Are Hyperlinks Allowed in ESEF Submissions?
[February 2023 Update] Update based on Guidance 2.5.1 of the ESEF Reporting Manual [August 2022]:
Since ESEF is a format requirement and is not expected to impact the “human readable layer” of a report, this guidance should not be seen as limiting the inclusion of links to external websites, to other documents or to other sections of the annual financial report. In case of inclusion references to e-mail addresses, these should be provided in form of a non-linked text, i.e. stripped of the ‘mailto’ link.
Hyperlinks, with the exception of mailto hyperlinks, are allowed.
[Original Content] However, this is not as simple as a yes or no answer.
In ESMA’s Reporting Manual Updates released in July 2021, Guidance 2.5.1 was updated and the recommended violation of “referencesPointingOutsideOfTheReportingPackagePresent” was removed.
The guidance now reads “...this guidance should not be seen as limiting the inclusion of links to external websites, to other documents or to other sections of the annual financial report.”. The change allows external hyperlinks, while still restricting users from referencing items that are not human readable (e.g. other executable code).
The XBRL error for external hyperlinks will no longer be included in XBRL validations.
However, there are two additional complications for this:
- Regulator implementation
- Individual financial statements
Regulators have the choice of whether to follow ESMA’s recommendation and some regulators may still restrict users from including external hyperlinks in their submissions. Check with your regulator to ensure they are accepting external hyperlinks in upcoming submissions. Germany will not be accepting external hyperlinks.
In these updates, additional guidance was added for individual financial statements and standards other than IFRS reported in XHTML. Guidance 4.1.6 refers to the standalone XHTML document (those not included in the submission package for consolidated financials), which “must be a standalone, self-explanatory and complete set of information”.
This guidance recommends that “software firms include rules in their tools ensuring: XHTML documents MUST NOT contain references pointing to resources outside the reporting package”. If such references are found, a violation message is recommended to be used to let the user know about external references”.
How Can I Review Hyperlinks?
On ESEF document types, a warning will be triggered in the Doc Health Checks for hyperlinks. This is a warning to bring the user’s attention to any instances of hyperlinks for review. Depending on the hyperlink type and purpose of the document, these do not have to be removed; it is up to the user and where the hyperlink points to (remember: internal hyperlinks to different sections of the document are always allowed!).
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