April 2025 – Despite the 6 July 2024 transposition deadline for the full implementation of the Corporate Sustainability Reporting Directive (CSRD), several jurisdictions – including the Czech Republic and Romania – remain subject to infringement proceedings initiated by the European Commission in September 2024 for failing to fully communicate their national measures.
It remains unclear how this infringement process will proceed, particularly in light of the postponement of the second wave of the reporting obligation, as approved under the so-called “stop-the-clock” directive incorporated into the Omnibus I package.
At the same time, and also as a consequence of the “stop-the-clock” directive – which postponed the deadline for implementing the Corporate Sustainability Due Diligence Directive (CS3D) by one year to 26 July 2027 and was incorporated into the Omnibus I package – it seems that Member States are slowing down their efforts to begin the necessary legislative work. In other words, legislative developments remain at an early stage.
In addition, the evolving EU-level Omnibus I package – which includes further proposals for changes, particularly to CS3D and CSRD – adds further uncertainty, prompting local lawmakers to reconsider thresholds and timelines for ESG disclosures.
How are individual jurisdictions responding? Below is an overview of recent developments in Bulgaria, Croatia, the Czech Republic, Hungary, Romania and Slovakia.
Bulgaria
CS3D
There have been no developments in Bulgaria, and no official information is available regarding when the implementation process is expected to begin.
CSRD and Omnibus I
On 19 February 2025 the Bulgarian Parliament adopted an amendment to the Accountancy Act by which the sustainability reporting, as required under the CSRD, has been delayed by one year. After these amendments, large public-interest companies that have more than 500 employees will now have to prepare their first sustainability reports for the year 2025 instead of 2024. Other large enterprises will follow with their first reports covering 2026 instead of 2025 and the last group covering small and medium enterprises will prepare their first sustainability reports covering 2027 instead of 2026. The amendments to the Accountancy Act have been promulgated in the Bulgarian State Gazette and entered into force on 28 February 2025.
There is no official information regarding the Omnibus I impact.
Croatia
CS3D
There have been no developments in Croatia and no official information when the implementation process should start.
CSRD and Omnibus I
CSRD implemented in Croatia. Recently, the Ministry of Finance has published a list of entities required to report on sustainability in the first phase (reporting in 2025 for the 2024 financial year), and an indicative list of potential reporting entities for the second phase (reporting in 2026 for the 2025 financial year). More information is available at the following link.
There is no official information regarding the Omnibus I impact
Czech Republic
CS3D
No formal changes to the transposition process have been formally made yet. However the Ministry of Justice, as the ministry responsible for the implementation of CS3D, has indicated that further work on the implementing legislation has effectively paused, particularly in light of the expected formal postponement of the CS3D transposition deadline to 26 July 2027, following the European Parliament’s approval and the anticipated Council agreement and the extensive scope of amendments needed in the initial policy draft, which would make further legislative drafting premature at this stage.
Once the postponement of the transposition deadline is officially adopted at the EU level, the Ministry plans to initiate corresponding updates to the Czech Government's Legislative Work Plan.
CSRD and Omnibus I
The transposition process in the Czech Republic is taking place in two phases:
- The first phase of transposition relates to companies subject to the Non-Financial Reporting Directive which took effect from 1 January 2024; and
- The second phase of transposition to be implemented through amending the existing Accounting Act and Act on Auditors, however the adoption of this amending act is still under way.
The legislative proposal was submitted in August 2024, and the first reading in the Chamber of Deputies concluded in February 2025.
Following the ESG Omnibus Package proposal—in particular ESG Omnibus I—the responsible parliamentary committee has proposed amendments to align the draft with the EU-level ESG developments. These include:
- Exclusion of companies falling under phases 2 and 3 of the transposition from the scope of the Czech legislation;
- Raising the employee threshold for phase 1 companies from 500 to 1,000 employees.
These proposed changes are a response to the current direction of ESG reporting requirements at the EU level. However, the adoption of the draft legislation is still pending, and the originally proposed effective date of 1 January 2025 will not be met. The earliest adoption timeline is expected in Q3 2025
The adoption of a new Accounting Act is still under way but is expected to be delayed past its original goal of adoption in 2025 and is expected now to be effective in 2026 or 2027. (The legislative proposal is currently in the governmental stage. A revised draft was published by the Ministry of Finance in May 2025, following the intergovernmental comment procedure. awaiting governmental approval).
Czech Republic was included in the EU Commission’s infringement notice from September 2024.
Hungary
CS3D
There have been no updates on the implementation of CS3D in Hungary.
CSRD and Omnibus I
The Ministry of National Economy published the draft amendment of the ESG Act for public consultation, which relates to the Omnibus Packages. The public consultation closed on 29 March 2025, however, as of today, it has not yet been filed before the Parliament.
According to our interpretation, the draft would not exempt large enterprises from the administrative burdens associated with preparing the ESG report. However, they would not be required to submit the report would be modified. These indicators would be defined in a separate decree by the Ministry of National Economy. This decree has not yet been published in the current legislative amendment process.
According to our interpretation, the draft would not exempt large enterprises from the administrative burdens related to preparing the ESG report, however, they would not be required to submit the ESG report to the Supervisory Authority for Regulated Activities (SZTFH), nor would they be required to publish it on their website.
Romania
CS3D
Since the last update, there has not been any progress on the transposition of the CS3D into Romanian law (the responsible authority has still not been designated).
CSRD and Omnibus I
No changes regarding CSRD related local legislation. As a result, no amendments have been made to the table.
In relation to Omnibus I’s effects in Romania, we note that the local thresholds for determining the reporting companies, as adopted under Romanian legislation and currently in force, were lower than those established at EU level. Thus, there may be a possibility that, following the Romanian transposition of Omnibus package, the new amended thresholds may still be different from those foreseen in the EU Omnibus initiative. In any case, as the Omnibus proposal has to first be adopted at European level and then transposed into national legislation, the impact could not be clearly determined.
Slovakia
CS3D
There have been no updates or developments in Slovakia.
CSRD and Omnibus I
The CSRD has been implemented into Slovak law through amendments to the Slovak Accounting Act and other related legislation effective as of 1 June 2024.
There is also no official information regarding the Omnibus I impact.
Authors: Jan Lehký, Jakub Rubáš, Svilen Issaev, Vedran Kopilović, Dana Sarbu, Mónika Frank, Viliam Achberger
For more information, please contact Partners Jan Lehký and Olena Kuchynska.