Member states have discretion of the following areas:
- Extending the scope of entities, by thresholds or legal entity type, required to report under the CSRD;
- Mandating which parties can provide assurance over the sustainability information;
- Aligning requirements for submission of the sustainability information with local statutory filing requirements;
- Subsidiary exemption criteria and mandating specific disclosure and filing requirements within the consolidated sustainability report of the parent company where a subsidiary is taking a reporting exemption;
- Extending the requirements set out in the ESRS standards; and
- Imposing sanctions for non-compliance.
Businesses operating across the EU and the EEA will need to navigate different implementing requirements on a country by country basis which could result in additional compliance requirements, stakeholder consultations e.g. employee and directors’ duties for EU and EEA subsidiaries to comply with.
Our EU member state transposition of CSRD briefing provides an update of the status of transposition in each member state and EEA country as at 1 May 2024 and will be helpful to businesses who are affected by CSRD.