CSRD Transposition Tracker: CSRD, Stop-the-Clock and Omnibus I Laws in the 27 Member States and Norway

Two of the three transposition deadlines have passed, and the Commission decided letters of formal notice to 17 Member States in September 2024.

The Corporate Sustainability Reporting Directive, Directive (EU) 2022/2464, binds the Member States, and companies report under the national law that transposes it. The European Sustainability Reporting Standards (ESRS), adopted as delegated regulations, apply directly. Who reports and what the regime requires are set out in the CSRD explained after the Omnibus.

This tracker gives one row for each of the 27 Member States and Norway, with the national act for each of the three directives, the Commission's infringement step and, separately, the national choices on who may assure a sustainability report. Every status is dated 29 October 2026.

What Transposition Means and Why National Law Decides

Transposition is the step by which each Member State writes a directive into its own law, and the CSRD, Directive (EU) 2022/2464, reaches companies only through that national law, while the ESRS delegated regulations apply directly. The CSRD amended four EU acts: the Accounting Directive 2013/34/EU, the Transparency Directive 2004/109/EC, the Audit Directive 2006/43/EC and Regulation (EU) No 537/2014. National acts therefore amend accounting, company and audit law, such as the Austrian Commercial Code (UGB) or the Finnish Accounting Act (kirjanpitolaki).

Member States notify their national measures to the Commission, and the notified measures are recorded in Cellar, the EU database shown on the national-measures tab of EUR-Lex, with the act and its notification date. Directives (EU) 2025/794 and 2026/470 follow the same route: each binds the Member States, and each reaches companies through the national acts that transpose it.

Three Transposition Deadlines: 2024, 2025 and 2027

Member States had to transpose the CSRD by 6 July 2024 (Article 5(1) of Directive (EU) 2022/2464) and the Stop-the-clock Directive by 31 December 2025 (Article 3(1) of Directive (EU) 2025/794), and must transpose Articles 1 to 3 of Directive (EU) 2026/470 by 19 March 2027 (Article 5(1) of Directive (EU) 2026/470). The table below lists the three deadlines with their provisions.

The first two deadlines have passed. A missing national measure for Directive (EU) 2026/470 is not late before 19 March 2027. How these dates translate into first reporting years is set out among the reporting deadlines on the CSRD timeline.

Transposition Tracker: Status per Member State as of 2026-10-29

The tracker below gives, for each of the 27 Member States and Norway as of 29 October 2026, the national act for the CSRD, the measure for the Stop-the-clock Directive, the record for Directive (EU) 2026/470 and the Commission's step in the 2024 CSRD infringement cases, with one detailed page per country. "Notified" means a dated record in EUR-Lex; "no record" means that no notification was recorded on 29 October 2026. A "no record" cell is not the same as "not transposed": only the rows for Germany, Luxembourg, the Netherlands and Spain state that no transposing act exists.

Norway is in the European Economic Area (EEA), not the EU; its row follows EEA-Lex and Norwegian law. In the last column, LFN stands for the letter of formal notice decided on 25 September 2024. The records come from the EUR-Lex national measures for the CSRD; "notified" means a measure notified to the Commission, not a finding of complete transposition.

The national status decides which text a company reports under, and each row leads to the country page with its scope and first reporting years. The CSRD compliance steps whatever the national status are set out on one page.

The 2022 Directive in National Law: Acts, Bills and Gaps

As of 29 October 2026, EUR-Lex records notified CSRD measures for 22 Member States, and five Member States have none: Germany, Spain, Luxembourg, the Netherlands and Portugal. The status of the five, each as of 29 October 2026, is listed below.

• Germany: Germany has not transposed the CSRD; the government bill (BT-Drs. 21/1857) has been referred to committee and not adopted, and the CSR-RUG rules still apply.
• Luxembourg: bill n° 8370, filed on 29 March 2024, is in committee and has not been voted; its last recorded update dates from 22 December 2025.
• The Netherlands: bill 36678 (Wet implementatie richtlijn duurzaamheidsrapportering) has not been debated or voted, and the committee postponed its handling on 12 February 2026 pending an amending memorandum.
• Spain: Real Decreto 806/2026 of 5 October 2026 dissolved the Congreso and the Senado (elections on 29 November 2026), so the CSRD bill 121/000038 lapsed on 6 October 2026.
• Portugal: no measure is recorded for any of the three directives.

Two national acts cover less than the full CSRD scope. Austria's NaBeG (BGBl. I Nr. 6/2026) covers first-wave companies only, the large public-interest entities with more than 500 employees of § 243b UGB. Czechia's Zákon č. 316/2025 Sb., in force since 1 January 2026, covers public-interest entities that meet the large-entity criteria and have more than 1,000 average employees, for accounting periods from 1 January 2025 (§ 32f(1) of the Czech Accounting Act).

The CSR-RUG of 11 April 2017 (BGBl. I 2017 S. 802) in Germany and the EINF regime of Ley 11/2018 in Spain, which still applies, are national rules transposing the NFRD, Directive 2014/95/EU. Those predecessor duties are explained under the NFRD rules that still apply in national law.

The 2025 Postponement in National Law

As of 29 October 2026, EUR-Lex records national measures for Directive (EU) 2025/794 from 21 Member States, and none from Czechia, Germany, Spain, Luxembourg, the Netherlands or Portugal. The Stop-the-clock Directive changed only the application dates in Article 5(2) of the CSRD.

Germany folds the postponement into its CSRD bill, whose title names Directive (EU) 2025/794. France transposed it by article 7 of loi n° 2025-391 du 30 avril 2025, and Belgium by the loi du 12 décembre 2025. Denmark notified Lov nr. 1636 af 16. december 2025 on 13 and 28 January 2026, and Greece notified Ν. 5255/2025 on 5 January 2026.

Czechia is the only state with CSRD records in EUR-Lex but no record for the postponement. The reports that the EU moved, and their new first years, are set out under which CSRD reports were postponed in 2025.

Omnibus Amendments in National Law before 19 March 2027

As of 29 October 2026, EUR-Lex records national measures for Directive (EU) 2026/470 from four Member States, Poland (notified 30 March 2026), Croatia (4 May and 11 June 2026), Finland (30 June 2026) and Belgium (31 July 2026), and the deadline for the others runs until 19 March 2027. Each record shows a notification, not that the whole amendment is in national law.

The dated national steps without a record, each as of 29 October 2026, are listed below.

• Denmark: bill L 7 (2026-27) had its first reading on 23 October 2026.
• France: the French Omnibus transposition is pending: the DDADUE bill (article 9) passed the Sénat on 18 February 2026 and is in committee at the Assemblée nationale (texte n° 2518).
• Germany: the coalition amendment 21(6)73 of 30 March 2026 to the CSRD bill covers Directive (EU) 2026/470 and is not adopted.
• Sweden: the inquiry report SOU 2026:27 makes proposals; no act is adopted.
• Norway: Prop. 106 L (2025-2026) was sent to the Storting's Finance Committee on 30 September 2026.

These steps record procedure, not content. What the amendments change at EU level is set out under what Omnibus I changed in the CSRD.

The Optional Relief for FY 2025 and FY 2026 Reports

Directive (EU) 2026/470 lets each Member State exempt first-wave undertakings and issuers that do not exceed EUR 450 million net turnover or an average of 1,000 employees (consolidated where applicable) for financial years starting between 1 January 2025 and 31 December 2026 (Article 5(2) of Directive (EU) 2022/2464 as amended by Article 3 of Directive (EU) 2026/470). The option takes effect only through national law. Austria used the option: under § 908 Abs. 2a UGB, undertakings with up to EUR 450 million turnover or not more than 1,000 employees on average are not obliged to report for the individual report and may apply the rules voluntarily; the same applies to groups.

Infringement Procedures: Letters of Formal Notice and a Reasoned Opinion

On 25 September 2024 the Commission decided to send letters of formal notice to 17 Member States (Belgium, Czechia, Germany, Estonia, Greece, Spain, Cyprus, Latvia, Luxembourg, Malta, the Netherlands, Austria, Poland, Portugal, Romania, Slovenia and Finland), announced on 26 September 2024, with two months to respond. The letters concern the failure to notify full transposition of the CSRD after the deadline of 6 July 2024 (Commission package INF/24/4661). The Commission may send a reasoned opinion where a reply is not satisfactory.

An infringement procedure under Article 258 TFEU is a case of the Commission against a Member State, and companies are not parties to it. These are cases against states, and company penalties, unlike infringement procedures, are set out per Member State under national law.

The case steps recorded in the Commission's infringement decisions as of 29 October 2026 are listed below.

• Closed on 30 January 2026: Belgium INFR(2024)0209, Cyprus 0212, Estonia 0218, Finland 0225, Greece 0220, Latvia 0236, Poland 0242, Romania 0247 and Slovenia 0250.
• Closed on 1 October 2026: Austria INFR(2024)0207.
• Open at letter-of-formal-notice stage as of 29 October 2026: Czechia 0214, Germany 0216, Spain 0223, Luxembourg 0234, Malta 0238, the Netherlands 0240 and Portugal 0244.

Sweden faced a separate case, INFR(2024)2195. The Commission sent Sweden a letter of formal notice on 25 July 2024 and a reasoned opinion on 16 December 2024 because Swedish law required reporting only for financial years beginning on or after 1 July 2024, delaying application by half a year; it closed the case on 8 October 2025 (INF/24/6006).

Who May Assure: National Choices on Independent Providers

The CSRD lets each Member State decide whether independent assurance services providers, and not only statutory auditors, may give the assurance opinion, and the national choices recorded on 29 October 2026 differ. Article 34(4) of Directive 2013/34/EU allows a Member State to admit an independent assurance services provider established in its territory, an accredited conformity assessment body (Article 2(20)), subject to equivalent requirements. A Member State that allows them must also allow a statutory auditor other than the one auditing the financial statements.

Of the 11 choices in the table below, five provide for a route beyond statutory auditors and audit firms: France and Norway, and Belgium, Austria and Poland under conditions. The Netherlands, Ireland, Italy, Sweden and Czechia keep the opinion with auditors and audit firms, and the German bill would do the same. Who may sign and on what conditions is explained under independent assurance providers under the CSRD.

What This Tracker Does Not Show

This tracker shows national acts, notification records and Commission steps; it does not tell any company whether it must report, and it gives no official count of reporting companies, because no official count of companies in scope after the Omnibus exists. The two kinds of detail kept elsewhere are listed below.

• Each country's scope, first reporting years, penalties and supervisors, on its country page.
• The content of national acts transposing Directive (EU) 2026/470.

Is a Notified Measure the Same as Complete Transposition?

No: a record in Cellar shows that a Member State notified a measure for a directive, not that the Commission found the measure complete or correct. The Commission's own steps appear in its infringement decisions, not in Cellar.

A record can also cover a narrower act, as the Austrian row shows. The transposition article itself, Article 5(1), is in the CSRD legal text with its transposition article.

How the EEA Agreement Reaches Norway

The CSRD reaches Norway through the EEA Agreement, and the CSRD and Directive (EU) 2026/470 are not yet incorporated into the EEA Agreement (draft Joint Committee Decision under consideration, EEA-Lex, as of 29 October 2026). EEA-Lex records the draft decision for the CSRD as sent to the Commission on 9 October 2024.

Norway applies its own act, LOV-2024-06-21-42 on sustainability reporting (bærekraftsrapportering), in force since 1 November 2024. The Commission's infringement procedure does not cover Norway.