EU Omnibus – 2025

On 26 February 2025, the EU Omnibus simplification package was submitted. We have continuously reported on its implications, decisions, and reception.

Amendment of the ESG Act – 2025

The wave of regulatory decisions throughout 2025 was partially mirrored in domestic legislation as well. On 17 June 2025, Hungary adopted an amendment to the ESG Act, introducing:

• new entry thresholds,
• revised requirements,
• a narrower scope of obligated entities,
• and changes to SME involvement.

Additionally, based on the EU Omnibus Stop‑the‑Clock proposal, the amendment postponed previous disclosure deadlines by two years.

Key changes of the amendment

New Entry Thresholds

Beyond public‑interest large companies, entities remain under the scope of the ESG Act if they exceed:

• HUF 90 billion annual net revenue, and
• 500 employees,

and…

Sector Classification

…their primary economic activity appears under the TEÁOR codes of industries explicitly included in the scope of the Act.
(Annex available here – see page 34.)

Obligations of companies remain unchanged

Obligated companies continue with their processes through 2025 and into 2026. They must:

• prepare their ESG report (including the annexed questionnaire) by 30 June 2026,
• but no assurance, publication, or submission to SZTFH is required yet.

These will only become mandatory starting 2028 (according to current legislation).

Amendment of the Accounting Act – 2025

Sustainability reporting—regulated by the Accounting Act—also stalled in timing and standardisation.
Due to Stop‑the‑Clock, obligated entities gained two additional years for preparation, and throughout 2025 the CSRD–ESRS standard system was reshaped under the influence of the EU Omnibus.

Key developments:

• an ESRS simplified standard package was published at the end of the year,
• and the voluntary reporting standards are also being renewed.

How 2025 Concluded

By the end of the year, ESG regulation experienced a true regulatory avalanche.

On 16 December, not only did the EU pass the EU Omnibus I package and the new entry thresholds, but the Hungarian Gazette also published several laws incorporating ESG considerations and strengthening the credibility of sustainability actions.
Moreover, on 22 December 2025, SZTFH initiated amendments to the decree defining the ESG questionnaire.

EU Omnibus I Package — Approved

We have covered this extensively earlier; here are the key changes:

CSRD – Sustainability Reporting

Only companies that meet both criteria will be obligated to report:

• more than 1,000 employees, and
• annual net revenue over €450 million (approx. HUF 173 billion).

Smaller companies with fewer than 1,000 employees are protected from mandatory reporting obligations.

CSDDD – Due Diligence

Applies only to major companies with:

• more than 5,000 employees, and
• annual net revenue above €1.5 billion.

16 December – Domestic Legislative Changes (Hungary)

Issue 153 of the Hungarian Gazette (2025.12.16.) included three relevant announcements:

1. Act XCI of 2025 – Amendments related to the EU’s 2024/1265 fiscal framework directive
2. Act XCIV of 2025 – Amendments to consumer protection laws supporting SMEs and harmonisation
3. Act C of 2025 – Amendments affecting the financial intermediary system

Act XCI of 2025

Key requirement: the central budget proposal must incorporate climate‑protection considerations, beginning already with the 2026 budget planning process.

Further obligations include:

• detailed reporting of indirect subsidies via tax reliefs, including their environmental and climate impacts
• annual and multi‑year macroeconomic forecast reviews
• assessment of whether medium‑term fiscal planning aligns with sustainability expectations

Act XCIV of 2025 – Greenwashing Prevention

A milestone amendment aimed at preventing greenwashing. It also constitutes the Hungarian transposition of the international Green Claims Directive (effective January 2026).

Key additions

• The act formally defines the concept of a sustainability label
• Misleading sustainability labels are prohibited

Sustainability Label – Definition
A voluntary trust mark or quality label—public or private—intended to distinguish or promote a product, process, or company based on environmental or social characteristics (or both), excluding legally mandated EU labels.

The act states:
Misleading consumers about the environmental, social, or circular attributes of a product is always considered unlawful commercial practice.

Act C of 2025 – ESG in the Financial Sector

This amendment obliges financial institutions to consider ESG risks at every level of risk management.

ESG Risk – Definition
Any negative financial effect resulting from current or expected environmental, social, or governance‑related impacts on an institution’s partners or invested assets, materialising through traditional financial risk categories.

Updated ESG Questionnaire

Amendments were driven partly by the MNB’s updated minimum ESG questionnaire for credit‑risk assessments.

Implications for companies:

• changes to data‑collection processes
• updates to databases
• adjustments to supplier due diligence
• required modifications to ESG software

These must all be implemented in early 2026.

A new, nationally relevant data point was added:
the presence of a certified green‑space (zöldfelületi) certificate.

The updated questionnaire is now available on the SZTFH website.

2026 – What We’re Waiting For

This is where we stand today: we wait.

We await the final text of the EU Omnibus I package, expected in Q1 2026, which will enter into force on the 20th day after publication in the Official Journal of the European Union.

We also await how Hungarian legislation will respond—both the Accounting Act and ESG Act—and how new EU simplification goals will be adopted domestically, including:

• new entry thresholds,
• alignment of the two regulatory regimes,
• and updated expectations for companies.

Uncertainty or Conscious Preparation? Our Choice.

The beginning of 2026 does not need to be about uncertainty.
Instead, it can be a period of purposeful preparation.

Companies that use this time not to wait, but to strengthen their systems, data flows, and internal decision‑making, will gain a competitive advantage in the coming years.

We believe ESG will remain a strategic priority, not an administrative burden.
Our mission is to monitor developments and support organisations in navigating the evolving regulatory environment.

Free 30‑Minute Consultation

You know you need to do something — but you’re not sure what? We can help.

Corporate sustainability is complex and regulations evolve rapidly.

Many companies have just exited the scope of obligations, while others face entirely new expectations.

If you’re unsure whether:

• CSRD applies to you,
• you need to prepare an ESG report,
• or which services would support your compliance,

this is your opportunity to ask.

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During the session:

• we help interpret the regulations relevant to your company,
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• and outline the recommended next steps.

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