[ESMA32-51-370 APM Q8 - last revised: 12/07/2017]

Yes. Paragraph 31 of the APMs Guidelines applies to APMs related to quarterly financial figures included in ad-hoc disclosures published in accordance with article 17 of MAR even when the issuer is not required to publish quarterly financial statements in accordance with the TD. Please refer to question ESMA_QA_1870 (historic reference ESMA32-51-370 APM Q4).

The following example illustrates how issuers may comply with provisions included in paragraph 31 and 32 of the APMs Guidelines:

An issuer publishes in ad-hoc disclosures in accordance with article 17 of MAR an ‘adjusted EBITDA’ for Q3 and the subtotal published historically in its financial statements is an EBITDA (most directly reconcilable line item included in the financial statement). As the Q3 ‘adjusted EBITDA’ is an APM, the issuer should define and reconcile the Q3 ‘adjusted EBITDA’ to the Q3 EBITDA as if that figure had been included in financial statements.

[16/02/2026] This is the revised Q&A version which will be effective from 1 January 2027: 

Answer: Yes. Paragraph 31 of the APMs Guidelines applies to APMs related to quarterly financial figures included in ad-hoc disclosures published in accordance with article 17 of MAR even when the issuer is not required to publish quarterly financial statements in accordance with the TD. Please refer to question 4.

The following example illustrates how issuers may comply with provisions included in paragraph 31 and 32 of the APMs Guidelines:

An issuer publishes in ad-hoc disclosures in accordance with article 17 of MAR an ‘adjusted EBITDA’ for Q3 and the subtotal published historically in its financial statements is an EBITDA Operating result (most directly reconcilable line item included in the financial statement). As the Q3 ‘adjusted EBITDA’ is an APM, the issuer should define and reconcile the Q3 ‘adjusted EBITDA’ to the Q3 EBITDA Operating result as if that figure had been included in financial statements.