News 24/10/25

Key focus areas for 2025 reporting

The Dutch Authority for the Financial Markets (AFM) asks listed companies to pay extra attention to the enforcement priorities of the European Securities and Markets Authority (ESMA) and to transparent sustainability reporting when preparing their 2025 reports. These points are also relevant for audit committees overseeing the reporting process and audit firms reviewing the reports.

In short

Address ESMA’s enforcement priorities in 2025 reporting
Communicate clearly about the identification of impacts, risks, and opportunities, and the double materiality analysis
Take note of the updated Corporate Governance Code

Address ESMA’s enforcement priorities in 2025 reporting

On October 14, ESMA published its enforcement priorities for 2025 reporting. The AFM will pay extra attention to these points in the coming year. In summary, they concern:

1. Financial reporting: geopolitical risks and uncertainties, and segment reporting (IFRS 8)
2. Sustainability: materiality considerations in reporting under European Sustainability Reporting Standards (ESRS), and the scope and structure of the sustainability report
3. Correct application of the European Single Electronic Format (ESEF): ESMA has compiled an overview of common ESEF errors in the cash flow statement

ESMA’s publication also highlights the importance of connectivity between financial and sustainability information, recent IFRS developments, and consistency in the use of Alternative Performance Measures (APMs).

Communicate transparently about impacts, risks, and opportunities, and the double materiality analysis

A transparent explanation of the impacts, risks, and opportunities (IROs) helps readers of the sustainability report understand how the company affects society and the environment, and how external factors may impact its operations. These IROs form the input for the double materiality analysis, which plays a key role in sustainability reporting. See also our reports: Ten navigation points for proper CSRD application and The company and its place in the world: 3 focus points for CSRD.

Take note of the updated Corporate Governance Code

The AFM points to the updated Corporate Governance Code from March 2025. This update includes the management statement on the effectiveness of internal risk management and control systems, which clarifies the responsibilities of directors and supervisory board members regarding risk management.