Partner
Auditor, Certified Sustainability Assurance Expert FS, Certified Tax Advisor, Graduate in Business Administration, IT-Auditor IDW
ESMA & BaFin: Audit Priorities for Fiscal Year 2025
- ESMA's audit priorities are divided into IFRS financial statements, sustainability & ESEF reporting
- BaFin focuses on the impact of the changing macroeconomic environment
Thomas Rattler
Partner
Auditor, CPA, Graduate in Business Administration
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ESMA and BaFin have published their audit priorities for 2025. For capital market-oriented companies, the focus is on geopolitical risks, segment reporting and specific aspects in sustainability and ESEF reports. BaFin also emphasizes the balanced presentation of the changing macroeconomic environment – characterized by energy prices, trade restrictions, AI and regulation – in the management report.
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ESMA Audit Priorities
On October 14, 2025, the joint audit priorities of the European Securities and Markets Authority (ESMA) and the national supervisory authorities of the European Economic Area for the 2025 financial year were published. These are particularly relevant for capital market-oriented companies and their supervisory boards and auditors when preparing and auditing the 2025 IFRS financial statements.
The audit priorities are divided into the following areas:
- IFRS financial statements
- Geopolitical risks and uncertainties
- Segment reporting
- Sustainability reporting
- Materiality considerations in ESRS reports
- Scope and structure of the report
- ESEF reporting
- Common errors in the cash flow statement
In addition, ESMA formulates general considerations and references to other topics, which, however, do not represent audit priorities. These include, for example, the connectivity of financial and sustainability reporting and Alternative Performance Measures (APMs).
Audit priorities of the financial supervisory authority BaFin
The Federal Financial Supervisory Authority (BaFin) also published its 2025 audit priorities on November 27, 2025.
As part of the 2026 balance sheet control, BaFin will focus on how companies present the effects of the changing macroeconomic environment in their management reports on the 2025 annual and consolidated financial statements.
The economic situation is currently characterized by trade restrictions, unstable energy and raw material prices, structural upheavals and technological change. The increasing use of AI, globalized value chains and new regulatory requirements create additional uncertainty.
With the management report, the company management presents the current situation and the expected future development of the company and how it deals with these challenges. Companies must paint a comprehensible picture and analyze the macroeconomic influencing factors in a balanced and comprehensive manner.
BaFin sees potential sources of error above all in inadequate data bases, overly optimistic forecast assumptions or the tendency not to clearly highlight or relativize possible negative developments. Contradictions between internal control logic and external reporting should also be avoided.
The management report is not only a legally required reporting element, but also a central communication instrument. Its quality and reliability decisively shape the image of the company’s economic performance and resilience in an environment characterized by change.
In addition, BaFin also takes into account the audit priorities published by ESMA in its sample audits of the 2025 financial year.