What is ESAP?
The European Single Access Point (ESAP) will be a ‘single point of access’ platform for public financial, non-financial and sustainability-related information about EU companies and financial products.
ESMA is due to establish and operationalise ESAP by mid-2027.
The EU legislative package establishing the ESAP amends a range of EU legislation in the areas of capital markets, financial services and sustainability to facilitate the provision of information to ESAP, which necessitates amendments to existing domestic transposing legislation.
Irish Implementing Measures
The Minister for Finance made three statutory instruments (the Regulations) on 10 February 2026 to give effect to the ESAP in Ireland:
- European Union (European Single Access Point) Regulations 2026 (S.I. No. 32 of 2026) – establishes the foundational framework and designates the Irish collection bodies.
- European Union (European Single Access Point) (No. 2) Regulations 2026 (S.I. No. 33 of 2026)
- European Union (European Single Access Point) (No. 3) Regulations 2026 (S.I. No. 34 of 2026)
- S.I.s 33 and 34 amend primary legislation and various Irish statutory instruments to facilitate the provision of information to the ESAP.
Key Obligations for In-Scope Entities
While the Regulations do not impose new requirements to disclose additional information, they create new procedural obligations:
- Entities must submit information to designated collection bodies at the same time as publishing it.
- Information must be submitted in data extractable format or, where specified, in machine-readable format.
- Information must be accompanied by prescribed metadata including entity name, legal entity identifier (LEI), size category, industry sector (where applicable), type of information, and whether personal data is included.
Designated Collection Bodies
The following have been designated as collection bodies in Ireland:
- the Central Bank of Ireland (the Central Bank)
- the Registrar of Companies (CRO)
- the Irish Auditing and Accounting Supervisory Authority (IAASA)
- the Irish Takeover Panel
- the Pensions Authority.
Scope of Amendments
| Sector | Collection Body | Key Amendments | Commencement |
| Corporate Reporting | CRO (Accounting Directive, certain Audit Directive and Shareholder Rights Directive matters)
IAASA (Audit Directive Article 30c, Audit Regulation Article 13) Central Bank (institutional investors, asset managers, proxy advisors under Shareholder Rights Directive) Pensions Authority (IORPs under Shareholder Rights Directive) |
Amendments to the Companies Act 2014 regarding transmission of information under the Accounting Directive, Audit Directive, Audit Regulation and Shareholder Rights Directive | 10 January 2028 (Obligations under Accounting Directive, Shareholder Rights Directive)
10 January 2030 (Obligations under Audit Regulation) |
| Capital Markets | Central Bank | Amendments to the Irish Market Abuse Regulations and the Irish Prospectus Regulations regarding transmission of information under EU MAR and the EU Prospectus Regulation | 10 July 2026 (Transparency obligations[1], Prospectus obligations)
10 January 2028 (Market abuse obligations) |
| Crypto Assets | Central Bank | Amendments to the Irish MiCA Regulations regarding transmission of information under MiCA
|
10 January 2030 |
| Public Takeovers | Irish Takeover Panel | Amendments to the Irish Takeover Regulations regarding transmission of information under Takeover Bids Directive | 10 January 2030 |
| Insurance and Reinsurance | Central Bank | Amendments to the Irish Insurance and Reinsurance Regulations and the Irish Insurance Distribution Regulations regarding transmission of information under Solvency II and the Insurance Distribution Directive (IDD) | 10 January 2030 |
| Investment Funds | Central Bank | Amendments to the Irish UCITS Regulations, the Irish AIFM Regulations, the Irish ELTIF Regulations, the Irish PRIIPS Regulations, the Irish Benchmarks Regulations, the Irish MMF Regulations, the Irish SFD Regulations regarding transmission of information under the UCITS Directive, AIFMD, the ELTIF Regulation, the PRIIPS Regulation, the Benchmarks Regulation, the MMF Regulation and SFDR | 10 January 2028 (UCITS, PRIIPS, Benchmarks, SFDR)
10 January 2030 (AIFMD, ELTIF, MMF) |
| Investment services and activities | Central Bank
|
Amendments to the Irish MiFID Regulations regarding transmission of information under MiFID II
|
10 January 2030 |
| Credit Institutions | Central Bank | Amendments to the Irish Capital Requirements Regulations regarding transmission of information under CRD IV
|
10 January 2030 |
| Pensions | Pensions Authority | Amendments to the Pensions Act 1990 regarding transmission of information under the SFDR Regulation and IORP II Directive | 10 January 2028 (SFDR obligations)
10 January 2030 (IORP II Directive)
|
Non-Compliance
The Regulations create various offences for non-compliance, including:
- Companies Act 2014: Failure to comply with ESAP submission requirements under the Accounting Directive will constitute a category 3 offence. Failure by a statutory auditor or audit firm to comply with ESAP submission requirements under the Audit Regulation will constitute a category 4 offence.
- Takeover Bids: Failure, without reasonable excuse, to submit information to the Irish Takeover Panel is punishable on summary conviction by a class C fine, imprisonment for up to 12 months, or both.
- Financial Services: Failure to comply with ESAP submission requirements under MAR, the Prospectus Regulation, MICA and MiFID II will constitute a contravention under the relevant Irish implementing regulations and will be subject to sanction by the Central Bank.
[1] S.I. No. 312 of 2025 (Transparency (Directive 2004/109/EC) (Amendment) Regulations 2025) amended the Irish Transparency Regulations regarding the transmission of information under the Transparency Directive.