Comments are due on the European Single Electronic Format

The amended Transparency Directive will require issuers listed on regulated markets to submit corporate annual financial reports in an ESEF beginning January 1, 2020.

The objectives is to make submission easier for issuers while facilitating ease of access and analysis for investors and regulators. The paper's authors state at the outset:

"In particular, ESMA seeks views on its [proposal] that the AFR should be published in PDF format with, in addition, IFRS consolidated financial statements reported as structured electronic data in XBRL or iXBRL."

What ESMA's paper does not do

ESMA's consultation paper includes an assessment of current approaches to electronic reporting, and discusses the prospects and impact of establishing an ESEF. What the paper does not do, however, is recommend - or even discuss - the use of PDF/A-3 as the ideal vehicle for delivery of both structured and unstructured information. This is unfortunate, as PDF/A-3 is a superb solution for the functional requirements ESMA has outlined.

ESMA requests comment from interested parties. Their "request for consultation" page provides the relevant contact information.

The consultation closes on 24 December 2015.