EU CSRD and Omnibus I: Transposition Tracker

The Stop-the-Clock Directive was transposed through Act No. NN 126/25 (Zakon o izmjenama i dopunama Zakona o tržištu kapitala NN 126/25) amending the Accounting Act and the Capital Market Act aligning the national legislation.

Additionally, the Ministry of Finance has announced that the Directive will also be transposed through the Act on Amendments and Supplements to the Accounting Act.  The Act entered into force on 31 December 2025.

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.

On 10 July 2025, the Federal Ministry of Justice and Consumer Protection (BMJV) reintroduced a draft implementing bill for transposing the CSRD. The draft bill takes into account the Omnibus developments. implementation of the ‘Stop-the-Clock’ Directive. Furthermore, the draft law already incorporates the EU Commission's proposal in the draft Omnibus Directive to limit the scope of the CSRD by stipulating that “first wave” companies with up to 1,000 employees must report for the first time for fiscal years beginning in 2027. Further simplifications currently being discussed as part of the Omnibus legislative process have not been included, as the German legislator intends to wait for developments at the EU level..

An earlier draft bill was approved in July 2024 but lapsed in accordance with the principle of discontinuity following the break-up of the coalition government. The content of the new draft bill is largely based on the previous government’s bill.

The Ministry of National Economy published the draft amendment of the ESG Act for public consultation, which relates to the Omnibus Packages. The public consultation closed on 29 March 2025, however, as of today, it has not yet been filed before the Parliament.

According to the draft amendment, the enterprises subject to the ESG Act would be modified in such a way that small and medium-sized enterprises of public interest would be excluded from the scope of the ESG Act, while for large enterprises, the indicators based on which it would be determined who is required to prepare an ESG report would be modified. These indicators would be defined in a separate decree by the Ministry of National Economy. This decree has not yet been published in the current legislative amendment process.

According to our interpretation, the draft would not exempt large enterprises from the administrative burdens related to preparing the ESG report, however, they would not be required to submit the ESG report to the Supervisory Authority for Regulated Activities (SZTFH), nor would they be required to publish it on their website.

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.

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.

Transposition of the original CSRD and the Omnibus proposals are currently still on hold. The Dutch legislator has published updated draft legislation transposing the original CSRD and Omnibus I but prefers to wait until the adoption of Omnibus II at the European Union level before continuing with the transposition process (provided that the negotiations regarding Omnibus II progress sufficiently). The Dutch legislator has been once again reminded by the European Commission of the passing of the transposition deadline and which also noted that there is no scope for further delays.

The Netherlands held elections on 29 October 2025 and is currently in the process of forming a new government. Depending on the composition of the new government, the transposition process may be affected.

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.

At this stage, the companies' reporting obligation (under Art. 1 of the CSRD) has been implemented in national law, as per the transposition rules under Art. 5 of the CSRD. However some additional legislation needs to be adopted to finalise the legal framework under the CRSD, particularly to finalise the transposition of some changes under Art. 2 on the Transparency Directive and Art. 3 on the Audit Directive.

This means that the reporting obligation of companies, as provided by the CSRD has been transposed in Romania, while some of the changes brought by the CSRD, particularly as regards the Transparency and Audit Directives are still in the pipeline locally. The remaining points are expected to be transposed in the beginning of 2025.

At the end of 2024, the Government also finalised the transposition of the provisions of Article 3 of the CSRD in the Audit Directive. However, additional legislation needs to be adopted to finalise the legal framework under the CRSD, particularly to finalise the transposition of changes under Article 2 on the Transparency Directive. This means that the reporting obligation of companies, as provided by the CSRD has been transposed in Romania, while some of the changes brought by the CSRD, particularly as regards the Transparency Directive are still in the pipeline locally. The remaining points are expected to be transposed in the beginning of 2025. No changes regarding CSRD related local legislation. As a result, no amendments have been made to the table.

In relation to Omnibus I’s effects in Romania, we note that the local thresholds for determining the reporting companies, as adopted under Romanian legislation and currently in force, were lower than those established at EU level. Thus, there may be a possibility that, following the Romanian transposition of Omnibus package, the new amended thresholds may still be different from those foreseen in the EU Omnibus initiative. In any case, as the Omnibus proposal has to first be adopted at European level and then transposed into national legislation, the impact could not be clearly determined.

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.