5.4 Management Report and European Single Access Point (ESAP)

An important factor that will significantly change the current reporting practice is the central integration of the required sustainability information in the management report. Under the former NFRD framework, EU member states can allow companies to report outside of the management report, such as within a separate sustainability report. The new draft removes this option. Thus, the CSRD intends to place sustainability information on an equal footing with financial information to standardize sustainability reporting.

Since non-financial information will be disclosed in the management report, the CSRD requires that in-scope companies provide the sustainability information in a digital machine-readable format, specifically in XHTML format in line with the European Single Electronic Format (ESEF) regulation. Furthermore, the directive requires the reported sustainability information to be digitally tagged, so that it can be found and used easily. This requirement also helps to create a European single access point (ESAP) for public corporate information, as proposed by the European Commission in November 2021 and published in the Official Journal of the European Union on December 20, 2023. The aim of this is to centralize and improve public access to entities’ financial and sustainability information through a data platform, in line with the EU’s digital finance strategy. 

Under the proposal, the disclosures according to the CSRD would be submitted to collection bodies, meaning the national authorities or bodies that collect and store information submitted by entities in each country. Once the collection bodies receive the information, it would be automatically forwarded to the ESAP through a single application programming interface. Data would need to be stored in each of the national collection bodies and with the European Securities and Markets Authority (ESMA) in Paris.

The ESAP platform is expected to be operational from January 1, 2026, subject to the adoption of delegated and implementing acts by the European Commission and ESMA. These acts will establish further details regarding the technical and operational aspects of the ESAP, including its work program for 2024 and beyond, as well as its data strategy (2023–2028).