On August 12, 2025, an amendment to the Act amending the Accounting Act, the Act on Statutory Auditors, Audit Firms and Public Oversight, and certain other acts entered into force.
This amendment deferred the obligation to report information on sustainability (ESG) for some small, medium and large companies by two years. As a result of the change, the so-called second-wave companies, i.e. large entities and small and medium-sized companies that are issuers of securities admitted to trading on one of the regulated markets in the European Economic Area, will be required to prepare ESG reports in 2028 (for the 2027 financial year). On the other hand, entities from the so-called third wave, i.e. companies not listed on the stock exchange, will be required to report on sustainability in 2029 (for the 2028 financial year).
The amendment also stipulates that entities for which ESG reporting is important due to their business strategy or the need to provide information to capital providers will be able to prepare it voluntarily.
As a reminder, EU Member States were required to adapt their national legislation to Directive 2025/794 by the end of 2025, insofar as it relates to corporate sustainability reporting, the so-called CSRD. This Directive introduced an obligation to provide information on the impact of an entity’s activities on the areas of the environment, social matters, including human rights, and corporate governance, as well as the impact of these three areas on the entity’s development, performance and position (the so-called sustainability reporting or ESG reporting). Currently, reporting is required for large entities and small and medium-sized entities that are issuers of securities admitted to trading on one of the regulated markets in the European Economic Area, as well as parent entities of large groups.
The obligation to report for the first time under the CSRD requirements has been divided into three stages. At first, in 2025, the largest public interest entities with more than 500 employees and exceeding at least one of the financial thresholds for a large entity would report for the 2024 financial year. This also includes public interest entities at the head of a group with more than 500 employees and exceeding at least one of the financial thresholds for a large group. Under the current regulations, in a second round, the remaining large entities and other large groups would have to report in 2026 for the 2025 financial year, while in a third round, small and medium-sized issuers from the regulated market would have to report in 2027 for the 2026 financial year.
However, on February 26, 2024, the European Commission presented the first sustainability simplification package, the so-called Omnibus I. This draft is currently being processed in the EU. Among other things, the EC proposed to narrow the scope of entities required to prepare sustainability reporting.
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