On 21 January 2026, the Austrian National Council adopted the Sustainability Reporting Act (Nachhaltigkeitsberichtsgesetz – NaBeG), implementing the EU’s Corporate Sustainability Reporting Directive (CSRD) as amended by the “Stop-the-clock”-Directive (Directive 2025/794) and taking into consideration the simplifications under the expected “Omnibus”-Directive.
The NaBeG includes extensive amendments to the Austrian Commercial Code (Unternehmensgesetzbuch – UGB) and introduces a stand-alone act for third-country undertakings (Drittlandsunternehmen-Berichterstattungsgesetz – DriBeG). This reflects the CSRD’s intention to ensure a level playing field and comprehensive ESG transparency across the EU market.
What you need to know
1. Scope – Including non-EU group companies
The scope of the NaBeG for mandatory sustainability reporting encompasses:
- Austrian, public interest companies generating more than EUR 450 million turnover and having (on average) more than 1000 employees;
- Austrian subsidiaries (being large or public interest companies) of non-EU/EEA parent companies (generating more than EUR 450 million turnover in the EU on a group-level); and
- Austrian branches (generating more than EUR 50 million turnover) of non-EU/EEA undertakings (generating more than EUR 450 million turnover in the EU on a group-level).
As a result, non-EU/EEA entities may be subject to mandatory CSRD sustainability reporting through their Austrian presence.
2. Extensive sustainability disclosures
Inscope entities must include a sustainability report in the (group) management report or prepare a separate sustainability report. Required disclosures with regard to its own business activities, but also the supply chain include, in particular:
- business model and strategy, including alignment with the Paris Agreement and the EU’s climate neutrality objective;
- concrete, time-bound sustainability targets (e.g. GHG reduction targets);
- governance structures, policies and incentive systems linked to ESG matters;
- due diligence processes across the value chain;
- actual and potential adverse impacts on environmental and social matters and related mitigation measures; and
- relevant qualitative and quantitative KPIs.
3. Mandatory use of ESRS
Sustainability reporting must follow the European Sustainability Reporting Standards (ESRS) adopted by the European Commission. For third-country undertakings, reporting may alternatively be based on dedicated CSRD third-country standards or other standards formally recognised as equivalent.
4. Assurance, governance and transparency
Sustainability reports will be subject to mandatory external assurance, initially based on a “limited assurance” engagement. Management and supervisory bodies face enhanced corresponding responsibilities, and employee representatives must be informed and consulted.
5. Non-ESG-elated changes
NaBeG introduces non-ESG related accounting changes as well, such as
- abolishing the mandatory recognition of discounts (disagio) and introducing the effective interest method, requiring material debt-related transaction costs to be amortised over the term of the liability; and
- an additional obligation for Austrian inscope entities to include reporting on key intangible assets, such as self-generated intangibles, employees and stakeholder-relationships.
6. Phased application
Most reporting-related obligations apply to financial years ending on or after the date of entry into force of NaBeG, which is expected for end of February 2026. Austrian inscope entities sustainability reporting for third-country undertakings will apply for financial years beginning on or after 1 January 2028, subject to transitional provisions.
Summary
The NaBeG marks a decisive step towards fully integrated ESG reporting in Austria. For international groups, the new regime reinforces the need for early scoping, group-wide data governance and alignment of sustainability reporting across jurisdictions. However, NaBeG is not purely an ESG issue but affects finance and governance of undertakings too.
