Sustainability report

We support companies in developing sustainability statements and XBRL tagging, as well as provide independent assurance reviews for both mandatory and voluntary reporters.

The Law on Sustainability Disclosures, which transposes the requirements of the European Corporate Sustainability Reporting Directive at the national level, requires that entities subject to the law include a sustainability statement in a single electronic format (ESEF) in their annual report. Both the sustainability statement itself and the ESEF format shall be reviewed by a sworn auditor.

Which companies must prepare a sustainability statement?

According to the currently applicable regulations, Wave 1 companies (public interest entities with more than 500 employees), which prepared their first ESRS-compliant sustainability statement for 2024, continue to report.

The 2025 amendments to the Law on Sustainability Disclosures postpone the start of sustainability reporting for Wave 2 and 3 companies by two years:

• large companies will have to report starting from the FY2027;

• listed SMEs will have to report starting from the FY2028.

In addition to these “temporary” amendments postponing the start of reporting, the Omnibus I package aims to narrow the scope of the CSRD, namely to reduce the number of companies for which an ESRS-compliant sustainability reporting is mandatory. At the end of 2025, the European institutions negotiated and voted on the following:

• the Wave 2 will include only large companies with more than 1,000 employees and a turnover exceeding EUR 450 million;

• the Wave 3 companies – listed SMEs – will be excluded from the CSRD scope.

These changes are still subject to approval by the European Council, followed by publication of the amending directive in the EU Official Journal and transposition at national level. The Council approval is expected in early 2026.

Which standards should be used to prepare the statement?

Companies falling within the scope of the CSRD must prepare, tag, and audit their sustainability statement in accordance with the requirements set out in the Directive and the ESRS. Currently, the first version of the ESRS, published in 2023, is still in force.

In addition to narrowing the CSRD scope, the Omnibus I package also provided for a significant simplification of the ESRS. In late 2025, EFRAG published drafts of the simplified ESRS and submitted them to the European Commission for review. The further process includes review and possible adjustments by the Commission, the development and approval of the delegated regulation, which, according to currently available information, is expected around mid-2026.

The European Parliament and the Council are then given time to examine the act and submit objections. If no objections are received within the specified period, the delegated regulation is published in the EU Official Journal and enters into force.

It is expected that the simplified ESRS will be applied from FY2027, with the possibility of using it earlier (for FY2026), depending on the date of entry into force of the delegated regulation.

What should companies do that fall outside the CSRD scope?

The narrowing of the CSRD scope will significantly increase the number of companies for which sustainability reporting will be voluntary. These companies have a fairly wide range of options available, which can be divided into two basic approaches:

• proactive voluntary reporting:
  • using one of the voluntary frameworks, such as VSME (the European Commission–recommended standard for SMEs), GRI (widely used global guidelines with a primary focus on the impact materiality), or the ISSB Standards (with a primary focus on the financial materiality);
  • using the simplified ESRS as a guide when preparing the company’s sustainability statement, or aiming to develop a statement fully compliant with the ESRS requirements;
• reactive voluntary reporting: ad hoc responses to requests from customers, financiers, and other stakeholders.

If you're confused or do not know where to start your sustainability journey, contact us for advice.