The supervisor has already told you what it will check

Most risks in financial reporting arrive without warning. This one comes with a published agenda.

On 13 October 2026, the European Securities and Markets Authority (ESMA) set out its European Common Enforcement Priorities for 2026 annual reports. National enforcers, such as Finanssivalvonta in Finland, use these priorities when they select and examine reports next year. In other words, the topics on this list are where the questions will come from.

The stakes are not theoretical. In its report on 2025 enforcement, ESMA states that European enforcers examined the IFRS financial statements of 628 issuers, and 41 per cent of those examinations led to enforcement action. Alternative performance measures alone were examined 434 times, and 16 per cent of those examinations led to action.

What is on the 2026 list

For IFRS financial statements, ESMA highlights two themes: how geopolitical risks and uncertainties are reflected in the financial statements, and restructuring provisions and debt restructuring.

For sustainability statements, the focus is on the materiality assessment and on connected information: a clear line from impacts, risks and opportunities to policies, actions, targets and metrics.

For ESEF, the digital format of the annual financial report, ESMA points to common filing errors in the statement of changes in equity.

Why the risk is rarely in the note itself

In our experience, the finance team usually gets the note right. The accounting has been discussed with the auditor, the numbers reconcile, the disclosure follows the standard.

The risk sits elsewhere: the same topic is told in four or five places, by different authors, at different times.

Take geopolitical risk. The CEO's review says the impact was limited. The risk section of the board of directors' report lists it as a key risk. The impairment note runs a sensitivity analysis on assumptions that the outlook section does not mention. The English version softens a caveat that the Finnish version keeps. Each paragraph is defensible on its own. Read together, they tell a supervisor that the company has not made up its mind.

Restructuring follows the same pattern. A programme is announced in a spring stock exchange release with one cost estimate and one timeline. By year-end, the provision, the CEO's review and the alternative performance measures each describe it slightly differently. Debt restructuring adds another layer: the terms were described in an interim report, and the annual report now has to tell the same story with the accounting outcome attached.

The ESEF point is the most technical, and in practice the one most likely to fall between chairs. Tagging is often done late, by a separate team or a service provider, on a version of the report that may still change.

Five questions to ask before February

1. Does every mention of geopolitical risk tell the same story, in the CEO's review, the risk section, the notes and the outlook, and in every language version?
2. Can a reader follow each restructuring from the first stock exchange release to the provision in the balance sheet, with consistent amounts and timing?
3. Are debt restructurings described the same way as in your interim reports, and is the accounting outcome explained?
4. Does each material sustainability topic link to a policy, action, target and metric, with the same figures wherever they appear in the report?
5. Does the statement of changes in equity in your ESEF filing match the human-readable report line by line, and was it tagged from the final version?

This is cross-reading work

None of these questions requires a new accounting judgement. They require someone to read the whole report against itself, against what the company has published before, and across languages. That is exactly the work that gets squeezed in the last week before publication, when everyone is busy with their own section.

It is also the work Release Proofing was built for. Our agents recompute every figure, compare every claim with the company's disclosure history and compare language versions claim by claim. A person verifies every finding against the source page before it is delivered, and the decisions stay with you.

Start with the report you have already published

The themes on ESMA's list rarely appear for the first time in the annual report. Geopolitical uncertainty, restructuring and refinancing are usually already in your interim reports. An inconsistency found in the Q3 report now can be fixed in the annual report. One found by the supervisor next year has to be explained.

We offer a free check of your last published report, so you can see what a cross-read finds before you share anything unpublished.