How will the CSRD be implemented in Dutch law?

How the implementation of the CSRD will take shape is not yet final. The implementation is intended to take place in two steps. The obligation for an undertaking to report on sustainability will be laid down in the implementation decree on the Corporate Sustainability Reporting Directive (in Dutch: Implementatiebesluit richtlijn duurzaamheidsrapportering). In addition, the remaining obligations from the CSRD will be provided for through the legislative act on the implementation of the Corporate Sustainability Reporting Directive (in Dutch: Wet tot implementatie richtlijn duurzaamheidsrapportering). The legislative proposal on the implementation of the corporate sustainability reporting directive covers the mandatory assurance and the method of publishing the sustainability report.

In 2023, a draft version of both the legislative proposal and the decree was submitted for consultation.

After the consultation, the implementation decree and the explanatory notes were adjusted. It is now up to the House of Representatives (in Dutch: Tweede Kamer) and the Senate (in Dutch: Eerste Kamer) to approve the decree. After parliamentary approval, the decree will be submitted to the Council of State (in Dutch: Raad van State). Publication in the Official Gazette (in Dutch: Staatscourant) will follow thereafter.

In 2024 a revised of version of the legislative proposal, including an explanatory memorandum, was submitted to the Council of State for advice. The Council of State issued a blank advice on 28 August 2024. On 13 January 2025, the legislative proposal for the implementation of the Corporate Sustainability Reporting Directive (in Dutch: wetsvoorstel implementatie richtlijn duurzaamheidsrapportering) was submitted to the House of Representatives. The discussion of this proposal in the House of Representatives has not been scheduled yet. After the debate in the House of Representatives, the proposal will be reviewed by the Senate.

The implementation of the CSRD will lead to several amendments of existing Dutch laws (such as the Audit Firms Supervision Act, the Financial Supervision Act, the Civil Code and some other laws).

The CSRD includes some options for member states (member state options). Additionally, a national legislator may impose extra requirements in national law, such as expanding the scope (a so-called "gold-plating" measure). Nevertheless, the legislators of the various EU member states must transpose the obligations of the CSRD as precisely as possible into national law in order to keep reporting obligations uniform across EU member states. Based on the submitted legislative proposal and draft decree, it appears that the Dutch legislator will do so and will ‘only’ implement the CSRD rules as written in the CSRD itself.

Questions CSRD & ESRS

Do you have questions about the CSRD, ESRS or are you missing a question in this list? Send us an e-mail and we will contact you as soon as possible. For technical questions, EFRAG has set up an ESRS Q&A platform (latest release of technical explanations: December 2024). Here you can submit a question, and also find answers to previously asked questions.

Questions regarding individual facts or circumstances will not be answered through these channels. For such questions, we recommend that you contact an advisor such as your company accountant.

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