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?
CSRD obligations apply in line with the EU phased implementation timetable following national transposition. For financial years starting in 2024, the requirements apply to large public-interest entities, including listed companies, banks and insurance undertakings already within the scope of the former Non-Financial Reporting Directive, as well as parent undertakings of large groups meeting the relevant criteria.
From financial years starting in 2025, the scope extends to other large undertakings as defined under the CSRD size thresholds.
From 2026, listed small and medium-sized enterprises fall within scope, subject to transitional opt-out provisions. From 2028, certain EU subsidiaries of non-EU parent companies are required to report where the group meets the €150 million EU turnover threshold and has a qualifying EU presence.
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. On August 29, 2024, the advice of the Council of State was issued on the Act implementing the Sustainability Reporting Directive by companies. On September 26, 2024, the European Commission announced that it opened infringement procedures against Netherlands for failing to fully transpose the Directive.
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