Belgium

Status of transposition: Not transposed as yet. A draft law providing for a partial implementation has been submitted to the Council of State for review, which provided its comments to the legislator for consideration. No legislative proposal to implement the amendments to the transparency rules has been published yet.

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 13 September 2024.

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 16 September 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 16 September 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)

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

This information was last checked and updated on 16 September 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 9 September 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.) 

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 1 October 2024.

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 12 September 2024.

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 16 September 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 12 September 2024.

Italy

Status of transposition: Italian Council of Ministers transposed the CSRD on 30 August 2024. The legislative decree was published in the Official Gazette on 10 September 2024, meaning it will take effect on 25 September 2024 (15 days after publication).

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 12 September 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.

Confirmation regarding goldplating to follow.

Contact Silke Bernard, Rémy Bonneau, Melina Perera or Marie Arnaud-Rio to talk about developments in Luxembourg

This information was last checked and updated on 13 September 2024.

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 

Contact Xu Wang to talk about developments in the Netherlands.

This information was last checked and updated on 16 September 2024.

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. The Polish Ministry of Finance (as the author of the implementation project) has received a number of comments from different organisations and stakeholders over recent months and now they need to address it in the implementation project or respond before publishing the new draft.

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 17 September 2024.

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 13 September 2024.

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 16 September 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 16 September 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 16 September 2024.

Sweden

Status of transposition: Transposed. Final draft law was approved on 29 May 2024; effective as of 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 11 September 2024.