CSRD Implementation Tracker: Country-by-Country Status

What you'll learn

Which EU Member States have transposed the original CSRD and which have not (as of early 2026)
How the Stop-the-Clock directive and the Omnibus I amendments changed the reporting timeline for each wave
Where individual countries have made national choices on assurance providers, subsidiary exemptions, and scope extensions
What the status of simplified ESRS adoption means for your methodology planning

The three waves after Omnibus I

The original CSRD phased in reporting across four waves. Omnibus I collapsed this into a revised timeline with transitional relief.

Wave 1: Large public-interest entities with more than 500 employees that were already subject to the Non-Financial Reporting Directive (NFRD). These companies first reported under ESRS for FY 2024 (published in 2025). Under Omnibus I, Member States may exempt these entities from reporting in FY 2025 and FY 2026.

Wave 2: Large companies meeting two of the following: €50 million net turnover, €25 million total assets, or 250 or more employees, plus parents of large groups. Originally required to report for FY 2025. The Stop-the-Clock directive (Directive (EU) 2025/794, entered into force 17 April 2025) postponed this by two years. Wave 2 companies now report for FY 2027 (published in 2028).

Wave 3: Listed SMEs, small and non-complex credit institutions, captive insurance entities, and certain other listed entities. Originally FY 2026. Now postponed to FY 2028 (published in 2029).

Member States had to transpose the Stop-the-Clock directive by 31 December 2025. Transposition of the full Omnibus I amendments is due by 19 March 2027.

Wave	Scope	Original reporting year	Post-Omnibus I reporting year
Wave 1	Large PIEs (>500 employees, ex-NFRD)	FY 2024	FY 2024 (MS may exempt FY 2025-2026)
Wave 2	Large companies / parents of large groups	FY 2025	FY 2027
Wave 3	Listed SMEs, small credit institutions	FY 2026	FY 2028

Original CSRD transposition: who completed it

The CSRD transposition deadline was 6 July 2024. As of early 2025, fewer than ten Member States had not yet completed transposition. The European Commission opened infringement procedures against 17 Member States in September 2024 for failing to notify national transposition measures.

Countries that completed transposition on or before the deadline include France, Germany (with modifications), Italy, and the Netherlands. Countries where transposition was delayed include Sweden (which received a reasoned opinion from the Commission in December 2024 after extending its own implementation deadline by six months, which the Commission deemed non-compliant) and several Central and Eastern European states.

Finland and Romania transposed the CSRD but the Commission deemed their transposition non-compliant. The reasons for this have not been publicly clarified as of early 2026.

Stop-the-Clock directive transposition

The Stop-the-Clock directive (Directive (EU) 2025/794) entered into force on 17 April 2025 and postponed CSRD reporting for Wave 2 and Wave 3 entities by two years. Member States had until 31 December 2025 to transpose it.

Most Member States have transposed the Stop-the-Clock provisions. Key country-specific developments:

Germany published a draft bill that not only postpones the timeline but also exempts large companies (including capital market-oriented entities, credit institutions, and insurance companies) with fewer than 1,000 employees from reporting for FY 2025 and FY 2026.
Denmark held a consultation and drafted provisions that postpone application deadlines without changing the reporting content.
Italy defined three waves in Law No. 118 of 8 August 2025: Wave 1 companies on the original timeline, Wave 2 starting 1 January 2027, Wave 3 starting 1 January 2028.
Ireland amended the Companies Act 2014 to push Wave 2 reporting to FY 2027 and Wave 3 to FY 2028, while also clarifying the subsidiary exemption and net turnover definition.

Hungary transposed the Stop-the-Clock directive into national law. Sweden's position remains complicated: the Commission issued a reasoned opinion in December 2024, and as of August 2025 there was no public record of a referral to the CJEU. Poland and Norway were among the countries where Stop-the-Clock transposition was still in process as of late 2025.

Omnibus I: what changed

Directive (EU) 2026/470, published in the Official Journal on 26 February 2026, is the culmination of the Omnibus I legislative process. It amends both the CSRD and the CSDDD. The key changes for sustainability reporting and assurance:

Scope and transitional relief. Member States may exempt Wave 1 companies from reporting in FY 2025 and FY 2026. The practical effect: a company that reported under ESRS for FY 2024 might not need to report for FY 2025 if its Member State exercises this option.

Simplified ESRS. The Commission must adopt revised and streamlined ESRS within six months of the amended CSRD entering into force. EFRAG sent its technical advice on draft simplified ESRS to the Commission on 3 December 2025. The simplified standards preserve double materiality but reduce data points, introduce flexibility for estimates, and add a top-down materiality option. Final adoption is expected Q2 2026.

Assurance level. Reasonable assurance is no longer required. Limited assurance requirements are maintained. The Commission must adopt harmonised limited assurance standards by 1 July 2027. Until then, Member States may permit national assurance standards.

Value chain cap. Companies cannot request sustainability information from entities with fewer than 1,000 average employees beyond what the VSME (voluntary SME) standard requires.

Climate transition plans. The CSDDD's requirement to adopt climate transition plans is deleted. However, ESRS provisions on reporting existing plans are expected to remain, meaning companies that have plans must still disclose them.

Transposition deadline. Member States have until 19 March 2027.

Country tracker: key national choices

Member States have flexibility on several provisions. The most relevant national choices for audit firms:

Who can provide assurance? Some Member States allow only the financial statement auditor to provide sustainability assurance. Others allow a different statutory auditor or an independent assurance services provider (IASP). France allows IASPs. The Netherlands allows both a different auditor and an IASP. Germany's position followed its existing dual-track system.

Subsidiary exemption. The CSRD allows subsidiaries of EU parent companies to be exempt from standalone sustainability reporting if the parent publishes consolidated sustainability information. National transposition determines how this exemption works in practice. Ireland's 2025 regulations clarified that ineligible entities are not automatically in scope, and that Irish subsidiaries with EU parents can use the exemption.

Scope extensions. Some Member States extended CSRD scope beyond the minimum. Others kept to the directive thresholds.

Track multiple jurisdictions

For country-level detail, the Linklaters CSRD Transposition Tracker, the Accountancy Europe tracker (updated September 2025), and the Ropes & Gray tracker (updated monthly) are the most current publicly available resources. For clients with EU subsidiaries in multiple Member States, map each subsidiary's reporting obligation separately. National transposition differences mean the same group may face different deadlines and assurance requirements across jurisdictions.

Assurance requirements: what auditors need to know

The assurance requirement creates a new engagement type for many firms. Under the amended CSRD, limited assurance over sustainability reporting is required. The key points for audit firms:

Applicable standard. Until harmonised EU limited assurance standards are adopted (deadline: 1 July 2027), Member States may permit national standards. For engagements falling under the IAASB framework, ISAE 3000 (Revised) applies to current sustainability assurance engagements. ISSA 5000 becomes effective for periods beginning on or after 15 December 2026.

Registration. The Audit Directive amendments introduce simplified auditor registration requirements for a transitional period from 2025 to 2030. Third-country auditors and audit entities issuing assurance reports receive an exemption from supervision during this period.

Capacity. The AFM's State of the Auditing and Reporting Industry 2025 noted that the number of companies subject to CSRD in the Netherlands expands from 95 (FY 2024) to over 3,000 from FY 2025 onward (before Omnibus I adjustments). Dutch non-PIE firms providing sustainability assurance need to build capacity in advance.

Quick-fix ESRS amendments. For Wave 1 entities continuing to report, the Commission adopted delegated acts on 11 July 2025 extending certain first-year transitional provisions to FY 2025 and FY 2026 reporting, providing additional relief in specific areas. This delegated act was published in the Official Journal on 10 November 2025 and entered into force on 13 November 2025. Wave 1 entities that reported under ESRS for FY 2024 can maintain, and in some cases reduce, their level of reporting for FY 2025 and FY 2026.

Simplified ESRS: what changes

EFRAG's technical advice on draft simplified ESRS, submitted to the Commission on 3 December 2025, represents a significant reduction in reporting burden compared to the current Set 1 ESRS. The key changes in the draft:

The double materiality assessment is preserved but streamlined. A top-down materiality approach is now available as an option, meaning companies can start with sector-level presumptions rather than building from scratch. Fewer disclosure requirements apply overall, and the total number of mandatory data points is reduced.

EFRAG introduced greater flexibility for data collection, including the explicit ability to use estimates where precise data is unavailable. Interoperability with ISSB standards (IFRS S1 and S2) is improved, which matters for groups reporting under both frameworks.

The Commission is not required to follow EFRAG's technical advice, but the timeline is tight: formal adoption is expected in Q2 2026 via delegated act. For audit firms planning methodology, the working assumption should be that the simplified ESRS will closely follow EFRAG's draft. If you're building assurance programmes for Wave 2 clients reporting from FY 2027, the simplified ESRS is the framework to prepare for.

Worked example: determining a client's reporting obligation

Scenario: Brouwer Holdings B.V. is a Dutch large company with €85 million net turnover, €52 million total assets, and 320 employees. It is not a PIE and was not previously subject to the NFRD.

1. Which wave?

Brouwer meets two of the Wave 2 criteria (turnover above €50 million and assets above €25 million). Under the original CSRD timeline, it would have reported for FY 2025. Under the Stop-the-Clock directive, this is postponed to FY 2027. Omnibus I does not change this; the transitional exemption for FY 2025 and FY 2026 applies to Wave 1 entities, not Wave 2.

Documentation note: Record the client's classification as Wave 2 in the engagement acceptance file. Note that the first CSRD reporting period is FY 2027, with the sustainability report published in 2028.

2. Which ESRS version?

If the simplified ESRS is adopted by Q2 2026 (as expected), Brouwer will report under the simplified standards. The double materiality assessment is preserved but streamlined. Fewer data points are required compared to the current Set 1 ESRS.

Documentation note: Flag the ESRS version dependency in the engagement planning. Monitor the Commission's delegated act adoption timeline. If the simplified ESRS is not adopted before Brouwer's reporting period, the current Set 1 ESRS applies.

3. Who provides assurance?

The Netherlands allows a different statutory auditor or an IASP to provide sustainability assurance. Brouwer's current audit firm (a non-PIE firm) can provide the assurance engagement if it has the capacity and competence. Alternatively, Brouwer can appoint a separate provider.

Documentation note: Document the firm's competency assessment for sustainability assurance under ISQM 1. If accepting the engagement, confirm that the firm meets the ethical requirements for independence when providing both the statutory audit and the sustainability assurance.

4. What standard applies to the assurance engagement?

For Brouwer's FY 2027 sustainability report, ISSA 5000 is effective (periods beginning on or after 15 December 2026). If the Netherlands has also adopted harmonised EU limited assurance standards by that date, those may apply instead or in addition.

Documentation note: Identify the applicable assurance standard in the engagement letter. For FY 2027, ISSA 5000 is the baseline unless the Dutch transposition specifies otherwise.

Practical checklist

For every client in CSRD scope, confirm its wave classification and the reporting period under the post-Omnibus I timeline. Wave 1 entities should check whether the Netherlands (or the relevant Member State) has exercised the option to exempt FY 2025 and FY 2026 reporting
Monitor the Commission's adoption of simplified ESRS (expected Q2 2026). Until adopted, current Set 1 ESRS applies to entities in reporting scope
Confirm whether your firm has the capacity and competence to accept sustainability assurance engagements, and that your independence position under ISQM 1 permits it
If your firm plans to provide CSRD assurance, build familiarity with ISSA 5000 now. The standard is standalone and does not require concurrent application of ISAE 3000 (Revised)
Check your Member State's national choices on assurance provider eligibility, subsidiary exemption implementation, and any scope extensions beyond the CSRD minimum
For clients with EU subsidiaries in multiple Member States, map each subsidiary's reporting obligation separately. National transposition differences mean the same group may face different deadlines and assurance requirements across jurisdictions

Common mistakes

Telling Wave 2 clients they report for FY 2025. They don't. The Stop-the-Clock directive (Directive (EU) 2025/794) postponed Wave 2 to FY 2027 and Wave 3 to FY 2028. This was transposed by most Member States by 31 December 2025.
Assuming ISSA 5000 applies to all CSRD assurance engagements immediately. ISSA 5000 is effective for periods beginning on or after 15 December 2026. For assurance on FY 2024, FY 2025, or FY 2026 sustainability reports, ISAE 3000 (Revised) or national standards apply, depending on the Member State.

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Frequently asked questions

When do Wave 2 companies need to report under the CSRD?

Wave 2 companies (large companies meeting two of: EUR 50 million turnover, EUR 25 million total assets, or 250+ employees) now report for FY 2027, published in 2028. The original FY 2025 deadline was postponed by the Stop-the-Clock directive (Directive (EU) 2025/794), which entered into force on 17 April 2025.

What changed under the Omnibus I directive?

Omnibus I (Directive (EU) 2026/470, published 26 February 2026) allows Member States to exempt Wave 1 companies from reporting in FY 2025 and FY 2026. It also mandates simplified ESRS adoption, caps value chain data requests at the VSME standard level for companies with fewer than 1,000 employees, removes the reasonable assurance requirement (keeping limited assurance), and deletes the CSDDD climate transition plan obligation.

Which assurance standard applies to CSRD sustainability reports?

For sustainability reports covering periods beginning on or after 15 December 2026 (FY 2027 for calendar year-end entities), ISSA 5000 applies as the international standard. For earlier reporting periods (FY 2024, 2025, 2026), ISAE 3000 (Revised) or national standards apply, depending on the Member State. Harmonised EU limited assurance standards must be adopted by 1 July 2027.

Can a different auditor or non-auditor provide CSRD assurance?

This depends on the Member State. Some allow only the financial statement auditor to provide sustainability assurance. Others allow a different statutory auditor or an independent assurance services provider (IASP). France allows IASPs. The Netherlands allows both a different auditor and an IASP. Each Member State's national transposition determines the eligibility rules.

What are the simplified ESRS?

EFRAG submitted technical advice on draft simplified ESRS to the Commission on 3 December 2025. The simplified standards preserve double materiality but reduce data points, introduce flexibility for estimates, add a top-down materiality option, and improve interoperability with ISSB standards. Formal adoption is expected in Q2 2026 via delegated act. Wave 2 companies reporting from FY 2027 are expected to use these simplified standards.

Has every EU Member State transposed the CSRD?

No. The CSRD transposition deadline was 6 July 2024. The European Commission opened infringement procedures against 17 Member States in September 2024 for failing to notify national transposition measures. Countries like France, Germany, Italy, and the Netherlands completed transposition on time. Sweden was delayed and received a reasoned opinion from the Commission. Finland and Romania transposed but were deemed non-compliant.