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ESG (Environmental, Social, Governance) and CSRD reporting are no longer voluntary initiatives. With the adoption of Greek Law 5164/2024, which transposes the EU Corporate Sustainability Reporting Directive (CSRD), Greece has entered a new era of mandatory, audited, and standardised sustainability reporting.
For management teams across Greece, understanding this framework is now a strategic requirement. Even companies not directly subject to the law will be impacted through supply-chain obligations and partner demands.
1. Who Is Directly Affected?
Law 5164/2024 revises the size criteria of Law 4308/2014. A company is classified as a large entity if, for two consecutive financial years, it exceeds at least two of the following:
- €25 million total balance sheet
- €50 million net turnover
- 250 employees (average)
While these thresholds define direct obligations, indirect impact is far broader. Large companies will require verified sustainability data from their suppliers—meaning SMEs must prepare as well to avoid losing key partnerships.
2. Compliance Timeline
Implementation follows a phased plan:
- 2025 reporting (for FY 2024): Large public-interest entities (>500 employees) already under NFRD
- 2026 reporting (for FY 2025): All other large entities—this is the major expansion point
- 2027–2029: Gradual inclusion of listed SMEs and specific non-EU parent companies
For many companies, data collection began on 1 January 2025, making early preparation essential.
3. What Does Compliance Involve?
CSRD compliance requires a structured approach built on three pillars:
- Double Materiality Assessment
Companies must assess what is material both:- Financially (outside-in): How sustainability risks affect the business
- In terms of impact (inside-out): How the business affects society and the environment
- Reporting Based on ESRS Standards
Reports must follow the strict European Sustainability Reporting Standards, defining specific disclosures and indicators. - Mandatory Assurance
Sustainability reporting must undergo statutory audit, placing ESG data under the same scrutiny as financial statements.
This demands internal systems, policies, and controls equivalent to those used for financial reporting.
4. Legal & Operational Risks of Non-Compliance
Law 5164/2024 introduces significant consequences:
- Criminal liability for false or incomplete reporting (up to 3 years' imprisonment)
- Administrative fines up to €100,000 for inpiduals and €500,000 for legal entities (with doubling for repeated offenses)
- Professional sanctions, including temporary bans for management and auditors
Beyond legal exposure, non-compliance may impact bank financing and investment readiness, as ESG performance is increasingly linked to risk assessment.
Conclusion
CSRD is not only a regulatory shift but a strategic opportunity. Companies that act early can strengthen risk management, improve access to capital, and gain a competitive edge.
Given the complexity of the standards and the heightened legal responsibilities, continuous specialised support, legal, financial, and operational, will be essential for a smooth transition.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
