When the European Union gave final sign-off to the Omnibus I package in February 2026, part of Slovakia’s supplier base breathed out: the threshold for mandatory ESG reporting was raised and several deadlines slipped by two years. Yet the counterintuitive takeaway runs the other way — a delayed obligation is not delayed pressure. A smaller Slovak manufacturer that will never cross the thousand-employee line typically enters sustainability reporting through a customer’s purchase order sooner than through the statute itself. That is what makes the CSRD a topic a firm cannot shelve even when it sits formally outside the directive.
This is an analytical overview of the position as of 2 July 2026. The legislation around sustainability reporting is in motion — at EU level a simplification (Omnibus) is under way, and at Slovak level the transposition of the substantive part into the Accounting Act is not yet closed. Every figure and date is therefore given with an as-of point, and readers are advised to verify the current wording in the Collection of Laws (Slov-Lex) at the moment of any decision.
What the CSRD asks, and how it entered Slovak law
The Corporate Sustainability Reporting Directive — Directive (EU) 2022/2464 (CSRD) — replaced the older Non-Financial Reporting Directive and introduced a considerably broader, standardised regime. Instead of a loose „non-financial statement“, affected companies must report environmental, social and governance (ESG) data under the single European Sustainability Reporting Standards (ESRS), with mandatory limited assurance and in a machine-readable format as part of the annual report (Directive (EU) 2022/2464).
The CSRD entered Slovak law through an amendment to the Accounting Act — according to secondary analyses (e.g. LeitnerLeitner, KPMG Slovakia, Bureau Veritas), via Act No. 105/2024 Coll., effective from 1 June 2024, which inserted the sustainability-reporting obligation and the reference to the ESRS into Act No. 431/2002 Coll. on Accounting. Slovakia adjusted the size limits for inflation: the mandatory-reporting line was tied to exceeding at least two of three criteria — assets above EUR 25 million, net turnover above EUR 50 million, and more than 250 employees — across two consecutive accounting periods (per secondary analyses by Accace and KPMG; the exact wording should be verified against the text of the Act on Slov-Lex).
For a foreign investor, the relevant point is that Slovakia did not „gold-plate“ beyond the directive, nor did it soften the ESRS — those standards are defined at EU level as delegated acts, and a member state does not alter their content. As a result, the report of a Slovak subsidiary and the report of its Western European parent draw on the same methodology. That alignment is deliberate: the CSRD’s purpose was to make ESG data comparable across the single market.
Who reports, and from when — three waves and a two-year delay
The original CSRD architecture envisaged a phased start in three waves. The first wave — large public-interest entities (listed companies, banks, insurers) with more than 500 employees — began reporting for financial year 2024, publishing its first statements in early 2025. In Slovakia this covers roughly 20 such entities, per Grant Thornton Slovakia’s estimate; their obligation continues.
The second wave — other large companies that are not public-interest entities — was originally due to report for 2025 and publish first in 2026. This is where the most visible change came. Directive (EU) 2025/794, the so-called „Stop-the-clock“ measure, approved by the European Parliament on 3 April 2025 and effective from 17 April 2025, postponed the start of application for this group by two years. In practice, second-wave companies will now report first for financial year 2027 and publish only in 2028. Per Grant Thornton Slovakia’s estimate, the delay affects roughly 700 companies in Slovakia’s larger-enterprise category.
The third wave — listed small and medium-sized enterprises — was to phase in for 2026. Under the Omnibus package, however, this group is effectively removed from the mandatory scope and steered towards voluntary reporting under the simplified standard for smaller undertakings (VSME). For Slovak listed SMEs this means a mandatory ESG report under the full ESRS methodology will most likely not arise — which, as shown below, does not mean the topic passes them by.
The second wave’s two-year delay was carried into Slovak law through an indirect amendment to the Accounting Act; according to secondary sources (SKDP, Grant Thornton) it was adopted within an amendment to related capital-market legislation. Act No. 256/2025 Coll. is cited among the legislative vehicles in this context; its exact wording and the scope of its impact on the accounting regime should be verified on Slov-Lex at the moment of any decision, since this is an area that changed repeatedly across 2025 and 2026.
Omnibus shifts the threshold — and the timeline is still moving
More consequential than the deadline slippage is the change to which companies are caught. The substantive part of the Omnibus I package was formally approved by the Council of the European Union on 24 February 2026, with the text published in the Official Journal of the EU on 26 February 2026, entering into force 20 days after publication (Council of the EU, press release of 24 February 2026). Omnibus narrows the CSRD’s scope substantially: the duty to report under the ESRS is to apply only to companies that cross both thresholds at once — more than 1,000 employees and net turnover above EUR 450 million (Council of the EU; confirmed by secondary analyses from Clifford Chance and Accountancy Europe).
Against the original setting (250 employees, EUR 50 million turnover, EUR 25 million assets) this is a radical increase. According to secondary analyses (Prosman & Pavlovič, RSM SK), most companies that had been preparing for the second wave will fall out of the mandatory scope once Omnibus is transposed. For first-wave companies that no longer reach the raised threshold, the directive additionally introduces a transitional exemption for 2025 and 2026, so they need not report and then drop out.
That „still moving“ qualifier matters. Omnibus I is an EU directive that each member state must transpose into national law; Slovakia is required to reflect it in Act No. 431/2002 Coll. on Accounting and related legislation by 19 March 2027, with first application for financial years beginning on or after 1 January 2027. As of 2 July 2026 this substantive transposition in Slovakia is not yet closed — the national legislator has signalled the intent to narrow the population of reporting companies, but the final wording depends on the legislative process. In parallel, a revision of the ESRS themselves is under way at EU level, intended to simplify the content of reporting. Readers should therefore not treat any figure as „final“: the 1,000-employee and EUR 450 million threshold is the state of the adopted directive, while its precise translation into Slovak law and into the revised ESRS is still being settled.
Scope 3 and supply-chain pressure — why reporting reaches the smaller supplier too
Here the opening thesis returns. Even though most Slovak suppliers will have no reporting duty of their own after Omnibus, they will not sit outside the CSRD’s reach. The reason is Scope 3 — emissions and impacts across the value chain. The ESRS require a large reporting company to account for impacts at its suppliers and customers, not only in its own operations. A large customer that is in scope therefore needs ESG data from its suppliers in order to assemble its own report at all.
For Slovakia this mechanism has a concrete shape. The country is one of the world’s most automotive-intensive economies, and its industry is deeply tied to major carmakers — Volkswagen in Bratislava, Kia in Žilina, Jaguar Land Rover in Nitra, Stellantis in Trnava and the planned Volvo Cars plant near Košice. Each of these makers carries its own decarbonisation targets and its own Scope 3 agenda. On an expert reading of the chain (this is interpretation, not a legal norm), even a smaller Tier 2 or Tier 3 supplier that meets no threshold of its own is effectively drawn into reporting — through questionnaires, contract clauses and requests for the carbon footprint of deliveries. In practice, an „ESG clause“ in an OEM purchase order is a more effective trigger than any statutory limit.
The Omnibus package softens this asymmetry in part. It introduces a value-chain cap: a large reporting company should not require from smaller sub-threshold firms more data than the voluntary simplified VSME standard sets out (per secondary analyses from KPMG and Accountancy Europe). The aim is to prevent the administrative load from „trickling down“ onto small firms in the full ESRS scope. For a Slovak supplier the practical conclusion follows: preparing a manageable but consistent dataset along VSME logic — energy use, emissions, basic social and governance indicators — is a more realistic strategy than hoping the chain’s request never arrives. Sustainability data is becoming part of a supplier’s commercial fitness, not merely an accounting obligation.
What this means for a Slovak supplier
First conclusion: the delay and the raised threshold are real, but should not be read as „the CSRD does not concern us“. For most Slovak suppliers, an own statutory duty after Omnibus either shifts to financial year 2027 (second wave, statements in 2028) or falls away entirely (smaller firms below the new threshold). Value-chain pressure through Scope 3, however, remains — and arrives faster than the legislation.
Second conclusion: the timeline is open. As of 2 July 2026, the „Stop-the-clock“ Directive (EU) 2025/794 and the substantive Omnibus I are both adopted at EU level (Council of the EU, 24 February 2026), yet Slovakia’s transposition of the substantive part into Act No. 431/2002 Coll. has a deadline as late as 19 March 2027 and is not closed; the ESRS are being revised in parallel. A company that fixes precise numbers and dates today risks planning against an interim state.
Third conclusion: regardless of which wave a firm falls into, it is worth starting with a handful of reliable indicators — energy and water use, direct and purchased emissions, basic workforce and governance data. These are precisely the figures large buyers in the automotive and logistics chains will request from suppliers, and precisely what the simplified VSME standard is built around. For a foreign investor entering the Slovak market through supply to local OEMs, this is a practical due-diligence item: a supplier’s ability to provide consistent ESG data is becoming a precondition of the contract, not an add-on to it.
Symbol Consulting is tracking the transposition of Omnibus into Slovakia’s Accounting Act and the revision of the ESRS, and will update this overview as the timeline settles. Until then, for any decision that bears on reporting, the current wording should be verified on Slov-Lex at the moment of that decision.
This article is for general information only and does not constitute legal, tax or financial advice.
Sources & data: Directive (EU) 2022/2464 (CSRD); Directive (EU) 2025/794 („Stop-the-clock“); Omnibus I — Council of the EU press release and Official Journal of the EU, 24–26 February 2026; Act No. 105/2024 Coll. and Act No. 431/2002 Coll. on Accounting, Act No. 256/2025 Coll. (verify on Slov-Lex); ESRS. Secondary analyses (marked as secondary): LeitnerLeitner, KPMG Slovakia, Accace, Grant Thornton Slovakia, Bureau Veritas, Clifford Chance, Accountancy Europe, Prosman & Pavlovič, RSM SK, SKDP. As of 2 July 2026.