ESG & Sustainability Reporting in Greece
ESG regulation in Greece is no longer aspirational – it’s mandatory, and the framework that governs it has shifted significantly in the past year. If you’re operating a company in Greece or have Greek subsidiaries, you need to understand what’s required, what’s coming, and what the recent EU simplification package means for your obligations. We advise on ESG compliance as a legal matter – regulatory obligations, governance structures, reporting requirements, and transaction-related ESG risks – not as a branding exercise.
The regulatory landscape – where things stand
Greece has transposed the CSRD into national law through Law 5164/2024 (effective December 2024), making sustainability reporting mandatory for in-scope companies. The Ministry of Development issued implementing guidance in January 2025, aligning Greek reporting standards with the European Sustainability Reporting Standards (ESRS).
But the ground has already shifted. The EU’s Omnibus Simplification Package, agreed in December 2025, substantially narrows the scope of mandatory reporting:
Who must report now. Wave 1 companies – large public-interest entities with over 500 employees (banks, insurers, listed companies already subject to the prior NFRD regime) – are already reporting under CSRD for the 2024 financial year, with first reports published in 2025. This hasn’t changed.
Who gets more time. The “Stop-the-Clock” Directive (transposed by member states by 31 December 2025) postponed reporting obligations for Wave 2 (large companies) and Wave 3 (listed SMEs) by two years. Wave 2 companies will now first report in 2028, covering the 2027 financial year.
Who falls out of scope entirely. Under the revised CSRD thresholds agreed in the Omnibus package, mandatory reporting will apply only to EU companies with more than 1,000 employees and over €450 million in net annual turnover. This reduces the number of companies in scope across the EU by roughly 80%. Wave 1 companies that no longer meet these higher thresholds may be exempt for the 2025 and 2026 financial years, pending national transposition.
The CSDDD. The Corporate Sustainability Due Diligence Directive – which imposes supply chain human rights and environmental due diligence obligations – has been pushed back to July 2028 for transposition, with compliance required from July 2029. Its scope is now limited to companies with over 5,000 employees and €1.5 billion in net turnover.
The practical effect: most Greek companies outside the financial sector and the Athens Exchange’s largest listings are no longer subject to mandatory CSRD reporting in the near term. But “not mandatory” does not mean “not relevant.”
CORPORATE GOVERNANCE : LAW 4706/2020
For companies listed on the Athens Exchange, ESG governance isn’t new – it’s been a legal requirement since Law 4706/2020 took effect in July 2021.
The law requires listed companies to adopt suitability and diversity policies for board composition (including a minimum 25% gender representation, raised to 33% for larger companies under the 2025 amendment via Law 5178/2025), establish audit, nomination, and remuneration committees with independent non-executive members, implement an internal corporate governance system including a sustainable development policy, and adopt the Hellenic Corporate Governance Code (2021 version), which operates on a comply-or-explain basis and includes specific ESG and sustainability provisions.
The Hellenic Capital Market Commission (HCMC) supervises compliance and has issued extensive guidance, circulars, and Q&As since 2021. Non-listed companies may also voluntarily adopt the Law 4706/2020 framework – and increasingly do so to attract investors and institutional partners who expect governance standards comparable to listed peers.
WHY IT STILL MATTERS – EVEN IF YOU’RE NOT IN SCOPE
The narrowing of mandatory CSRD scope doesn’t eliminate ESG pressure – it redistributes it. Companies outside the reporting threshold still face ESG requirements through several channels: as value chain partners of in-scope companies who need sustainability data from their suppliers and counterparties; through banking and financing relationships, where Greek and European banks increasingly require ESG disclosures as a condition of lending; in M&A and investment contexts, where ESG due diligence is now standard practice; and through the EU Taxonomy Regulation, which defines what qualifies as an environmentally sustainable economic activity and affects access to “green” financing instruments.
For companies preparing for a future listing, seeking institutional investment, or operating in sectors with direct environmental exposure (energy, real estate development, shipping, tourism), voluntary ESG reporting and governance alignment are increasingly commercial necessities rather than regulatory obligations.
WHAT WE DO
We provide legal advice on the specific ESG obligations that apply to your company under Greek and EU law. This means identifying whether and when CSRD reporting applies to your operations, advising on corporate governance compliance under Law 4706/2020 and the Hellenic Corporate Governance Code, drafting sustainability policies, codes of conduct, and board governance frameworks, conducting ESG due diligence in M&A and financing transactions, reviewing sustainability disclosures for legal risk and regulatory compliance, and monitoring the evolving regulatory landscape – including the Omnibus implementation timeline – so you know when obligations shift.
We don’t offer sustainability consulting, carbon accounting, or ESG ratings advisory. We handle the legal framework: what the law requires, what your governance structure needs to look like, and what your legal exposure is.
Contact us if you need clarity on your ESG obligations in Greece. The regulatory picture is moving fast, and the difference between what applied a year ago and what applies today is significant.
Frequently Asked Questions
Which ESG regulations apply to my company?
This depends on your size, structure, sector, and activities. Large companies and listed entities face the most extensive obligations under CSRD, CSDDD, and the Taxonomy Regulation, but mid-sized companies are increasingly captured—either directly through phased implementation timelines or indirectly as suppliers to regulated entities. Sector-specific rules apply in areas like energy, finance, and telecommunications. We assess your particular situation and identify exactly which frameworks govern your operations.
When do we need to start complying with CSRD?
CSRD applies in phases. Companies already subject to the Non-Financial Reporting Directive must comply for financial years starting January 1, 2024. Large companies not previously covered follow for years starting January 1, 2025. Listed SMEs have until January 1, 2026 (with a potential opt-out until 2028). The first reports under these timelines are published the following year. If you’re approaching a compliance deadline, preparation should begin immediately – building systems and gathering data takes longer than most companies anticipate.
What is double materiality and why does it matter?
Double materiality is the foundation of CSRD reporting. It requires assessing sustainability matters from two perspectives: impact materiality (how your business affects people and the environment) and financial materiality (how ESG issues affect your financial performance). You report on matters that are material from either perspective. This is a significant departure from traditional financial reporting and requires structured processes, stakeholder engagement, and often challenging judgments. Getting it wrong creates regulatory risk and stakeholder criticism.
Do we need external assurance for our sustainability reporting?
Under CSRD, yes – limited assurance initially, moving to reasonable assurance in the future. This means auditors or assurance providers will verify your disclosures, much like financial statement audits. The assurance requirement significantly raises the stakes for accuracy and creates legal exposure if disclosures are materially misstated. We help clients prepare for assurance by ensuring underlying data systems, controls, and documentation can withstand scrutiny.
How does CSDDD affect our supply chain relationships?
CSDDD requires companies to conduct human rights and environmental due diligence throughout their value chains. This means identifying actual and potential adverse impacts, taking action to prevent or mitigate them, establishing grievance mechanisms, and monitoring effectiveness. Practically, this requires engaging with suppliers, potentially changing procurement practices, and building systems to track compliance. Non-compliance can result in administrative sanctions and potential civil liability. For companies with complex international supply chains, this is among the most challenging ESG obligations.
What are the risks if we don’t comply with ESG regulations?
The risk landscape is expanding rapidly. Direct regulatory sanctions can include administrative fines, operational restrictions, and in some cases director liability. Capital markets consequences include disclosure violations triggering HCMC enforcement. Contractual exposure arises when you’ve made ESG representations in financing or commercial agreements. Reputational damage from non-compliance or greenwashing allegations can affect customer relationships, investor confidence, and employee retention. Increasingly, ESG failures are becoming materiality triggers in M&A contexts, affecting valuations and deal certainty.
Can we handle ESG compliance internally without external counsel?
Some companies with sophisticated in-house legal and sustainability teams can manage certain ESG workstreams internally. However, most companies benefit from external counsel at least for initial framework design, complex regulatory interpretation, high-stakes disclosures, and transactional matters. ESG regulations are new, detailed, and evolving—even experienced teams face interpretation questions. The cost of getting it wrong typically exceeds the cost of getting advice upfront.
How is ESG different from traditional corporate social responsibility?
CSR was largely voluntary, reputational, and marketing-focused. ESG is mandatory, legally binding, and enforceable. The shift from principles to prescriptive rules, from voluntary disclosure to mandatory reporting with assurance, and from reputational risk to regulatory sanctions fundamentally changes the game. Companies that treat ESG as a rebrand of their CSR programs will find themselves non-compliant.
Contact us today for a free initial discussion
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