A Look at CSRD Omnibus Developments Across the EU Member States

Ropes & Gray – in conjunction with leading law firms across Europe – has once again updated its monthly CSRD Transposition Tracker. The updated Tracker is available here. The Tracker describes Corporate Sustainability Reporting Directive transposition activity across the 27 EU member states and three EEA EFTA countries.

New for this update, the Tracker also discusses action relating to the Omnibus Proposal in 16 countries, specifically Austria, Bulgaria, Croatia, Denmark, Estonia, France, Germany, Ireland, Italy, Latvia, Lithuania, Netherlands, Norway, Poland, Slovakia and Spain.

To recap regarding the Omnibus Proposal:

• In late February, the European Commission proposed significant amendments to the CSRD, known as the Omnibus Proposal. The Omnibus Proposal included two proposed directives related to the CSRD, as well as proposed regulations to amend the EU Taxonomy Regulation and contemplated (but not yet released) proposals to amend the European Sustainability Reporting Standards. The Omnibus Proposal is discussed in more detail in this Ropes & Gray post.
• The first directive, often referred to as the “stop the clock” directive, was adopted by the European Parliament on April 3 and by the European Council on April 14. It is now awaiting publication. The “stop the clock” directive postpones the due dates for the first CSRD reports by large undertakings that are not public interest entities and listed SMEs by two years. Member states are required to transpose the “stop the clock” directive into national law by December 31.
• The second proposed directive would make a number of substantive amendments to the CSRD, including increasing reporting thresholds. The second proposed directive is at an earlier stage than the “stop the clock” directive. It also will need to be approved by both the European Parliament and European Council and then transposed by the member states.

So far, 20 countries have adopted legislation implementing the current CSRD (at least in part) and another six have proposed legislation, as further discussed in the Tracker.

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