The EU’s 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 needs to be transposed into national law in every EU member state. The deadline for transposition was 6 July 2024. The European Commission has started infringement procedures against 17 member states who failed to fully transpose by this deadline. (This includes Belgium, Czech Republic, Germany, Estonia, Greece, Spain, Cyprus, Latvia, Luxembourg, Malta, the Netherlands, Austria, Poland, Portugal, Romania, Slovenia and Finland.)  

Transposition (and the effect of the transposed CSRD in jurisdictions which have met the deadline) has been complicated by the EU’s simplification project (the so-called “Omnibus package”) whose aim is to reduce the regulatory burden of complying with the EU’s sustainability reporting and due diligence rules. Its particular focus is on the CSRD, as well as the Corporate Sustainability Due Diligence Directive (CSDDD) and the EU Taxonomy. The first Omnibus package includes proposals to amend the CSRD to extend reporting timelines, reduce the number of companies in scope, reduce the number of disclosures, amend the assurance requirements and clarify specific requirements under the CSRD and CSDDD. It is intended to simplify the sustainability requirements and give businesses more time to prepare, not do away with these rules completely. The first step towards achieving this is already underway through the “Stop-the-clock” directive which delays some of the reporting timeframes under the CSRD and CSDDD. The “Stop-the-clock” has been published by the EU Commission and itself must be transposed into Member State law by the end of 2025. You can read more about the Omnibus package under the “Featured content” here and view our 'Stop-the-Clock' directive transposition tracker here.

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, and any information about the impact of the Omnibus package on transposition.

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.