by Judy Bard
Translators should be familiar with their requirements to ensure accuracy and compliance when working with corporate terminology. This can be a challenge! The European Union for example, has enacted a dizzying number of financial regulations Many of these regulations include templates for the disclosures that companies must make and it is important to adhere to this terminology.
The most recent example of newly implemented requirements that I encountered was the first-time application of European Sustainability Reporting Standards (ESRS) under the Corporate Sustainability Reporting Directive (CSRD) for companies’ 2024 reporting. The ESRS contain very specific environmental, social and governance topics that companies are required to cover in their sustainability statements.
Much of the wording can easily be found through the EUR-Lex site, which is home to EU directives, regulations, and other related documents in multiple languages. A number of other bodies also issue documents that translators may find useful. For example, the ESRS were developed by the private association EFRAG.
When I first began freelancing, I was unfamiliar with the large number of official documents that I might need to refer to when translating a regulatory-related document. Such a document will often refer explicitly to one regulation, which makes it easy to find on EUR-Lex. However, there are sometimes multiple related documents: directives, regulations, delegated acts, implementing acts, FAQs, etc., not to mention updated versions of each type of document.
Implementation of the EU Taxonomy was more or less the first time I realized the extent of the regulatory documentation I might need to consult to ensure the accuracy of my translations, and the large number of Taxonomy-related documents on EUR-Lex initially left me feeling overwhelmed by the amount of information I needed to absorb. I gradually built up my own reference library containing French and English PDFs of all these documents and learned which ones applied in different contexts.
Using the terminology found in these regulatory documents did at times present certain challenges when it came to translating companies’ universal registration documents. Rightly or wrongly, my inclination is generally to use the wording from the regulation, especially as found in the key performance indicator templates (see Commission Delegated Regulation (EU) 2023/2486). This is not always possible or can lead to confusion.
Let’s take, for example, the very common French term chiffre d’affaires. Every company translates this in its own way, from revenue to sales to turnover, while the KPI template uses turnover. For companies that have always preferred revenue, it did not seem ideal to use turnover in the context of the template and revenue everywhere else. However, in at least one instance, this was the client’s approach, so naturally we followed their instructions. Translating this term in two different ways can also introduce some confusion into the translation memory (TM) and means the translator must take great care when using inputs from the TM.
Turning to marketing documents, particularly for financial products and funds, translators also need to be aware of certain templates and requirements. The first one that many financial translators will be familiar with is the Key Investor Information Document (KIID) required under the UCITS directives.
Some documents are clearly labeled as such and the corresponding translations are easy to find. Others are not so immediately obvious. Earlier this year I edited the translation of a brochure for a specific financial product. It seemed to me that some of the text was likely to be a legal requirement and I began to do some research. I eventually discovered that this text matched some of the text from the Key Information Document (KID) for packaged retail investment and insurance products (PRIIPs). Although I had heard about the PRIIPs Regulation, I had somehow never been asked to translate any KIDs up until that point and had therefore never come across this particular phrasing.
Checking for this type of language not only saves the translator time, but also ensures compliance. Translators must, of course, carefully confirm the wording. Differences from EU texts can arise once directives are transposed into local legislation and it may not be clear whether the client is referring to local or EU laws. But it can be useful to have the “official” translation to work from and then adapt it as necessary.
Disclaimers are another area where it can be helpful to see if certain language is legally required. I recently translated some legal disclaimers as part of my translation of a monthly fund management report. My initial attempts at translating this legal language were not at all successful. While I was not able to find the original French in any regulation, after considerable research I did eventually find some language that matched my tentative translation on the UK Financial Conduct Authority’s website, which gave me some degree of confidence that I was on the right track.
In short, given how tightly regulated financial reporting has become, it is important for translators to think about verifying, in certain contexts, whether the text they are working on comes directly from a local regulation. We should follow the terminology used in certain disclosures to help ensure our clients’ compliance with their reporting requirements.
About Judy:
Judy Bard is a French-to-English translator. She has worked for more than ten years as an in-house translator and editor in equity research. She specializes in finance and stock market-related subjects and translates a variety of documents, ranging from registration documents, in-house newsletters and fund commentaries to compliance and regulatory materials.
Follow Judy on: linkedin.com/in/judybard
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