EU Corporate Sustainability Reporting Directive Transposition Analysis

Introduction

The Corporate Sustainability Reporting Directive (CSRD) is a European Union (EU) directive that requires companies to disclose their environmental, social and governance (ESG) impacts on society as part of an annual non-financial reporting duty. Specifically, the CSRD applies to all public EU-based companies, private, large EU organisations, non-EU companies that meet certain criteria, and small and medium-sized enterprises (SMEs) that are listed on European markets and meet other criteria. According to the European Commission, the CSRD is an adoption of “common standards which will help companies to communicate and manage their sustainability performance more efficiently and therefore to have better access to sustainable finance”.

For more information on specific criteria, please see Vixio’s Interactive Map: European Union CSRD Transposition.

The CSRD is part of the larger European Green Deal, which is a set of policies that aim to make the EU climate neutral by 2050. The directive aims to increase transparency, accountability and trust by standardising the reporting of non-financial data. This information will enable investors, consumers and other stakeholders to assess a company’s impact on the environment and society, and to identify related risks and opportunities.

The CSRD replaces the Non-Financial Reporting Directive (NFRD), which was enacted in 2016. The NFRD required large companies to disclose non-financial information in their annual reports and to report on how they manage ESG issues. The CSRD expands upon the NFRD by requiring more detailed, transparent reporting from a larger number of companies. Additionally, the CSRD, unlike the NFRD, will require third-party, independent assurance of the information companies report.

The European Commission adopted the CSRD in November 2022 and it took effect on January 5, 2023. The directive required applicable member states and European Economic Area (EEA) states to transpose certain articles of the directive into their national legislation by July 6, 2024. The CSRD will be phased in between 2024 and 2029, and the applicable reporting date will depend on the size and other thresholds, such as the amount of turnover and balance sheet numbers, of in-scope companies.

Under the CSRD, large companies and public-interest entities already subject to the NFRD must produce a sustainability report by January 1, 2025 that covers the 2024 financial year. The exception is Sweden, which has delayed its reporting timeline — more on this below.

Other large companies will be included in the second wave, with a report due in 2027 that covers the 2026 financial year. The third wave encompasses non-EU companies under certain threshold criteria that must cover the 2028 financial year in their 2029 sustainability reports.

The CSRD provides an “opt out” option for listed SMEs until 2028. This means that listed SMEs may delay their reporting by an additional two years, from 2026 to 2028, until they adapt to the new reporting standards. According to the European Commission, the last possible date for a listed SME to start reporting is financial year 2028, with the first sustainability statement published in 2029.

A set of Frequently Asked Questions (FAQs) published by the EC on November 13, 2024 clarifies the interpretation of certain provisions on sustainability reporting introduced by the CSRD. The FAQs largely clarify the provisions already contained in the applicable legislation; however, the EC provides updated numeric thresholds for in-scope companies, as outlined below.

The CSRD expands the NFRD’s scope and applies to large undertakings which on their balance sheet dates exceed the limits of at least two of the three following criteria: 

• Balance sheet total: €25m.
• Net turnover: €50m
• Average number of employees during the financial year: 250 or greater.

Large undertakings will have to comply with the CSRD beginning from 2026. Large undertakings will need to produce a sustainability report in 2026 covering the 2025 financial year.

The CSRD also covers listed small- and medium-sized enterprises (SMEs) trading in EU markets. SMEs meeting at least two of the following criteria are in scope:

• Balance sheet total: €25m.
• Net turnover: €50m.
• Average number of employees during the financial year: Up to 250.

SMEs will have to comply with the CSRD beginning from 2027. SMEs will need to produce a sustainability report in 2027 covering the 2026 financial year. However, listed SMEs may be able to opt out until 2028. In such cases, the undertaking must briefly state in its management report why the sustainability reporting was not provided, according to the CSRD.

As of January 2025, 17 jurisdictions have transposed the CSRD in full, while Czechia and Hungary have partially transposed the CSRD. Eight jurisdictions have introduced legislation to transpose the CSRD. Three EU member states — Austria, Malta and Portugal — have yet to release specific details around proposed legislation to transpose the CSRD. 

In addition, non-EU member states, including Liechtenstein and Norway, have transposed the CSRD, while Switzerland has initiated a consultation to transpose the CSRD. Lastly, Iceland has yet to introduce legislation to transpose the CSRD. These countries are members of the European Economic Area (EEA) and are thus required to transpose the CSRD into national law.

On September 25, 2024, the European Commission announced that it had decided to open infringement procedures against 17 member states for failing to meet the July 6 deadline. The 17 member states were given a two-month deadline to respond to the formal notice and complete their transposition. According to the commission, in absence of a satisfactory response, the commission “may decide to issue a reasoned opinion”.

In this report, Vixio outlines each jurisdiction’s transposition status and analyses a number of key member states that have significantly expanded beyond the minimum scope of the EU CSRD. Vixio will continue to monitor all developments and update this report accordingly.

For reference, a list of national transposition measures by all member states can be found here. 

Notable Numbers - January 2025

• 17 jurisdictions have transposed the CSRD
• 2 jurisdictions have partially transposed the CSRD
• 8 jurisdictions have introduced legislation to transpose the CSRD
• Transposition is expected in a further 4 jurisdictions 
• 17 jurisdictions have received a formal notice of infringement procedures from the European Commission for failing to meet the transposition deadline and/or complete transposition

EU Member States Transposition

Austria – Not transposed

The government has yet to release draft legislation to transpose the CSRD into local law, although the deadline to transpose the CSRD was July 6, 2024. 

On September 25, 2024, the European Commission called on 17 member states, including Austria, to fully transpose the CSRD.

Belgium – Transposed

Legislation: Belgium’s draft legislation to transpose the CSRD was introduced on October 24, 2024 and later approved by the Belgian Parliament on November 28, 2024.

Effective date: The draft law, which was adopted by the Belgian Parliament on November 28, 2024, will take effect once it is published in the Belgian Official Gazette.

There are no notable deviations from the CSRD.

Bulgaria – Transposed

Legislation: Act to amend and supplement the Accounting Act

Effective date: July 6, 2024

There are no notable deviations from the CSRD.

Croatia – Transposed

Legislation: Law on Accounting

Effective date: July 27, 2024

There are no notable deviations from the CSRD.

Cyprus – Not transposed

Cyprus’ draft legislation to amend the Cypriot Companies Law was introduced in March 2024 but has not yet been transposed into national law. There are no notable deviations from the CSRD proposed in the draft legislation.

Czechia – Partially transposed

The Czech government has begun transposing the CSRD in two phases:

• The first phase involves companies who are already subject to the Non-Financial Reporting Directive requirements, and who must comply with the CSRD from 2025.
  • The sustainability reporting requirements were adopted under Act No. 349/2023 Coll. in December 2023, and took effect from January 1, 2024.
• The second phase of the transposition will extend the reporting requirements to all other remaining applicable groups, starting with large undertakings and parents of large groups. 
  • The requirements will be implemented into the amended Accounting Law, which has received government approval and has been submitted to parliament for consideration. 
  • The amended Accounting Act is proposed to take effect on January 1, 2025.

There are no notable deviations from the CSRD in Act No. 349/2023 Coll.

Denmark – Transposed

Denmark’s CSRD regulations apply to all large enterprises, all listed companies, and certain medium-sized and small enterprises, depending on the numeric thresholds of the company. 

In addition to covering all public small, medium-sized and large companies, Denmark’s regulations also apply to commercial foundations, co-operatives, limited partnerships and state-owned and private limited liability companies, as well as public limited companies, which extends the reach of the baseline CSRD as drafted by the European Union.

Additionally, Denmark raised its revenue and asset thresholds, largely due to inflation. Therefore, large and medium-sized entities will be categorised differently and, in turn, fewer companies will be covered by the CSRD reporting requirements.

Estonia – Not transposed

Estonia’s draft legislation was published on February 23, 2024 and awaits approval of the Riigikogu, which is the parliament in Estonia. 

There are no notable deviations from the CSRD proposed in the draft legislation.

On September 25, 2024, the European Commission called on 17 member states, including Estonia, to fully transpose the CSRD.

Finland – Transposed

Finland has implemented all minimum provisions of the EU CSRD and expanded the scope to include additional entities and enterprises, such as credit institutions, insurance companies, large pension-funding companies and large co-operatives.

In Finland, an “enterprise” means limited liability companies, cooperatives and other legal persons falling within the scope of the Accounting Act.

France – Transposed

France became the first EU member state to transpose the CSRD into national law on December 6, 2023.

According to France’s CSRD regulations, thresholds for large companies are €20m for the balance sheet and €40m for turnover, which is lower than the reporting thresholds as dictated by the CSRD. 

Pursuant to the CSRD, the upper limit on the balance sheet and turnover is €25m for assets and €50m for turnover.

Germany – Not transposed

Germany’s draft legislation was published on March 22, 2024. On July 24, 2024, the German government adopted an agreed upon governmental draft of the Act implementing the EU Directive on Sustainability Reporting (Directive (EU) 2022/2464 – CSRD) into German law. The German parliament is now expected to discuss the government draft law prior to full adoption.

There are no notable deviations from the CSRD proposed in the draft government law.

On September 25, 2024, the European Commission called on 17 member states, including Germany, to fully transpose the CSRD.

Greece – Not transposed

Greece’s draft bill was submitted for public consultation on November 15, 2024. The bill was later approved by the Greek Parliament and published in the Government Gazette on December 12, 2024 as Law 5164/2024.

The bill will need to be signed by the responsible ministers, promulgated by the president and again published in the Government Gazette in order for it to take effect.

There are no notable deviations from the CSRD proposed in the draft bill.

On September 25, 2024, the European Commission called on 17 member states, including Greece, to fully transpose the CSRD.

Hungary – Partially transposed

Hungary adopted the minimum provisions of the CSRD in late 2023. Act CVIII of 2023 (ESG Act), which entered into force on January 1, 2024, functions as a baseline regulatory framework to set out sustainability due diligence reporting obligations and applicable entities. 

The ESG Act will also regulate the activities of:

• ESG advisors who provide ESG-related information and advisory services for covered undertakings.
• ESG certifiers who review and certify ESG reports.
• ESG qualifiers who provide a rating for undertakings.
• Companies distributing and manufacturing ESG software.

Hungary later amended its ESG Act to, among other changes, allow companies to prepare and submit a single, consolidated sustainability report, including information on their subsidiaries. Additionally, in-scope companies may satisfy their ESG reporting obligations by filling out a questionnaire as part of an annex to the ESG report. The amended act was published in the Hungarian Gazette on April 17, 2024 and took effect in May 2024.

On August 8, 2024, four decrees to supplement the ESG Act were published in the Hungarian Gazette. The decrees contain provisions for accreditation, registration and education of ESG consultants. Three of the four decrees entered into force on August 9 and one entered into force on August 12, 2024.

Supplemental regulations are required to further transpose the CSRD, specifically around sanctions and penalties for failure to comply with due diligence reporting obligations. Additional details are expected to be provided through government decrees.

Ireland – Transposed

Ireland’s CSRD regulations are applicable to large companies, small and medium-sized enterprises, as well as public-interest entities that have transferable securities admitted to trading on a regulated market of any member state of the EU. 

The regulations are also applicable to certain branches and subsidiaries of non-EU companies that are established in Ireland.

Irish partnerships, limited partnerships and co-operatives are not covered under the reporting requirements. Other explicitly excluded entities include central banks, credit unions and alternative investment funds, which extends the reach of the baseline CSRD as drafted by the European Union.

Italy – Transposed

Italy’s CSRD legislative decree requires large companies, including public-interest entities and listed companies, as well as certain small and medium-sized companies to comply with the environmental, social and governance reporting requirements as set out by the EU’s CSRD. 

The decree also applies to insurance companies, including captive insurance and reinsurance companies, pursuant to Articles 88 and 95 of the Legislative Decree of September 7, 2005, no. 209, as well as credit institutions pursuant to Article 4 of Regulation (EU) No. 575/2013 of the European Parliament and of the Council, June 26 2013. This scope extends the reach of the baseline CSRD as drafted by the European Union.

Latvia – Transposed

Legislation: Sustainability Disclosure Act

Effective date: October 3, 2024

There are no notable deviations from the CSRD.

Lithuania – Transposed

Legislation: On the audit of financial statements of the Republic of Lithuania Law No. VIII-1227

Effective date: July 1, 2024

There are no notable deviations from the CSRD.

Luxembourg – Not transposed

Luxembourg’s draft legislation was introduced to parliament on March 29, 2024 and the legislative process is underway, according to the Commission de Surveillance du Secteur Financier. 

On October 28, 2024, parliamentary amendments to the draft legislation were adopted by the Finance and Justice committees. There are no notable deviations from the CSRD proposed in the draft legislation.

Malta – Not transposed

The Maltese government has yet to release draft legislation to transpose the CSRD into local law, although the deadline to transpose the CSRD was July 6, 2024. 

On September 25, 2024, the European Commission called on 17 member states, including Malta, to fully transpose the CSRD.

Netherlands – Not transposed

The Netherlands’ draft legislation was introduced in November 2023 and the consultation period for the draft legislation expired in December 2023. There are no notable deviations from the CSRD proposed in the draft legislation.

The Dutch Authority for the Financial Markets (AFM), in the meantime, has published guidance on CSRD compliance in anticipation of transposition. The Dutch AFM published additional guidance on July 4, 2024, entitled “Ten waypoints for CSRD – Double Materiality”.

On September 25, 2024, the European Commission called on 17 member states, including the Netherlands, to fully transpose the CSRD.

Poland – Tansposed

Legislation: Act of 6 December 2024 amending the Act on Accounting, the Act on Statutory Auditors, Audit Firms and Public Supervision and certain other acts

Effective date: On December 17, 2024, the Act amending the Act on Accounting, the Act on Statutory Auditors, Audit Firms and Public Supervision and certain other acts was published in the Journal of Laws. The act enters into force 14 days after publication, with some articles taking effect on different dates. Please see the act for more information.

There are no notable deviations from the CSRD.

Portugal – Not transposed

The Portuguese government has yet to release draft legislation to transpose the CSRD into local law, although the deadline to transpose the CSRD was July 6, 2024. 

On September 25, 2024, the European Commission called on 17 member states, including Portugal, to fully transpose the CSRD.

Romania – Transposed

Romania has fully transposed the EU’s CSRD. 

However, unlike the EU CSRD, Romania applies the same thresholds to large and medium-sized undertakings in its accounting provisions. Therefore, the threshold is now lower for medium-sized companies and they are subject to the same reporting requirements as large companies. 

Slovakia – Transposed

Legislation: Law of April 24, 2024, which amends Act no. 431/2002 Coll. on accounting as amended and which amends some laws

Effective date: June 1, 2024

There are no notable deviations from the CSRD.

Slovenia – Transposed

Legislation: The Law on Amendments and Amendments to the Law on Business Companies

Effective date: December 18, 2024

There are no notable deviations from the EU CSRD.

Spain – Not transposed

Spain’s draft bill, which was introduced in November 2024, is under negotiation in the Spanish Congress.

On September 25, 2024, the European Commission called on 17 member states, including Spain, to fully transpose the CSRD.

Sweden – Transposed

Sweden has implemented all minimum provisions of the EU CSRD. One notable deviation from the CSRD is Sweden’s reporting timeline as set out under its new rules.

The CSRD requires reports for certain companies to be filed in 2025 for financial years beginning on or after January 1, 2024. However, Sweden’s legislation, which took effect on July 1, 2024, introduced a transitional relief for large public interest companies in order to give such companies more time to prepare. Therefore, the initial phase of reporting for Sweden’s large companies is delayed and will instead begin in 2025. 

However, in a July 1, 2024 infringement package, the European Commission announced an infringement procedure against Sweden, citing that Sweden’s delayed implementation date is not in line with the CSRD and that by introducing this delay: “Sweden risks creating an unlevel playing field between EU companies in different Member States”.

Sweden has additionally extended the requirement to submit a sustainability report to include listed small and medium-sized companies, large or listed subsidiaries and certain larger branches of third-country companies that have significant operations within the European Economic Area. The reporting requirements also apply to insurance companies and credit institutions, regardless of their legal form, provided they are large companies or small and medium-sized companies.

Furthermore, the Swedish legislation has adjusted its turnover and balance sheet thresholds for large undertakings, a move likely to account for inflation.

Notable Non-EU Transpositions

Iceland – Not transposed

Although Iceland is not an EU member state, it is a member of the European Economic Area (EEA). EEA countries are required to transpose the CSRD into national law.

However, to the best of Vixio’s knowledge, Iceland has yet to launch a consultation or present draft legislation to transpose the CSRD to the Icelandic parliament. It is unclear when transposition legislation will be introduced.

Liechtenstein – Transposed

Although Liechtenstein is not an EU member state, it is a member of the EEA. EEA countries are required to transpose the CSRD into national law.

Following a consultation process, the Liechtenstein government approved proposed amendments to the Liechtenstein Personen- und Gesellschaftsrechts (the Persons and Companies Act) and the Liechtenstein Wirtschaftsprüfergesetzes (the Auditors and Auditing Companies Act) to implement the CSRD. The consultation period ended in August 2023. 

The Liechtenstein government later approved the draft legislation to transpose the CSRD, which entered into force on July 1, 2024.

Norway – Transposed

Norway is not an EU member state, but is a member of the EEA. EEA countries are required to transpose the CSRD into national law; therefore, Norway has incorporated the EU’s CSRD into its Accounting Act and expanded the number of companies required to comply with the sustainability reporting requirements.

In particular, Norway has significantly increased the thresholds for large and small companies, which will, for example, reclassify previously classed small companies to micro companies, which are exempt from reporting requirements. 

Medium-sized companies will be companies that exceed the new thresholds for small companies but that do not exceed the new thresholds for large companies.

Switzerland – Not transposed

Although Switzerland is not a part of the EU, the Swiss government is nevertheless planning to align its reporting rules with the CSRD. 

According to the Swiss Federal Council: “Due to the close economic ties, both large and small Swiss companies are affected by the new EU rules - directly or indirectly.”

The government initiated a consultation process in June 2024. The consultation closed on October 17, 2024. According to the consultation announcement, the Federal Council will analyse the effects on Swiss companies of the EU rules and then determine the next steps.