All Licensees and Exempted Licensees must submit the ESR Notification within 6 months from the Licensee’s financial year end. Following which, all Licensees must submit the ESR Report within 12 months from the Licensee’s financial year end.Entities are expected to use a ‘substance over form’ approach to determine whether they undertake a Relevant Activity and as a result will be considered Licensees for the purpose of ESR Regulation, irrespective of whether such Relevant Activity is included in the trade license or permit of the entity.