Member States must transpose Articles 1, 2 and 3 by 19 March 2027, and Article 4 by 26 July 2028. The article also requires the national measures to be communicated to the Commission.

Article 5 contains the deadline that gives this product its key date. Paragraph 1 requires Member States to bring into force the laws, regulations and administrative provisions needed to comply with Articles 1, 2 and 3 by 19 March 2027, and to communicate the text to the Commission immediately. A second sentence sets 26 July 2028 for Article 4. The split matters: the sustainability reporting changes and the due diligence changes do not arrive on the same day.

The article also sets the form of the national measures. When Member States adopt them, they must contain a reference to the directive or be accompanied by such a reference on official publication, and they decide how the reference is made. Paragraph 2 requires them to communicate the main national measures in the field to the Commission.

For a company, the article is not itself a duty. It is the clock. The national measure is what creates the enforceable obligation, and the national measure may use the options the directive leaves open, including the 2025-2026 exemption in Article 5(2) of the CSRD and the financial holding option in Article 29a(7a). A plan that treats 19 March 2027 as the date the company must file is reading the transposition date as a reporting date. The first reporting year is a financial year, and for the main threshold it starts on or after 1 January 2027.

The article does not state a penalty for late transposition, and it does not state a filing route. Those are matters for national law and for the Commission's infringement powers under the Treaties. The record says so rather than inventing a penalty.

Why it matters

The date people search for is real, but it is a deadline for governments, not a filing deadline for companies. Getting that distinction right changes the board timetable: the company's work is to be ready when the first in-scope financial year begins, and to know what its Member State has chosen.

Dates

19 March 2027 for Articles 1 to 3; 26 July 2028 for Article 4. The directive entered into force on 18 March 2026, the twentieth day after publication in the Official Journal on 26 February 2026 (Article 6).

What to do

  • Separate the government deadline from the company's first reporting year in the board paper.
  • Track the national transposition measure and the options it uses.
  • Do not state a penalty or a filing route unless the national measure provides one.

Source

Article 5, Directive (EU) 2026/470, OJ L 2026/470, 26 February 2026. Our statement, not the instrument verbatim.

Not legal advice; does not certify. A reading of the article and the duties inside it, not a substitute for the Official Journal text or the national transposing measure.