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CSRD in Belgium

Belgium's nominal CSRD fine is €50 to €10,000 — a criminal fine on individuals who act knowingly. Belgium's penal surcharge multiplies that by 10, so the effective range is about €500 to €100,000. Fraudulent breaches carry up to one year in prison.

In forceDisclosure & reportingChecked 9 August 2026Our EI can make mistakes — check important info.

In force from
2024-12-30
Transposition
Transposed
Instrument
CSRD Implementation Act (published 20 Dec 2024)
Maximum on the undertaking
€10,000
Criminal fine on officers, directors and auditors acting knowingly, from a €50 floor — nominal amounts, multiplied by the penal surcharge (décimes additionnels)
Maximum on an individual
€10,000
Authority
Enterprise courts / FSMA (listed companies)

Where do these figures come from?

The statute says €10,000; the courtroom says about €100,000

Belgian criminal fines are multiplied by the décimes additionnels surcharge — ×10 since the Act of 19 December 2025 (×8 before 2026). The €50–€10,000 range in the implementation act is therefore about €500 to €100,000 as actually imposed. A figure of '€1 million or 3% of turnover' could not be traced to any instrument and is not shown here.

In short

Belgium transposed CSRD through its implementation act published on 20 December 2024, in force from 30 December 2024. The penalty is a criminal fine of €50 to €10,000 nominal on officers, directors and auditors who act knowingly. Belgian criminal fines carry a penal surcharge (décimes additionnels) — ×10 since the Act of 19 December 2025, ×8 before 2026 — so the effective range is about €500 to €100,000. Fraudulent breaches carry imprisonment of one month to one year. Enterprise courts enforce, and for listed companies the FSMA has a separate administrative enforcement track.

Who actually pays the Belgian fine?

The criminal character of the sanction requires knowing conduct and targets officers, directors and auditors personally. Fraudulent breaches carry imprisonment of one month to one year.

For listed companies, the FSMA enforces under separate administrative powers not capped by the criminal maximum.

The law of 12 December 2025 transposes the stop-the-clock deferral — wave 2 to FY2027, wave 3 to FY2028 — without changing the penalties.

What are the penalties?

Criminal fine on individuals — about €500 to €100,000 after the surcharge — plus a separate FSMA track for listed companies.

  • Individuals — €50 to €10,000 nominal

    Criminal fine on officers, directors and auditors acting knowingly, from a €50 floor — nominal amounts, multiplied by the penal surcharge (décimes additionnels)

  • Effective range — about €500 to €100,000

    The décimes additionnels surcharge multiplies criminal fines by 10 since the Act of 19 December 2025 (by 8 before 2026).

  • Imprisonment for fraudulent breaches

    One month to one year where the breach is fraudulent.

  • FSMA administrative track (listed companies)

    For listed companies the FSMA enforces separately under its own powers, not capped by the criminal maximum.

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Common questions

Is the CSRD fine in Belgium really only €10,000?
€10,000 is the nominal statutory maximum on officers, directors and auditors acting knowingly. Belgium's penal surcharge multiplies criminal fines by 10, so the effective maximum is about €100,000. It is also not a cap on a listed company's exposure — the FSMA enforces separately — and fraudulent breaches carry one month to one year of imprisonment.
Does Belgium fine companies 3% of turnover under CSRD?
No. That figure could not be traced to any Belgian instrument, so no such amount is shown for Belgium.
Where can I read the full text of BE CSRD?
The authoritative version is the official text: CSRD in Belgium. The full text is linked in the "Read the original document" section on this page. This page summarises the obligations; the official text governs.
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