The ESG report may be audited by an ESG auditor listed in the Authority’s (Supervisory Authority for Regulatory Affairs (abbreviated in Hungarian: SZTFH) register of ESG auditors. Previously, there was no legislation in force laying down detailed provisions on the register of ESG auditors, which has now changed significantly.
On 26 December 2025, an SZTFH decree on the register of ESG auditors entered into force. Accordingly, ESG audits may only be performed by ESG auditors accredited by the National Accreditation Authority and listed in the Register of Auditors maintained by SZTFH. The procedure for registering an ESG auditor in the Register of Auditors is initiated upon request, which may be submitted on a form designated for this purpose. The registration of an ESG auditor is valid for five years and may be renewed for additional five-year periods.
The activities of ESG auditors are regulated by a government decree that entered into force also on 26 December 2025. Based on this, prior to commencing the ESG audit, the ESG auditor shall conduct a readiness assessment to determine the resources required to perform the ESG audit and prepare an audit plan. The ESG auditor shall then verify compliance with the requirements set out in the government decree and conduct at least one on-site inspection. The audit concludes with a report documenting the results of the audit. If the report finds the ESG report to be compliant, the ESG auditor issues an assurance opinion on the ESG report, i.e. an ESG certificate. The ESG auditor shall conduct the audit within 45 days of receiving the ESG report.
An important conflict of interest rule is that a legal entity and its related persons may not perform ESG audit activities for an enterprise or its subsidiaries where they act or have acted as ESG advisors in relation to a given report in two consecutive financial years. Annex 2 to the decree sets out further conflict of interest rules.
It is also important that the SZTFH decree establishing the detailed rules for companies' sustainability due diligence obligations was also amended on 22 December 2025. Due to the diversity of ESG, the relevant legislation is constantly changing and may change, so it is worth monitoring the updates.