ESAP First Phase: Where Regulated Disclosures Must Now Be Filed

On 10 July 2026, ESMA started pulling regulated disclosures into the European Single Access Point (ESAP). The public ESAP portal is not yet accessible; Regulation (EU) 2023/2859 requires ESMA to establish and operate it by 10 July 2027. What went live on 10 July was the plumbing underneath it: from that date, Officially Appointed Mechanisms and National Competent Authorities began feeding information and metadata into ESAP for the first three bodies of law in scope.

The gap between those two dates is the part that catches reporting teams. Firms tend to read July 2027 as the deadline and assume they have a year to prepare. The requirement that bites is already live. From 10 July 2026, the specified public information covered by Article 23a of the Transparency Directive, Article 21a of the Prospectus Regulation and Article 11a of the Short-selling Regulation must be submitted to the designated collection body in the required format with the prescribed metadata. Collection bodies must reject submissions that fail the applicable automated technical validations. The public site is a year out. The filing change is not.

This article walks through what the first phase of ESAP actually changed on 10 July 2026, who the collection bodies are, what a compliant submission now has to include, and which reporting frameworks join the platform in the waves that follow.

Related reading: our guide to the ESMA ESEF taxonomy update, which covers the structured format issuers already use for annual financial reports.

The 10 July 2026 start and the platform the public gets in 2027

ESAP is built on Regulation (EU) 2023/2859, adopted on 13 December 2023 and in force from 9 January 2024. The regulation gives ESMA the job of establishing and operating a single, EU-wide access point for publicly available information relevant to financial services, capital markets and sustainability. ESMA has to have that platform running for public access by 10 July 2027.

Between now and then, the data has to get in. ESMA has described 10 July 2026 as the first milestone toward go-live: from that day, collection bodies started providing ESAP with the information and the metadata they hold for entities in scope. ESMA has said the platform will gather a meaningful set of EU-wide information over the twelve months before it opens to the public. That twelve-month window is why the obligation lands now. The public go-live date follows separately, in July 2027, and a collection body cannot forward a filing it never received in the right shape.

Here is the operative calendar for the first phase and the waves that follow:

• 13 December 2023: the ESAP Regulation (EU) 2023/2859 adopted; in force from 9 January 2024.
• 10 July 2026: the first phase of ESAP data collection begins. Collection bodies start feeding ESAP with information under the Transparency Directive, the Prospectus Regulation and the Short-selling Regulation.
• By 10 July 2027: ESAP becomes accessible to the public, the date fixed in the regulation for ESMA to have the platform operational.
• 10 January 2028: phase 2 begins, adding the first further group of sectoral instruments.
• January 2029: phase 2bis begins.
• January 2030: phase 3 is currently scheduled to begin if confirmed following the Commission review; specified 2030 inclusions may be postponed under Article 13 of Regulation (EU) 2023/2859.
• 10 January 2030: entities may begin making eligible voluntary submissions to the national collection body designated for that purpose.

Read that calendar as two separate clocks. One is the public-access clock, which stops in July 2027. The other is the filing clock, which for the first wave started a year before the public platform opens and for each later wave falls on that wave’s own phase date. Reporting teams work to the filing clock.

What the first phase actually pulls in

The first phase covers three instruments, and only three. ESMA named them precisely: information relating to the Transparency Directive (Directive 2004/109/EC), the Prospectus Regulation (Regulation (EU) 2017/1129) and the Short-selling Regulation (Regulation (EU) No 236/2012). Nothing else is in ESAP scope on 10 July 2026.

In practical terms, the first phase covers regulated information submitted under Article 21(1) of the Transparency Directive; the specified prospectus information listed in Article 21a(1) of the Prospectus Regulation; and public net short-position information under Article 6(1) of the Short-selling Regulation. The short-selling limb does not extend to private net short-position notifications to competent authorities. ESAP adds submission-format and metadata requirements without changing the underlying disclosure content.

Scope creep is the likely misreading here. ESAP is described as an access point for financial, capital-markets and sustainability information, so teams assume their whole reporting stack routes into it from day one. It does not. ESAP does not receive firms’ EMIR, MiFIR or SFTR transaction-reporting submissions. The later ESAP provisions for MiFIR and SFTR concern specified information that is already made public under those regulations, while EMIR transaction reporting is not brought into ESAP by the current ESAP legislative package. SFDR and MiCA information enters ESAP in later phases under the relevant amending provisions.

Collection bodies: the OAM or NCA is the gate

ESAP does not take filings directly from issuers. The regulation routes information through collection bodies, and for the first phase those collection bodies are the Officially Appointed Mechanisms and the National Competent Authorities the ESMA announcement named.

An Officially Appointed Mechanism, or OAM, is the national storage system each Member State designates under the Transparency Directive to hold issuers’ regulated information. In Luxembourg, for example, the Luxembourg Stock Exchange operates the OAM, and from 10 July 2026 it took on the ESAP-facing tasks of collecting the required metadata and validating document formats before information is passed on. Every Member State has an equivalent mechanism. For prospectus and short-selling information, the National Competent Authority sits in the collection-body seat.

The operational consequence is quieter than a new ESAP portal. Entities submit first-phase information to the collection body designated under the relevant sectoral provision, not directly to ESAP. The legal destination may remain the OAM or competent authority already responsible for the information, but the collection body may adapt its portal, submission process and validation controls for ESAP. Firms should therefore follow the collection body’s current filing instructions rather than assume that every pre-ESAP channel is unchanged.

One thing to check early: which body is your collection body for each instrument. A group with listed debt in one Member State and equity in another can face two different OAMs, and a prospectus approved in a third jurisdiction routes through that NCA. The collection-body map follows the existing filing obligations under each of the three instruments, so it is knowable, but it is worth drawing before the next reporting reference date rather than during it.

Format and metadata: what a compliant submission now carries

The detail that decides whether a filing clears the gate lives in two Commission Implementing Regulations that turn the ESAP Regulation into operational rules. Implementing Regulation (EU) 2025/1338 sets implementing technical standards for the functionalities of ESAP. Implementing Regulation (EU) 2025/1339, of 10 July 2025, sets implementing technical standards for the tasks of the collection bodies. The second one is where a reporting officer should look first.

Under that ITS, information has to reach ESAP in a data-extractable format, or in a machine-readable format where the underlying act requires one. For annual financial reports subject to the European Single Electronic Format, the report is prepared in XHTML. Where it contains IFRS consolidated financial statements, those statements are marked up using Inline XBRL embedded in the XHTML document. ESAP therefore reuses the existing ESEF document and adds the applicable ESAP metadata rather than introducing a separate document format.

The applicable sectoral ESAP provision specifies the metadata that the submitting entity must provide with the information. For first-phase legal-person submissions, this includes the relevant name, legal entity identifier, entity-size category, information type and personal-data indicator, with additional attributes such as industry sector where the sectoral provision requires them. Legal persons covered by those provisions must obtain an LEI. Separately, the Annex to Implementing Regulation (EU) 2025/1339 specifies the broader metadata record that collection bodies make available to ESAP, including metadata generated or derived by the collection body. Where a qualified electronic seal is required, it must comply with Commission Implementing Decision (EU) 2015/1506 at conformance level LT or higher.

Implementing Regulation (EU) 2025/1338 requires an ESAP legal entity identifier to pertain to the relevant person or entity, comply with ISO 17442 and appear in the GLEIF database. Implementing Regulation (EU) 2025/1339 requires collection bodies to validate the applicable LEI conditions. The ITS does not state that an LEI is rejected solely because its GLEIF registration status is lapsed; a submission fails where the identifier does not satisfy the statutory conditions or does not correspond to the relevant entity.

Where a qualified electronic seal is required, the ITS requires the collection body to perform the applicable eIDAS validations and verify that the seal complies with Commission Implementing Decision (EU) 2015/1506 at conformance level LT or higher. Whether a seal is required, and the practical submission process for providing it, should be checked against the applicable collection body’s current filing instructions.

The validation loop and what a rejection looks like

Collection bodies check what they receive before forwarding it. The ITS requires them to run automated technical validations on incoming information and its metadata, and to report the results back to the submitting entity. Under Implementing Regulation (EU) 2025/1339, a collection body must use its best efforts to give the submitting entity detailed results of those automated validations within 60 minutes of receiving the information.

The 60-minute period is a best-efforts standard, not a guaranteed turnaround time. A later response is permitted only in duly justified exceptional circumstances, including major accidents and errors, deliberate attacks and natural events. Once the exceptional circumstance has been resolved, the collection body must again use its best efforts to provide the validation results within 60 minutes of that resolution.

That validation is a technical and metadata check, not a supervisory review of whether the disclosure itself is correct. A collection body confirms that the format is one ESAP can ingest, that the mandatory metadata is present and internally consistent, and that identifiers resolve. It does not opine on whether a half-yearly report is accurate or a prospectus is complete. Reading the ESAP validation as a substance review is a mistake in both directions: it will not catch a disclosure error for you, and a clean ESAP validation is not a supervisory sign-off.

For planning, budget the 60-minute feedback as a real step in the timetable rather than an instant confirmation. Near a hard reporting deadline, a submission that fails validation at 17:30 for a metadata reason leaves little room to correct and refile before the cut-off. Teams that have run the format and identifiers through a dry run well before the reference date are less likely to discover an incorrect or non-matching identifier on deadline day.

The waves after 10 July 2026

The first phase is the opening slice of a much wider scope. The ESAP package pairs the core regulation with two amending instruments, Directive (EU) 2023/2864 and Regulation (EU) 2023/2869, which insert ESAP submission requirements across the EU financial rulebook and set the phased application dates for each act.

Phase 2 starts in January 2028, followed by phase 2bis in January 2029. ESMA currently presents phase 3 as starting in January 2030 if confirmed following the Commission review. The current consolidated ESAP Regulation permits the Commission to postpone specified 2030 inclusions by up to 36 months where the review identifies severe and pervasive difficulties. Separately, Article 3 of Regulation (EU) 2023/2859 permits eligible voluntary submissions to designated national collection bodies from 10 January 2030.

For a reporting team, the useful move is to place your own obligations on that timeline. Knowing your own dates matters more than holding the full act-by-act list in your head. Transaction-reporting submissions are not ESAP filings; map only the public information expressly brought into ESAP by the amended sectoral act. If you produce sustainability disclosure, watch the second phase. If you issue crypto-assets under MiCA, your obligations reach ESAP in 2030. Firms that already track application dates for CSRD, MiFIR or the Capital Requirements framework have a head start here: ESAP layers a filing-format obligation on top of dates many reporting calendars already carry for other reasons, rather than introducing a wholly new set of deadlines to track separately. Our overview of the ESMA transaction reporting simplification across EMIR, MiFIR and SFTR covers a framework where the transaction-reporting duty itself stays outside ESAP; only the specified information already made public under MiFIR and SFTR joins ESAP in the third phase, and EMIR transaction reporting is not brought into ESAP by the current package. Our CSRD sustainability reporting guide covers a second-phase instrument, and the MiCAR reporting obligations guide covers a third-phase instrument. Mapping your filings to the right wave now is cheaper than reacting to each application date as it arrives.

What ESAP does not change

ESAP re-routes and re-formats disclosures that already exist. It does not create a new disclosure obligation on issuers, and it does not change what the Transparency Directive, the Prospectus Regulation or the Short-selling Regulation require you to disclose. The substantive duties are the same on 11 July 2026 as they were on 9 July. What sits on top is a distribution and standardisation layer.

That also changes who inside a reporting team should own the task. The content itself, what a half-yearly report says or what a prospectus discloses, still belongs to investor relations or the deal team preparing it. The format and metadata gate sits downstream of that content decision, closer to the reporting or company-secretarial function that already manages the OAM or NCA filing relationship. Routing the ESAP requirement to the wrong owner is the more common early misstep: it lands as a legal question when it is actually an operational one.

That distinction matters for how a team resources the change. The change lands in the filing pipe: the format your existing filings travel in, the identifiers and metadata they carry, and the validation gate they pass through at the collection body. There is no fresh return to stand up and no new content to source, only an existing feed to reshape. The work is in the filing workflow and the reference data, especially the legal entity identifier, and our coverage of ESMA issuer registers and external reviewer reporting shows how the same identifier discipline runs through the wider ESMA data estate.

Frequently Asked Questions

Do issuers file anything directly to ESAP or to ESMA on 10 July 2026?

No. Entities submit first-phase information to the collection body designated under the relevant sectoral provision: the OAM for Transparency Directive regulated information and the competent authority for the specified prospectus and short-selling information. The collection body performs the ESAP-facing tasks and makes the information available to ESAP. Firms should follow the collection body’s current submission instructions rather than assume that every pre-ESAP portal or process is unchanged.

If ESAP only opens to the public in July 2027, why does the format change matter in 2026?

Because collection bodies started feeding ESAP on 10 July 2026 and run automated format and metadata validation on the way in. A filing that does not meet the format and metadata requirements can be rejected by the collection body now, a year before the public site exists. The public go-live date and the filing-compliance date are two different clocks.

Which disclosures are in scope for the first phase?

Only information under three instruments: the Transparency Directive (Directive 2004/109/EC), the Prospectus Regulation (Regulation (EU) 2017/1129) and the Short-selling Regulation (Regulation (EU) No 236/2012). EMIR transaction reporting is not brought into ESAP by the current package; specified information already public under MiFIR and SFTR joins ESAP in a later phase. Sustainability disclosure under the SFDR and crypto-asset disclosure under MiCA also join ESAP on later application dates.

What metadata does a submission have to carry?

The applicable sectoral ESAP provision specifies the metadata the submitting entity must provide, including the entity name, legal entity identifier, entity-size category, information type and personal-data indicator. The Annex to Implementing Regulation (EU) 2025/1339 separately sets out the broader metadata record collection bodies make available to ESAP. Legal persons covered by the first-phase provisions must obtain an LEI. Where a Member State permits the collection body to require it, the information must be accompanied by a qualified electronic seal complying with the applicable technical requirements, including Commission Implementing Decision (EU) 2015/1506.

How quickly does a collection body confirm whether a submission passed?

The collection body must use its best efforts to return the detailed automated-validation results within 60 minutes. A later response is permitted only in duly justified exceptional circumstances; teams should therefore allow for the validation step without treating ordinary processing pressure as an unrestricted extension of the filing timetable.

Does a clean ESAP validation mean the disclosure itself is approved?

A passed validation confirms the submission is technically ingestible by ESAP; it says nothing about whether a supervisor has reviewed its content. The automated validation checks format, metadata completeness and identifier consistency. It does not assess whether the disclosure is substantively correct or complete under the underlying instrument.

When do the frameworks I report under join ESAP?

It depends on the instrument. The first phase covers specified information under the Transparency Directive, Prospectus Regulation and Short-selling Regulation from 10 July 2026. Phase 2 starts in January 2028 and phase 2bis in January 2029. Phase 3 is currently scheduled for January 2030 if confirmed following the Commission review, and specified 2030 inclusions may be postponed under Article 13 of Regulation (EU) 2023/2859. Map each obligation to its applicable sectoral provision and the current ESMA timeline.

Related Articles

• ESMA ESEF Taxonomy Update 2026 – The structured Inline XBRL format issuers use for annual financial reports, the machine-readable output ESAP reuses for Transparency Directive filings.
• ESMA Transaction Reporting Simplification: EMIR, MiFIR, SFTR – Where the transaction reporting frameworks stand; specified MiFIR and SFTR public information joins ESAP in a later phase, not EMIR transaction reporting.
• CSRD Sustainability Reporting – Sustainability disclosure obligations that intersect with the sustainability information ESAP centralises in later waves.
• ESMA EU Green Bond External Reviewers Register – How issuer identifiers and ESMA registers connect across the wider ESMA data estate.

Key Takeaways

• ESAP data collection began on 10 July 2026. The public platform opens by 10 July 2027, but the filing-format and metadata requirements apply from the collection start, not the public go-live.
• The first phase covers only three instruments: the Transparency Directive, the Prospectus Regulation and the Short-selling Regulation. EMIR transaction reporting is not brought into ESAP; specified MiFIR/SFTR public information, SFDR and MiCA join in later waves.
• Entities continue submitting to the collection body designated under the relevant sectoral provision: the OAM for Transparency Directive regulated information and the competent authority for specified prospectus and short-selling information. Firms should follow that body’s current filing instructions because its portal or submission process may have changed for ESAP.
• Implementing Regulation (EU) 2025/1339 sets the collection-body tasks: data-extractable or machine-readable format, a defined metadata set including the legal entity identifier, and, where a Member State permits the collection body to require it, a qualified electronic seal.
• Collection bodies run automated validation and must use best efforts to return results within 60 minutes. Build that step into the filing timetable near deadlines.
• ESAP validation is an automated check on format, metadata and identifiers. It is not a supervisory review of the disclosure’s substance or a sign-off on accuracy.
• Phase 2 starts in January 2028 and phase 2bis in January 2029. Phase 3 is currently scheduled for January 2030 if confirmed following the Commission review, with specified 2030 inclusions subject to the postponement mechanism in Article 13 of Regulation (EU) 2023/2859.

Sources and References

• ESMA, “ESMA launches data collection under the first phase of ESAP”, 10 July 2026: esma.europa.eu
• Regulation (EU) 2023/2859 of 13 December 2023 establishing a European single access point (ESAP): eur-lex.europa.eu
• ESMA, European Single Access Point (ESAP) activity page: esma.europa.eu
• Commission Implementing Regulation (EU) 2025/1339 of 10 July 2025 (ITS on tasks of collection bodies): eur-lex.europa.eu
• Commission Implementing Regulation (EU) 2025/1338 (ITS on ESAP functionalities): eur-lex.europa.eu
• Directive 2004/109/EC (Transparency Directive): eur-lex.europa.eu
• Regulation (EU) 2017/1129 (Prospectus Regulation): eur-lex.europa.eu
• Regulation (EU) No 236/2012 (Short-selling Regulation): eur-lex.europa.eu
• AMF, “The European single access point (ESAP) enters its implementation phase”: amf-france.org
• Luxembourg Stock Exchange, “Preparing for ESAP: key changes for OAM users”: luxse.com

Filing for a reader that does not exist yet

The odd thing about ESAP in 2026 is that a firm is now formatting disclosures for a platform no member of the public can open. That is exactly why it is easy to defer. The public search box is the visible payoff, and it is a year away, so the work behind it feels optional. It is not. The collection bodies switched on their validation gates on 10 July 2026, and a filing that fails those gates today does not reach ESAP tomorrow. The teams that act on the format and metadata as live obligations now, and prove their identifiers before the next reference date, are the ones who will not be explaining a rejected filing when the platform finally opens.

Last updated: July 2026

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