New obligations for employers in connection with the implementation of the CSRD directive
Legislative work is underway on an amendment to the Act amending the Accounting Act, the Act on Statutory Auditors, Audit Firms and Public Supervision and Certain Other Acts.
One of the objectives of the amendment is to implement the Corporate Sustainability Reporting Directive (CSRD), which will result in a new obligation for employers to report on corporate sustainability. Depending on the number of employees, employers will be required to provide information on environmental, social and human rights issues and corporate governance. Analysis of the social issues will be important from an employment law perspective.
In particular, the following must be reported:
- the way in which the interests, views and rights of company employees are taken into account and their impact on the entity's strategy and business model,
- implemented internal procedures and policies,
- the characteristics of employees and other persons employed by the company (in particular the number of permanent and temporary employees broken down by gender, the number and turnover rate of employees during the reporting period),
- the gender distribution of positions at the highest levels of the entity's corporate structure and the number of employees in each age group: under 30, between 30 and 50 and over 50,
- the remuneration of employees in the company, including pay differences between female and male employees,
- participation of people with disabilities in employment,
- scale of employee accidents,
- discrimination incidents, including bullying, and human rights violations.
The above reporting obligation will be introduced in three stages:
- public interest companies with more than 500 employees that are already covered by the Non-Financial Reporting Directive (NFRD) will report in 2025,
- large companies not previously subject to the NFRD, with more than 250 employees or a certain turnover and balance sheet total, will report in 2026,
- smaller listed companies and other businesses will also have to report, in 2027.
The draft is currently at the assessment phase.