Are the requirements of CSRD transposed? If yes, what was the implementation date and what is the name of the legislation?
Yes. The CSRD was transposed in two phases through amendments to Accounting Act and Act on Auditors in May 2024.
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 was transposed in the second phase through amendments to those pieces of legislation.
The Omnibus I Directive has not been transposed yet, as the transposition deadline is 19 March 2027. The government approved draft transposition legislation on 27 July 2026 and has since submitted it to Parliament for the ordinary legislative procedure.
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 1,000 employees), for 2024 financial year
- 2028: all other large enterprises (including on a consolidated basis) - for 2027 financial year
- 2029: for listed small and medium-sized enterprises - for 2028 financial year
- 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. The Accounting Act provides for administrative fines for failure to prepare or publish sustainability reports in accordance with the transposing legislation.
© Eversheds Sutherland. All rights reserved. Eversheds Sutherland is a global provider of legal and other services operating through various separate and distinct legal entities. Eversheds Sutherland is the name and brand under which the members of Eversheds Sutherland Limited (Eversheds Sutherland (International) LLP and Eversheds Sutherland (US) LLP) and their respective controlled, managed and affiliated firms and the members of Eversheds Sutherland (Europe) Limited (each an "Eversheds Sutherland Entity" and together the "Eversheds Sutherland Entities") provide legal or other services to clients around the world. Eversheds Sutherland Entities are constituted and regulated in accordance with relevant local regulatory and legal requirements and operate in accordance with their locally registered names. The use of the name Eversheds Sutherland, is for description purposes only and does not imply that the Eversheds Sutherland Entities are in a partnership or are part of a global LLP. The responsibility for the provision of services to the client is defined in the terms of engagement between the instructed firm and the client.
Connect with us
