In addition to Portugal, letters of formal notice were also sent to Austria, Bulgaria, Croatia, Slovenia, Spain, Estonia, France, Italy, Latvia, Lithuania, the Netherlands, Poland, Romania, and Sweden for failing to fully transpose Directive (EU) 2023/2864.

The ESAP is part of a package of laws that will create a centralised system that will allow investors and other interested parties to find public information in a simple, comparable, and useful way, according to a Commission statement.

The legislative package provides for three phases of development of the ESAP, the first beginning in July 2026, when information published in accordance with European Union (EU) rules will begin to be communicated to the competent national authorities for inclusion in the ESAP.

For this first phase, Member States were required to transpose the amendments introduced to the Transparency Directive by July 10, 2025. The 15 Member States now have a two-month deadline to complete transposition and communicate their measures to the Commission.

In the absence of a satisfactory response, the Community executive may decide to issue a reasoned opinion.