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. In December 2023, amendments were made to the Accounting Act, the Auditing Act, the Companies Act, the Securities Markets Act to transpose the CSRD requirements. The Stop-the-Clock Directive was transposed through amendments to the Accounting Act, entering into force on December 1, 2025.
Has the local legislation extended the scope of the CSRD, by adding any additional requirements or going beyond the Directive in any way?
Yes Changes include:
- a broader scope of entities/groups, including certain non-EEA entities/groups
- a greater granularity in the information to be published, which must be understandable, relevant, verifiable, comparable and represented in a faithful manner
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 and already subject to the NFRD) for 2024 financial year
- 2028 – all other large enterprises meeting at least two of the following three criteria: >250 employees, €50m turnover, €25m balance sheet - 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 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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