CSSF Publication
On 12 December 2025 and as in previous years, the Commission de Surveillance du Secteur Financier (the “CSSF”) published a press release outlining a number of topics and issues on which issuers subject to the law of 11 January 2008 on transparency requirements for issuers, as amended (the “Transparency Law”) will need to pay attention when drawing up their reporting for the 2025 financial year.
As Luxembourg competent financial supervising authority pursuant to article 22 of the Transparency Law, the CSSF is monitoring the financial and non-financial information to be published by issuers and ensures that the latter are in accordance with the applicable reporting frameworks as set out at the European and Luxembourg levels.
Those issuers, as well as their auditors, must carefully consider these focus areas as they are preparing their financial statements in accordance with the International Financial Reporting Standards (the “IFRS”) and/or their sustainability reports in accordance with the Commission Delegated Regulation (EU) 2023/2772 of 31 July 2023 supplementing Directive 2013/34/EU of the European Parliament and of the Council as regards sustainability reporting standards (the “ESRS”).
Issuers will remain subject to the requirements of the Directive 2014/95/EU of the European Parliament and of the Council of 22 October 2014, amending Directive 2013/34/EU as regards disclosure of non-financial and diversity information by certain large undertakings and groups (the “NFRD”) as long as the Directive (EU) 2022/2464 of the European Parliament and of the Council of 14 December 2022 amending Regulation (EU) No 537/2014, Directive 2004/109/EC, Directive 2006/43/EC and Directive 2013/34/EU, as regards corporate sustainability reporting (the “CSRD”) has not been transposed in the Grand Duchy of Luxembourg. The CSSF however outlines that many issuers have voluntarily applied the requirements of the CSRD starting with the 2024 financial year. In parallel, the CSSF confirms that it will continue to focus on ESRS-related topics to support issuers during the transition to the new sustainability reporting framework.
Disclosures requirements under the Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment, and amending Regulation (EU) 2019/2088 (the “EU Taxonomy Regulation”) also remain applicable for issuers falling within the scope of the NFRD.
Please find the full text of the CSSF 2025 publication available on
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ESMA Publication
The CSSF’s press release follows European Securities and Markets Authority (the “ESMA”) public statement issued on 14 October 2025 identifying the European Common Enforcement Priorities (the “ECEPs”) for 2025 annual financial reports of issuers admitted to trading on European Economic Area (the “EEA”) regulated markets.
The ESMA presented the 2025 ECEPs, which included priorities related to IFRS financial statements, sustainability statements as well as statements and annual financial reports to be submitted in the European Single Electronic Format (the “ESEF”) reporting.
In addition to some general remarks on specific topics, the ESMA reminded issuers and their auditors to consider the following topics, namely:
ECEPs related to IFRS financial statements:
- Geopolitical risks and uncertainties; and
- Segment reporting.
ECEPs related to sustainability statements:
- Materiality considerations in reporting under ESRS; and
- Scope and structure of the sustainability statement.
ECEPs related to ESEF reporting:
Common errors found in the Statement of Cash Flows.
Please find the full text of ESMA’s public statement on the 2025 ECEPs available on https://www.esma.europa.eu/document/european-common-enforcement-priorities-2025-corporate-reporting.
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Issuers preparing their reporting for the 2025 financial year in accordance with the requirements set out in the Transparency Law must consider the ECEPs as well as the below CSSF specific point of focus deriving from said ECEPs.
- IFRS financial statements
Issuers need to pay attention to the following when preparing their 2025 IFRS financial statements.
- 1. Priority 1: Geopolitical risks and uncertainties
The main current geopolitical tensions across the globe, being the ongoing war in Ukraine, the conflicts in the Middle East as well as the intermittent trade war between the world greatest economic powers, cause risks and uncertainties (such as asset impairments and write-downs, revenue recognition patterns, recoverability of deferred tax assets, need for new/additional provisions, liquidity risks, valuation models, compliance with debt covenants or even any going concern assumptions) susceptible to affect issuers’ business and financial reporting in 2025.
Generic references to “geopolitical uncertainties” should be avoided – issuers are required by the CSSF to provide clear, granular and tailored disclosures to allow an investor to assess the impact of such risks and uncertainties on their financial position and performance.
To that extent, the CSSF gives further guidance by providing a table summarizing areas which could potentially be affected.
- 2. Priority 2: Segment reporting
On 29 July 2024, the IFRS Interpretations Committee issued a decision[1] highlighting certain disclosures requirements under paragraph 23 of IFRS 8[2]. These requirements aim to provide users of financial statements with a clear understanding of how an issuer’s operations are organised and managed, and to enable an assessment of the performance of different segments of the business.
It clarifies that disclosure requirements under such paragraph should include certain income and expense items if they are (i) included in the measure of segment profit or loss reviewed by the relevant chief operating decision maker (the “CODM”) (if they are not separately provided to, or reviewed by, the CODM) or (ii) regularly provided to the CODM (even if they are not included in the measure of segment profit or loss).
The CSSF emphasises that material items or income and expenses referred to in paragraph 23 (f) of IFRS 8 should be apprehended under the general prism of materiality defined in IAS 1[3] (Presentation of Financial Statements) (§7, §97), and do not only concern unusual or non-recurring items.
It is critical for issuers to review their segment reporting disclosures of sub-totals and items in light of the above.
The CSSF further outlines that, in the current environment of trade barriers and geopolitical uncertainties, entity-wide disclosures on geographical areas and major customers required by paragraphs 32 and 34 of IFRS 8 are particularly relevant.
- Sustainability report
Due to the current shifting regulatory environment regarding sustainability reporting, the two first priorities addressed below, already pointed out by the CSSF in its last year’s press release, remain of utmost importance.
- 1. Priority 1: Materiality considerations in reporting under ESRS
Disclosing detailed and entity-specific methodology descriptions of input parameters related to the materiality assessment process is important to clarify the basis for determining whether an Impact, Risk or Opportunity (“IRO”) is material.
To allow users of the sustainability statement to understand the main considerations relied upon for the determination of material sustainability matters, issuers should be transparent about the disclosures related to thresholds (most notably for the matters whose materiality issuers were most uncertain during the assessment process, with negative impacts requiring details on severity scales applied).
The CSSF further stresses that it expects issuers to also be transparent on how they have considered gross impacts (before the effect of any prevention, mitigation or remediation actions) in their materiality assessment process.
Information on engagement with affected stakeholders during the materiality assessment process should also be provided, to help users of the sustainability statement to understand how their interests and views were integrated into the materiality assessment process.
Importance of ESRS 2 disclosure of the information related to the results of the materiality assessment (SBM-3 and IRO-2) is also highlighted by the CSSF, as they provide a complete view of the issuers’ material IROs and how they relate to their strategies and business models, and also guide the users of the sustainability statement to where and how the management of these IROs is addressed in the topical sections through policies, actions, targets – or the absence thereof – and related metrics.
Particular attention should also be paid as to positive impacts, which should not be confused with mitigation of negative impacts.
- 2. Priority 2: Scope and structure of the sustainability report
The CSSF encourages issuers to map IROs to ESRS topics and sub-topics by using ESRS terminology to help users of the sustainability statement to navigate through topical disclosures and identify entity-specific disclosures.
Non-material information, where permitted under the ESRS, should be clearly identified and must not obscure material information.
The CSSF further reminds issuers that a report on the results of a review of corporate practices in the first year of reporting under ESRS has been released. This report intends to inform stakeholders about maturity, clarity and comparability of reports, and highlighting good practices and areas for improvement[4].
The scope of the sustainability disclosures must cover the same reporting entity as the financial statements and should also extend to information on material IROs connected with the issuers’ entire value chain.
Sustainability information should be structured in four parts, namely: General, Environment, Social and Governance.
Proper cross-referencing within the sustainability statement, as well as incorporation of documents by reference (as allowed by ESRS 1) are encouraged by the CSSF to avoid unnecessary duplication and emphasise connections among disclosures.
Consistency and transparency across the sustainability report and the financial statements must be ensured, and description of the relationships between the different pieces of information should also be included.
- 3. Priority 3: Policies and actions to manage material sustainability matters
To prevent, mitigate and remediate actual and potential material impacts, the CSSF will also focus on the disclosure requirements on policies and actions.
Policies adopted to address material IROs
Issuers should include a description of the key contents and scope of any adopted policy (including affected stakeholders, when applicable). References to any third-party standards or initiatives to be complied with by the issuers in connection with any adopted policy should also be indicated. Significant changes to any adopted policy should be explained.
Actions and resources
The CSSF reminds that the objective of disclosing actions and resources during the reporting year as well as the ones planned for the future (including their scope and related time horizons, their expected outcome and, where relevant, how their implementation contributes to the achievement of the policy objectives and targets) is to provide understanding of the key actions taken and/or planned.
Details and amounts on the current and future financial, as well as other resources allocated to the actions should also be provided by the issuers, in case those resources are significant.
Presentation of policies and actions
The CSSF also recalls that, when a single policy or same actions address several interconnected sustainability matters, issuers should disclose the required information under one topical ESRS, and cross refer it under the other topical ESRS to avoid repeating the information.
Disclosure of information related to policies and actions should be structured as prescribed by the ESRS.
In case no policies and/or actions related to a material sustainability matter were adopted by the issuers, it should be clearly disclosed in the sustainability report.
- Other considerations
- 1. Priority 1: ESEF reporting
When examining the 2025 annual financial reports subject to ESEF requirements, the CSSF will focus, inter alia, on common ESEF markup errors affecting the issuers’ statement of cash flows (as further detailed in the ESMA’s public statement on the 2025 ECEPs).
- 2. Priority 2: General considerations
Considerations on IFRS 18
The CSSF recommends issuers to be prepared to implement IFRS 18 (Presentation and disclosure in financial statements) by familiarising themselves to this standard to assess its impact on their financial statements, communication and reporting systems, as it is expected to be endorsed in the course of 2026 and should thus become effective as from 1 January 2027.
Considerations on Taxonomy disclosures
The CSSF finally highlights that, on 4 July 2025, the European Commission adopted a delegated regulation, amending (i) the Commission Delegated Regulation (EU) 2021/2178 as regards the simplification of the content and presentation of information to be disclosed concerning environmentally sustainable activities and (ii) the Commission Delegated Regulations (EU) 2021/2139 and (EU) 2023/2486 as regards simplification of certain technical screening criteria for determining whether economic activities cause no significant harm to environmental objectives, with the objective to reduce the administrative burden for companies and simplify the application of the EU Taxonomy Regulation[5] (the “Upcoming Delegated Act”).
The Upcoming Delegated Act will enter into force after the end of the ongoing scrutiny period, in case no objections are raised by co-legislators during this period.
The CSSF encourages issuers to apply the revised rules from 2026 (for financial year 2025) but still leave the option to apply the previous rules to that reporting cycle.
[1] https://www.ifrs.org/content/dam/ifrs/supporting-implementation/agenda-decisions/2024/disclosure-revenues-reportable-segments-jul-2024.pdf
[2] https://www.ifrs.org/issued-standards/list-of-standards/ifrs-8-operating-segments
[3] https://www.ifrs.org/issued-standards/list-of-standards/ias-1-presentation-of-financial-statements
[4] https://www.cssf.lu/en/Document/csrd-first-year-of-reporting-by-issuers
[5] https://webgate.ec.europa.eu/regdel/#/delegatedActs/2859