Member States had until 19 September 2020 to transpose the Directive and communicate their transposition measures to the Commission. In November 2020, the Commission sent letters of formal notice to 23 Member States for not having notified full transposition. The Commission is now taking the second step in the infringement procedure by sending a reasoned opinion to the afore-mentioned nine Member States that have still not notified full transposition. They now have two months to reply to the Commission, or the Commission may decide to refer their cases to the Court of Justice of the European Union.