Share on LinkedIn Share on Twitter Share on Facebook ESEF Reporting in 2H 2025: What UK and European Listed Companies Need to Know Share on LinkedIn Share on Twitter Share on Facebook As we enter the second half of 2025, the regulatory landscape for financial and sustainability reporting continues to evolve. For UK and EU-listed companies, the European Single Electronic Format (ESEF) and its UK variant (UKSEF) remain central to annual reporting obligations. With updated taxonomies, growing ESG disclosure expectations, and increased scrutiny from regulators, now is the time for finance leaders to reassess their ESEF readiness. 1. ESEF and UKSEF: Where We Are Now Since 2021, ESEF has been mandatory for issuers on EU-regulated markets, requiring annual financial reports (AFRs) to be submitted in XHTML format with iXBRL tagging for consolidated financial statements. In the UK, the Financial Conduct Authority (FCA) has also implemented a similar framework through both ESEF and the UK Single Electronic Format (UKSEF), supplemented by additional guidance tailored to UK-specific reporting needs. As of 2025, the ESEF taxonomy has been updated once again, and the FCA’s National Storage Mechanism (NSM) has been upgraded to support the latest version. Companies must now ensure they are using the correct taxonomy and fully understand the technical filing requirements, including the structure of XBRL report packages and the submission process via the NSM. Another major development is the introduction of Provision 29 in the UK Corporate Governance Code 2024, which places new emphasis on internal controls related to digital reporting. This includes compliance with XBRL tagging and both ESEF and UKSEF standards. Provision 29, applicable for accounting periods beginning on or after 1 January 2026, elevates digital reporting controls to a “material” level—requiring boards to treat them with the same rigor as other financial reporting controls. The FCA’s Disclosure Guidance and Transparency Rules (DTR 4.1.15R–4.1.18R) continue to mandate ESEF/UKSEF compliance. However, the FCA has highlighted persistent issues with low compliance rates and tagging accuracy, prompting many companies to reassess their internal digital reporting controls in light of the new governance expectations. 2. ESG Reporting and the Rise of Dual Taxonomies A significant development in 2025 is the growing integration of ESG disclosures into the annual reporting process. EU companies are preparing for the Corporate Sustainability Reporting Directive (CSRD), which will require many additional entities to report using European Sustainability Disclosure Standards (ESRS). Meanwhile, in the UK, a public consultation was launched in June 2025 regarding the Exposure Draft of UK Sustainability Reporting Standards (UK SRS) with companies expected to align with these standards in due course. This divergence means companies operating across jurisdictions must prepare for dual compliance—navigating ESEF requirements while managing ESG disclosures in line with evolving sustainability standards. 3. Other Common ESEF Challenges in 2025 Despite several years of ESEF implementation, many companies continue to face recurring challenges in digital reporting. Key operational challenges include: Late-stage tagging: Applying iXBRL tags after the report design is finalized often leads to errors and delays. Version control issues: Managing multiple document versions across teams increases the risk of inconsistencies. Limited internal expertise: iXBRL tagging and taxonomy mapping require specialized knowledge that many in-house teams lack. ESG integration: Combining financial and non-financial disclosures into a single structured report remains a complex task. To provide a more comprehensive view of current digital reporting challenges, we’ve summarized key issues identified in two recent regulatory reviews: the FRC’s April 2025 Structured Digital Reporting Insights Report and the ESMA 2024 Corporate Enforcement Report. These findings offer insights into common pitfalls and compliance expectations for listed companies across the UK and EU. Tagging Issues Highlighted by the FRC (April 2025 Review) The FRC’s 2024/25 structured digital reporting insights report identified several persistent tagging problems among UK-listed companies: Unnecessary custom tags/extensions: These complicate data analysis and may be ignored or misinterpreted by users. Omission of mandatory tags: Missing key tags (e.g., ‘Principal place of business’, Domicile of entity’) reduces report completeness. Incorrect anchoring of extensions: Custom tags are often not properly linked to standard taxonomy elements. Misapplication of accounting standards: Tags sometimes fail to reflect the correct accounting meaning or standard. Incorrect sign or scale: Numerical values are occasionally reported with the wrong sign or magnitude. Design and usability issues: Poor formatting and lack of accessibility (e.g., not publishing the file on the company website) limit the report’s usefulness. Read more Key Issues from ESMA’s 2024 Corporate Reporting Enforcement Report ESMA and national enforcers across the EU also highlighted several critical compliance concerns in the 2024 Corporate Reporting Enforcement Report: No financial data as images: Financial information must not be embedded as images in ESEF reports. Images should only be used for branding, layout, or visual elements. ESEF is the official AFR: Only the ESEF-formatted Annual Financial Report (AFR) is considered the official version for regulatory purposes. PDF versions must include a disclaimer stating they are not the official AFR. Avoid discrepancies between ESEF and PDF versions: Inconsistencies between the ESEF and PDF versions of AFRs were frequently observed. Issuers must ensure alignment and have controls in place to prevent such discrepancies. Timely publication: AFRs in ESEF format must be published within four months of the financial year-end. If other formats are published earlier, issuers must justify this based on legal or regulatory grounds. Auditor’s opinion availability: Where required, the auditor’s opinion on the ESEF AFR must be publicly available at the time of publication. 4. Preparing for 2025 Filings As regulatory expectations around digital reporting continue to rise, listed companies must take a proactive and structured approach to preparing their 2025 Annual Financial Reports (AFRs). Early preparation is essential—not only for financial disclosures but also for integrating ESG data into a cohesive, structured report. Companies should ensure their reporting tools are updated to support the latest 2024/2025 ESEF taxonomies and engage cross-functional teams—including finance, legal, ESG, and investor relations—early in the process. Testing filings using the National Competent Authority’s submission tools can help identify issues before final submission, reducing the risk of non-compliance. Given the complexity of iXBRL tagging and evolving regulatory requirements, many companies are also turning to external providers for expert support that combines both technology and regulatory insight. In parallel, digital reporting controls are now explicitly considered material under governance frameworks like Provision 29. This includes ensuring tagging accuracy, compliance with XHTML and iXBRL formats, robust submission processes via the FCA’s digital gateway, and effective change management for taxonomy updates. Maintaining clear audit trails of tagging decisions and validations is also critical, as these controls are now subject to board-level scrutiny. Why ActiveDisclosure by DFIN is the Right Fit While many solutions offer basic tagging tools, ActiveDisclosure by DFIN is a comprehensive platform built specifically for the evolving needs of listed companies. As ESEF and ESG reporting requirements grow more complex, ActiveDisclosure provides the technology, expertise, and support to help you stay ahead. What Sets ActiveDisclosure Apart Built-in iXBRL Tagging Reduce manual effort with intelligent automation that tags both your financial statements and full annual report in line with the latest ESEF taxonomy. Excel Linking Maintain consistency and accuracy across your report with dynamic Excel linking—ensuring that updates to source data are reflected instantly throughout your document. Real-Time Collaboration Enable seamless collaboration across finance, legal, sustainability, investor relations, and external advisors. Draft, edit, and review in real time—on a single, secure platform. Built-in Compliance Checks Ensure your reports meet all regulatory requirements with automated validations and error detection—reducing risk and saving time. Future-proof your reporting for UK SRS/ISSB Taxonomy/CSRD ESRS Taxonomy Tag your ESG disclosures in accordance with the ISSB taxonomy/CSRD ESRS taxonomy, and UK Sustainability Disclosure Standards (UK SDS), ensuring alignment with emerging sustainability frameworks. 24/7/365 Expert Support Gain access to the largest team of XBRL experts in the industry. Our regulatory specialists are available around the clock to support your team through every step of the process. Transparent Pricing No hidden fees. No surprises. Just clear, predictable pricing that aligns with your reporting needs. Whether you're preparing your first structured report or looking to streamline a complex, multi-jurisdictional process, ActiveDisclosure delivers the clarity, control, and compliance you need. Get Ahead of Your 2025 Filing Don’t wait until year-end. Schedule a demo today to see how ActiveDisclosure can simplify your ESEF and UKSEF reporting. Patricia Myles Global Regulatory Compliance and Strategy Consultant Related Products and Solutions Knowledge Hub Page (Insight) ActiveDisclosure℠ Collaborate easily. Simplify reporting. Learn More Related Content White paper XBRL Digital Tagging for CSRD & ESRS: How Companies Can Meet the EU’s New Digital Reporting Requirements   Knowledge Resources CSRD Readiness: Key Steps and Challenges for Compliance