Austria transposed the Corporate Sustainability Reporting Directive (CSRD) through amendments to the Unternehmensgesetzbuch (UGB) in 2024. Large listed Austrian companies reported for FY 2024 in 2025. Following the Omnibus I simplification directive (in force 18 March 2026), mandatory CSRD reporting is confined to undertakings with more than 1,000 employees and net turnover above €450 million. Those Wave 2 companies now report for FY 2027 (published 2028). The separate listed-SME reporting track has been removed. Companies below the 1,000-employee, €450 million thresholds, including most small and mid-sized businesses, are not CSRD filers, but they are drawn in through supplier data requests from larger Austrian and German clients.
This guide is for anyone dealing with CSRD in Austria. If you run an in-scope company, it sets out the thresholds, timeline, and submission rules that apply to you. If you are a supplier or a smaller business pulled in through procurement, it explains how to respond proportionately using the Voluntary Sustainability Reporting Standard for SMEs (VSME) rather than taking on the full ESRS scope. Advisers will find the Austrian specifics, the UGB transposition, and the FMA’s supervisory role covered throughout, with notes in both English and German (DE/EN).
1. CSRD in the Austrian Context
Austria began implementing the CSRD into national law in 2024, through amendments to the Unternehmensgesetzbuch (UGB) and related auditing regulations. These changes align Austria with the EU-wide sustainability reporting framework defined in Directive (EU) 2022/2464.
Timeline for Austrian Companies
| Company Type | First CSRD Report | Reporting Year | Assurance Required |
|---|---|---|---|
| Wave 1: large public-interest entities (FY 2024) | 2025 | FY2024 | Limited assurance |
| Wave 2: companies above 1,000 employees and €450m turnover | 2028 | FY2027 | Limited assurance |
| Smaller businesses (VSME) | Voluntary | Any year | Optional |
Wave 1 entities that have fallen below the new 1,000-employee and €450 million thresholds can use an optional transitional exemption for FY 2025 and FY 2026, subject to how Austria implements it. On 3 July 2026 the European Commission adopted the revised, simplified ESRS delegated act: it applies to financial years starting 1 January 2027 (with early adoption from FY 2026) and is in the Parliament and Council scrutiny period. Wave 2 Austrian companies will therefore report against the simplified ESRS, under which only ESRS 2 remains mandatory for all reporters and every topical standard applies only where the double materiality assessment flags it. For the full picture of what Omnibus I changed, see what the CSRD Omnibus changed.
In Austria, the FMA (Financial Market Authority) and the Austrian Chamber of Accountants (KSW) oversee compliance, assurance, and guidance for auditors.
2. Size Thresholds for CSRD Applicability in Austria
After the Omnibus I changes, an undertaking falls within mandatory CSRD scope only where it meets both of the following thresholds:
| Criterion | Austrian Threshold |
|---|---|
| Average number of employees | More than 1,000 |
| Net turnover | Above €450 million |
National law implements the EU directive, so these EU-wide thresholds apply in Austria through the UGB. The earlier “two of three” test based on 250 employees, €50 million turnover and €25 million balance sheet no longer determines who must report under CSRD.
If your company exceeds these thresholds, you will report under the ESRS (European Sustainability Reporting Standards).
If you are below them but supply to larger companies, expect to provide sustainability information as part of their Scope 3 or value chain reporting.
3. The Voluntary SME Standard (VSME) – Simplified Reporting
The VSME Standard, developed by EFRAG, enables Austrian small and growing businesses (SMEs) to disclose sustainability data in a lighter, modular format. It is widely used by family-owned firms and by suppliers answering client requests.
VSME also carries legal weight under Omnibus I: it caps the sustainability data a CSRD-reporting company may demand from a value-chain partner with 1,000 or fewer employees. On 3 July 2026 the Commission adopted the delegated act turning VSME into the Voluntary Standard (VS), which applies from financial years starting 1 January 2027. See what changes when VSME becomes the VS.
Core Modules
| Module | Focus | Example Data |
|---|---|---|
| Basic Module (B1–B11) | Core environmental, social, and governance disclosures | Energy and GHG (B3), water (B6), waste (B7), workforce (B8–B10), governance (B11) |
| Comprehensive Module (C1–C9) | Advanced disclosures for firms with ESG-focused clients or lenders | Climate targets (C3), climate risks (C4), value chain (C7), human rights (C6) |
The VSME template can be completed in German or English, and data can be published as part of your annual management report or shared with business partners directly.
4. Reporting and Submission in Austria
For companies under mandatory CSRD:
- Reports must be submitted digitally to the Austrian Business Register (Firmenbuch) together with financial statements.
- Reports must follow the XHTML format and include an assurance statement by an accredited statutory auditor (Wirtschaftsprüfer).
- Content must comply with the ESRS standards adopted by the EU Commission; from FY 2027 that means the revised, simplified ESRS.
For VSME voluntary reporters:
- No official submission is required.
- Reports can be shared directly with banks, clients, or investors upon request.
- Documentation and evidence should be retained for at least seven years, following Austria’s accounting retention rules.
5. If you’re a supplier: how to respond
If your company exceeds the 1,000-employee and €450 million thresholds, your obligations are the mandatory ESRS path set out in sections 2 and 4. If you fall below them, you are not a CSRD filer, but larger Austrian and German clients will still ask for sustainability data through procurement. The steps below set out how to prepare a proportionate VSME response. An ESG answer bank is built for exactly this, letting small businesses reuse one set of answers across the customer and bank requests they receive.
Step 1: Check your reporting scope
Confirm whether your company exceeds the 1,000-employee and €450 million turnover thresholds. If not, you are not a CSRD filer and can use voluntary reporting under VSME to answer requests.
Step 2: Focus on priority topics
Start with core areas such as energy, workforce, and governance, which are relevant for nearly all industries.
Step 3: Build internal data processes
Use simple data templates to collect:
- Energy and fuel invoices
- Waste disposal records
- Payroll and HR data
- Supplier declarations
For workflow setup, see How to Integrate CSRD Data Collection into Existing Workflows.
Step 4: Plan for external requests
Large Austrian clients (especially manufacturers, construction, and retail) will increasingly ask for sustainability metrics. Having your VSME data ready will save time and strengthen supplier relationships.
Step 5: Engage your auditor early
Your financial auditor (Wirtschaftsprüfer) can help align sustainability disclosures with accounting and assurance requirements.
6. Local Resources and Support
- Kammer der Steuerberater und Wirtschaftsprüfer (KSW) – Guidance for auditors and SMEs on CSRD implementation.
- Wirtschaftskammer Österreich (WKÖ) – Offers workshops and practical CSRD toolkits.
- Bundesministerium für Arbeit und Wirtschaft (BMAW) – Publishes official Austrian CSRD guidance and translations.
- Austrian Standards Institute – Translations and references to ESRS standards.
- Regional chambers (WKO Landesstellen) – Local business support for SMEs adopting the VSME standard.
7. Beispiel: CSRD-Bericht (Kurzfassung auf Deutsch)
Unternehmen: ABC Maschinenbau GmbH Berichtsjahr: 2025 Mitarbeiterzahl: 85 Energieverbrauch: 120.000 kWh Strom, 18.000 Liter Heizöl Abfallaufkommen: 6,5 Tonnen (davon 4,2 Tonnen recycelt) Schulungen: 12 Stunden pro Mitarbeiter im Jahr Diversity: 22 % Frauenanteil, 10 % Führungskräfte Frauen Governance: Verhaltenskodex aktualisiert im April 2025
This simple summary meets VSME expectations and demonstrates progress transparently without requiring a full ESRS report.
Frequently Asked Questions
Is CSRD mandatory for Austrian SMEs?
No. Only undertakings above 1,000 employees and €450 million net turnover are required to report under CSRD. Smaller businesses are not CSRD filers and can voluntarily report using the VSME framework, which is the usual way to answer ESG requests from clients and banks.
Can reports be published in English?
Yes. Austrian law accepts English-language CSRD reports, although companies may choose to provide German versions for local stakeholders.
Do SMEs need an auditor for VSME reports?
No, but voluntary limited assurance can enhance credibility, especially for supplier or financing relationships.
How long must CSRD data be stored?
At least seven years, consistent with Austrian accounting and audit record retention rules.
Key Terms
- CSRD (Corporate Sustainability Reporting Directive) – EU directive harmonising sustainability reporting.
- VSME Standard – Simplified framework for voluntary SME reporting.
- ESRS – European Sustainability Reporting Standards.
- Wirtschaftsprüfer – Statutory auditor responsible for assurance.
- Limited assurance – Moderate-level verification confirming plausibility of data.
Conclusion
CSRD in Austria now splits cleanly into two readerships. In-scope undertakings above the 1,000-employee and €450 million thresholds report under ESRS, submit through the Firmenbuch, and obtain limited assurance from a Wirtschaftsprüfer. Everyone else, including most suppliers and smaller businesses, meets CSRD through the data requests of larger clients rather than any filing obligation of their own.
If you are in scope, engage your finance and audit partners early and align disclosures with the ESRS timeline. If you are responding to requests, start small with the VSME Standard and focus on essential data. Either way, the pragmatic approach keeps reporting simple, compliant, and credible.
To plan your company’s reporting cycle, refer to the Annual CSRD Reporting Calendar.