On October 16, 20109, the German professional association of investment professionals (DVFA e.V.) commented on the draft bill for the further implementation of the transparency directive – amending directive with regard to a uniform electronic format for annual financial reports.
The objectives of the EU directive to improve the European capital market and the associated automation require valid data from the issuer; this cannot be achieved without technically enforced compliance with submission and validation rules!
Excerpt from the opinion of the DVFA e.V., Corporate Analysis Commission: “We therefore propose within the framework of the law: to authorize the Federal Gazette … to issue regulations on the “technical submission and validation rules” to be observed by the issuers. § 328 HGB, according to which these “technical submission and validation rules” must be complied with in the context of disclosure, as well as the right and obligation to impose the right and obligation on the Federal Gazette in § 329 HGB to check the ESEF data for compliance with the submission and validation rules and to reject them if necessary. “
DVFA e.V., Opinion on the draft bill of the Federal Ministry of Justice and Consumer Protection and the Federal Ministry of Finance – Draft of a law for the further implementation of the Transparency Directive – Amendment directive with regard to a uniform electronic format for annual financial reports from October 16, 2019