Are the requirements of CSRD transposed? If yes, what was the implementation date and what is the name of the legislation?
Transposition not yet complete.
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 CSRD requirements are being transposed in line with the EU-wide phased application timeline. The first wave applies to large public-interest entities, including listed companies already subject to the Non-Financial Reporting Directive, for financial years starting in 2024 (reporting in 2025).
From financial years starting in 2025, the requirements extend to other large undertakings.
From 2026, listed small and medium-sized enterprises will fall within scope, subject to transitional opt-out provisions until 2028.
From 2028, certain non-EU parent companies will also be required to report where they generate more than €150 million in net turnover within the EU and have a qualifying EU subsidiary or branch.
Do any enforcement provisions, such as sanctions or penalties exist under local law for non-compliance with CSRD?
Yes.
If the CSRD has not yet been transposed, what steps have been taken towards implementation?
Transposition in process The Luxembourg legislation transposing the CSRD – draft bill no. 8370 – was introduced on 29 March 2024. On 26 September 2024, the European Commission announced that it opened infringement procedures against Luxembourg for failing to fully transpose the Directive.
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