Resources · Regulation
ESG deadlines on one page: key dates, scope and legal basis of the CSRD, NaBeG, ESRS, CBAM, EUDR, ETS, ESPR, EmpCo and CSDDD.
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Already applies
Operators of installations in emissions trading: verified emissions report by March 31, surrender of allowances by September 30. Directive 2003/87/EC.
Large public-interest entities with more than 500 employees. Member States may exempt wave-one undertakings that do not exceed at least one of the two thresholds (EUR 450 million turnover or 1,000 employees) for 2025 and 2026; Austria did so in NaBeG (see below). Directive (EU) 2022/2464, amended by (EU) 2026/470.
Financial market participants and financial advisers. Other undertakings may feel the SFDR through data requests from banks and investors. Regulation (EU) 2019/2088.
2026
Importers of more than 50 tonnes of CBAM goods per year need the status of authorised CBAM declarant; the de minimis threshold does not apply to electricity and hydrogen. Regulation (EU) 2023/956, amended by (EU) 2025/2083.
Undertakings that must disclose taxonomy KPIs. Non-financial undertakings need not assess activities for taxonomy eligibility and alignment if together they make up less than 10% of the denominator of a KPI. Applies already to financial year 2025; for financial years that begin in 2025, the previous rules may still be applied. Delegated Regulation (EU) 2026/73.
For CBAM goods, free allocation falls step by step (2026: 97.5%, 2030: 51.5%) until it ends from 2034. For aviation, the formerly free allowances are in principle auctioned. Directive 2003/87/EC.
Large public-interest entities with more than 1,000 employees and more than EUR 450 million turnover report under the new law, first for financial years with a balance sheet date on or after entry into force. Wave-one undertakings that do not exceed at least one of the two thresholds (EUR 450 million turnover or 1,000 employees) report under the previous law (NaDiVeG) or voluntarily under the new one. BGBl. I Nr. 6/2026.
New range of coercive penalties for corporate reporting documents. In the first 3 financial years, content errors in sustainability reporting are penalised only if a court order to correct them is not obeyed. BGBl. I Nr. 6/2026.
By this date, Member States had to transpose the new buildings directive, for example trajectories for the renovation of residential buildings, minimum standards for non-residential buildings and energy performance certificates with classes A to G. For undertakings, the national laws apply. Directive (EU) 2024/1275.
Large undertakings may not destroy unsold apparel and footwear, with derogations under Delegated Regulation (EU) 2026/296; medium-sized undertakings from Jul 19, 2030. By Jul 19, 2026, the Commission also had to set up the registry for the digital product passport. Regulation (EU) 2024/1781.
Manufacturers, importers and distributors of packaging. The Regulation has applied since this date, among other things with limit values for PFAS in food-contact packaging; further duties such as labelling and recyclability follow from 2028 and 2030 at the earliest. Regulation (EU) 2025/40.
All undertakings without a CSRD duty may apply it voluntarily. Delegated Regulation (EU) 2026/1560.
All undertakings that advertise to consumers with environmental claims. Transposed in Austria in the UWG; for goods placed on the market by Sep 27, 2026, civil claims are excluded for 3 years. Directive (EU) 2024/825, BGBl. I Nr. 58/2026.
Undertakings that already report under the ESRS choose, for financial years that begin in 2026: the old set, the new set, or the old set with reliefs from the new one. They state the version chosen. Delegated Regulation (EU) 2026/1563.
Undertakings that place on the market, make available or export cattle, cocoa, coffee, oil palm, rubber, soya, wood or products made from them under Annex I. The later date Jun 30, 2027 applies only to the operators named there; all others fall under this date, including small undertakings established after Dec 31, 2024. Regulation (EU) 2023/1115, amended by (EU) 2025/2650.
2027
Undertakings and groups with more than 1,000 employees and more than EUR 450 million net turnover. Member States transpose this by Mar 19, 2027; in Austria, the rule for large undertakings that are not public-interest entities is still pending, in Germany the whole transposition act (as of November 2026). Directive (EU) 2026/470.
Mandatory for all undertakings that must report under the CSRD. Delegated Regulation (EU) 2026/1563.
Sale on the central platform; from 2027, at the end of each quarter, certificates must be held for at least 50% of the embedded emissions imported since the beginning of the year.
Validations under V2 possible; mandatory for all new submissions from Feb 1, 2028.
For operators that are natural persons, micro or small undertakings and were established as such on Dec 31, 2024; not for timber products of the former Timber Regulation.
By this date, the Commission adopts standards for limited assurance. Directive (EU) 2026/470.
Declaration and surrender of certificates for the imports of 2026, then yearly by September 30.
Further products are added, for example soluble coffee and certain palm oil derivatives. Certain products have no longer been covered since Sep 18, 2026, for example leather. Delegated Regulation (EU) 2026/2102.
2028
Suppliers of fuels for buildings, road transport and additional sectors, not end consumers. First auctions are planned as early as 2027, and the system becomes fully operational in 2028; the first surrender, for the emissions of 2028, is due by May 31, 2029. Permits and monitoring have applied since 2025, reports since 2026. The amendment of the European Climate Law moved the start from 2027 to 2028.
Austrian subsidiaries and branches of third-country undertakings with more than EUR 450 million turnover in the EU that meet the further size criteria. DriBeG is part of NaBeG.
2029
EU companies with more than 5,000 employees and more than EUR 1.5 billion worldwide net turnover, also at group level; third-country companies with more than EUR 1.5 billion net turnover in the EU. Transposition by Jul 26, 2028; the reporting duty applies from financial year 2030 and not to undertakings that report under the CSRD. Directive (EU) 2024/1760, amended by (EU) 2026/470.
2030
The destruction ban and the disclosure of unsold goods also apply to medium-sized undertakings.
2034
No more free allocation for the production of CBAM goods.
Commission proposal COM(2025) 989, procedure 2025/0419(COD), planned start 2028. Not law yet.
Commission proposal COM(2026) 616, procedure 2026/0212(COD). Among other things, it provides for a slower phase-out of free allocation for CBAM sectors. Not law yet. Today's rules apply until a decision.
Commission proposal COM(2025) 841, procedure 2025/0361(COD). Product categories are to replace today's classification under Articles 8 and 9. No application date is fixed.
The standards are under revision; until publication, today's standards apply unchanged. A private standard, not law.
In October 2026, the European Supervisory Authorities presented advice on the revision of the disclosure rules; it may lead to targeted amendments. According to its call for advice of Mar 4, 2026, the Commission intends to adopt amendments in Q1 2027, with entry into force planned for Q3 2027. Nothing has been adopted yet. Until then, the simplified version of 2026 applies.
In 2025, the Commission announced that it would withdraw the proposal; it has not been formally withdrawn. The EmpCo rules are binding.
Omnibus I has been in force since Mar 18, 2026. From financial year 2027, only undertakings and groups above both thresholds of 1,000 employees and EUR 450 million net turnover report, under the revised, much shorter ESRS set. Assurance stays at limited assurance. Digital tagging of the sustainability statement is needed only once the rules for it have been adopted in the ESEF Regulation; there is no date.
Austria used the option from Omnibus I in NaBeG even before Omnibus I was published. Under the new law, only large public-interest entities above both thresholds currently report; the other undertakings that had to report so far apply NaDiVeG or report voluntarily under the new law, and state which version they use. Large undertakings that are not public-interest entities need a further act by Mar 19, 2027.
In Germany, the CSRD has not yet been transposed into national law. The government bill of 2025 (BT-Drs. 21/1857) is before the Bundestag; after the public hearing in April 2026, the decision is still pending (as of November 2026). Until then, the previous rules on the non-financial statement apply. The Directive provides for the new scope from financial year 2027; Member States must transpose it by Mar 19, 2027. It becomes binding on undertakings through the national act. The legislative process should therefore be followed.
The CSDDD comes later and for fewer undertakings than first planned. The EUDR, in contrast, attaches to the goods, not to company size: it also affects small undertakings if they place one of the 7 commodities or products made from them listed in Annex I on the market or trade in them.
For importers of CBAM goods above the de minimis threshold, the imports of 2026 trigger CO2 costs for the first time, even though the certificates for them are bought and surrendered only in 2027. At the same time, free allocation in emissions trading falls. From 2028, ETS2 puts a price on fuels for buildings, road transport and additional sectors; until then, a national CO2 price applies in Austria and Germany. For now, the ESPR works mainly through the destruction ban and the disclosure of destroyed goods; product requirements and the product passport come only with the acts for each product group.
Since Sep 27, 2026, the Austrian UWG has set fixed bans on generic environmental claims without recognised excellent environmental performance, on claims that a product is climate neutral or has a reduced greenhouse gas impact because of offsetting, and on sustainability labels that neither rest on a certification scheme nor are established by public authorities. They affect undertakings of any size that advertise to consumers.
Only if, from financial year 2027, it has more than 1,000 employees and more than EUR 450 million net turnover. Below that there is no duty. Customers and banks may still ask for ESG data.
If you do not exceed at least one of the two thresholds (EUR 450 million turnover or 1,000 employees), you must continue to prepare a non-financial report under the previous law for 2026, unless you report voluntarily under the new law. The report must state which version you apply.
For EU companies with more than 5,000 employees and more than EUR 1.5 billion worldwide net turnover, also at group level, from Jul 26, 2029. For third-country companies, a net turnover of more than EUR 1.5 billion in the EU counts. As a supplier to such a company, you may still receive requests. For the in-depth assessment, it may ask partners with fewer than 5,000 employees only for information that it needs and cannot obtain in another way.
No (as of November 2026). Both are Commission proposals still being negotiated between Parliament and Council. Today's rules apply until a decision.
The deadlines come from the legal texts and standards linked below. Before you decide, it is worth checking the current legal position.
This page explains the legal position in simplified form and is not legal or tax advice. The linked legal texts, as currently in force, are authoritative.
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