On 2 September 2025, Act No. 317/2025 Coll. was published in the Collection of Laws, concerning the establishment and operation of a European single access point (ESAP). This Act introduced, among other things, a new Section 21c into the existing Accounting Act.
Act No. 317/2025 Coll., which amends certain financial market laws in connection with the establishment and operation of the European single access point, transposes European directives and regulations and introduces changes to a total of 16 laws, including the Banking Act, the Insurance Act, the Capital Market Supervision Act, the Bonds Act, and other acts. For our purposes, the amendment to Act No. 563/1991 Coll., on Accounting, is of particular interest.
Within the European single access point (ESAP), financial and sustainability-related information will be consolidated in a single publicly accessible location. The aim is to support the integration of EU capital markets, improve access to financing for European companies, and enable individuals to invest safely over the long term. ESAP is intended not only for investors but for all interested stakeholders and the general public. Access to information in ESAP will therefore be open to everyone, without restrictions and free of charge.
The approved law represents the second phase of ESAP implementation, centralising the location and standardising the format of data that entities are already required to disclose, without imposing any new content-related reporting obligations.
A new Section 21c – Access to Documents via the European Single Access Point – is being added to the existing Accounting Act. It requires specified reporting entities to submit certain documents to the Czech National Bank for immediate availability through ESAP upon their publication.
It applies to reporting entities required to publish an individual or consolidated sustainability report, or an individual or consolidated sustainability report of a third-country entity. Currently, the new obligation would apply to companies, savings and credit cooperatives, and insurance companies that are public-interest entities, meet the criteria for a large reporting entity, and have an average of more than 1,000 employees during the reporting period as of the balance sheet date.
In principle, it concerns all documents that are currently published in the Collection of Deeds, i.e., individual and consolidated annual reports, financial statements, all auditor’s reports (on statutory audits and the sustainability report assurance), all sustainability reports (if not included in the annual report), and the report on payments to the government of an EU Member State or a third country.
Reporting entities will submit the documents in a machine-readable format (XHTML). Details regarding the format and method of submission to the Czech National Bank will be specified in a decree issued by the Czech National Bank, which is not yet available.
The section of the law concerning the amendment to the Accounting Act will take effect on 10 January 2028.
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