Accounting

ESG Reporting 2026: New Obligations for Czech Companies

Tým P&T Europe Services 3/5/2026 7 min

The Omnibus I package (Directive (EU) 2026/470) narrowed mandatory ESG reporting to companies with more than 1,000 employees and turnover above EUR 450 million. Who must report, from when, and what it means for everyone else.

Table of Contents

The CSRD (Corporate Sustainability Reporting Directive) introduces mandatory sustainability reporting. The original timeline, however, changed fundamentally in 2025 – the "stop-the-clock" directive of April 14, 2025 postponed the obligations for the second and third wave of companies by two years.

Who Must Report and When

First wave – large public-interest entities with more than 500 employees (already reporting under NFRD) report from the 2024 accounting period
Second wave – other large companies file their first reports in 2028 for the 2027 accounting period, but only if they fall within the new, much narrower scope under the Omnibus I package (see below)
Listed small and medium enterprises (the original third wave) fall outside the new scope, which starts only above 1,000 employees

The Omnibus I package has been adopted

Update as of 26 October 2026: the Omnibus I package was adopted in February 2026 as Directive (EU) 2026/470. Under the final text, the obligation to prepare a sustainability report applies only to undertakings and groups with an average of more than 1,000 employees and an annual turnover above EUR 450 million. Already for the Commission's original proposal (a 1,000-employee threshold), the Czech Ministry of Finance estimated that the circle of obligated companies in Czechia would shrink from about two thousand to around 250. The final text adds an even stricter turnover threshold. Other changes according to the Ministry of Finance:

a reporting company may not ask value-chain partners with fewer than 1,000 employees for more information than the voluntary standard provides, and they may refuse to supply it,
the planned sector-specific standards are dropped,
due-diligence obligations (CSDDD) apply only to companies with more than 5,000 employees and turnover above EUR 1.5 billion.

For most Czech companies, mandatory ESG reporting therefore falls away. Banks and large customers, however, still often ask for sustainability data, typically under the voluntary standard. The changes still have to be transposed into the Czech Accounting Act.

ESRS Standards

European Sustainability Reporting Standards (ESRS) define specific metrics: 1. Environmental (E)

Greenhouse gas emissions (Scope 1, 2, 3)
Energy and water consumption
Biodiversity and ecosystems
Circular economy

2. Social (S)

Working conditions and remuneration
Equal opportunities and diversity
Health and safety at work
Supply chain

3. Governance (G)

Ethical management and compliance
Anti-corruption policies
Whistleblower protection
Cybersecurity

Impact on Accounting and Payroll

ESG reporting directly affects the work of accounting and payroll departments:

Gender pay gap tracking – mandatory reporting of pay differences between men and women
Emission accounting – new accounting categories for carbon footprint
Employee training – recording ESG-related educational activities
Supplier due diligence – verifying ESG standards with partners

How to Prepare

1. Conduct a gap analysis of current state vs. ESRS requirements 2. Designate a responsible person or team for ESG 3. Implement a data collection system 4. Engage an external auditor for report verification 5. Start communicating ESG strategy to stakeholders

Penalties

Failure to submit an ESG report can lead to fines under the Accounting Act and there are also reputational risks when dealing with partners who require ESG compliance. Sources (as of 26 October 2026): Czech Ministry of Finance — Omnibus I package, Directive (EU) 2026/470, CSRD and the Czech Accounting Act No. 563/1991 Coll..

Legal Notice

This article is for informational purposes only and does not replace professional legal or tax advice. Information is processed according to Czech law valid at the date of publication. We always recommend consultation with an expert for specific situations.

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TPES

Tým P&T Europe Services

Specialists in payroll accounting, HR and accounting