Summary:
- With the Sustainability Reporting Act (NaBeG), Austria has nationally implemented the EU-CSRD.
- For many companies, sustainability reporting will thus become gradually mandatory and significantly more demanding than before.
- Reports must be prepared according to ESRS standards, integrated into the management report and be auditable (audit-proof).
- Even companies not directly subject to reporting requirements can be indirectly affected, e.g. by ESG data requests from customers, corporations or banks.
- For ESG managers & ESG consultants: Now start pragmatically with Materiality Assessment, IRO logic, clear roles/processes and a reliable database.
Austria has transposed the CSRD (Corporate Sustainability Reporting Directive) into national law with the resolution of the National Council on January 21, 2026 – with 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?
- ESG reports are standardized (less “marketing report”, more “proof”)
- The requirements are significantly higher than before and data-driven with concrete KPIs
- The sustainability data must be verifiable and comprehensible
- Many companies will be indirectly affected (e.g. as suppliers)
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 therefore subject to reporting requirements:
- More than 1,000 employees
- Over 450 million euros in turnover
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 updated draft of the “Simplified ESRS” (as of December 2025) still sees the CSRD reporting as a core element of the implementation of a double Materiality Assessment.
Subsequently, it is necessary to report on the ‘material’ topics. In the course of the Omnibus, however, the reporting requirements – in particular the number of data points – were significantly reduced and the ESRS topic structure adjusted.
Practical guide: What ESG managers should do now
1) Clarify impact
Sustainability managers of Austrian companies should clarify:
- Are we subject to CSRD?
- From when?
- Individual report or group report?
Tip: Even if it only applies “later”: 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 lie in the specialist departments.
Create a stakeholder map and list the requirements clearly:
- CFO / Finance: Wants security, comprehensible figures, little risk
- Legal / Compliance: Needs rules & evidence
- Purchasing / Supply Chain: Requires supplier data
- HR: Has the key figures for the KPIs of the social topics
- Management: Should not only see sustainability as a cost factor, but also understand the business case. In addition, the level of ambition for the report should be clarified.
Insight: CSRD is an internal change project. If you only treat it as an ESG topic, you will lose.
3) Perform Materiality Assessment
Many see materiality as a mandatory exercise, but overlook the strategic potential of the DMA. The Top-Down Approach allows you to focus on the most relevant topics for the company and the industry in the Materiality Assessment. This is an efficient way to achieve a result.
In addition, there are valuable aids such as 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 and which not. So it’s a complexity reduction tool.
4) Software decision
Consider whether you want to purchase ESG software for NaBeG reporting or not. A software solution can save considerable time, especially in the data collection process, and usually also creates audit security.
The CSRD software selection guide and the ESG tool selection assessment model will help you find your way around the jungle of CSRD solutions.
However, it is also possible to create a CSRD report without software.
Tip: We have already supported numerous companies in selecting suitable ESG software. Contact us if you would like to benefit from our knowledge.
5) Find contact persons and inventory data sources
If no software is used, the EFRAG data point list can serve as a basis or you can create a simple table with the following columns yourself:
- ESRS topic
- KPI / data point
- Data source
- Data quality
- Data owner
- Availability
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, this can become a big problem.
Practical tip: Define the calculation logic; the data source; the approval process and the versioning / documentation for each KPI.
7) Progress is more important than perfection
The creation of a sustainability report to fulfill the NaBeG in Austria is a process. In the first reporting year, not all data points may be available yet. As long as you deal with this transparently, it is not a problem.
Depending on the sustainability strategy and reporting ambition level, the report can be an opportunity to actively position yourself on the topic of ESG or initially only meet the minimum requirements in order to be compliant.
Tip: If your company actively communicates about sustainability, observe the EmpCo Directive.
Conclusion: NaBeG brings clarity
With the NaBeG it is clear: Austria is taking the CSRD path in a binding manner. For ESG managers, this means above all one thing: structure beats actionism.
