There is no EU-wide CSRD fine. CSRD sets no harmonised fine — Article 51 requires each EU member state to set its own penalties in national law. Confirmed maximums range from €5,000 in Ireland to €10,000,000 in Italy. Of the 27 member states, 4 have not yet transposed CSRD at all — including Germany.
23
states transposed
12
with a maximum traced to source
4
not yet transposed
Every figure below is traceable to a national gazette or competent authority. Where a maximum could not be established from primary sources we say so rather than estimate.
Why there is no single EU-wide CSRD fine
CSRD (Directive 2022/2464) sets no harmonised penalty. Article 51 requires each member state to provide penalties that are 'effective, proportionate and dissuasive' in its own national law. The figure that applies to your company is set exclusively by the member state where the reporting obligation arises.
A figure of “up to 5% of annual revenue” is widely quoted as the EU CSRD penalty. It is not one. A 5%-of-turnover provision exists in the separate CSDDD due diligence directive and in some national transpositions — but CSRD itself sets no EU-level amount.
Confirmed maximum penalties
12 member states where a maximum is traceable to a cited source.
Italy
D.Lgs. 125/2024
€10,000,000
Primary source
Applies to: Administrative fine under Art. 193 TUF, via Art. 10 D.Lgs. 125/2024
Individuals:
€2,000,000
Turnover basis:
5% of annual turnover where turnover exceeds €10,000,000
Authority:
CONSOB
In force:
2024-09-25
Transitional regime For the first two years from entry into force, entity fines are capped at €2,500,000 (€150,000 for natural persons, €125,000 for audit firms).
The €10M maximum is not what applies today. Until 25 September 2026 the transitional cap of €2.5M is in force.
Applies to: Geldbuße under HGB §334 Abs. 3a Nr. 1 — capital-market-oriented companies
Turnover basis:
5% of annual Gesamtumsatz (HGB §334 Abs. 3a Nr. 2)
Authority:
BaFin / Bundesamt für Justiz
Germany has NOT transposed CSRD and is subject to infringement proceedings. The €10M figure is the existing HGB §334 penalty for capital-market-oriented companies, in force today for statutory accounts. The draft CSRD-UmsG would extend it to the sustainability report — that extension is not law yet.
Applies to: Administrative fine by the General Commercial Registry (GEMI), from a €100 floor
Individuals:
€50,000
Authority:
GEMI / ELTE
In force:
2024-12-12
Penalty articles cross-checked via law summaries rather than read line-by-line in the Greek text. Separate ELTE fines of up to €500,000 apply to audit firms.
Applies to: Criminal fine on officers, directors and auditors acting knowingly, from a €50 floor
Individuals:
€10,000
Authority:
Enterprise courts / FSMA (listed companies)
In force:
2024-12-30
Fraudulent breaches carry imprisonment of one month to one year. For listed companies the FSMA has a separate administrative enforcement track, so €10,000 is not necessarily the total exposure.
Applies to: Category 3 offence — failure to file a compliant directors' report
Individuals:
€500,000
Authority:
CRO / courts
In force:
2024-07-06
Ireland created no separate CSRD penalty — existing Companies Act 2014 offences apply. A knowingly false statement is a Category 2 offence carrying up to €500,000 and 10 years' imprisonment, far above the €5,000 filing penalty.
Applies to: Capped at 1% of net turnover — for improper ESG data requests, not for reporting failure
Authority:
SZTFH
In force:
2025-01-01
This figure does NOT penalise failure to file a sustainability report — the fine for a missing report has not yet been specified. It applies to specific ESG data-request offences.
Accountancy Act (Закон за счетоводството), Arts. 72 & 75
BGN 15,000
Secondary source
Applies to: Property sanction on the undertaking for sustainability-report breaches (Arts. 72, 75)
Authority:
National Revenue Agency
General accounting breaches carry BGN 300–2,000 for the undertaking and BGN 200–1,000 for individuals. Repeat offences within a year double the amount.
Applies to: Misdemeanour fine on the legal entity, from a €1,320 floor (Art. 42)
Individuals:
€2,650
Authority:
Financial Inspectorate / Fina
In force:
2024-07-27
Art. 42 is the penalty provision of the Accounting Act, which also governs sustainability reporting. Amounts were confirmed via secondary summaries of Art. 42 rather than line-read from the gazette text.
Act 105/2024 amending the Accounting Act 431/2002, §38(1)(p)
€3,000,000
Secondary source
Applies to: Maximum administrative fine under the Accounting Act, raised from €1,000,000 to €3,000,000
Authority:
Finančná správa
In force:
2024-06-01
Sustainability-reporting breaches were added as an administrative offence at §38(1)(p), penalised under §38(2). The €3,000,000 figure is the Act's overall ceiling — we could not isolate the specific tier applying to sustainability offences, so treat it as an upper bound rather than the expected fine.
Applies to: Fine on a large company, from a EUR 6,000 floor. Scaled by company size: medium EUR 4,000-20,000, small EUR 1,000-10,000
Individuals:
€2,500
Authority:
AJPES / courts
In force:
2024-12-18
Slovenia is one of the few member states to scale the fine by company size rather than setting a single maximum. Figures are consistent across several independent Slovenian firms' summaries of ZGD-1M but were not line-read from the Uradni list, so they carry a medium rather than high confidence label.
Where CSRD has not been transposed there is no national CSRD penalty regime in force. Exposure comes from pre-existing company and accounting law instead.
Germany
Germany has NOT transposed CSRD and is subject to infringement proceedings. The €10M figure is the existing HGB §334 penalty for capital-market-oriented companies, in force today for statutory accounts. The draft CSRD-UmsG would extend it to the sustainability report — that extension is not law yet.
Spain
Transposition bill before the Congreso since November 2024, not enacted. The €1.5M figure circulating online could not be traced to a primary source for CSRD.
Portugal
No transposition measures published.
Luxembourg
Bill 8370 pending since March 2024.
All 27 member states
Ranked by confirmed maximum. Amounts are shown in their national currency and are never converted — Hungary and Bulgaria are ranked using an indicative conversion, but the figure you see is the one in the statute.
CSRD transposition status and maximum entity penalty by EU member state, ranked by penalty size. Last reviewed 2026-08-02.
Member state
Maximum entity penalty
Transposition status and evidence
ITItaly
€10,000,000
TransposedPrimary source
DEGermany
€10,000,000
Not transposedPrimary source
SKSlovakia
€3,000,000
TransposedSecondary source
HUHungary
HUF 50,000,000
TransposedSecondary source
ATAustria
€100,000
TransposedPrimary source
GRGreece
€100,000
TransposedSecondary source
SISlovenia
€30,000
TransposedSecondary source
HRCroatia
€13,270
TransposedSecondary source
BEBelgium
€10,000
TransposedPrimary source
BGBulgaria
BGN 15,000
TransposedSecondary source
IEIreland
€5,000
TransposedPrimary source
RORomania
RON 3,000
TransposedSecondary source
CYCyprus
No figure traced
TransposedNo primary source located
CZCzechia
No figure traced
TransposedNo primary source located
DKDenmark
No figure traced
TransposedNo primary source located
EEEstonia
No figure traced
TransposedNo primary source located
FIFinland
No figure traced
TransposedNo primary source located
FRFrance
No figure traced
TransposedPrimary source
LVLatvia
No figure traced
TransposedNo primary source located
LTLithuania
No figure traced
TransposedNo primary source located
MTMalta
No figure traced
TransposedNo primary source located
NLNetherlands
No figure traced
TransposedNo primary source located
PLPoland
No figure traced
TransposedNo primary source located
SESweden
No figure traced
TransposedNo primary source located
LULuxembourg
No figure traced
Not transposedNo primary source located
PTPortugal
No figure traced
Not transposedNo primary source located
ESSpain
No figure traced
Not transposedNo primary source located
“No figure traced” means we could not establish a maximum from a national gazette or competent authority. It does not mean no penalty exists — it means we will not publish a number we cannot evidence.
Where these figures come from
—Every figure traces to a national official gazette or the competent regulator's own page. Law-firm and vendor summaries were used for corroboration only, never as a sole source.
—Transitional regimes are recorded separately, because the headline maximum is frequently not the number in force today — Italy is the clearest example.
—Amounts are given in their native currency and are not converted.
—Where sources conflicted or no primary text could be located, the entry is left blank rather than estimated.
—CSRD penalties are kept strictly distinct from CSDDD, from legacy NFRD provisions, and from national due-diligence laws such as France's Loi de Vigilance and Germany's LkSG — a conflation common in published summaries.
Last reviewed 2026-08-02. Regulations change — check the linked primary source before relying on any figure for a compliance decision. This page is information, not legal advice.
CSRD is one of the regulations tracked in the XG regulation database — obligations, deadlines and penalties across every jurisdiction in the corpus.
Not sure whether CSRD applies to you?
The Omnibus package changed the thresholds in December 2025. Our checker walks through jurisdiction, entity type and size to tell you which wave you fall into — in about two minutes.