Are the requirements of CSRD transposed? If yes, what was the implementation date and what is the name of the legislation?
Yes. The CSRD has been transposed into the NaBeG Sustainability Reporting Act, published on 18 February 2026. The transposing legislation implements the core CSRD obligations, including reporting on environmental, social and governance factors, subject to the scope, assurance and enforcement provisions described in the adjacent columns. The Stop-the-Clock Directive has been partially transposed - it postponed the second and third CSRD reporting waves by two years (to financial years starting on or after 1 January 2027 and 1 January 2028, respectively). Wave-1 companies (large public-interest entities with more than 500 employees) continue to report under the original CSRD timetable (from financial year 2024). The Omnibus I Directive has not been transposed yet, as the transposition deadline is 19 March 2027.
Has the local legislation extended the scope of the CSRD, by adding any additional requirements or going beyond the Directive in any way?
No.
How does the transposition affect different types of companies? Are there specific provisions for different sizes or types of companies, such as SMEs versus large enterprises?
The sustainability reporting obligation is phased in as follows: • 2025: for Wave-1 large public-interest entities with more than 500 employees, for 2024 financial year 2024 • 2028: for large companies that are not public‑interest entities (the “second wave”), for 2027 financial year • 2029: for listed SMEs (the “third wave”), also postponed by two years; they must report for the financial year beginning in 2028 instead of 2026. • 2029: for third‑country companies with large EU turnover, whose reporting obligation remains for financial years starting 1 January 2028 or later.
Do any enforcement provisions, such as sanctions or penalties exist under local law for non-compliance with CSRD?
Yes. Non-compliance with sustainability reporting obligations may give rise to administrative penalties under the NaBeG and related supervisory provisions.
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