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The Corporate Sustainability Reporting Directive: tracking transposition and goldplating across the EU.

The Corporate Sustainability Reporting Directive (CSRD) is EU legislation requiring in-scope companies to report on the impact of their activities on the environment and on society, and which requires the audit (assurance) of that reported information.

After much wrangling, the CSRD entered into force in 2023. However that was not the end of the story: because it is a directive, it now needs to be transposed into national law in every EU member state. The deadline for transposition is 6 July 2024.

Unlike some EU directives, the CSRD is not a maximum harmonisation directive. This means member states can extend it – “goldplate” – when they transpose it into national law.

Click on the names of the countries below to find out about the status of transposition in each one, including a headline of any goldplating coming along.

Where there has been, or looks likely to be, goldplating, we have more detail on the substance of this. Get in touch with us if you would like to find out more.

Superimposing a collection of slightly different national requirements onto an institution’s global reporting framework is difficult and bears regulatory risk. Talk to your contacts at Linklaters to discuss how to manage multiple national law requirements to build one holistic CSRD disclosure methodology.

CSRD transposition

click on a country to find out what has happened there.

Brussels

Belgium

Status of transpositionNot transposed as yet. A draft law providing for a partial implementation has been submitted to the Council of State for review.

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

This information was last checked and updated on 28 May 2024.

Bulgaria

Bulgaria

Status of transposition: Not transposed as yet. The two draft legislations implementing the CSRD were subject to public consultation between March and May 2024. The next step will be for the final drafts to be submitted to Parliament for consideration. 

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

This information was last checked and updated on 3 June 2024.

Croatia

Croatia

Status of transposition: Not transposed as yet. Public consultation on the draft legislation has been completed. It has now been submitted to the parliamentary legislative procedure. No date has been set for voting.

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

This information was last checked and updated on 3 June 2024.

Czech_2000x300

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 be now implemented through amendment of existing Accounting Act and Act on Auditors with effective date on 1 January 2025 (legislative proposal in intergovernmental commentary procedure stage).- 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); TBC (in respect of second phase)

Scope and content of reporting? No (in respect of first phase); TBC (in respect of second phase)  

Assurance of sustainability reporting? No (in respect of first phase); TBC (in respect of second phase)

Additional transitional provisions? No (in respect of first phase); TBC (in respect of second phase)

Is there any other goldplating? No (in respect of first phase); TBC (in respect of second phase)

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

This information was last checked and updated on 3 June 2024.

Paris

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 3 June 2024.

Germany

Germany

Status of transposition: Not transposed as yet. First draft legislation has been published. 

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

This information was last checked and updated on 3 June 2024.

Greece

Greece

Status of transposition: Not transposed as yet. It is understood that the relevant committee has completed its work and submitted the draft law to the Ministry, which then has the option of either publishing it for a quick consultation process (more likely) or directly presenting it to Parliament. The draft has not yet been made public.

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

This information was last checked and updated on 3 June 2024.

Hungary

Hungary

Status of transposition: Partial transposition (the specific rules have not yet been transposed).

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 3 June 2024.

Ireland

Ireland

Status of transposition: Not transposed as yet, however the policy response to the consultation has been published.

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 3 June 2024.

Italy

Italy

Status of transposition: Not transposed as yet. A draft law has been published for consultation.

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

This information was last checked and updated on 3 June 2024.

Lux

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 will go through the Luxembourg parliamentary procedure.

Confirmation regarding goldplating to follow.

Contact Silke Bernard, Rémy Bonneau or Melina Perera to talk about developments in Luxembourg

This information was last checked and updated on 1 May 2024.

Netherlands

The Netherlands

Status of transposition: Not transposed as yet. Draft texts were published on 20 November 2023. The Dutch Government has announced that implementation will be delayed but has not indicated reason or timing of next steps.

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 Xu Wang to talk about developments in the Netherlands.

This information was last checked and updated on 3 June 2024.

Warsaw

Poland

Status of transposition: Not transposed as yet. Draft act was published on 19 April 2024 and is now under public consultation. Formal adoption is expected by Parliament by Q2 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 Wojciech Kobylinski or Piotr Zbyszyński to talk about developments in Poland.

This information was last checked and updated on 3 June 2024.

Lisbon

Portugal

Status of transposition: Not transposed as yet. Nothing has been published.

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

This information was last checked and updated on 3 June 2024.

Romania

Romania

Status of transposition: 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? No

Is there any other goldplating? No

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

This information was last checked and updated on 3 June 2024.

Slovakia

Slovakia

Status of transposition: Transposed. Amendment to the Accounting Act as well as 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 3 June 2024.

Spain

Status of transposition: Not transposed as yet. A draft law has been published.

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

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

This information was last checked and updated on 3 June 2024.

Sweden

Sweden

Status of transposition: Not transposed as yet. Final draft law approved and will be effective from 1 July 2024.

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 3 June 2024.

Key Contacts


To read more on CSRD and many other topics in the ESG space, visit our global Sustainable Futures blog. And find out more about we can help you with the challenges and opportunities arising out of the transition to a lower carbon economy and the complexities and interdependencies in the external landscape which our clients will be navigating over the coming years.

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