Results of the enforcement of the 2024 financial and non-financial information published by issuers subject to the Transparency Law

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
• 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 Assessment (DMA) Focus: The CSSF emphasized the importance of issuers not only disclosing the results of their DMA but also explaining the process itself, including granular information on activities, business relationships, geogra

Suggested Considerations

• *Financial Information (IFRS):
• *Enhanced Note Disclosures: Provide sufficient disaggregation and additional information in financial statement notes for material amounts and variances, particularly where information is not presented on the face of primary statements. The CSSF emphasizes compliance with paragraph 112(c) of IAS 1.
• *Cash Flow Statement Presentation: Ensure cash flows are presented on a gross basis (not net), exclude non-cash transactions, and disclose restricted cash balances with accompanying management commentary as required by paragraph 48 of IAS 7.
• *Segment Reporting Completeness: Clearly disclose all income and expense items in segment reporting, even when not separately provided to or reviewed by the Chief Operating Decision Maker (CODM), if they are included in reported segment results.
• *Going Concern Assessment: Maintain high transparency regarding accounting policies and judgments applied when classifying going concern assumptions.
• *Non-Financial Information (ESRS):

Key Dates

Who is Affected