European Single Access Point: first steps in Dutch implementing process explained

The European Single Access Point (ESAP) will provide investors and other stakeholders with a centralised, EU wide platform that provides a free and single point of access to public financial and sustainability information about European companies. The ESAP is expected to go live no later than 10 July 2027. The platform will be managed by the European Securities and Markets Authority (ESMA).

On 20 July 2026, the ESAP Implementing Act was published in the Netherlands, amending Dutch law to accommodate the ESAP. This act amends the Financial Markets Supervision Act (FMSA), the Audit Firms Supervision Act, the Dutch Civil Code (DCC), the Trade Register Act, the Pension Act and the Mandatory Occupational Pension Scheme Act, with further decrees to follow to complete the implementation process. 

The Dutch Authority for the Financial Markets (AFM) (for FMSA purposes), the Dutch Central Bank (DNB) (for FMSA and pension disclosure purposes) and the Chamber of Commerce (KvK) (for DCC purposes) have been designated as collecting entities, which means that these supervisory authorities are responsible for collecting and forwarding relevant information to ESMA for inclusion in the ESAP. 

What does this mean for you? 

The Dutch implementing act is relevant for issuers in the short term. However, this act will also have implications for non-listed companies in scope of the CSRD (as narrowed by the recent EU Omnibus simplification package), audit firms, proxy advisers, shareholders and certain financial institutions in the future. We have set out the relevant timeline below. 

Importantly, the implementing act does not introduce new reporting obligations as such; the material information to be provided to the collecting entities remains the same as is currently required by law. There will also be no change in the collecting entity to which the relevant information must be submitted, this will continue to depend on the company and the information concerned.

The implementing act does require information within scope to be (i) submitted in either a machine-readable format as already required by law (as is currently the case for issuers' annual accounts), or another data-extractable format (such as PDF) and (ii) accompanied by certain metadata, such as the company's name, identifier and size, and other data depending on the type of information. 

Companies remain responsible for the accuracy and completeness of the information they submit to the collecting entities, which in turn are responsible for forwarding it to ESMA to publish it on the ESAP.

Timeline for entry into force

The entry-into-force decree connected to the Dutch implementing act provides for the new requirements taking effect in several phases.

21 July 2026: proposed annual accounts and related filings, MAR and prospectus disclosures, and information on share capital

From 21 July 2026, issuers will have to submit the following information in the right format and with the relevant metadata to the AFM: (i) notifications of changes in capital and voting rights, (ii) information relating to the Prospectus Regulation, including the publication of a prospectus, registration document or an information document on securities offered in connection with a takeover, merger or division, describing the transaction and its impact on the issuer, and (iii) regulated information as referred to in article 5:25m FMSA, including the applicable press releases, in relation to:

• the prepared (but not yet adopted) annual accounts, the management report, the responsibility statements, and the remuneration report (and, once the CSRD requirements apply, the related sustainability reporting), half-yearly reports and the report on payments to governments;
• changes in the rights attached to shares or other securities; and 
• inside information disclosures. 

In addition, from 21 July 2026, the requirements as to the correct format and accompanying metadata for ESAP purposes also apply to notifications of changes in the capital interest, voting rights or short positions held by shareholders and other persons entitled to vote, including the related follow-up notifications made once such a change has been processed in the AFM's register.

The AFM has indicated that it is currently adapting its portals for the submission of regulated information to accommodate the requirements. The AFM will inform the market once there is more clarity on this. We recommend monitoring AFM communications on the portal adaptations. The portals for submitting the other information types listed above are already in place, based on existing legislation.

10 January 2028: adopted annual accounts and related filings

The next tranche of filing requirements will become effective from 10 January 2028. In respect of financial years starting on or after 1 January 2027 (that is, FY2027 and onwards) issuers must submit their adopted annual accounts, including the management report and the other information within the meaning of article 2:392 DCC, to the AFM in accordance with ESAP requirements. In accordance with the existing system, the AFM must submit this information to the KvK. The KvK then provides the documents to ESMA for ESAP purposes.

In addition, under the newly introduced article 2:394a DCC, non-listed companies in scope of the CSRD (as narrowed by the recent EU Omnibus simplification package) will need to ensure that their annual reporting for FY2027 and onwards meets the ESAP format and metadata requirements when filed with the KvK. This includes the annual accounts and accompanying information as required by law, such as the management report, including the sustainability reporting, the report on payments to governments, and the related auditor's reports and assurance statements.

And finally, certain information provided by financial institutions is also in scope from 10 January 2028 (with the annual reporting relating to FY2027 and onwards). For UCITS this includes the prospectus, annual accounts, management report and other related information, and the half-yearly figures, all of which are to be provided to the AFM. For pension providers it covers the annual accounts, management report, remuneration report and statement of investment policy principles, to be provided to the DNB.

10 January 2030: remaining obligations 

The last set of filing requirements under the Dutch implementing act will take effect on 10 January 2030. These apply to several parties, including issuers, non-listed companies in scope of the CSRD, financial institutions and shareholders. The specific information to be submitted varies depending on the party in scope.

We will continue to monitor developments closely and keep you updated.