ESAP and investment marketing: investor visibility, explained honestly

"Investment marketing based on ESAP" is a phrase you will hear more often as the portal approaches. This guide explains what is real behind it: how investors and their software will consume ESAP data, what a company must get right to be found and compared, where the voluntary route for unlisted companies fits — and what ESAP will never do for you.

1. What investors will actually get from ESAP

• One search across the EU. By entity name, legal entity identifier (LEI), type of information, date, size of entity, country of registered office, industry sector and collection body. A fund manager screening "industrial companies below €200 million in Poland, Czechia and Romania" will do it in one query instead of three national portals.
• Structured data, not only PDFs. Annual financial reports arrive as ESEF files with iXBRL tags; other documents in data-extractable formats. Figures can be read by software without re-typing.
• A free API and bulk access. The channel data vendors, fintechs and quantitative teams are expected to use. Information is free in the standard case; fees are allowed only for very large volumes or very frequent access.
• Machine translation and alerts from 10 July 2028 — a report filed in one EU language becomes readable in another without the company lifting a finger, and users can subscribe to new filings.

Who will use this? Analyst and asset-manager associations have welcomed ESAP, but with conditions: uniform data quality across all 27 Member States, licence-clean and free access, structured rather than PDF data, and for some users near-real-time availability. Several have also said plainly that today most investment professionals still rely on PDFs and on commercial vendors, and that a free EU database is not automatically used. Both things are true at once; see the sources at the end.

2. What that changes for a company

1. Your data is read by machines first. A screening tool does not "read" an annual report. It pulls tagged values, checks them against rules and compares them with peers. A missing or wrongly tagged value is not a nuance; it is a gap in a dataset.
2. Errors become visible EU-wide. Validation warnings that today sit in one national repository will be exposed in one place. Legal commentators have pointed out that this immediate accessibility of errors to investors' algorithms increases the risk attached to inaccurate data, and that the issuer remains responsible even when tagging is outsourced.
3. You will be compared whether you like it or not. Sector, size and country filters mean a company with no analyst coverage will sit next to its peers in a table someone else built.

Our own analysis of 14,804 ESEF filings shows how far the starting point is from "clean": among filings for 2024–2025, 54% carry at least one validation warning and 65% of issuers had at least one flagged filing. The data, by country →

3. Five things that make a company findable and comparable in ESAP

1. An active LEI. ESAP identifies entities by LEI and searches by it. A lapsed LEI means a company that is hard to find and hard to link across documents. Renewal is an annual task that is easy to forget.
2. Correct metadata. Country of registered office, industry sector and size category are entered at submission and drive the filters investors use. A wrong sector code puts you in the wrong peer group.
3. Filings free of validation errors — and with warnings understood. Technical errors can make a file unreadable to software. Warnings (formula-rule inconsistencies) may not block a submission, but they are visible and they reduce trust in the numbers.
4. Consistent entity data across documents. The same legal name, the same LEI and the same reporting entity in the annual report, the half-yearly report, the prospectus and the notifications.
5. Timely submission through the right collection body. Information reaches ESAP through your collection body's pipeline. A late or misrouted filing is invisible until it is fixed.

None of these is new. What is new is that, from July 2027, all five are checked by other people's software at once.

4. The voluntary route from 2030 — opportunity, with open questions

From 10 January 2030, any entity governed by the law of a Member State — including unlisted small and medium-sized companies and start-ups — may submit information to ESAP voluntarily, through the collection body of its home country, with an LEI and metadata flagging the submission as voluntary, in a data-extractable format. The regulation's stated aim is to increase the visibility of smaller companies to potential investors and their access to funding.

Three facts temper the enthusiasm, and we think a company deserves to hear them before planning anything:

• The format is not yet known. Draft technical standards on metadata, formats and templates for voluntary information are due to the Commission by 10 January 2028. Until they exist, nobody can tell you what to prepare.
• Voluntary information is flagged. ESAP must present it separately from mandatory disclosures, with a note that it may not meet all requirements and will not be updated. It will not look like a listed company's filing.
• Demand is unproven. In 2026 EFRAG assessed interest in a voluntary ESAP template for SMEs and start-ups and found it insufficient overall. Interest was conditional among start-ups facing financing needs (if cheap and without sensitive information), present among smaller IPO and M&A advisers, and low among large venture and private-equity investors, business angels and banks, who prefer the channels they already use.

Our reading: the voluntary route is most likely to matter for companies that already have a reason to be compared with listed peers — a planned listing, a bond issue, a cross-border fundraising — and for the advisers who prepare them. It is unlikely to matter for a company that merely wants to "be on the map". Everything known about voluntary submissions, in one place →

5. What ESAP will not do

• It will not rank, rate, score or recommend companies.
• It will not promote a company, feature it, or send its data to investors who did not ask.
• It will not replace investor relations, analyst coverage, roadshows or a listing.
• It will not certify that voluntary information is correct — the company remains responsible.
• It will not make a weak equity story strong. It makes data easier to find; what the data says is up to the company.

Any service that promises more than this on the back of ESAP is promising something the regulation does not provide.

6. Preparation checklist, 2026–2030

• Now: confirm your LEI is active and renewed; check name, country and sector codes used in your last filings.
• Before the 2027 annual report: have the ESEF file checked for errors and warnings before it goes to the auditor and the collection body; keep a written record of what was checked.
• July 2027: look your company up in ESAP on day one; confirm the documents and metadata shown are correct; fix anything that is not through your collection body.
• 2028: expect more errors in the first annual report under IFRS 18; plan the check earlier in the season. Read the draft standards for voluntary information when they are published.
• 2029: follow the Commission's review — later phases may move.
• 2030: decide on voluntary submissions only with a concrete audience in mind (a transaction, a lender, a listing), not "visibility" in the abstract.

Frequently asked questions

Can a company use ESAP for investment marketing?

Not in the sense of promotion. ESAP is neutral infrastructure: it presents information and does not rank or recommend. What a company can do is make sure that the data investors' tools pull from ESAP is complete, correct, consistently identified and comparable — a necessary condition for being considered, not a guarantee of attention.

Will investors actually use ESAP?

Analyst and fund associations support it on conditions (uniform data quality, free and licence-clean access, structured data). Today most professionals still work from PDFs and commercial vendors. Usage will follow data quality and the API; it should not be assumed.

Can an unlisted company appear in ESAP?

From 10 January 2030, yes — voluntarily, through the collection body of its home country, with an LEI, flagged as voluntary and shown separately. The exact format will be defined by technical standards due in draft by 10 January 2028.

What makes a company findable in ESAP?

An active LEI, correct and consistent metadata (name, country, sector, size), filings free of validation errors, and timely submission through the right collection body — the fields ESAP searches on.

Sources

• Regulation (EU) 2023/2859 — Art. 3 (voluntary submissions; LEI and metadata; draft ITS by 10 January 2028), Art. 7 (search fields; separate presentation of voluntary information; machine translation and notifications by 10 July 2028), Art. 10 (free access; fees for large volumes).
• EFRAG — limited interest in a voluntary template for SMEs and start-ups on ESAP (April 2026).
• EFFAS — why structured reporting remains essential (June 2026) — on analysts' use of a limited set of core KPIs and on coverage of smaller companies.
• BVI — position on the ESAP consultation (March 2024) — asset managers' conditions and the note that a free ESMA database is "hardly used".
• Börsen-Zeitung / DVFA — "Sixty minutes is unacceptable" (September 2025) — on data quality across 27 Member States and the attractiveness of small companies to professional investors.
• Paperjam — ESAP, LuxSE and the CSSF — on issuer responsibility and the visibility of errors to investors' algorithms (citing Clifford Chance).
• filings.xbrl.org (XBRL International) — the public ESEF filing index used for our data analysis.

This guide is information, not legal or investment advice. Where we state an opinion ("our reading"), it is labelled as such. Last reviewed 29 October 2026.