Security Alert
On 10.12.2024 the CSRD ((EU) 2022/2464) was transposed into Greek law.
What is Changing?
New law amends Law 4548/2018 and extends non-financial reporting obligations for large companies, small and medium sized companies of public interest, non-EU companies and branches with significant operations in the EU (e.g., revenues of third country companies either at group level, or individually, exceeding €150 million in the EU for the last two years), requiring disclosure of sustainability-related information including among others, business model, climate-related risks, adopted sustainability policies, governance, sustainability strategies, as well as supply chain impacts, in the form of Sustainability Report as part of the BoD Management Report. Companies must prepare their sustainability reports by following specific standards to be issued by the Ministry of Development (which should follow the EU Sustainability Reporting Standards), while independent verification of the disclosed information by external auditors (who are criminally liable if they knowingly give false opinions) or third-party assurance services providers is also required. Sustainability reports and information of the persons responsible for their publication must be published on the General Commercial Registry (GEMI).
Finally, Law 3556/2007 regarding listed companies is also amended, setting out indicatively that the Management Report shall also include the sustainability information following standardised sustainability reporting standards.
Key Dates
New reporting standards will apply from fiscal years starting on or after 1st January 2024, with specific provisions for SMEs by 2026.
The deadline for complying with the obligations differentiates for in scope entities:
Large entities of public interest and parent companies of large groups which are of public interest exceeding 500 employees: starting from the fiscal year 01.01.2024.
Large entities and parent companies of large groups, apart from the above mentioned : starting on the fiscal year 01.01.2025
Small and medium-sized entities of public interest, SNCIS and captive insurance and reinsurance companies (large or SMEs of public interest): starting from the fiscal year 01.01.2026.
Non-EU undertakings: starting from the fiscal year 01.01.2028.
To be noted that the Law introduces increased thresholds regarding size criteria for the classification of entities into large, small, medium-sized and micro and amends the figures provided in Law 4308/2014 regarding net turnover, total assets and average number of employees.
In a nutshell:
Scope:
Applies to large companies and SMEs of public interest (excluding micro-enterprises).
Includes third-country companies with substantial EU operations.
Mandatory Sustainability Standards:
Establishes uniform, mandatory sustainability reporting standards to ensure consistency and comparability.
Focus on Double Materiality:
Requires companies to assess and disclose:
The impact of sustainability issues on the company.
The company’s impact on society and the environment.
Forward-Looking and Value-Chain Information:
Emphasis on future risks, opportunities, and entire value chains.
Integration with Global Standards:
Aligns with international frameworks like the UN Sustainable Development Goals (SDGs) and the Task Force on Climate-related Financial Disclosures (TCFD).
Why It Matters?
It facilitates transparency for investors, stakeholders, and civil society.
It aims to combat greenwashing by standardising disclosures.
It supports the EU’s transition to a climate-neutral economy by 2050.
What Businesses Need to Do Now
Evaluate your current reporting practices.
Prepare for mandatory third-party assurance of sustainability data.
Engage with stakeholders to align on sustainability strategies.