Are the requirements of CSRD transposed? If yes, what was the implementation date and what is the name of the legislation?
Yes, in principle. 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 below. CSRD was transposed first through the amendment of two acts, namely; the Accounting Act and the Independent Financial Audit Act on August 14, 2024 and September 4, 2024 respectively. The amendments to the Accounting Act entered into force retroactively as of July 6, 2024.
The amendments to the Independent Financial Audit Act, changed the title of the law to "Independent Financial Audit and Sustainability Assurance Act", and entered into force on September 20, 2024. The Stop-the-Clock Directive was transposed through amendments to the Accounting Act.
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:
- 2027 – for large enterprises that are enterprises of public interest and with an average number of employees over 500 people (including on a consolidated basis) - for 2026 financial year
- 2028 – all other large enterprises (including on a consolidated basis) - for 2027 financial year
- 2029 - for small and medium-sized enterprises, whose shares are traded on a regulated market or which are certain types of financial institutions - for 2028 financial year
- 2029 – for third‑country companies with large EU turnover, whose reporting obligation remains for financial years starting January 1, 2028 or later.
Do any enforcement provisions, such as sanctions or penalties exist under local law for non-compliance with CSRD?
Yes.
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