Belgium

Status of transposition: 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.

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 Tom Cobbaert to talk about developments in Belgium.

This information was last checked and updated on 29 April 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.

On 19 February 2025 the Bulgarian Parliament adopted an amendment to the Accountancy Act by which the sustainability reporting, as required under the CSRD, has been delayed by one year. After these amendments, large public-interest companies that have more than 500 employees will now have to prepare their first sustainability reports for the year 2025 instead of 2024. Other large enterprises will follow with their first reports covering 2026 instead of 2025 and the last group covering small and medium enterprises will prepare their first sustainability reports covering 2027 instead of 2026. The amendments to the Accountancy Act have been promulgated in the Bulgarian State Gazette and entered into force on 28 February 2025.

There is no official information regarding the Omnibus I impact.

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

This information was last checked and updated on 12 April 2025.

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.

CSRD implemented in Croatia. Recently, the Ministry of Finance has published a list of entities required to report on sustainability in the first phase (reporting in 2025 for the 2024 financial year), and an indicative list of potential reporting entities for the second phase (reporting in 2026 for the 2025 financial year). More information available on following link. There is no official information regarding the Omnibus I impact.

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 12 April 2025.

Estonia

Status of transposition: Transposed

On 17 December 2024, the Estonian Parliament adopted the law transposing the CSRD into national law. The adopted law introduces the following main changes in Estonian law:

1. provides for the obligation to prepare, submit and have audited sustainability report;
2. amend the size criteria for micro, small, medium and large enterprises:
3. specifies the format of the annual report;
4. provides for two different types of auditor;
5. raising the thresholds for the statutory audit and review of annual accounts; and
6. a reduction in the statutory audit requirement for foundations. The law transposing the CSRD into national law entered into force on 17 January 2025.

Estonia was included in the EU Commission’s infringement notice from September 2024.

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

This information was last checked and updated on 23 April 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 29 April 2025.

Hungary

Status of transposition: The Ministry of National Economy published the draft amendment of the ESG Act for public consultation, which relates to the Omnibus Packages. The public consultation closed on 29 March 2025, however, as of today, it has not yet been filed before the Parliament.

According to the draft amendment, the enterprises subject to the ESG Act would be modified in such a way that small and medium-sized enterprises of public interest would be excluded from the scope of the ESG Act, while for large enterprises, the indicators based on which it would be determined who is required to prepare an ESG report would be modified. These indicators would be defined in a separate decree by the Ministry of National Economy. This decree has not yet been published in the current legislative amendment process.

According to our interpretation, the draft would not exempt large enterprises from the administrative burdens related to preparing the ESG report, however, they would not be required to submit the ESG report to the Supervisory Authority for Regulated Activities (SZTFH), nor would they be required to publish it on their website.

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 12 April 2025.

Ireland

Status of transposition: Transposed The CSRD took effect in Ireland on 6 July 2024.  

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 23 January 2025.

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 23 April 2025.

Lithuania

Status of transposition: Transposed. Lithuania transposed the CSRD through 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, which were approved on 25 June 2024 and entered into force on 1 July 2024.

The law transposing CSRD has not yet been amended as a result of the adoption of the ‘Stop-the-Clock’ directive, but the Lithuanian Ministry of Finance informed that it is planned to transpose the ‘Stop-the-Clock’ into national laws still in the spring Parliament session.

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 23 April 2025.

Norway

Status of transposition: The legislative amendments implementing the CSRD into Norwegian law were approved on 21 June 2024, and entered into force as of 1 November 2024.

Is there any goldplating in respect of:

Scope of application? The Norwegian transposition of the CSRD is generally closely aligned with the CSRD.

Scope and content of reporting? No 

Assurance of sustainability reporting? No 

Additional transitional provisions? No 

Is there any other goldplating? No 

Contact: Anne Katrine Ramstad and Georg Abusdal Engebretsen at Wiersholm.

This information was last checked and updated on 30 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 23 April 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 in the beginning of 2025.

Even though the EU Commission notified Romania in its infringement notice, the companies' reporting obligation (under Article 1 of the CSRD) has already been implemented in the national law, as per the transposition rules under Article 5 of the CSRD. At the end of 2024, the Government also finalised the transposition of the provisions of Article 3 of the CSRD in the Audit Directive. However, additional legislation needs to be adopted to finalise the legal framework under the CRSD, particularly to finalise the transposition of changes under Article 2 on the Transparency 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 Directive are still in the pipeline locally. The remaining points are expected to be transposed in the beginning of 2025. No changes regarding CSRD related local legislation. As a result, no amendments have been made to the table.

In relation to Omnibus I’s effects in Romania, we note that the local thresholds for determining the reporting companies, as adopted under Romanian legislation and currently in force, were lower than those established at EU level. Thus, there may be a possibility that, following the Romanian transposition of Omnibus package, the new amended thresholds may still be different from those foreseen in the EU Omnibus initiative. In any case, as the Omnibus proposal has to first be adopted at European level and then transposed into national legislation, the impact could not be clearly determined.

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 12 April 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 23 April 2025.

Czech Republic

Status of transposition: Partially transposed The transposition for Czech Republic is in two phases:

• The first phase of transposition relates to companies subject to the Non-Financial Reporting Directive which took effect from 1 January 2024; and 
• The second phase of transposition to be implemented through amending the existing Accounting Act and Act on Auditors, however the adoption of this amending act is still under way. The legislative proposal was submitted in August 2024, and the first reading in the Chamber of Deputies concluded in February 2025. Following the ESG Omnibus Package proposal—in particular ESG Omnibus I—the responsible parliamentary committee has proposed amendments to align the draft with the EU-level ESG developments. These include:
  • Exclusion of companies falling under phases 2 and 3 of the transposition from the scope of the Czech legislation;
  • Raising the employee threshold for phase 1 companies from 500 to 1,000 employees.

These proposed changes are a response to the current direction of ESG reporting requirements at the EU level. However, the adoption of the draft legislation is still pending, and the originally proposed effective date of 1 January 2025 will not be met. The earliest adoption timeline is expected in Q3 2025

The adoption of a new Accounting Act is still under way but is expected to be delayed past the original goal of adoption in 2025. It is now expected to become effective in 2026 or 2027. (The legislative proposal is in the governmental stage: the draft proposal has been reworked by the Ministry of Finance and published as a reaction to intergovernmental comment procedure awaiting governmental approval). Czech Republic was included in the EU Commission’s infringement notice from September 2024.

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 2 April 2025.

France

Status of transposition: Almost fully transposed. The French Senate has proposed delaying the effective date of the reporting requirements by four years, in an amendment to a proposed national legislation published on 3 March 2025.

In early April 2025, the French legislator passed a law amending this ordinance to align the implementation deadlines for the CSRD in French law with the recently adopted "Stop the clock Directive” at the European level. This law also includes an exception regarding the publication of certain sustainability information that could seriously harm the company’s commercial position. Certain information could be omitted from the sustainability report upon a reasoned opinion from the board of directors, the executive board, or the manager, and would instead be submitted to the Autorité des marchés financiers.

The law, adopted on 2 and 3 April 2025 by the legislator, was enacted by the President of the Republic and published in the Official Journal on 2 May 2025. This law is now applicable.

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 6 May 2025.

Germany

Status of transposition: Not transposed as yet. The German cabinet approved a draft law on 24 July 2024. Since the legislative process could not be completed before the federal elections on 23 February 2025, the law will need to be introduced in the new legislative period. 

Germany was included in the EU Commission’s infringement notice from September 2024.

On 9 April 2025, the CDU/CSU and SPD presented their political agenda – the so-called Coalition Agreement – for the new legislative period. The agreement sets out the political goals and plans for the coming years. In it, the coalition partners announce, with regard to the CSRD, that they will support the EU's Omnibus Initiative and, in particular, advocate ‘a low-bureaucracy solution’ for SMEs. The coalition agreement does not provide guidance on when the government will address the implementation of the CSRD and the Stop-the-clock-proposal during the new legislative period.

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 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 May 2025.

Luxembourg

Status of transposition: Not transposed as yet. A draft law n°8370 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 were published on 6 May 2025 by the Luxembourg government. These proposed amendments mainly reflect the new timelines under the Stop-the-Clock legislation (Directive (EU) 2025/794) and include new provisions which, in their current version, confirm that in-scope entities whose financial year started on 1st January 2024 or after this date and closed before the entry into force of the law are not required to establish and publish sustainability information for said exercise.

Luxembourg was included in the EU Commission’s infringement notice from September 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 7 May 2025.

The Netherlands

Status of transposition: Not transposed as yet. A revised draft CSRD implementation law was published mid-January. Main changes related to the assurance services in connection with sustainability reporting from listed companies.

There have been discussions in the news (articles published in the Dutch Financial Times) about the retroactive effect of the implementation legislation. The Dutch government was also quoted to still want the first group of in-scope companies to comply with their obligations for FY24.

Primary Dutch accountancy organisations have argued for a delay of at least one year for the CSRD obligations to be effective and to not apply with retroactive effect as of 2024.

In mid-February, the Dutch Parliamentary Committee responsible for CSRD implementation requested from the Dutch Minister of Finance a letter on the expected impact of the Omnibus on the CSRD. Pending such letter, discussions by the Dutch Parliamentary Committee on implementing the CSRD in the Netherlands (including around the draft legislation) have been suspended. As with the wider Omnibus, we wait to see the reaction to this and what it might mean for transposition in the Netherlands. The Netherlands was included in the EU Commission’s infringement notice from September 2024.

The original CSRD is yet to be transposed. The idea is to take everything together and transpose at some point although no clarity on timing.

More recently various political parties submitted questions around the Omnibus changes and the Dutch implementation. The relevant Ministry responsible for implementation is expected to respond to the queries around 7 May after which we hopefully will know a little bit more again.

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 30 April 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 22 April 2025.

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 21 April 2025.