With the Sustainability Reporting Act (NaBeG), Austria has transposed the Corporate Sustainability Reporting Directive (CSRD) into national law. The Nationalrat (Austria's National Council) passed the law on January 21, 2026. The vote in the Bundesrat (Federal Council) is expected in early February 2026, and publication in the Federal Law Gazette is expected by the end of February 2026.
This will soon replace the existing Sustainability and Diversity Improvement Act (NaDiVeG). Since 2017, this act has implemented the requirements of the European Non-Financial Reporting Directive (NFRD, Directive 2014/95/EU) and obliges large capital market-oriented companies with more than 500 employees to publish a sustainability report, without prescribing a specific standard.
What does the NaBeG change in terms of content?
In terms of content, the NaBeG introduces mandatory sustainability reporting under the CSRD and the European Sustainability Reporting Standards (ESRS). Sustainability information thus becomes part of regular corporate reporting, is subject to external assurance and has a clear legal basis. The NaBeG already contains numerous specifications and already includes the reliefs from the Omnibus process at EU level. These include in particular:
- The thresholds are set at 1,000 employees and €450 million revenue
- The Stop-the-Clock Directive is implemented, which means wave 2 companies (non-capital market-oriented companies) only have to report from 2027
- Information requests to companies with < 1,000 employees in the value chain are limited to the scope of the VSME standard
- Financial statement audits and sustainability assurance can be carried out as a joint audit by several auditors
- For violations, coercive penalties are set at up to €100,000 for public interest entities and can be imposed repeatedly
- The audit rules are expanded (including adjustments to professional qualifications)
Scope of the NaBeG: who has to report?
CSRD wave 1: large capital market-oriented companies
Large capital market-oriented companies with more than 1,000 employees and revenue above €450 million fall into the first CSRD phase. In Austria, this affects around 120 companies.
If the balance sheet date for fiscal year 2025 falls before the NaBeG is published, there is no obligation to report on sustainability under the NaBeG for fiscal year 2025. Voluntary application is possible; otherwise, the existing reporting obligations under the NaDiVeG still apply for 2025.
If the balance sheet date falls after the NaBeG is published, sustainability reporting under the NaBeG, including external assurance, is mandatory. Depending on the fiscal year and balance sheet date, this may already apply to fiscal year 2025 (especially for companies with a non-calendar fiscal year). For companies whose fiscal year matches the calendar year, however, the obligation applies for the first time to fiscal year 2026.
For companies that already have to report for 2025 due to a non-calendar fiscal year, the old ESRS still apply. The new ESRS are expected to be adopted in June 2026 and may then be applied voluntarily for 2026 annual reports and mandatorily from 2027.
Under both the NaDiVeG and the NaBeG, wave 1 companies must also report under the EU Taxonomy. For fiscal year 2025, they can already use the simplified provisions.
CSRD wave 2: large non-capital market-oriented companies
For wave 2 companies, the reporting obligations are to be added later, once the “Omnibus” process at EU level has been finalized. Large non-capital market-oriented companies with more than 1,000 employees and revenue above €450 million will likely have to prepare sustainability reports under the NaBeG from fiscal year 2027. This includes a sustainability statement under the ESRS with EU Taxonomy disclosures, its inclusion in the management report and mandatory external assurance.
How Tanso supports you
Tanso supports CSRD reporting under the old ESRS and already includes a filter for the draft of the new ESRS. This lets companies collect the data required for their sustainability report across complex organizational structures in an audit-proof, AI-supported way, including the double materiality assessment and EU Taxonomy.
For wave 2 companies, we recommend preparing one or more trial reports for 2025/26. This lets you test processes, data availability and internal responsibilities early on.
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