Eversheds Sutherland CEE Insights

Introduction

CEE is navigating a more complex – but increasingly defined – economic landscape.

As 2026 unfolds, governments and businesses are recalibrating priorities. Investment momentum is increasingly shaped by the final phase of EU recovery funding, large scale infrastructure programmes, energy transition projects, and a structurally higher focus on defence and security. Traditional manufacturing sectors continue to face pressure, while technology, AI-enabled services, renewables, and critical infrastructure are emerging as key growth drivers.

This environment creates both opportunity and risk.

CEE economies remain exposed to global trade dynamics, regulatory change and fiscal tightening, but they also benefit from resilient domestic demand, improving investor sentiment and renewed clarity around trade and monetary policy. For businesses operating across borders, the challenge is no longer just managing uncertainty – it is making informed strategic decisions in a more disciplined, policy driven environment.

At Eversheds Sutherland, we advise clients across seven CEE jurisdictions, giving us a front row view of how these macro trends translate into legal, regulatory, and transactional realities on the ground. Whether you are reassessing investment plans, managing regulatory change, restructuring operations, or pursuing growth opportunities, our teams are ready to support you in turning today’s complexity into long-term advantage.

We are ready to help you turn challenges into opportunities.

Ewa Łachowska-Brol, Managing Partner – Eversheds Sutherland Poland

Legal updates

Austria

Pay Transparency in Austria: Implementation deadline June 2026 approaching

Pay transparency is set to become a central topic for corporate governance and human resources in the coming years. Although Austria has not yet published a concrete draft law to implement the EU Pay Transparency Directive (Directive (EU) 2023/970), the timeline is clearly defined — and it is tight. The Directive must be transposed into national law by 7 June 2026 at the latest. For companies, this means that compensation structures will increasingly fall under the spotlight of governance, risk management and public scrutiny.

Read more information

---

Bulgaria

Economic performance for 2025 financial year

In 2025, Bulgaria’s economy is estimated to have grown at a stable pace, with GDP expanding up to 3.2% for the third quarter, driven mainly by domestic consumption and public investment as external demand remains relatively weak due to slower growth in key EU trading partners. Pursuant to the latest data from the National Statistical Institute, the unemployment rate for the third quarter of 2025 has been reduced to 3.4%, supported by sustained demand for labour and remains significantly below the EU average of 6%.

For consultation, please contact Irina Tsvetkova, Head of corporate, employment and M&A, Managing Partner – Eversheds Sutherland Bulgaria

VAT registration obligation for EU Suppliers of Goods with Assembly and Installation in Bulgaria

The latest amendments to the Bulgarian VAT Act, effective as of 1 January 2026, repealed the possibility for reverse charge mechanism for supplies of goods with assembly or installation in Bulgaria by EU-established suppliers to Bulgarian VAT registered customers. As a result, the EU suppliers of goods with assembly and installation in Bulgaria will be required to register for VAT purposes in Bulgaria prior to the date on which VAT becomes chargeable and VAT will be chargeable by the foreign supplier, regardless of whether the Bulgarian customer is VAT registered. Exception is provided only for suppliers applying in Bulgaria the EU Small Enterprises mechanism. Even in this case, the Bulgarian customer will not be required to apply the reverse charge mechanism, irrespective of its VAT status.

For consultation, please contact Irina Tsvetkova, Head of corporate, employment and M&A, Managing Partner – Eversheds Sutherland Bulgaria

---

Czech Republic

Czech “Mini-Funds”: Regulatory Update

In 2025, CNB - the Czech regulator updated its guidance on „mini-funds“ to reflect 2024 legislative changes and highlighted several practical implications. The term “mini-funds” typically refers to investment vehicles managed under a registration-only, sub-threshold AIFM regime.

The early-2025 update clarified how the regime applies where a single manager runs more than one investment strategy. The regulator highlighted key practical points: entities must include the Czech “risk capital” wording in their legal name and must not use “fund” (including translations) or other reserved “investment fund” wording. Fundraising is limited, with only a small number of non-qualified investors that may be approached and a minimum commitment threshold for qualified investors. If capital is raised from more than 20 investors, an auditor’s compliance report must be send to CNB. A mid-2025 update also addressed MiCA: holding or investing in crypto-assets within the managed portfolio will usually not require a MiCA CASP licence, but providing crypto-asset services to third parties may. Czech “mini-funds” continue to be a flexible vehicle for various types of investments.

If you need more information, please contact our capital markets experts Lenka Vavřichová or Vojtěch Laga

Zero Emission Buildings

The revised EU Energy Performance of Buildings Directive introduces the new zero emission building standard, which will apply to all new buildings from 2030. The Czech implementation is underway and will bring significant changes to permitting and technical requirements by May 2026. Developers and owners should prepare early, as the new rules may affect costs, project planning and future renovations.

For consultation, please contact partner Dominika Veselá – Eversheds Sutherland Czech Republic.

Changes in criminal liability of legal entities

Effective 1 January 2026, an amendment to the Czech Act on Criminal Liability of Legal Entities introduces new sentencing criteria for corporate offenders. Courts must now consider also the number of employees and the nature of the entity’s business activities when determining both the type and severity of penalties. In addition, courts are required to assess whether the entity had an effective compliance programme in place prior to the offence or implemented one only afterwards. These changes significantly increase the importance of proactive compliance management, as a well designed programme may meaningfully mitigate sanctions.

For consultation, please contact senior associate Eliška Miklíková Eversheds Sutherland Czech Republic.

---

Hungary

In this edition, the Team provides a clear overview of Hungary’s foreign direct investment (FDI) notification requirements, summarizing when notifications are required, which transactions and sectors are affected, and what procedural steps and deadlines apply.

The overview was prepared by Dr Ildikó Szegedi and Dr Gréta Zanócz to support clients in understanding the key points of the Hungarian FDI regime and to assist them in approaching upcoming transactions with greater certainty. Please see our website

Changes to the Cybersecurity Act Clarify Exit Timing for SMEs

As of 6 January 2026, Small and medium-sized enterprises (SMEs) subject to the Cybersecurity Act by virtue of their size and specified activities can now determine with certainty when they cease to fall within its scope. If the size-related conditions triggering coverage under the Act ceases to exist, the organization will exit the Act. For instance, if an organization’s size drops below 50 employees and €10 million in net turnover, it will no longer be subject to the Act as of the end of the second calendar year following the cessation of those conditions. Previously, the exit timing was not clarified.

Hungarian Constitutional Court Reviewed Rules on Health-Related Unfitness for Work – case nr. 1/2025. (II. 27.) AB

In 2025, the Hungarian Constitutional Court annulled a 2023 amendment to the Labour Code that had allowed employers to maintain the employment relationship of medically unfit employees without assigning work, paying wages, or the obligation to provide alternative roles. The Court held that the provision created a legal vacuum in which such workers were denied income and social protection and this resulted in discrimination and violated constitutional guarantees. This decision means that employers must pay remuneration even to employees who are unfit for work for health reasons and therefore cannot be employed in their job, unless they wish to terminate the employment relationship.

Hungarian Supreme Court (Curia) – Immediate Termination of Employment case nr. BH2025. 146.

The Curia ruled that an employer cannot lawfully terminate an employment relationship “with future effect” by labeling a notice as an immediate termination if, at the time of giving notice, the known reasons were sufficiently serious to justify immediate termination. The Court held that allowing termination to take effect at a later date undermines the very purpose of the immediate termination regime, which is to end the employment relationship at the moment serious misconduct makes continuation impossible; a delayed effectiveness is therefore contrary to law and invalid.

426/2025. (XII. 23.) Government Decree – Minimum Wage and Guaranteed Wage Minimum for 2026

The Hungarian Government’s Decree sets the mandatory minimum wage and the guaranteed wage in Hungary, effective from 1 January 2026. Under this decree: 

• The monthly minimum wage for full time employees will be HUF 322,800 (approx. EUR 845).

The guaranteed wage for jobs requiring at least a secondary education or a vocational qualification will be HUF 373,200 (approx. EUR 978) per month.

---

Poland

New construction requirements for energy storage systems

The amendment to the Construction Law Act of 4 December 2025 (the “Amendment”) introduced new provisions governing the construction process for energy storage systems. It specifies which projects require a building permit or notification, and those that require neither. The Amendment also introduces a definition of an energy storage system and new fire safety obligations.

The changes are intended to help investors correctly classify a structure as an energy storage system and, consequently, avoid doubts regarding the fulfilment of obligations to obtain building permits and notifications. The new regulations are also designed to support the integration of renewable sources into the power system. The adopted regulations also contribute to increasing the presence of energy storage systems on the Polish energy market, which fulfils the goals of the energy transition.

For more information, please contact Dr Aleksandra Kunkiel-Kryńska and Marta Gadomska-Gołąb, Corporate Team, Partners - Eversheds Sutherland Poland

SENT reporting obligations for concrete deliveries

The Polish Government adopted a draft act concerning the transport monitoring system SENT, which expands the statutory list of goods subject to monitoring to include concrete. Under the proposed regulations, the SENT system would cover the transport of commercial concrete, i.e. ready-mix concrete and other mixes ready to be poured, spread, installed, incorporated, or otherwise used, including in connection with deliveries to investors.

For more information, please contact Dr Aleksandra Kunkiel-Kryńska and Marta Gadomska-Gołąb, Corporate Team, Partners - Eversheds Sutherland Poland

New regulations concerning Ukrainian citizens signed by the President

President of the Republic of Poland signed the Act of 23 January 2026 on the expiry of measures resulting from the Act on assistance to Ukrainian citizens in connection with the armed conflict in that country and on amendments to certain other acts. The Act provides for the gradual expiry of some of the provisions of the so-called Ukrainian special act and the application of general rules relating to persons enjoying temporary protection in the European Union, regardless of their nationality, to Ukrainian citizens. In addition, the Act provides for the validity of visas and residence permits of Ukrainian citizens to be maintained until 4 March 2027.

For more information, please contact Ewa Łachowska-Brol, Employment Team, Partner - Eversheds Sutherland Poland

---

Romania

Legal updates:

The second fiscal-budgetary reform package proposed by the Romanian Government, aimed at reducing the budget deficit and boosting economic growth, came into effect in December.

Key fiscal provisions include the possibility for companies to be declared inactive for tax purposes if they lack a bank or Treasury account in Romania or fail to submit annual financial statements.

On the corporate side, new rules require limited liability companies to have a minimum share capital of RON 500 for newly established companies and RON 5,000 for existing companies with a net turnover exceeding RON 400,000. New formalities apply to transfers of controlling stakes, the grounds for piercing the corporate veil in cases of abuse have been broadened, and all companies are required to maintain a bank account in Romania.

In terms of labour law, a recent legislative proposal in Parliament aims to address burnout by requiring paid leave for professional recovery. The initiative assigns clear responsibilities to employers in a field currently without dedicated regulation.

---

Slovakia

Preparation for implementation of below-threshold merger reviews (call-in model) in Slovakia

The Slovak competition authority is introducing a “call-in” model for merger notifications, allowing it to require notification even if turnover thresholds are not met, where competition concerns exist. Companies can no longer rely solely on financial thresholds. Implementation is expected no earlier than next year, with soft law guidance planned. Transactions may face delays and extra costs if called in. Voluntary notification is advised for deals that could raise competition concerns.

For more information, please contact Petra Hager, Partner - Eversheds Sutherland Bratislava

Waste shipment undergoes significant changes!

From 21 May 2026, a new European regulation on waste shipments will come into effect, introducing, for example, the following changes:

• All information and documents will be shared via the electronic DIWASS system. Therefore, all companies, carriers, and recovery facilities involved in waste shipments must register in this system.
• Even the transport of so-called “green listed waste” will be monitored and must be notified in DIWASS two working days in advance.

For more information, please contact Annamária Tóthová, Partner - Eversheds Sutherland Bratislava

---

Deal insights

Czech Republic

WOOD & PAPER a.s.

The Czech team of Eversheds Sutherland advised WOOD & PAPER a.s. on an intra-group merger by absorption. The transaction was led by partner Stanislav Dvořák, with senior associates Lola Florianová and Michal Růžička advising on the transaction and coordinating the process with the client’s other advisers.

Raiffeisen Real Estate Fund

Eversheds Sutherland Czech Republic provided comprehensive legal advice to the Raiffeisen Real Estate Fund in connection with the acquisition of IMMOMARKET-1 s.r.o., the owner of the newly developed retail park Stříbrný Dvůr in Havlíčkův Brod. The legal services included a comprehensive legal due diligence and negotiation of the transaction documentation. The project was led by the firm’s partner Dominika Veselá, with the involvement of senior associate Kristýna Zirhut.

---

Poland

Lehtovuori Oy

We have supported Lehtovuori Oy on the landmark cross-border transaction involving the acquisition of Tejbrant Gruppen AB. The transaction included Tejbrant Group’s manufacturing companies and real estate company in Sweden, as well as its operating companies in Poland and Germany. with operations in Sweden, Poland and Germany.

The Polish office of Eversheds Sutherland advised on the transaction with a team under the supervision of Partner Ewa Szlachetka.

Conseq

We provided legal assistance to the companies owned by CONSEQ FUNDS INVESTIČNÍ SPOLEČNOST, A.S. acting for CONSEQ REALITNÍ OPF on the acquisition of retail parks in Włocławek and Inowrocław, Poland, from the seller owned by the investment fund.

The Eversheds Sutherland team in Poland was led by partner Michał Smolny.

---

Romania

Our Romanian team recently finalized the signing for FutureLife’s latest strategic acquisition, through which it has strengthened its position in the Romanian healthcare market.

Moreover, the team supported a German holding throughout the entire process of acquiring a company that provides ancillary road transport services, strategically growing its investments in the Romanian market.

---

Awards

CEE

The Eversheds Sutherland offices across the CEE region have significantly strengthened their position in the Chambers Europe rankings. This achievement would not have been possible without the continued trust and confidence of our clients. Below, we outline the details, including the areas in which we have received new nominations.

New practice rankings:

• Austria: TMT – Information Technology
• Poland: Arbitration, Corporate/M&A: Mid-Market, Litigation: Highly Regarded, Public Procurement
• Romania: Corporate/M&A, Dispute Resolution

New individual lawyer rankings for:

• Austria: TMT – Data Protection
• Czech Republic: Employment
• Poland: Arbitration, Corporate/M&A: Mid-Market, Food & Beverages Litigation: Highly Regarded, Public Procurement
• Romania: Dispute Resolution: Arbitration
• Slovakia: Employment, Real Estate

---

Team news

Hungary

Strengthening our ESG expertise

We are proud to announce that our Head of Employment Law, partner Dr. Katalin Varga, has earned a postgraduate LL.M. degree in the ESG approach to Business Law. As ESG criteria increasingly redefine the corporate landscape, Katalin’s new expertise ensures that our firm remains at the forefront of sustainable business practices. Her deep understanding of the intersection between labor law and environmental, social, and governance standards will be a significant asset to our clients.

New Hire with broad Big Four experience

Dr. Rita Szakolcai has joined our firm as Counsel. Rita brings a powerhouse background to our Team, most notably having successfully built and led the legal services department at a Big Four firm in Budapest. This proven track record of leadership and scaling complex legal operations makes her an invaluable asset to our international corporate clients. Rita’s practice is defined by a proven track record in supporting regulated businesses, transport infrastructures, media agencies, the energy sector and IT companies, as well as non-profit organizations.

---

Poland

Strengthening our public contracts expertise

The Public Contracts Team welcomes a new Counsel. Agnieszka Gilowska specializes in public procurement law. She has extensive experience in public contract management for projects in the rail and road transport, energy, defence and healthcare sectors. She has advised contractors in numerous public procurement proceedings conducted under all procedures provided for by Polish public procurement law, as well as in EU proceedings based on EU regulations.

Strengthening our commercial expertise

The Commercial Team welcomes a new Counsel. Magdalena Mitas has 18 years of experience handling projects in the energy sector, including renewable energy sources, conventional energy, construction, and water infrastructure. Her areas of expertise include energy law, environmental protection, nature conservation, waste management, forestry, water and construction law, and spatial planning.

---

Romania

Strengthening our arbitration expertise

Starting January, the Romanian team welcomes a new Partner for our International Arbitration team. Luminita Popa, an acclaimed lawyer with over 25 years’ experience in transactions and international arbitration, will head the team’s commercial litigation practice. Luminita is recognised as a Thought Leader in the Lexology Index Thought Leaders - Arbitration, as Leading Partner in Legal 500 and she is ranked in Band 1 of Chambers Europe – Arbitration.