Guide
Voluntary submissions to ESAP from 2030: what is known today
The European Single Access Point was designed for information companies must publish. It also has a second door: from 10 January 2030, any entity governed by the law of an EU Member State may submit information voluntarily. This page collects what the regulation already fixes, what remains to be decided, what is known about demand, and what — if anything — a company can usefully do before 2028.
What the regulation fixes
| Question | Answer in Regulation (EU) 2023/2859 |
|---|---|
| From when? | 10 January 2030 (Article 3(1)). |
| Who may submit? | Any entity governed by the law of a Member State — listed or not, any size. |
| What information? | Information about the entity's economic activities relevant to financial services, capital markets or sustainability, which the entity is not already obliged to submit to ESAP. |
| Where? | To the collection body of the Member State where the entity has its registered office. Member States must designate at least one such body by 9 January 2030. |
| In what form? | In a data-extractable format, with metadata stating that the information is submitted voluntarily and whether it contains personal data; with a legal entity identifier (LEI). Personal data should be avoided unless required by law or essential to the information. |
| How is it shown? | ESAP must present voluntary information separately from mandatory information, with a statement that it may not meet all requirements of the regulation and will not necessarily be updated (Article 7(1)(h)). |
| Who decides the details? | The three European Supervisory Authorities, through their Joint Committee, must submit draft implementing technical standards on the metadata and any required formats or templates to the Commission by 10 January 2028 (Article 3(4)). |
| Who is responsible for the content? | The submitting entity. Collection bodies carry out automated checks of format, metadata and integrity; they do not verify content. |
What is still open
- The template. Whether there will be a fixed set of data points (for example, basic financials and sustainability indicators), free-form documents, or both. This is what the 2028 technical standards will decide.
- The cost. Collection bodies may charge for their services; whether and how much they will charge for voluntary submissions is not yet known.
- Historical information. The regulation's five-year look-back applies to mandatory information under sectoral acts; the treatment of past voluntary information will follow the standards.
- Timing. The Commission's review report is due by 10 January 2029 and may, by delegated act, postpone by up to 36 months the inclusion of information not yet covered. The practical start of voluntary submissions could therefore move.
- Whether investors will look. See the next section.
What is known about demand
In 2025–2026 EFRAG, the body that advises the European Commission on reporting standards, assessed interest in a voluntary ESAP template for SMEs and start-ups. Its findings, published in April 2026:
- Overall interest was insufficient to generate meaningful engagement.
- Start-ups and fast-growing companies expressed conditional interest — when facing financing challenges, provided the template is not costly to complete and does not require commercially sensitive information.
- Smaller IPO facilitators and M&A advisers were interested in the template.
- Large private-equity and venture-capital providers showed little interest, preferring commercial databases, pitch events and direct requests; appeal is limited for most business angels, who operate locally; banks are unlikely to use it.
- A voluntary template on a platform other than ESAP might further reduce the cost of providing the information.
XBRL International drew a similar conclusion from the exercise: smaller entities remain cautious about additional voluntary disclosures where the benefit is unclear and resources are constrained, and without clear requirements, uptake is rarely high enough to support comparability.
Our reading. The voluntary route is most likely to be used by companies with a concrete audience already in view — a planned listing on a growth market, a bond issue, a cross-border fundraising or a sale process — and by the advisers who prepare them. It is unlikely to be used by companies that merely want to "be visible". Anyone selling "ESAP visibility" to SMEs before 2028 is selling something whose shape is not yet defined.
What a company can usefully do before 2028
- Get and keep an LEI. It is the one hard requirement already fixed, it is cheap, and it is also useful for bank and counterparty onboarding today.
- Keep structured financials. If your annual accounts are already prepared in a structured format (for example, for a national business register), the step to a data-extractable submission will be short.
- Decide what you would never publish. EFRAG's finding that start-ups will not disclose commercially sensitive information is a reminder to define that boundary before a template arrives, not after.
- Watch the 2027 consultation. The European Supervisory Authorities will most likely consult publicly on the draft standards before January 2028. Written responses from companies and advisers shape the template. We will publish a summary and our own response.
- Do not budget for it yet. There is nothing to buy until the format exists.
Sources
- Regulation (EU) 2023/2859 — Article 3 (voluntary submission of information), Article 7(1)(h) (presentation), Article 13 (review).
- European Parliament Legislative Observatory — summary of the ESAP regulation (voluntary submissions, LEI and metadata).
- EFRAG — EFRAG finds limited interest in a voluntary template for SMEs and start-ups on the European Single Access Point (April 2026).
- XBRL International — Limited appetite for voluntary SME sustainability reporting (April 2026).
- Accountancy Europe — ESAP: what do auditors need to know.
Information, not legal advice. Last reviewed 29 October 2026.