CSRD, "Stop-the-clock" and Omnibus I tracker: past the halfway point to the Omnibus I transposition deadline

With under five months until the 19 March 2027 deadline for transposing the CSRD amendments in Omnibus I, our interactive tracker shows that most Member States still have work to do. Croatia, Finland and Slovenia completed transposition by the end of July, and Romania followed on 13 October. Eight have yet to take any legislative step (three of which have also still to transpose the original CSRD) and time is getting tight for those needing primary legislation, including Spain, whose CSRD bill has lapsed following the dissolution of parliament. For those interested in Luxembourg, our local counsel, Arendt & Medernach, understand that the CSRD and Omnibus I changes will be dealt with in a single bill and are working on the assumption that the CSRD will be mandatory for FY2027.

As businesses continue work on their sustainability reports for financial years beginning in 2025 and 2026, Wave 1 undertakings (large public-interest entities and issuers on an EU regulated market with more than 500 employees, first in scope a year earlier) need to be sure whether they must report under the CSRD, under national rules implementing the Non-Financial Reporting Directive (NFRD), or at all. Omnibus I lets Member States exempt all but those exceeding both new thresholds (more than 1,000 employees and €450m net turnover) for 2025 and 2026; some have done so for both years, some for 2026 only and some have not yet acted. Spain has no exemption in the absence of any CSRD transposition, but on 20 October its regulators recommended that larger companies align their FY2026 reporting with the ESRS as far as they can, while continuing to comply with current law. To help navigate the options, our Wave 1 exemption map, redesigned around exactly this, sets out the position country by country.

Groups with operations in non-euro Member States also need to check local currency thresholds. Denmark has set its threshold at DKK3.53bn, about €472m, exempting more undertakings. Romania’s transposition goes the other way, and has drifted further: its RON 2,250m was already below the Directive figure when set, at about €442m on the 18 March rate, and is around €430m at October rates, leaving more undertakings required to report.

Our CSRD, “Stop-the-clock” and Omnibus I: Implementation tracker covers all 27 Member States, including gold-plating, translation requirements and local currency thresholds. It is collated with our valued local counsel in each Member State, with our thanks to them. Subscribe to our monthly update to follow each Member State’s progress.

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