Interactive Map: Transposition of EU Corporate Sustainability Reporting Directive (CSRD)

February 21, 2025
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The Corporate Sustainability Reporting Directive (CSRD) is a new European Union (EU) directive that requires small, medium and large companies operating in Europe to disclose their environmental, social and governance (ESG) impacts on society as part of an annual non-financial reporting duty. This map outlines the transposition of the CSRD across EU member states, as well as European Economic Area and European Free Trade Association states.

The Corporate Sustainability Reporting Directive (CSRD) is a new European Union (EU) directive that requires small, medium and large companies operating in Europe to disclose their environmental, social and governance (ESG) impacts on society as part of an annual non-financial reporting duty. The directive 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 CSRD was adopted by the European Commission in November 2022 and took effect on January 5, 2023. The directive required applicable member states to transpose Articles 1-3 of the directive into their national legislation by July 6, 2024. 

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.

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.

The CSRD requires companies to follow the EU’s new sustainability reporting standards (ESRS) when disclosing information about their environmental and social risks and impacts. The standards “cover the full range of environmental, social, and governance issues, including climate change, biodiversity and human rights. They provide information for investors to understand the sustainability impact of the companies in which they invest.”

More information on the CSRD can be found here.

As of February 2025, 19 jurisdictions have transposed the CSRD in full, while Czechia and Hungary have partially transposed the CSRD. Seven jurisdictions have introduced legislation to transpose the CSRD. Three jurisdictions — Iceland, Malta and Portugal — have yet to release specific details around proposed legislation to transpose the CSRD. 

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

Vixio’s EU CSRD Transposition Analysis 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. Please see the EU CSRD Transposition Analysis for more information.

The interactive map below outlines the transposition of the CSRD across EU member states, as well as European Economic Area and European Free Trade Association statesIf this map is not displaying, please click here

Key:

Transposed: The state has transposed the CSRD.

Partially transposed: The state has partially transposed the CSRD, with further transposition required.

Not transposed: The state has not transposed the CSRD.

Index:

JurisdictionTransposition StatusReference
AustriaNot transposedDraft legislation has been introduced as of February 2025
BelgiumTransposedBelgium’s draft legislation to transpose the CSRD was introduced on October 24, 2024 and later approved by the Belgian Parliament on November 28, 2024.
BulgariaTransposedAct to amend and supplement the Accounting Act
CroatiaTransposedLaw on Accounting
CyprusNot transposedCyprus’ draft legislation to amend the Cypriot Companies Law was introduced in March 2024 but has not yet been transposed into national law. 
CzechiaPartially 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. 

DenmarkTransposedAct amending the Annual Accounts Act, the Auditors Act and various other acts(unofficial English translation available here)
EstoniaTansposedAct on Amendments to the Accounting Act and Other Acts Consequent thereto
FinlandTransposedAct on amending the Accounting Act(unofficial English translation available here)
FranceTransposedOrder No. 2023-1142 of December 6, 2023 relating to the publication and certification of information on sustainability and the environmental, social and corporate governance obligations of commercial companies
GermanyNot transposedGermany’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.
GreeceTransposedLaw 5164/2024
HungaryPartially 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. 

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.

IcelandNot transposedIceland has yet to launch a consultation or present draft legislation to transpose the CSRD to the Icelandic parliament.
IrelandTransposedS.I. No. 336/2024 — European Union (Corporate Sustainability Reporting) Regulations 2024
ItalyTransposedImplementation of Directive 2022/2464/EU of the European Parliament and of the Council of 14 December 2022, amending Regulation 537/2014/EU, Directive 2004/109/EC, Directive 2006/43/EC and Directive 2013/34/EU as regards corporate sustainability reporting
LatviaTransposedSustainability Disclosure Act
LithuaniaTransposedOn the audit of financial statements of the Republic of Lithuania Law No. VIII-1227
LiechtensteinTransposed

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.

LuxembourgNot 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.

MaltaNot transposedThe Maltese government has yet to release draft legislation to transpose the CSRD into local law.
NetherlandsNot transposedThe Netherlands’ draft legislation was introduced in November 2023 and the consultation period for the draft legislation expired in December 2023.
NorwayTransposedAct on amendments to the Accounting Act, etc. (sustainability reporting)and Transitional rules (unofficial English translation available here)
PolandTransposedAct of 6 December 2024 amending the Act on Accounting, the Act on Statutory Auditors, Audit Firms and Public Supervision and certain other acts
PortugalNot transposedThe Portuguese government has yet to release draft legislation to transpose the CSRD into local law.
RomaniaTransposedOrder no. 85/2024 for the regulation of sustainability reporting issues
SlovakiaTransposedLaw of April 24, 2024, which amends Act no. 431/2002 Coll. on accounting as amended and which amends some laws
SloveniaTransposedThe Law on Amendments and Amendments to the Law on Business Companies
SpainNot transposedSpain’s draft bill, which was introduced in November 2024, is under negotiation in the Spanish Congress.
SwedenTransposedNew rules on sustainability reporting (as approved)
SwitzerlandNot transposedIn June 2024, the government initiated a consultation process on a draft bill titled Transparency on Sustainability Aspects. 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.

 

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