ESEF (iXBRL) vs. HGB-XML: which electronic disclosure affects whom?
There are two electronic disclosure regimes, both filing to the Unternehmensregister, but affecting different companies and formats. This post clarifies which regime applies to whom — and where Uregistry fits in.
Two regimes, one Unternehmensregister
Both ESEF reporting and HGB-XML disclosure file to the Unternehmensregister, operated by Bundesanzeiger Verlag. They rest on different legal bases, affect different companies, and require different formats.
Anyone disclosing electronically must first clarify which regime they fall under – only then can the correct format be chosen.
What is ESEF?
ESEF (European Single Electronic Format) is a single electronic reporting format prescribed at EU level. It is based on the Transparency Directive 2004/109/EC and the Delegated Regulation (EU) 2019/815 (ESEF RTS).
The format is XHTML with embedded inline-XBRL tags (iXBRL): the same report is both human-readable and machine-readable. The tagging covers the IFRS financial statement data.
Who does ESEF affect?
ESEF affects issuers whose securities are admitted to trading on a regulated market in the EU — i.e. capital-market-oriented or listed companies (§ 264d HGB; Inlandsemittenten under WpHG § 114).
Typical HGB corporations without a stock-market listing are not affected: GmbH, non-listed AG, UG (haftungsbeschränkt), GmbH & Co. KG. For them the HGB-XML disclosure under §§ 325 et seq. HGB applies.
What is the HGB-XML disclosure (DiRUG)?
HGB disclosure under §§ 325 et seq. HGB affects corporations such as GmbH, AG, UG, GmbH & Co. KG and other legal forms. The filing format is XML, not iXBRL.
Since the DiRUG (Act Implementing the Digitalisation Directive), financial statements for financial years beginning after 31 December 2021 must be transmitted to the Unternehmensregister; for financial years beginning before 01 January 2022 the Bundesanzeiger is the disclosure medium.
ESEF vs. HGB-XML compared
The overview below shows the key differences between the two regimes.
| Aspect | ESEF (iXBRL) | HGB-XML (DiRUG) |
|---|---|---|
| Affected companies | Capital-market-oriented issuers (§ 264d HGB) | Corporations without a listing (§§ 325 et seq. HGB) |
| Format | XHTML with inline-XBRL (iXBRL) | XML |
| Legal basis | Transparency Directive 2004/109/EC + Delegated Regulation (EU) 2019/815 | HGB §§ 325 et seq. + DiRUG |
| Filing destination | Unternehmensregister (as OAM) with forwarding to the EU access point | Unternehmensregister (as disclosure medium) |
| Documents | Annual financial report (IFRS, tagged) | Annual financial statements and management report under HGB |
| Deadline | 4 months after balance-sheet date | generally 12 months after the balance sheet date |
Where does Uregistry's scope lie?
Uregistry currently supports HGB-XML disclosure (DiRUG): existing accounting documents from PDF, Excel or Word are turned into validated XML.
Preparation of ESEF reports (iXBRL) is planned. If you have an ESEF requirement, please get in touch — we will keep you informed about the current status.
FAQ
Does ESEF also affect GmbHs or non-listed AGs?
No. ESEF (iXBRL) affects capital-market-oriented issuers whose securities are admitted to a regulated market. Non-listed capital companies such as GmbH or non-listed AG fall under the HGB-XML disclosure (DiRUG).
Do ESEF and HGB-XML have to be submitted in different formats?
Yes. ESEF requires XHTML with embedded inline XBRL tags (iXBRL); the HGB-XML disclosure requires XML. Both routes lead to the Unternehmensregister but are based on different legal bases.
Does Uregistry support ESEF (iXBRL)?
Uregistry currently supports the HGB-XML disclosure (DiRUG). Preparation of ESEF reports is planned; there is no fixed date yet. If you have ESEF needs, please get in touch.
Without liability. Not legal advice. Verify binding requirements with the competent bodies or a qualified legal and tax advisor.