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. On July 27, 2024, the CSRD requirements were adopted into national law, amending the Accounting Act, Audit Act, and Capital Markets Act. 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 July 27. The Stop-the-Clock Directive was transposed through amendments to the Capital Market 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:
- 2025: for large public-interest companies (with over 500 employees, such as banks, insurance companies, etc.) already subject to the NFRD, for 2024 financial year
- 2028: for large companies that are not presently subject to the NFRD (with more than 250 employees and/or EUR 40 million in turnover and/or EUR 20 million in total assets), for 2027 financial year
- 2029: for listed SMEs and other financial undertakings, and for third-country businesses with large EU turnover, for financial year 2028
Do any enforcement provisions, such as sanctions or penalties exist under local law for non-compliance with CSRD?
Yes.
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