Must modified white papers comply with machine-readable format requirements?
Modified white papers: XBRL format
Section titled “Modified white papers: XBRL format”| Authority | ESMA |
| Q&A ID | ESMA_QA_2845 |
| Status | Answer Published |
| Published | 12 May 2026 |
| Legal basis | Reg. (EU) 2024/2984 |
| Source | ESMA Q&A |
Question
Section titled “Question”When a reporting entity notifies a modification of a white paper originally submitted before the Commission Implementing Regulation (EU) 2024/2984’s entry into application on 23 December 2025, must the modified white paper be submitted in machine-readable format?
Answer
Section titled “Answer”Yes. Since the entry into application of the formatting requirements on 23 December 2025, in the case(s) where a reporting entity notifies a modified white paper, and the original white paper was notified and published prior to the requirement, the reporting entity should prepare the modified white paper in the machine-readable format.
However, this does not mean that reporting entities who notified and published a white paper prior to the entry into application of the requirement on 23 December 2025 are automatically compelled to now submit a modified white paper. This guidance only applies when a ‘significant new factor’ triggers the white paper modification requirement. In other words, the entry into application of the ITS does not constitute a ‘significant new factor’.
Source: ESMA original document