The European Single Access Point (ESAP) is part of a broader EU effort to improve the accessibility and transparency of information in financial markets. It will provide centralised access to publicly available information relevant to financial markets and sustainability that is currently scattered across many different sources. ESAP will be implemented in phases, with Phase 1 information being reported from July 2026, Phase 2 from January 2028 and Phase 3 from January 2030.  ESAP will be maintained by the European Securities and Markets Authority (ESMA).

The Financial Supervisory Authority (FIN-FSA) will act as one ESAP collection body, whose task is to receive information falling within its area of responsibility, check its technical and structural quality, and submit the information to ESAP.

In Phase 1, information in accordance with the Short Selling Regulation (EU) 236/2012, the Prospectus Regulation (EU) 2017/1129 and the Transparency Directive 2004/109/EC will be submitted to ESAP. The FIN-FSA will act as the collection body with regard to the Short Selling Regulation and the Prospectus Regulation, while for information under the Transparency Directive, the collection body will be the Helsinki Stock Exchange, which maintains the Officially Appointed Mechanism (OAM) in Finland. Information concerning notifications of shareholders’ major holdings, for example, will therefore go to ESAP through a stock exchange release published by the issuer and submitted to the OAM.  There will be no changes to the reporting process for notifications of major holdings; notifications will continue to be submitted to the FIN-FSA by email.

The information submitted to ESAP must meet the format requirements set for it, i.e. it must be in a data extractable format or machine-readable format, depending on the requirements of the regulation in question. In addition, various metadata, such as the entity’s LEI code, size category and sector, must accompany the information. Format and metadata requirements improve the usability and comparability of the information.  

This article focuses on information falling within the scope of Phase 1 of ESAP, for which the FIN-FSA will act as the collection body. Other ESAP reporting sets or future phases are not discussed in this context.

Reporting process

Short-selling notifications and prospectus register notifications are reported via the FIN-FSA’s e-services, and this will not change with the introduction of ESAP. The notification forms in e-services have been modified to some extent and validations have been added to fields to ensure smooth transfer of information to ESAP. For this reason, it is important when making a notification to start with a new form and not use a previously submitted form as the template for a new notification. This applies, in particular, to the prospectus register notification form, to which changes resulting from Listing Act regulations have been added in addition to the ESAP changes. Special care must also be taken when making a notification.

The FIN-FSA will submit the information reported to it to ESAP, where automated validations ensure that the information submitted complies with the requirements. If there are errors in the reported information and ESAP rejects a submission because of this, the reporter must correct the incorrect information. The FIN-FSA will send a notification to the reporter in such cases.

Timeline

The FIN-FSA will start collecting information in accordance with ESAP requirements in June 2026, when the revised e-services forms are introduced. Information will begin to be submitted to ESAP in July 2026, when Phase 1 of ESAP starts. The information collected for ESAP will be made publicly available in July 2027.

Notification of short positions

There have been minor changes to the form used to make notifications of short positions. The layout of certain fields has been adjusted to make form completion more logical, and the LEI code of the position holder has become mandatory. A check against the interface has been added to the form to ensure the validity of the LEI code on the position date and to retrieve the official name and country of registered office of the position holder. Corresponding changes have also been made to the Excel form used for reporting in exceptional cases when access to the e-services system is unavailable for some reason.

Although information is only submitted to ESAP on positions that reach the publication threshold¹, which the FIN-FSA also publishes on its website, all positions that reach the reporting threshold² must still be reported to the FIN-FSA.

Making a prospectus register notification

In addition to the ESAP requirements, Listing Act changes have been made to the prospectus register notification form. These include, for example, the new types of prospectuses (EU Follow-on prospectus and EU Growth issuance prospectus) and sustainability information. The layout of some fields on the prospectus register notification form has also been adjusted to make form completion more logical. The system checks the issuer’s LEI code against the interface, which ensures the validity of the LEI code at the time in question. The system also retrieves the issuer’s official name based on the LEI code and populates it on the form. The same check and search against the interface is also performed in other fields on the form where the LEI code is provided.

An Additional information section has been created on the form for mandatory ESAP metadata. Information on the issuer’s size³ and industry sector⁴ as well as information on whether the notification contains personal data⁵ must be provided in this section.

More information about ESAP

• ESMA's ESAP website

For further information, please contact:

• Riikka Kantola, Specialist, riikka.kantola(at)fiva.fi, tel. +358 9 183 5398
• Ossi Eräkivi, Chief Specialist, ossi.erakivi(at)fiva.fi, tel. +358 9 183 5262

¹ 0.5% of the issued share capital

² 0.1% of the issued share capital

³ Large undertakings or small and medium-sized enterprises, as defined in: (EU) 2025/1338 Table 2 and (EU) 2017/1129 Article 2, point (f)

⁴ Either financial sector industry listing: (EU) 2025/1338, Table 3 or a listing of other industries: (EU) 2023/137, Annex (NACE classification).

⁵ (EU) 2016/679 Article 4(1) (GDPR)