European Single Access Point (ESAP): What financial institutions need to know

Entities listed on the EU-regulated exchanges, including foreign companies, are in scope of ESAP. In addition, large companies and listed SMEs regulated under the Corporate Sustainability Reporting Directive (CSRD), banks, payment institutions and credit institutions reporting under the Capital Requirements Directive (CRD), along with entities reporting under the Sustainable Finance Disclosure Regulation (SFDR) and EU taxonomy reporting requirements, are required to report under ESAP.

ESAP does not create any additional reporting requirements and, instead, requires the submission of information already readily available under sixteen EU directives and nineteen EU regulations. The major reporting requirements that fall under ESAP are the CRD, CSRD, SFDR, EU Taxonomy Regulation, Market Abuse Regulation (MAR) and the Prospectus Regulation.

To submit their information on ESAP, in-scope entities must first submit it via a designated collection body, which will then upload the relevant reporting files to the platform. The designated collection body can be an EU national entity, office, or agency.

Institutions such as non-EU companies that do not report under EU law, private entities, non-listed EU entities and market participants, including pension funds and small asset managers that do not meet the thresholds under SFDR, are not required under EU law to submit their information on the ESAP. However, from 10 January 2030, these entities can choose to voluntarily disclose information that will benefit them and reach a broader European Union investor market.

The European Single Access Point (ESAP) will be launched in phases by ESMA. The phases and their impacts are as follows:

• Phase 1, from 10 July 2026: ESMA will commence the set-up of ESAP, and users will be able to access data from the ESAP tool. Entities listed on the EU-regulated markets will be subject to ESAP requirements under the prospectus regulation. There will be no need for additional reporting requirements for in-scope institutions, only the submission of existing disclosures.
• Phase 2, from 10 January 2028: Credit institutions reporting under the Capital Requirements Directive (CRD) and companies reporting under sustainability disclosures such as SFDR, EU taxonomy regulations and CSRD will submit their Environmental, Social, and Governance (ESG) related disclosures on ESAP. Institutions such as e-money institutions, which are subject to the Payment Services Directive (PSD) and the Electronic Money Directive (EMD), will also be required to submit their information on ESAP. Institutions must understand the applicable regulations and directives before submitting the information to their respective EU authority. Furthermore, in-scope entities must submit their data in a machine-readable format and ensure accurate submission of risk disclosures related to sustainability risks.
• Phase 3, from 10 January 2030: In addition to the entities in scope in Phases 1 and 2, ESMA expects to fully integrate ESAP with the remaining EU Regulations and Directivesthat fall under the ESAP legislation reporting requirements

How can we help?

Our Prudential Risk experts recognise that the ESAP and similar regulations remain a pivotal driver for the strategic priorities of financial institutions. Our team excels at helping clients within the financial services sector navigate the intricate web of regulations and meet similar regulatory reporting requirements under ESAP and other regulations such as the SFDR and CSRD. We work closely with our clients to identify their regulatory responsibilities and develop effective strategies for full compliance.