Are the requirements of CSRD transposed? If yes, what was the implementation date and what is the name of the legislation?
Yes, in principle. The transposing legislation implements the core CSRD obligations, including reporting on environmental, social and governance factors, subject to the scope, assurance and enforcement provisions described below. On January 1, 2024, the Hungarian Accounting Act was amended to transpose the CSRD. Further rules were adopted on August 8, 2024 covering the preparation of an ESG report, rules on accreditation, registration and education of ESG advisors. As of June 20, 2025, the ESG Act was revised in scope. Following an amendment effective December 22, 2025, SZTFH Decree No. 13/2024 (VIII.15.) replaced the former ESG questionnaire. The Stop-the-Clock Directive has been transposed through amendemends to the Accounting Act.
Has the local legislation extended the scope of the CSRD, by adding any additional requirements or going beyond the Directive in any way?
No.
How does the transposition affect different types of companies? Are there specific provisions for different sizes or types of companies, such as SMEs versus large enterprises?
The ESG Act was revised so that public‑interest small and medium‑sized enterprises are no longer covered. ESG reporting is now required only for companies active in specific sectors (e.g., pharmaceuticals, energy, finance) and that exceed both of the following thresholds for two consecutive years: a) HUF 90 billion annual net revenue; More than 500 employees. Large companies that fall under the ESG rules do not need to submit ESG reports or certificates to SZTFH for financial years 2024–2026. Until June 30, 2027, micro and small companies cannot be obliged—or volunteer—to provide ESG information, and medium‑sized companies cannot take on contractual ESG reporting obligations. The timeline follows the EU-level one: large companies to report in 2028 for 2027 FY, listed SMEs and non-EU companies with large turnover to report in 2029 for 2028 FY. Companies must maintain a risk assessment system that includes an annual risk analysis (at least once every 12 months) and ad hoc assessments. The former deadline of June 30 for completing the yearly assessment has been removed.
Do any enforcement provisions, such as sanctions or penalties exist under local law for non-compliance with CSRD?
Yes.
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