[ESMA31-62-1258 Prospectuses Q&A 8.5]

No.

When new audited annual financial statements are published during the period of validity of a base prospectus or a non-equity prospectus, contrary to the situations specified in Article 18(1)(a) of Commission Delegated Regulation 2019/979, there is no automatic trigger to publish a supplement in such a scenario.

Without prejudice to the powers of the home competent authority, the issuer should make its own materiality assessment pursuant to Article 23(1) of the PR to determine whether a supplement is necessary or not.