ESMA’s 13 October statement makes liquidity disclosures and restructuring accounting part of its priorities for 2026 annual reports. The broader IFRS headings are geopolitical risks and uncertainties, and restructuring provisions and debt restructuring. The statement applies to issuers on European Economic Area regulated markets, with recommendations assessed for materiality and relevance.[1][2]
For listed brokers, investment firms and infrastructure providers, the financing picture can change even when headline debt barely moves. A maturity brought forward, a facility still awaiting approval or cash unavailable to the relevant entity can alter the practical funding position. Investors therefore need to connect the balance-sheet total to the dates and conditions on which money can actually be used.
Funding and restructuring issues in the 2026 priorities
| Area | What ESMA highlights |
|---|---|
| Maturity analysis | Use time bands that expose material repayment concentrations; include contractual principal and interest.Source 1 |
| Funding and cash | Distinguish committed financing from conditional plans; explain materially restricted cash.Source 1 |
| Restructuring provisions | A detailed formal plan must create a valid expectation through implementation or communication to those affected; provisions include direct restructuring expenditure, excluding ongoing costs.Source 1 |
| Debt modifications | Consider qualitative changes alongside IFRS 9’s 10% test when deciding whether changed debt requires recognition as a new liability.Source 1 |
The wider package also addresses sustainability materiality and connected disclosures, plus digital-reporting errors in the statement of changes in equity.[2]
Two earnings measures that failed scrutiny
A companion publication presents seven national enforcement decisions taken between October 2024 and January 2026. Two concern alternative performance measures, or APMs, used outside IFRS financial statements. These are newly published accounts of earlier decisions, rather than new October penalties against named firms.[3]
What the published APM cases demonstrate
| Case | Issuer’s approach | Enforcer’s conclusion |
|---|---|---|
| Management EBITDA in an IPO prospectus | Included future financing income from receivables sold shortly after recognition. | The issuer would never recognise that interest; the measure failed to explain faithfully the performance represented.Source 3 |
| A property developer’s underlying results | Excluded project write-downs but included proceeds from selling the related permit; also treated deferred-tax losses and gains differently. | Related negative and positive adjustments needed consistent treatment. The approach inflated the underlying measures.Source 3 |
The second case exposes a comparison problem that can survive a superficially clear reconciliation: remove a loss in one period, then keep the related recovery in another, and both periods’ adjusted results benefit. The issue is the consistency of the economic treatment over time.[3]
A clearer bridge from accounts to performance
For a firm explaining a refinancing, acquisition or operational overhaul, the practical task is to connect its account of the transaction with the resulting cash flows and performance measures. Calling a charge exceptional does not establish whether the operation is better funded or more profitable. ESMA’s cases show why the treatment of related gains and losses across periods matters.[3][1]
Sources & further reading
- Statement on the European common enforcement priorities for 2026 corporate reporting European Securities and Markets Authority · 13 Oct 2026 · Accessed 29 Oct 2026
- ESMA sets out 2026 European Common Enforcement Priorities European Securities and Markets Authority · 13 Oct 2026 · Accessed 29 Oct 2026
- 31st extract from the FRWG (EECS) database of enforcement European Securities and Markets Authority · 13 Oct 2026 · Accessed 29 Oct 2026