EU CSRD and Omnibus I: Transposition Tracker

The CSRD transposition for Czech Republic was divided in two phases: 

• The first phase of transposition relates to companies subject to the Non-Financial Reporting Directive which took effect from 1 January 2024; and

• The second phase of transposition was to be implemented through amending the existing Accounting Act and Act on Auditors, however this was subsequently revised to reflect the changes introduced by the Stop-the-Clock Directive and the amendments proposed by the ESG Omnibus proposals.

  The revised legislation was approved by the Czech Parliament on 23 July 2025 and signed by the President on 21 August 2025.

The Stop-the-Clock Directive was transposed into Danish law on 2 December 2025 with the adoption of a bill amending national legislation, thereby postponing the reporting application deadlines for sustainability reporting under CSRD for wave 1 and wave 2. It does not bring any changes to the content of the CSRD reporting obligation itself.

The Act also provides the minister with an enabling provision to issue regulations permanently exempting certain companies from sustainability reporting from 2025 if the EU adopts the expected simplification directive, without requiring new legislation.

Furthermore, a transitional arrangement is introduced for the deregistration of already appointed auditors or independent assurance providers.

The Act entered into force on 31 December 2025.

The Stop-the-Clock Directive was transposed into French law by Law 2025-391 of 30 April 2025, published in the Journal Officiel on 2 May 2025.

Before the publication of Law 2025-391, members of Parliament referred a provision (Article 23) to the Constitutional Council, but this provision was not related to the transposition of the Stop the Clock Directive.

The Constitutional Council issued a decision declaring the law to be in conformity with the Constitution on 29 April 2025.

As of 20 June 2025, the enterprises subject to the ESG Act has been modified in such a way that small and medium-sized enterprises of public interest are now excluded from the scope of the ESG Act.  ESG reporting applies only if the undertaking operates in certain sector (e.g. pharmaceuticals, energy, finance,) and in two consecutive years exceeds both:

1. HUF 90,000 million annual net revenue, and
2. 500 employees on average.

Large undertakings subject to ESG reporting are exempt from filing ESG reports and certificates with the  Supervisory Authority for Regulated Activities (SZTFH) for financial years starting in 2024–2026. Until 30 June 2027, micro and small undertakings cannot be required (or voluntarily commit) to provide ESG data, and medium-sized undertakings cannot contractually commit to ESG data provision.

Under the ESG Act, as of 1 January 2026, failure to comply with ESG data reporting obligations or submission of an ESG report that does not meet statutory requirements may result in administrative fines imposed by SZTFH. 

As of 22 December 2025, the  SZTFH Decree No. 13/2024 (VIII.15.) has also been amended, replacing the previous ESG questionnaire. According to the amendment, companies must operate a risk assessment system consisting of an annual risk analysis conducted at least every 12 months, as well as ad hoc risk assessments. The previous requirement to complete the annual risk assessment by 30 June has been removed.

As of 20 June 2025, the Accounting Act has been amended by Act LIV of 2025, extending the deadlines for applying the sustainability reporting requirements.

As of 20 June 2025, ESG Act has been amended by Act LI of 2025, introducing changes to the scope and ESG reporting obligations.

As of 6 September 2025, the  Government Decree No. 276/2025. (VIII.21.) has institutionalized transparent sanctioning rules in respect of violations of certain ESG obligations  proportionate to the gravity of the infringement and considering the economic circumstances of the parties concerned. The Decree designates SZTFH as the body competent to impose fines up to 50 million Hungarian forints

The European Union (Corporate Sustainability Reporting) Regulations 2025 were published on 11 June 2025. These regulations implement the provisions of the Stop-the-Clock Directive ensuring that those Irish companies required to report for the first time in respect of their 2025 or 2026 financial years have their sustainability reporting obligations pushed out to their 2027 or 2028 financial years respectively.

In addition, the regulations introduce amendments to Part 28 of the Companies Act which clarify several of the inconsistencies between CSRD and the Irish implementing legislation.

On 9 August 2025, Law No. 118 of 8 August 2025 was published in the Official Gazette (General Series, no. 184). This law converts Decree-Law No. 95 of 30 June 2025 (the "Omnibus Decree") into law. Among other measures, Law No. 118/2025 amends the Omnibus Decree to the Stop-the-Clock Directive.

In particular, Article 10, paragraph 1-bis of the revised Omnibus Decree amends Legislative Decree No. 125/2024, which had originally transposed the CSRD in Italy. These amendments implement the provisions of the Stop-the-Clock Directive ensuring that Italian companies that would have been required to publish sustainability reports for the first time in relation to the 2025 or 2026 financial years will now begin reporting for the 2027 or 2028 financial years, respectively.

On a related point, the updated transposition decree had originally required the Ministry of Economy and Finance and Consob to conduct, within 18 months of the decree’s entry into force, a study on the potential benefits and costs of permitting independent assurance service providers (in addition to traditional auditors) to certify sustainability reports, as allowed under Article 34(4) of the Accounting Directive. The recent amendments extend the deadline for this study to 31 October 2028.

Finally, the Omnibus Decree, as amended, introduces certain coordination measures to ensure that the postponed sustainability reporting requirements are aligned with the corresponding rules for auditors and audit firms regarding CSRD-related obligations.

The CSRD was transposed in Latvia through the Sustainability Information Disclosure Law which entered into force on 17 October 2024.

Additionally it is stated that the Government shall prepare legislature designating competent authority and develop a proper procedure for evaluating correctness and completeness of reported sustainability information by 30 June 2025.

Lithuania transposed the CSRD through amendments to the Law on Accountability of Companies and Groups of Companies; the Law on Audit of Financial Statements and Other Assurance Services; the Code of Administrative Misdemeanours and other laws, which were approved on 25 June 2024 and entered into force on 1 July 2024.

Draft implementation legislation has been published by the Dutch legislator in 2025 to reflect the Stop-the-Clock Directive. Omnibus II has not yet been reflected in Dutch implementation legislation. 

The provisions causing retroactive effect of CSRD (i.e. companies that would be required to publish CSRD report for FY24 and FY25 but not thereafter given the legislative changes) will be taken out from the Dutch implementation legislation. A number of organisations including the Dutch Royal Accountants Association and the associations for investors have been pushing for this amendment repeatedly and – in contrast to earlier statements from the Dutch legislator – this position has now finally been accepted. 

Transposition of CSRD and the Stop-the-Clock Directive are currently still on hold. While the Dutch legislator prefers to implement CSRD together with the Omnibus proposals,  the Dutch House of Representatives has decided not to wait and scheduled a debate on the CSRD Implementation Act on 2 March 2026. A discussion is ongoing regarding CSRD applying retroactively from FY2024 for public interest entities with over 1,000 employees, which a number of associations (including the association for institutional investors and the Dutch accountants association) have publicly urged the Minister of Finance to abandon this plan. It is currently unclear if a vote will take place during the 2 March meeting of the Dutch House of Representatives.

The Minister of Finance gave the following update regarding the Dutch implementation process: It is expected that the official translations of the Omnibus directives will be published in March 2026, following which the Dutch legislator is expecting to submit an amendment of the current draft implementation legislation (to reflect the changes made through the Omnibus proposals) to the Council of State. However, the amended draft implementation legislation will not be ready for the 2 March debate of the Dutch House of Representatives as mentioned above.

On 11 April 2025, the Ministry of Finance issued a consultation proposal regarding the implementation of the Stop-the-clock directive into Norwegian law.

The proposal changes the transitional rules by postponing the implementation of reporting requirements for companies in wave 2 and 3. The proposed amendments were adopted on 3 July 2025, and entered into force on the same day.

The amendments entail postponed reporting obligations for companies that have not yet reported under the CSRD, meaning that Norwegian companies will face the same application dates as companies in the EU.

On 7 May 2025, a draft law to implement the Stop-the-Clock Directive was published. The Polish Parliament adopted the final draft on 9 July 2025, and the President signed it on 23 July 2025. The law came into force on 12 August 2025.

The implementation of the Stop-the-Clock Directive in Poland postpones the application deadlines for sustainability reporting under the CSRD by two years. For the Second Wave, the deadline is shifted from financial years beginning after 31 December 2024 to financial years beginning after 31 December 2026. For the Third Wave, the deadline is deferred from financial years beginning after 31 December 2025 to financial years beginning after 31 December 2027. Simultaneously, the legislation eliminates the previous exemption for the Third Wave, which permitted a two-year deferral of reporting, as it has become redundant.

The implementation does not introduce any other changes to the CSRD sustainability reporting obligations, particularly with respect to the deadlines for the First Wave or the scope and content of CSRD reporting requirements.

The CSRD  has been transposed into Romanian legislation through the Ministry of  Finance's Order No. 85/2024 on sustainability reporting aspects, effective as of 26 January 2024, along with several additional regulations amending sector specific norms, including those governing the financial market and auditing, which were gradually adopted during 2024 and 2025.

To be noted that the Romanian legislation applies the CSRD reporting obligations to companies that are smaller than the European classification for large and medium-sized undertakings. In other words, many companies that would be exempt under the European criteria are required to comply in Romania. Thus, there may be a possibility that, following the Romanian transposition of Omnibus I package, the scope of reporting requirements may still be different from those foreseen in the EU Omnibus initiative. In any case, the impact could not be clearly determined now.

On 10 June 2025, the Slovak Parliament approved the amendments to the Securities Act and other acts (the Amendment), including amendments to the Accounting Act, which implemented the CSRD into Slovak law with effect from 1 June 2024. The Amendment implemented the Stop the Clock Directive. The postponement provisions became effective on 10 July 2025.

The Amendment also stipulates that individual and consolidated financial statements, auditors' reports, annual statements, sustainability reports (in Slovak: Správy o udrľateµnosti) and assurance reports (in Slovak: Správy o uistení v oblasti vykazovania informácií o udrľateµnosti) on sustainability reporting will have to be reported to the specialized portal operated by the Financial Directorate of the Slovak Republic. This obligation applies to the mandatory reporting of documents after 9 January 2028, and in the case of voluntary reporting, after 9 January 2030.

A draft law was filed with the Spanish Parliament on 15 November 2024 and the legislative approval process is ongoing. The Spanish Securities Market Commission (CNMV) and the Spanish Institute of Accounting and Auditing (ICAC) have published guidance with their expectations in the likely case the transposition is not finalised by 1 Jan 2025.

A second joint statement was published on 19 November 2025, which states that given that Spanish law may not yet be aligned with European law as of 31 December 2025, the CNMV recommends that Spanish Phase 1 entities publish their 2025 sustainability report in line with the ESRS so the information is comparable with that provided by most other European Union issuers. It also recommends considering the “quick fix” delegated regulation, which freezes certain disclosure requirements for two years.

Regarding entities in Phase 2, the CNMV recommends that they assess whether it would be advisable to apply the ESRS or the voluntary sustainability reporting standard for small and medium-sized enterprises (VSME), taking into account the temporary suspension Directive and other ongoing European regulations.

No developments yet

On 26 March 2025, CNMV’s Advisory Committee (a consultative body composed by market participants but with an independent opinion from the CNMV) published a feedback statement to the Commission welcoming the Omnibus Proposal for simplification and reduction of administrative burden while maintaining support for the environmental objectives of the EU.

The CSRD was transposed in Sweden on 29 May 2024 through new rules which became effective as of 1 July 2024. 

On 16 December 2024, the EU Commission sent a “reasoned opinion” to Sweden for failing to comply with the CSRD as the measures adopted by Sweden require companies to start reporting information for financial years beginning on or after 1 July 2024 - a delay of the application of sustainability reporting requirements by half a year. The Commission believes that by introducing this delay, Sweden risks creating an unlevel playing field between EU companies in different Member States. Sweden had two months to respond and address the shortcomings.