Belgium

Status of transposition: Partially transposed. A law providing for a partial implementation was approved in the Belgian Parliament on 28 November 2024 and entered into force at the end of 2024.

This law only provides for a partial implementation of the CSRD provisions and will need to be complemented with additional legislative texts to introduce in Belgian law the amendments made by the CSRD to the Transparency Directive. The law does provide for the necessary powers to adopt amendments to the Royal Decree regarding transparency obligations. At this stage there is no view on timing of the additional Royal Decree.

Scope of application? No

Scope and content of reporting? No 

Assurance of sustainability reporting? No 

Additional transitional provisions? No 

Is there any other goldplating? No 

On 26 September 2024, the European Commission announced that it opened infringement procedures against Belgium for failing to fully transpose the Directive.

Contact David Ballegeer and Tom Cobbaert to talk about developments in Belgium.

This information was last checked and updated on 7 January 2025.

Bulgaria

Status of transposition: Transposed
The draft amendments to the two acts implementing the CSRD in Bulgaria, the Accounting Act and the Independent Financial Audit Act, were adopted on 14 August and 4 September, respectively. The amendments to the Accounting Act entered into force retroactively as of 6 July 2024, whereas the amendments to the Independent Financial Audit Act are yet to be published in State Gazette.

Contact Jan Lehký at Kinstellar to talk about developments in Bulgaria.

This information was last checked and updated on 15 November 2024.

Croatia

Status of transposition Transposed
Under the urgent procedure for the adoption of legislation, the Croatian Parliament adopted the new Accounting Act and the amendments of the Audit Act and the Capital Markets Act on 12 July. The new legislation has been published in the Official Gazette on 19 July. The amendments to the Capital Markets Act entered into force on the same day, while the new Accounting Act and the amendments to the Audit Act entered into force on 27 July.

Is there any goldplating in respect of:

Scope of application? No

Scope and content of reporting? No 

Assurance of sustainability reporting? No 

Additional transitional provisions? No 

Is there any other goldplating? No 

Contact Jan Lehký at Kinstellar to talk about developments in Croatia.

This information was last checked and updated on 15 November 2024.

Czech Republic

Status of transposition: Not fully transposed yet (two phase transposition); First phase of transposition relating to companies subject to NFRD; Second phase of transposition will now be implemented through amendment of existing Accounting Act and Act on Auditors with proposed effective date on 1 January 2025 (legislative proposal has received governmental approval and has been submitted to the Czech Parliament for consideration) The adoption of a new accounting law is still under way but is expected to be delayed (legislative proposal in governmental stage awaiting governmental approval)

Is there any goldplating in respect of:

Scope of application? Yes (in respect of first phase); TBA Following adoption of Accounting act (based on draft proposal)

Scope and content of reporting? No (in respect of first phase); TBA Following adoption of Accounting act (based on draft proposal)

Assurance of sustainability reporting? No (in respect of first phase); TBA Following adoption of Accounting act (based on draft proposal) 

Additional transitional provisions? No (in respect of first phase); TBA Following adoption of Accounting act (based on draft proposal)

Is there any other goldplating? No (in respect of first phase); TBA Following adoption of Accounting act (based on draft proposal)

On 26 September 2024, the European Commission announced that it opened infringement procedures against Czech Republic for failing to fully transpose the Directive.

Contact Jan Lehký at Kinstellar to talk about developments in the Czech Republic.

This information was last checked and updated on 15 November 2024.

Estonia

Status of transposition: Partially transposed

Large undertakings which are a public interest entity as defined in the Auditors Activities Act and have over 500 employees are subject to publishing sustainability reports as a part of their annual reports. This requirement will be applicable for large enterprises from 2025 and for SME-s (other than micro enterprises) that are public from 2026. Draft law transposing CSRD is awaiting second reading in the parliament.

Is there any goldplating in respect of:

Scope of application? No

Scope and content of reporting? No 

Assurance of sustainability reporting? No 

Additional transitional provisions? No

Is there any other goldplating? No

On 26 September 2024, the European Commission announced that it opened infringement procedures against Estonia for failing to fully transpose the Directive.

Contact Karin Madisson at Sorainen and Elina Lumiste to talk about developments in Estonia.

This information was last checked and updated on 15 November 2024.

France

Status of transposition: Almost fully transposed

Is there any goldplating in respect of:

Scope of application? Yes 

Scope and content of reporting? No 

Assurance of sustainability reporting? No 

Additional transitional provisions? Yes 

Is there any other goldplating? Yes 

Read this for more on detail on the French transposition: France is the first member state to transpose CSRD.

Contact Ngoc-Hong Ma and Emilie Rochat to talk about developments in France.

This information was last checked and updated on 15 November 2024.

Germany

Status of transposition: Not transposed as yet. The German cabinet approved a draft law on 24 July 2024. The first reading of the draft law took place in the German Parliament (Bundestag) on 26 September 2024. The Federal Council (Bundesrat) adopted its statement on the draft law on 27 September 2024, proposing some minor amendments. (See our German October ESG newsletter for more detail.) 

On 9 October, the Federal Government (Bundesregierung) responded to the Federal Council’s statement and rejected some of the proposed amendments.  Due to the German coalition government break-up in November, it is currently unclear whether the law will be put to a vote in the legislative period running until the federal elections in February, and whether it will receive the necessary approval in the Bundestag in such a case.

In a letter sent to European commissioners on 17 December 2024, senior ministers in the German government called for a drastic reduction in reporting requirements, specifically for the start of reporting requirements for large non-capital-market-oriented companies and SMEs to be postponed by two years.

Is there any goldplating in respect of:

Scope of application? Yes

Scope and content of reporting? No

Assurance of sustainability reporting? No

Additional transitional provisions? No

Is there any other goldplating? No

On 26 September 2024, the European Commission announced that it opened infringement procedures against Germany for failing to fully transpose the Directive.

Contact Julia Macdonald, Julia Grothaus and Mareike Weidemann to talk about developments in Germany.

This information was last checked and updated on 6 January 2025.

Greece

Status of transposition: Transposed. Greece officially implemented the CSRD through Law No. 5164/2024, which was published in the Government’s Gazette on 12 December 2024 and became effective on the same date. The Law closely aligns with the provisions of the CSRD with no major deviations from the original wording.

Contact Michael Tsibris, Effie Papakonstantinou or Giannis Koumettis of Souriadakis Tsibris who are kindly providing updates on CSRD transposition developments in Greece.

On 26 September 2024, the European Commission announced that it opened infringement procedures against Greece for failing to fully transpose the Directive.

This information was last checked and updated on 7 January 2025.

Hungary

Status of transposition: Some new specific rules were adopted through decrees on 8 August 2024. They include rules on preparation of an ESG report, rules on accreditation, registration and education of ESG advisors. Further specific rules are yet to be transposed through additional decrees that are expected shortly.

Is there any goldplating in respect of:

Scope of application? Yes 

Scope and content of reporting? Yes 

Assurance of sustainability reporting? Yes 

Additional transitional provisions? Yes

Is there any other goldplating? Yes 

Contact Jan Lehký at Kinstellar to talk about developments in the Czech Republic.

This information was last checked and updated on 15 November 2024.

Ireland

Status of transposition: Transposed and came into operation on 6 July 2024. A FAQs is expected to be published in September.

Is there any goldplating in respect of:

  Scope of application? No

  Scope and content of reporting? No

  Assurance of sustainability reporting? Yes

  Additional transitional provisions? Uncertain at present

Is there any other goldplating? Uncertain at present

Contact Jill Shaw, Patrick Brandt or Rachel Hanley at A&L Goodbody LLP who are kindly providing updates on CSRD transposition in Ireland.

This information was last checked and updated on 15 November 2024.

Italy

Status of transposition: Italian Council of Ministers transposed the CSRD on 30 August 2024 and took effect on 25 September 2024. Read our client note for more details of the status in Italy.

Scope of application? Yes

Scope and content of reporting? No 

Assurance of sustainability reporting? No

Additional transitional provisions? No

Is there any other goldplating? No 

Contact Anna Ferraresso and Samuele Manfredo Pio to talk about developments in Italy.

This information was last checked and updated on 15 November 2024.

Latvia

Status of transposition: Transposed. Sustainability Information Disclosure Law is in force since 17 October 2024.

Additionally it is stated that the Government shall prepare legislature designating competent authority and develop a proper procedure for evaluating correctness and completeness of reported sustainability information by 30 June 2025.

Is there any goldplating in respect of:

Scope of application? No

Scope and content of reporting? No

Assurance of sustainability reporting? Yes

Additional transitional provisions? No

Is there any other goldplating? Yes

Contact Agita Sprūde at Sorainen to talk about developments in Latvia.

This information was last checked and updated on 15 November 2024.

Lithuania

Status of transposition: Transposed. Amendments to the Law on Accountability of Companies and Groups of Companies; the Law on Audit of Financial Statements and Other Assurance Services; the Code of Administrative Misdemeanours and other laws transposing the CSRD into Lithuanian law, were approved on 25 June 2024, effective as of 1 July 2024.

Is there any goldplating in respect of:

Scope of application? No

Scope and content of reporting? No

Assurance of sustainability reporting? No Additional transitional provisions? No

Is there any other goldplating? No

Contact Vitalija Impolevičienė at Sorainen to talk about developments in Latvia.

This information was last checked and updated on 15 November 2024.

Luxembourg

Status of transposition: Not transposed as yet. A draft law has been filed before the Luxembourg parliament (Chambre des Députés) on 29 March 2024 and is currently going through the Luxembourg parliamentary procedure. Amendments to the initial draft law have been adopted by the relevant parliamentary commissions on 25 October 2024.

Confirmation regarding goldplating to follow.

Contact Rémy Bonneau, Martin Mager, Melina Perera, Delphine Horn, Eugenie Syx or Marie Arnaud-Rio,  to talk about developments in Luxembourg.

On 26 September 2024, the European Commission announced that it opened infringement procedures against Luxembourg for failing to fully transpose the Directive.

This information was last checked and updated on 6 January 2025.

The Netherlands

Status of transposition: Not transposed as yet. Two pieces of draft implementation legislation were published on 17 July 2023 and 20 November 2023. Both were subject to public consultations, which closed on 10 September 2023 and 18 December 2023 respectively. Updated versions of the implementing legislation were published on 12 June 2024 and 28 June 2024, respectively. On 29 August 2024 the Council of State advised to submit the revised draft implementation Act to the Dutch Parliament for discussion and adoption. The Dutch legislator has not provided any indicative timeline around implementation.

Is there any goldplating in respect of:

Scope of application? No 

Scope and content of reporting? No 

Assurance of sustainability reporting? No 

Additional transitional provisions? No 

Is there any other goldplating? No 

On 26 September 2024, the European Commission announced that it opened infringement procedures against Netherlands for failing to fully transpose the Directive.

Contact Xu Wang to talk about developments in the Netherlands.

This information was last checked and updated on 9 January 2025.

Poland

Status of transposition: Transposed. The CSRD implementation draft law was announced in the Official Journal of Laws on 17 December 2024 and entered into force on 31 December 2024.

Is there any goldplating in respect of:

Scope of application? No

Scope and content of reporting? No 

Assurance of sustainability reporting? No 

Additional transitional provisions? No 

Is there any other goldplating? No

On 26 September 2024, the European Commission announced that it opened infringement procedures against Poland for failing to fully transpose the Directive.

Contact Wojciech Kobylinski or Piotr Zbyszyński to talk about developments in Poland.

This information was last checked and updated on 7 January 2025.

Portugal

Status of transposition: Not transposed as yet. The transposition process has resumed. The draft decree has not yet been made public, but it is likely the process shall conclude by early 2025.

Contact Gonçalo Veiga de Macedo, Vera Ferreira de Lima, Mariana Serra Baptista or Maria de Athayde Tavares to talk about developments in Portugal.

On 26 September 2024, the European Commission announced that it opened infringement procedures against Portugal for failing to fully transpose the Directive.

This information was last checked and updated on 9 January 2025.

Romania

Status of transposition: Almost fully transposed 

At this stage, the companies' reporting obligation (under Art. 1 of the CSRD) has been implemented in national law, as per the transposition rules under Art. 5 of the CSRD. However some additional legislation needs to be adopted to finalise the legal framework under the CRSD, particularly to finalise the transposition of some changes under Art. 2 on the Transparency Directive and Art. 3 on the Audit Directive.

This means that the reporting obligation of companies, as provided by the CSRD has been transposed in Romania, while some of the changes brought by the CSRD, particularly as regards the Transparency and Audit Directives are still in the pipeline locally. The remaining points are expected to be transposed by the end of 2024-beginning of 2025.

Is there any goldplating in respect of:

Scope of application? Yes 

Scope and content of reporting? No

Assurance of sustainability reporting? No

Additional transitional provisions? No

Is there any other goldplating? No

On 26 September 2024, the European Commission announced that it opened infringement procedures against Romania for failing to fully transpose the Directive.

Contact Jan Lehký at Kinstellar to talk about developments in Romania.

This information was last checked and updated on 15 November 2024.

Slovakia

Status of transposition: Transposed. Amendment to the Accounting Act and other laws transposing the CSRD into Slovak law was approved on 24 April 2024; effective as of 1st June 2024. 

Scope of application? Yes

Scope and content of reporting? No

Assurance of sustainability reporting? No

Additional transitional provisions? No

Is there any other goldplating? No

Contact Jan Lehký at Kinstellar to talk about developments in Slovakia

This information was last checked and updated on 15 November 2024.

Spain

Status of transposition: Not transposed as yet. A draft law was filed with the Spanish Parliament on 15 November 2024. Its legislative approval process is ongoing. The Spanish Securities Market Commission (CNMV) and the Spanish Institute of Accounting and Auditing (ICAC) have published guidance with their expectations in the likely case the transposition is not finalised by 1 Jan 2025.

Is there any goldplating in respect of:

Scope of application? No 

Scope and content of reporting? Yes

Assurance of sustainability reporting? No 

Additional transitional provisions? No 

Is there any other goldplating? Yes

On 26 September 2024, the European Commission announced that it opened infringement procedures against Spain for failing to fully transpose the Directive.

Contact Paloma Fierro and Antonio Camara to talk about developments in Spain.

This information was last checked and updated on 7 January 2025.

Sweden

Status of transposition: Transposed. Final draft law was approved on 29 May 2024; effective as of 1 July 2024. On 16 December 2024, the EU Commission sent a “reasoned opinion” to Sweden for failing to comply with the CSRD as the measures adopted by Sweden require companies to start reporting information for financial years beginning on or after 1 July 2024 - a delay of the application of sustainability reporting requirements by half a year. The Commission believes that by introducing this delay, Sweden risks creating an unlevel playing field between EU companies in different Member States. Sweden has two months to respond and address the shortcomings.

Is there any goldplating in respect of:

Scope of application? Yes 

Scope and content of reporting? No 

Assurance of sustainability reporting? No 

Additional transitional provisions? No 

Is there any other goldplating? No 

Contact Adam Wahlén Winqvist and Emma Josefsson to talk about developments in Sweden.

This information was last checked and updated on 7 January 2025.