Medium Companies and Sustainability Reporting in Romania
Updated: 5 days ago
Authors: Cristian Ormindean, Bogdan Nastase
Updated on 2 November 2026. We first published this article in August 2024, under the timetable set by Order 85/2024. Order 1281/2026 has since narrowed the scope of sustainability reporting, and the text below reflects the rules in force on the date of the update.
Short answer: a Romanian medium-sized company does not have to publish a sustainability report. After Order 1281/2026, the obligation applies to entities that exceed both a net turnover of RON 2,250,000,000 and an average of 1,000 employees, and to parent companies of groups that exceed both thresholds on a consolidated basis.
Who reports, and from which financial year
Financial years beginning between 1 January 2024 and 31 December 2026: public-interest entities that exceed the large-entity criteria and an average of 500 employees, and public-interest entities that are parents of a large group with more than 500 employees on a consolidated basis. For financial years beginning in 2025 and 2026, those that do not exceed a net turnover of RON 2,250,000,000 or an average of 1,000 employees may opt out.
Financial years beginning on or after 1 January 2027: entities that, at the balance sheet date, exceed both a net turnover of RON 2,250,000,000 and an average of 1,000 employees during the financial year, and parent companies of groups that exceed both thresholds on a consolidated basis.
Financial years beginning on or after 1 January 2028: Romanian subsidiaries and branches of non-EU undertakings, where the non-EU group generated an EU net turnover above RON 2,250,000,000 in each of the last two consecutive financial years and the Romanian subsidiary or branch exceeded a net turnover of RON 1,000,000,000 in the preceding financial year.
Financial year other than the calendar year: the rules apply from the first financial year that begins after 1 January 2027 or 1 January 2028, as applicable.
What a medium-sized company should expect
The direct reporting obligation falls away, but data requests from customers do not. A reporting customer must cover its value chain, so a Romanian supplier may still receive questionnaires on emissions, energy use or workforce data.
A supplier with an average of no more than 1,000 employees in the previous financial year, assessed at individual level, is a protected entity. It may refuse to provide information beyond the voluntary reporting standards referred to in Article 29ca of Directive 2013/34/EU, and a contract clause requiring more is not binding. The reporting customer may rely on the supplier's self-declaration. A subsidiary cannot claim protected status towards its own parent company when the parent is subject to sustainability reporting. We explain how to answer such requests in Your customer asks for ESG data: what a Romanian supplier can be asked for after Order 1281/2026.
The statutory auditor's role
Where an entity reports, its statutory auditor gives an opinion based on a limited assurance engagement on whether the sustainability reporting complies with the applicable requirements, including the sustainability reporting standards adopted by the European Commission and the disclosures under Article 8 of Regulation (EU) 2020/852. The auditor does not ask a protected entity for information beyond the voluntary standards. For the background, see Romania Aligns with CSRD: Law 137/2025 Expands the Role of Statutory Auditors.
Sources
Order of the Minister of Finance no. 1281/2026 on the simplification of sustainability reporting, Official Gazette of Romania, Part I, no. 858 of 13 October 2026, in force from 13 October 2026 (Article III amends Article II of Order 85/2024).
Order of the Minister of Finance no. 85/2024 on sustainability reporting, Official Gazette of Romania, Part I, no. 75 of 26 January 2024, as amended.
Directive (EU) 2026/470 of 24 February 2026 amending Directives 2006/43/EC, 2013/34/EU, (EU) 2022/2464 and (EU) 2024/1760, on EUR-Lex.
Piroi audits Romanian subsidiaries of international groups. To check whether a Romanian entity falls within scope from 2027, contact our audit team.
