Modified white papers: XBRL format

Q&A on 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

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?

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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’.

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Source: ESMA original document

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