Results of the enforcement of the 2024 financial and non-financial information published by issuers subject to the Transparency Law
Executive Summary
The CSSF's January 2026 enforcement report documents the results of its 2025 examination campaign on 2024 financial and non-financial disclosures by issuers under Luxembourg's Transparency Law. This publication is critical for compliance professionals because it reveals systematic compliance gaps across financial reporting (IFRS), sustainability reporting (ESRS), and Alternative Performance Measures (APMs), with 27% of enforcement decisions resulting in injunctions for non-compliance.
What Changed
The regulatory landscape has evolved significantly with the introduction of new sustainability reporting requirements: - ESRS Implementation (First Year): 2024 marked the first full reporting year under the European Sustainability Reporting Standards (ESRS), with the CSSF conducting a fact-finding exercise to assess reporting quality. The CSSF noted an overall increase in reporting quality with better-structured reports and more relevant disclosures, though key improvement areas remain in comprehensive financial effects disclosure and clearer time horizons. - Taxonomy Disclosures Amendment: On 4 July 2025, the European Commission adopted a Delegated Act amending the Taxonomy Disclosures as part of the Omnibus package, affecting Article 8 of the Taxonomy Regulation. - Double Materiality
What You Need To Do
- *Financial Information (IFRS)
- *Enhanced Note Disclosures
- *Cash Flow Statement Presentation
- *Segment Reporting Completeness
- *Going Concern Assessment
- *Non-Financial Information (ESRS)
Key Dates
Compliance Impact
Urgency: HIGH
Who is Affected
Summary
Communiqué