As a result, SMEs of public interest are generally not required to comply with the obligations applicable to “enterprises” under the ESG Act. This modification is in accordance with the Omnibus package adopted on 26 February 2025 by the European Commission, which aimed to remove around 80% of companies from the scope of the CSRD and to ensure that sustainability reporting requirements for large companies will not burden smaller companies in their value chains.
However, an organization is also required to comply with the provisions of the ESG Act if it voluntarily undertakes to provide ESG data in accordance with the ESG Act – whether based on a unilateral legal declaration or a contract – or if legislation requires it to provide ESG data. Furthermore, the scope of the ESG Act extends to organizations that request ESG data provision from another organization, provided that the content of such data falls within the scope of the ESG Act. In addition to the above, other circumstances may also establish that an entity still falls under the scope of the ESG Act.
Based on the above, SMEs may also fall under the scope of the ESG Act, even on a voluntary basis. For SMEs, compliance with ESG requirements represents a proportionally greater burden, which is why, coordinated by the Győr-Moson-Sopron County Chamber of Commerce and Industry and supported by the Enterprise Development Project, an “ESG Toolkit” was published, offering practical assistance in preparing for sustainability tailored specifically to the needs of Hungarian SMEs.
According to the Chamber of Commerce and Industry’s website, the purpose of the ESG toolkit is to provide SMEs with a unified, easy-to-use framework for taking the first steps toward ESG readiness. The package contains six interrelated Excel templates that together cover the fundamental logical steps of a sustainability assessment: from identifying stakeholders to developing a strategic action plan. The templates provide a general, sector-neutral framework. They were designed to be understandable on their own, but they do not replace a detailed, company-specific methodology. These tools follow the guidelines of the ESG Act and the ESG guidelines issued by the Supervisory Authority for Regulatory Affairs (abbreviated in Hungarian: SZTFH), and are based on their systemic logic.