Summary
Details
- Greece
Law 4403/2016 is binding for large public-interest entities (PIEs) that meet defined size thresholds.
Obligated entities must:
Prepare an annual non-financial statement at individual and, where applicable, consolidated level.
Disclose policies, risks and performance indicators on the required ESG topics.
Follow the “comply or explain” principle when no policy exists for a required area.
Ensure the statutory auditor checks the presence of the statement (at least limited involvement).
Scope (high level): Entities of public interest (listed companies, banks, insurers and other PIEs) that exceed specified thresholds (more than 500 employees and financial size criteria).
Exceptions:
Small and medium-sized enterprises below the thresholds are not directly required to publish a non-financial statement.
Subsidiaries can be exempt at individual level if included in a compliant consolidated non-financial statement prepared by their parent.
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What’s Required
Law 4403/2016 transposes the EU Non-Financial Reporting Directive (2014/95/EU) into Greek law. It requires certain large companies and groups to disclose non-financial information on environmental, social, and employee matters, human rights, anti-corruption and bribery, and diversity.
In-scope entities must prepare a non-financial statement that forms part of the management report or is published as a separate report referenced by the management report.
The statement must describe:
Business model and main non-financial risks.
Policies, outcomes, and key performance indicators for environmental and social matters.
Human-rights due diligence and anti-corruption measures.
Diversity policy for administrative, managemen,t and supervisory bodies.
Important Deadlines
The law applies to financial years starting in 2017, following its adoption in July 2016.
Non-financial statements must be published within the same deadline as annual financial statements, typically within a few months after the financial year-end.
Current Status
Law 4403/2016 remains in force and is the current legal basis for mandatory ESG reporting in Greece until full transposition of the Corporate Sustainability Reporting Directive (CSRD).
Greek regulators and the Athens Stock Exchange encourage companies, especially listed ones, to move toward CSRD and ESRS-aligned reporting, but Law 4403/2016 still sets the minimum legal requirements.
Penalties for Non-Compliance
Failure to publish the non-financial statement, late publication or materially incomplete information can trigger administrative fines, which may reach up to several million euros for serious cases.
Additional enforcement tools include orders to correct or re-issue reports and potential liability for directors in cases of serious misstatements.
Examples of Known Violations
Public sources mention general shortcomings (insufficient detail on ESG risks, weak metrics, lack of human-rights due diligence) rather than named sanction cases.
The law has nonetheless driven a steady increase in formal sustainability and non-financial reporting among large Greek companies, especially listed entities.
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