Corporate Sustainability Reporting DirectiveCSRD
CSRD sets no EU-wide penalty. Article 51 requires each member state to set penalties in national law. Maxima traced to primary sources for the same missed report range from a few hundred euros to €10,000,000 depending on the member state.
- Instrument
- Directive (EU) 2022/2464
- In force since
- 5 January 2023
- Applies from financial year 2024 for the first wave
- EU-level penalty
- None
- Article 51 delegates penalties to member states
- Assurance
- Limited assurance required
- Reasonable assurance under review
- Reporting standard
- ESRS
- Delegated Regulation (EU) 2023/2772
Where these figures come from
Maximum penalties for 12 of 27 member states, each traced to its national gazette
Each member state was checked against primary sources. 12 states have a maximum traced to the instrument itself; 4 had not transposed at the time of checking. Five figures widely repeated online — including a Belgian "3% of turnover" and a Spanish €1.5m — could not be traced to a primary source and are not shown. The spread between the lowest and highest traced maximum is over four orders of magnitude.
CSRD (Directive (EU) 2022/2464) requires large EU companies, listed SMEs and certain non-EU groups to report sustainability information under the ESRS standards, with third-party assurance. Article 51 requires each member state to set penalties in national law that are effective, proportionate and dissuasive. The figure that applies to a company is set by the member state where its reporting obligation arises.
Why there is no single CSRD fine
A directive is not directly applicable law. It binds member states to a result and leaves them the means. CSRD Article 51 requires penalties to be effective, proportionate and dissuasive, but sets no EU-wide figure.
Twenty-seven member states each attached CSRD to existing penalty machinery: securities-law fines in Italy, accounting-law fines in Poland, criminal provisions in some states, administrative charges in others. There is no European ceiling and no European floor.
Figures often misattributed to CSRD
The commonly repeated "5% of annual turnover" figure belongs to the Corporate Sustainability Due Diligence Directive, a separate instrument with a different scope. It does not apply to a missed sustainability report.
Several country-level figures could not be traced to any instrument when checked against national gazettes. Where no primary source could be found, no number is shown.
Penalties
Set nationally. Maxima traced to primary sources run from a few hundred euros to €10,000,000 for the same underlying failure.
No EU-level maximum
Article 51 of Directive (EU) 2022/2464 requires member states to lay down penalties in national law. The directive itself sets no figure.
Highest traced maximum: €10,000,000 (Italy)
Administrative fine under Art. 193 TUF via Art. 10 of D.Lgs. 125/2024, with an alternative of 5% of turnover where turnover exceeds €10m. A transitional cap of €2,500,000 applied for the first two years.
Six member states with no figure traced to a primary source
Cyprus, Estonia, Latvia, Lithuania, Malta and Slovenia had no maximum traceable to a primary source at the time of checking. No figure is shown for them.
Every figure on the country page is linked to the gazette or competent-authority page it came from.
Does this apply to you?
Scope was cut by roughly 85–90% by Directive (EU) 2026/470, published in the Official Journal on 26 February 2026 and in force from 18 March 2026. Both thresholds below must be met cumulatively; a company over one but not the other is out of scope.
- More than 1,000 employees, AND
- Net turnover above €450 million
- Revised thresholds apply to financial years beginning on or after 1 January 2027, so the first report on the new basis lands in 2028
Not sure whether CSRD catches you?
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Common questions
- What is the penalty for CSRD non-compliance?
- CSRD sets no EU-wide penalty. Article 51 requires each member state to provide effective, proportionate and dissuasive penalties in national law. Maxima traced to primary sources range from a few hundred euros to €10,000,000 depending on the member state.
- Does CSRD carry a fine of 5% of turnover?
- No. That figure belongs to the Corporate Sustainability Due Diligence Directive, a separate instrument with a different scope.
- Which member state's penalty applies to my company?
- The state where the reporting obligation arises — normally where the reporting entity is established, or where a non-EU group's designated subsidiary or branch sits. A group with entities in several member states can face several different regimes.
Go deeper
CSRD penalties in all 27 member states