February 28, 2024. When preparing the DVFA (German Association of Investment Professionals) statement for the ESMA consultation on the ITS of the new European Single Access Point, I came across the following question (Q24):

“Do you think that information required at national level pursuant to Article 3(1) of the Transparency Directive (so-called gold plating) should be captured by certain specific types of information? Or would you prefer such information to be captured by one generic category, namely “Additional regulated information required to be disclosed under the laws of a Member State”?

My IFRS SLC working group at XBRL Europe dealt with this topic in 2009. Based on a detailed study by the IFRS working group of XBRL Germany, which I also led, we showed which information was reported from which German legal sources. This resulted in a proposal for EU wide uniform, comparable reporting of these topics.

We have assessed the negative consequences in the event that the issue would not be regulated uniformly across the EU in future. In the case of the highest level of detail with 300 to 400 information points for Germany alone, we may end up with around 10,800 non-comparable data points for 26 member states, which would be a nightmare.

And that’s pretty much exactly what ESMA is asking for 15 years later. The DVFA has incorporated this into its current statement to ESMA.

more information:

• Kesselmeyer, XBRL Europe – IFRS SLC Working Group, XBRL International Conference, Paris, June 26 2009
• Kesselmeyer, Harmonizing the EU-National Extensions of the IFRS-XBRL-Taxonomy – Is an EU extension of the IFRS taxonomy a solution?, 20th XBRL International Conference, Finance Track – Capital Markets, Rome, April 20-22, 2010