — Directive (EU) 2023/2864 and Regulation (EU) 2023/2869.
  2. 10 July 2025Commission Implementing Regulations (EU) 2025/1338 and 2025/1339 set out ESAP’s functionalities and the tasks of collection bodies. XML, XBRL and Inline XBRL are listed as machine-readable formats; HTML, PDF and txt count only as extractable.
  3. 10 July 2026Implementing Regulation (EU) 2025/1339 applies. First wave: regulated information from listed issuers under the Transparency Directive, short-selling positions, and prospectuses.
  4. 10 July 2027ESMA must have established and be operating ESAP. Nothing collected in the first wave is publicly accessible before this date.
  5. 10 January 2028Second wave: annual and consolidated accounts and sustainability reporting under Directive 2013/34/EU, UCITS, SFDR, MAR, PRIIPs and benchmarks.
  6. 10 January 2030Third wave, which includes AIFMD and ELTIF — and, for those two, only ESMA’s central public registers. Voluntary submission also opens on this date.

What becomes machine readable

From July 2027, the annual and half-yearly financial reports of EU listed issuers, already produced in ESEF Inline XBRL under the Transparency Directive, through a single free API with standardised metadata including the issuer’s LEI.

granularity · Issuer and document. From January 2030, fund level — but identification only.

What stays out of reach

No private debt fund portfolio will enter ESAP under current law. Neither AIFMD nor ELTIF contributes position-level data to it. PDF is an acceptable format: ESAP accepts XBRL where a sectoral act already requires it, and does not impose it. Historical depth is bounded — information published at most five years before the date of application, kept for at most five years.

What it changes for the measurement

It is the honest answer to the question we are asked most often about Europe. ESAP will make European issuer reporting far easier to gather, and it will not make the measurement we publish in the United States reproducible in Europe. What is missing there is not a search interface; it is a position-level disclosure obligation.

primary sources

this page describes what the texts say · it is not legal advice, and the official text always governs · where we could not read a primary source, we have left the point out rather than paraphrase it