Preparing for ESAP
ESAP at a glance
The European Single Access Point (ESAP) is a cornerstone of the European Commission’s Capital Markets Union, contributing to the broader objectives of the Savings and Investments Union. It is expected to improve transparency, reduce information asymmetry and facilitate cross-border investments across Europe. By making financial and non-financial information about entities and investment products publicly available in a centralised, digital platform, ESAP aims to make it easier for investors to make more informed investment decisions.
ESAP is covered by Regulation (EU) 2023/2859, which instructs the European Securities and Markets Authority (ESMA) to establish and operate the ESAP platform by 10 July, 2027. The access point will contain information required by existing EU law, which will be collected by designated collection bodies. Officially Appointed Mechanisms (OAMs) will act as the collection bodies for information to be made publicly available by issuers falling under the scope of the Transparency Directive.
You can find more information about ESAP at the ESMA's website and at EUR-Lex.
On 10 July 2026, the first phase of the ESAP data collection will enter into force. The ESAP framework brings a series of new requirements linked to the data to be collected and the file formats to be respected by issuers in the context of OAM storages.
Who is concerned?
Each EU Member State is required to have an OAM, which acts as a national collection point for the central storage of regulated information, as defined under the Transparency Directive.
As the OAM in Luxembourg, the Luxembourg Stock Exchange (LuxSE) will act as the collection body in the Grand Duchy for regulated information under the Transparency Directive. As per the ESAP framework, LuxSE will start collecting new metadata and perform new controls on the documents submitted for storage on 10 July 2026.
How is the information collected?
The main changes under ESAP
New metadata to be included by the issuer
- Indicate the size of the issuer (from a pre-defined list)
- Indicate the field of activity of the issuer (from a pre-defined list)
- Indicate if any personal data, in accordance with GDPR, is included in the regulated information
- In the case of annual financial reports, indicate whether the document contains a management report including a sustainability statement
- In the case of annual financial reports submitted in XHTML, indicate whether the document contains XBRL tagging
Automated controls to be performed by LuxSE
- The document submitted must be drawn up in a format that is data extractable (not a scanned document) or machine readable (compliant with iXBRL and the ESEF taxonomy)
- The document submitted must not contain active code (e.g. JavaScripts)
- The Legal Entity Identifier (LEI) code of the issuer must be valid and consistent with the Global Legal Entity Identifier Foundation (GLEIF) register
- The size of the document must not exceed the limit defined by ESMA
- All the mandatory metadata must be included
- If the LEI code of the shareholder is provided (not mandatory), the LEI code must be valid and consistent with the GLEIF register
Important note: As of 10 July 2026, only documents that are compliant with ESAP will be accepted for storage by LuxSE.
Through a series of developments and initiatives, LuxSE strives to help issuers prepare for the new OAM storage requirements under ESAP and contribute to a smooth adaptation:
- End of the client testing window
- Adaptation of OAM system and FIRST application
This page will be updated regularly, as needed. The information provided is for general information purposes only and does not constitute legal advice.
Last updated on 14 October 2025
