Hungarian ESG Act

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The Hungarian ESG Act (Act CVIII of 2023) introduces reporting and due diligence obligations. The regulation is designed to ensure that companies identify and assess sustainability-related risks across their own operations and value chains, and, based on these assessments, implement appropriate preventive and mitigation measures.

 

Scope of application – Who is affected?

The regulation primarily imposes direct obligations on large companies, whit indirect impacts on suppliers.

Directly in-scope companies include:

Large undertakings classified as public-interest entities meeting at least two of the following criteria (based on the previous two financial years):

- More than 500 employees
- Net turnover exceeding HUF 20 billion
- Total balance sheet exceeding HUF 10 billion
Large companies meeting all three of the following criteria (based on the previous two financial years):

- More than 500 employees
- Net turnover exceeding HUF 90 billion
- Core activity specified under Annex 1 of Act CVIII of 2023

Reporting requirements:

  • The ESG report must be prepared and subject to assurance within six months following the end of the financial year.
  • From the 2026 financial year, ESG reports must be published on company websites.


The BDO approach:

We support clients in building a structured and practical ESG compliance framework through the following steps:

1
Materiality assessment
2
Completion of ESG questionnaires
3
Supply chain due diligence and pre-qualification
4
Risk assessment and prioritisation
5
Development of action plans
6
Establishment of ESG systems and processes design
7
Preparation of the ESG report and assurance support

Implementation timeline

A comprehensive ESG compliance project typically requires 6 to 12 months. Early preparation is therefore essential to ensure the compliance.

 

Consequences of non-compliance

Compliance with the ESG Act is monitored by the Supervisory Authority for Regulated Activities (SARA) . Non-compliance may result in significant financial penalties and regulatory sanctions, including:

  • Requesting information beyond the scope of the official ESG questionnaire
  • Conducting ESG data collection from micro and small enterprises before 30 June 2027
  • Failure to submit completed questionnaires to SARA
  • Failure to register ESG consultants or clients where required
  • Failure to implement a supplier readiness programme prior to issuing questionnaires

Penalties may range from HUF 200,000 to HUF 50 million.


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How can BDO support you?

ESG compliance is a complex, cross-functional process requiring coordinated legal, operational, and data-related capabilities. With the right support, it can be implemented in a structured, transparent, and efficient manner.


We support our clients in:

- Assessing regulatory exposure

- Defining the compliance roadmap

- Establishing required systems and processes

- Preparing ESG reporting and supporting assurance readiness


Get in touch with us to start your ESG compliance preparation in a timely and structured way.

 

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