The deadline for transposing Directive (EU) 2022/2464, the Corporate Sustainability Reporting Directive (CSRD), was last July 6th, but to date, only a few EU Member States have completed the legislative process. Most EU Member States, including all six founding members of the EU except for France, are still at the draft law stage or, in some cases, preliminary internal consultations.

This Directive represents the latest evolution in European regulations on sustainability reporting. The Corporate Sustainability Reporting (CSR) will replace the Non-Financial Declaration (NFD), which, since its implementation, has only applied to public interest entities with more than 500 employees. The new CSR will gradually include a broader range of entities, including listed SMEs.

The "virtuous" States include the Czech Republic, Denmark, France, Romania and Sweden. Among the laggards are four of the five largest EU economies by GDP: Germany, Italy, Spain and the Netherlands.

This slow domestic implementation process is creating uncertainty for entities that need to prepare for the new requirements. They may need to adjust their internal processes, especially regarding the approval of relevant information to be included in the report.

The greatest need is felt by groups currently not subject to the NFD, which, since its implementation, has only concerned...