Ropes & Gray – in conjunction with leading law firms across Europe – has published a new update of its monthly CSRD Transposition Tracker. The Tracker update is available here.
The Tracker describes Corporate Sustainability Reporting Directive transposition and Omnibus activity across the 27 EU member states and three EEA EFTA countries. This update includes information and developments as of January 31, and for some countries into February, as well as additional commentary from the participating law firms.
The Omnibus I “contents” Directive is now complete. It was published in the EU Official Journal on February 26, the first anniversary of the European Commission’s original proposal. EU member state transposition is required by March 19, 2027. Future Tracker updates will report on the transposition of the Directive.
This Ropes & Gray summary describes where the Directive landed. There was a lot of movement over the last year. See here for a discussion of the Commission's original proposal.
In addition to all the substantive changes, "omnibus" and "simplification" were introduced into the popular lexicon.
And Omnibus I led to an avalanche of memos, articles, alerts, blog posts, webinars, etc. We asked some of our AI tools for a count. They didn't come up with a pinpoint number, but the consensus was many thousands at least.
As Winston Churchill said, “Now this is not the end. It is not even the beginning of the end. But it is, perhaps, the end of the beginning.” That's the way to think about Omnibus I. Next comes EU member state transposition. Simplified European Sustainability Reporting Standards also need to be finalized. And there will be further guidance and guidelines under the CSRD addressing assurance and other topics. For many Wave 2 companies, including US-based multinationals, the compliance process now starts (or picks back up) in earnest.
