Sustainability Reporting Act (NaBeG): Austria implements CSRD

Austria has transposed the CSRD (Corporate Sustainability Reporting Directive) into national law with the resolution of the National Council on January 21, 2026, through the Sustainability Reporting Act (NaBeG). This makes it clear that sustainability reporting is no longer treated as a "nice-to-have", but is gradually becoming a mandatory obligation for many companies.

If you are an ESG manager or provide CSRD consulting, the most important question is no longer "Is it coming?", but: How do I implement it pragmatically? Without chaos, without being overwhelmed, but with a clean result?

In this article, you will get an understandable overview of what the NaBeG means, who is affected and what steps you should take now.

What is the NaBeG and why is it important?

The NaBeG (Sustainability Reporting Act) is the Austrian law with which the European sustainability reporting obligation is implemented in Austria. The CSRD stipulates throughout Europe how companies must report on sustainability in the future in order to make the data comparable, as with the financial reports.

The NaBeG ensures that these EU requirements actually become mandatory in Austria, including clear rules on publication and auditing.

Why is the NaBeG relevant?

Which organizations are affected by the NaBeG?

Directly affected: Large companies

The NaBeG implements the CSRD logic: companies that exceed both of the following thresholds are subject to reporting requirements:

Both criteria apply cumulatively. A company must exceed both thresholds to fall directly into scope.

Indirectly affected: SMEs in the supply chain

Small and medium-sized enterprises (SMEs) usually do not have to prepare full CSRD reports if they remain below the thresholds. However, most will still have to provide ESG data if their customers or suppliers subject to reporting requirements demand it. In addition, banks are increasingly being encouraged to take ESG criteria into account when granting loans.

For smaller companies, the VSME is suitable as a voluntary, significantly smaller EU reporting standard.

What must be included in the CSRD sustainability report?

The European Sustainability Reporting Standards (ESRS) define what specifically needs to be included in a CSRD report. The EU Commission published a draft of simplified ("revised") ESRS on 6 May 2026 for consultation, with feedback accepted until 3 June 2026.

Key changes in the revised ESRS draft:

The double materiality assessment remains a core element of CSRD reporting. You report on the topics that turn out to be material. The ESRS topic structure was also adjusted in the course of the Omnibus, and the number of required data points was significantly reduced.

Practical guide: What ESG managers should do now

1) Clarify your scope

Sustainability managers of Austrian companies should clarify:

• Are we subject to CSRD/NaBeG?
• From when?
• Individual report or group report?

Tip: Even if it only applies "later" for your company: start with the setup anyway. The effort is not in the writing, but in the collection of the data.

2) Create a stakeholder map

Creating a sustainability report is the task of the ESG manager. But it can only be successful as a cross-departmental team, because the data and information sit in the specialist departments.

Create a stakeholder map and list the requirements clearly:

Insight: CSRD is an internal change project. If you only treat it as an ESG topic, you will lose.

3) Perform the Materiality Assessment

Many see materiality as a mandatory exercise, but overlook the strategic potential of the DMA. A top-down approach lets you focus on the most relevant topics for your company and industry in the Materiality Assessment. This is an efficient way to reach a solid result.

Useful aids include the Materiality Assessment Excel Template, the AI-supported Materiality Master software, or Materiality Assessment Workshops.

The Materiality Assessment decides which data you really have to report. It is a complexity-reduction tool.

4) Make a software decision

Consider whether you want to purchase ESG software for NaBeG reporting. A software solution can save considerable time in the data collection process and usually creates audit security.

The CSRD software selection guide and the ESG tool selection assessment model will help you find your way through the range of CSRD solutions.

A CSRD report can also be created without dedicated software.

Tip: We have already supported numerous companies in selecting suitable ESG software. Contact us if you would like to benefit from our experience.

5) Find contact persons and inventory data sources

If no software is used, the EFRAG data point list can serve as a basis. Alternatively, create a simple table with these columns:

• ESRS topic
• KPI / data point
• Data source
• Data quality
• Data owner
• Availability

This table serves as the basis for the gap analysis. It shows which data exists, which is only estimated, which no one owns, and which IT systems are missing.

6) Consider auditability early on

The audit aspect is often underestimated. If an auditor later asks during the CSRD audit:

• "Why is this topic material?"
• "Where does the number come from?"
• "Who approved it?"
• "How is it calculated?"

...and you have no answer, it can become a significant problem.

Practical tip: For each KPI, define the calculation logic, the data source, the approval process, and the versioning and documentation approach.

7) Progress is more important than perfection

Creating a sustainability report to fulfill the NaBeG is a process. In the first reporting year, not all data points may be available yet. As long as you handle this transparently, it is not a problem.

Depending on your sustainability strategy and reporting ambition level, the report can be an opportunity to actively position your company on ESG, or it can initially just meet the minimum requirements to be compliant.

Tip: If your company actively communicates about sustainability, observe the EmpCo Directive.

Conclusion: NaBeG brings clarity

With the NaBeG, Austria has taken the CSRD path in a binding manner. For ESG managers, this means one thing above all: structure beats actionism.

Frequently asked questions about the NaBeG and CSRD in Austria