ESMA updated its GLESI compliance table on 1 April 2026, providing the latest picture of how national competent authorities across the EU and EEA are implementing the Guidelines on Enforcement of Sustainability Information. The table reveals a fragmented supervisory landscape: while 14 out of 30 authorities now fully comply, five have declared outright non-compliance, and several major economies — including Germany, Spain, and Luxembourg — remain in “intends to comply” status, pending CSRD transposition into national law.
The GLESI are ESMA’s blueprint for how national regulators should supervise the sustainability statements that listed companies are now required to publish under the Corporate Sustainability Reporting Directive and European Sustainability Reporting Standards. They cover everything from issuer selection models and examination procedures to enforcement powers and cross-border coordination. The compliance table is the public accountability mechanism — it shows which regulators are actually applying these standards and which are falling behind.
Compliance at a glance
The visual below maps each national authority’s declared compliance status. Green indicates full compliance, amber indicates intention to comply (typically pending CSRD transposition), and red indicates declared non-compliance with one or more GLESI guidelines.
What are the GLESI?
The Guidelines on Enforcement of Sustainability Information (GLESI) were finalised by ESMA in its July 2024 Final Report and issued in all EU languages in April 2025. They apply to sustainability information published from 1 January 2025 onwards. The GLESI are modelled on ESMA’s well-established Guidelines on Enforcement of Financial Information (GLEFI), which have been in operation since 2014, and are designed to ensure that sustainability reporting supervision is as rigorous as financial reporting supervision.
The guidelines cover 13 substantive areas, including the characteristics and powers enforcers must possess (Guideline 2), the selection model for choosing which issuers to examine (Guidelines 5–7), examination procedures (Guidelines 8–9), enforcement actions available when infringements are detected (Guideline 12), and coordination mechanisms with ESMA and other national authorities (Guideline 13). ESMA emphasised from the outset that the first years of ESRS application involve a learning curve for all parties, and that enforcement should be proportionate — but this does not exempt issuers from their obligation to comply with European Sustainability Reporting Standards.
Where the gaps are
The compliance table reveals two distinct categories of non-compliance. The first is structural: several Member States have not yet transposed the CSRD into national legislation, which prevents their national authorities from formally applying GLESI. The second is operational: some authorities comply with most guidelines but lack specific powers or resources required by certain provisions.
Authorities declaring non-compliance
Cannot comply with Guideline 2 due to the enforcement model’s delegation structure. Part of Austria’s enforcement responsibilities are delegated to AFREP, a private review panel. Confidentiality provisions in Austrian law prevent FMA from supervising AFREP’s staff, operations, or resource allocation in the manner Guideline 2 requires.
The Danish Business Authority focuses on thematic analysis rather than examination of individual companies, which means it cannot meet the selection model requirements of Guidelines 5–7 or the examination procedures of Guidelines 8–9. DBA commits to full compliance no later than 2027. Denmark’s other authority, Finanstilsynet (DFSA), fully complies.
The AMF has taken a principled position: it will comply only once all NCAs have the necessary legislative or regulatory basis to supervise sustainability information under CSRD. This conditional stance makes France the only major Member State to cite the uneven playing field across the EU as its reason for non-compliance.
The AFM cannot comply with parts of Guideline 2 and Guideline 12 because Dutch law does not grant it the authority to independently exercise three investigative powers and one corrective power without civil court involvement. The AFM intends to comply with all remaining guidelines once CSRD is transposed nationally.
The Financial Supervisory Authority complies with all guidelines except Guideline 2, citing insufficient human resources to meet the staffing and expertise requirements for sustainability information enforcement.
Norway’s financial supervisor has not established a GLESI-compliant selection model (Guidelines 5–7) and is focusing on thematic inspections rather than individual company examinations in 2025, resulting in non-compliance with Guidelines 8 and 12.
The CSRD transposition bottleneck
A recurring theme across the “intends to comply” declarations is that national CSRD transposition remains incomplete in several major jurisdictions. Germany (BaFin), Spain (CNMV), Luxembourg (CSSF), Malta (MFSA), and Portugal (CMVM) all condition their compliance on the transposition of CSRD into national law. This creates a significant supervisory gap: listed companies in these jurisdictions are publishing their first sustainability statements under ESRS, but the national regulators charged with supervising those statements have not yet formally adopted the enforcement framework.
ESMA acknowledged this tension in its June 2025 public statement, noting that GLESI application during the initial years must be proportionate and realistic. The guidelines include built-in flexibilities — NCAs can focus on priority disclosure areas, use dialogue and informal measures to support issuers, and calibrate their supervisory approach to the evolving regulatory context. However, the statement also made clear that flexibility does not remove the obligation to enforce where necessary.
What the GLESI require in practice
The guidelines establish a comprehensive supervisory framework for national authorities. Understanding what the GLESI demand helps explain why some authorities are struggling to comply.
| Guideline area | Key requirements | Common compliance issues |
|---|---|---|
| Guideline 2 — Enforcer characteristics | Adequate legal powers, operational independence, professionally skilled staff with sustainability expertise, sufficient resources | Austria (delegation model), Netherlands (legal powers), Romania (resources) |
| Guidelines 5–7 — Selection model | Mixed model combining risk-based selection with sampling and rotation; annual selection; convergence through ESMA’s Sustainability Reporting Working Group | Denmark DBA (thematic focus), Norway (no selection model) |
| Guidelines 8–9 — Examination procedures | Procedures for examining individual issuers’ sustainability statements, including scope, depth, and documentation | Denmark DBA (no individual examinations), Norway (thematic only) |
| Guideline 12 — Enforcement actions | Enforcers must have access to at least three enforcement actions: requiring correction in future statements, public disclosure of infringements, and other national enforcement measures | Cyprus (legislative gap), Netherlands (court involvement required), Norway |
| Guideline 13 — Coordination | All enforcers participate in ESMA’s Sustainability Reporting Working Group; annual Common Enforcement Priorities; cross-border information sharing | Greece (pending presidential decree) |
Why this matters for listed companies
The uneven compliance landscape creates practical implications for companies reporting under ESRS. An issuer listed in a jurisdiction where the NCA fully complies with GLESI — such as Belgium, Finland, or Italy — can expect structured, systematic supervision of its sustainability statements. An issuer in a jurisdiction where the NCA has not yet formally adopted GLESI may face less predictable supervisory engagement in the short term, but this does not reduce the issuer’s legal obligation to comply with ESRS disclosure requirements.
ESMA’s coordination mechanisms are designed to mitigate this fragmentation. The annual European Common Enforcement Priorities (ECEP) set shared supervisory focus areas across all Member States, regardless of individual NCA compliance status. In practice, this means that even where national enforcement capacity is limited, ESMA-coordinated thematic reviews can still highlight reporting deficiencies at a pan-European level.
For multinational groups with listings in multiple EU jurisdictions, the compliance table offers a useful indicator of where supervisory scrutiny is likely to be most rigorous. Markets with fully compliant NCAs — particularly those with established enforcement track records in financial information (Belgium, Finland, Ireland, Italy, Sweden) — are likely to apply GLESI principles most actively from the outset.
The Omnibus factor
The compliance table must also be read in the context of the EU’s Omnibus legislative process. The Commission’s February 2025 Omnibus I package included a stop-the-clock directive — published in the Official Journal in April 2025 — that postponed CSRD requirements for wave 2 and wave 3 companies (those scheduled to begin reporting in 2026 and 2027). A subsequent quick-fix delegated act, adopted in July 2025, relieved wave 1 companies from reporting additional information for financial years 2025 and 2026 compared to their first reporting cycle.
This evolving regulatory environment is explicitly referenced in the compliance table’s preamble, which notes that GLESI application must account for the uneven CSRD transposition and the Omnibus process. For national authorities, this creates a complex calibration exercise: they must build enforcement capacity for sustainability reporting while the scope and requirements of that reporting continue to shift. The AMF’s position — conditioning compliance on a level playing field across all NCAs — is a direct response to this uncertainty.
At Generation Impact Global, we help listed companies and financial institutions navigate this evolving enforcement landscape — from ESG reporting requirements under ESRS to SFDR disclosure frameworks — ensuring that sustainability data management systems are robust enough to meet supervisory expectations regardless of which jurisdiction applies scrutiny first.
Timeline of key developments
ESMA publishes Final Report on GLESI following public consultation
GLESI apply to sustainability information published from this date; wave 1 companies begin ESRS reporting for FY2024
ESMA issues GLESI in all EU languages; two-month notification window opens for NCAs
ESMA public statement on proportionate GLESI application during Omnibus environment
First GLESI compliance table published with NCA declarations
Updated compliance table published — 14 comply, 11 intend, 5 non-compliant
Domande frequenti
What are the GLESI?
The Guidelines on Enforcement of Sustainability Information are ESMA’s framework for how national competent authorities should supervise sustainability reporting by listed companies under the CSRD and ESRS. They cover issuer selection, examination procedures, enforcement powers, and coordination with ESMA. The guidelines are modelled on the existing enforcement framework for financial information.
Which EU countries fully comply with GLESI?
As of April 2026, 14 authorities have declared full compliance: Belgium, Czech Republic, Denmark (DFSA), Estonia, Finland, Croatia, Ireland, Italy, Lithuania, Latvia, Poland, Sweden, Slovenia, and Slovakia. Liechtenstein also complies within the EEA framework.
Why are Germany and Spain not yet compliant?
Both BaFin (Germany) and CNMV (Spain) have declared that they intend to comply with GLESI once the CSRD has been transposed into their respective national legislation. Until transposition is complete, these regulators lack the domestic legal basis to formally implement the enforcement framework. The same situation applies in Luxembourg, Malta, and Portugal.
Does non-compliance affect listed companies’ reporting obligations?
No. An NCA’s non-compliance with GLESI does not reduce or delay an issuer’s obligation to report under ESRS. Listed companies in all Member States must comply with the CSRD and applicable ESRS requirements regardless of their national regulator’s GLESI compliance status. However, the nature and intensity of supervisory review may vary in the short term.
How does the Omnibus process affect GLESI enforcement?
The Omnibus I stop-the-clock directive delayed CSRD requirements for wave 2 and wave 3 companies, and a quick-fix delegated act reduced reporting requirements for wave 1 companies in 2025–2026. ESMA has stated that GLESI application must be proportionate during this transition period. NCAs have flexibility to adapt their supervisory approach, but enforcement action remains available where necessary.
