As part of the ‘Omnibus I’ package on sustainability, the so-called ‘Stop-the-Clock’ directive entered into force last week. It postpones the application dates of certain corporate sustainability reporting requirements under the Corporate Sustainability Reporting Directive (CSRD). Most notably, the entry into application of the CSRD has been deferred by two years for large companies originally scheduled to begin reporting in 2025, and for listed small and medium-sized enterprises (SMEs) that were expected to start in 2026.
The updated application schedule is as follows:
- From 2024 onwards: Listed large companies with over 500 employees that were previously subject to the Non-Financial Reporting Directive. Reporting started in 2025.
- From 2027 onwards: Listed and non-listed large companies that exceed at least 2/3 of the following thresholds: MEUR 25 balance sheet, MEUR 50 net turnover and 250 employees. Reporting starts in 2028.
- From 2028 onwards: Listed small and medium-sized enterprises (SMEs). Reporting starts in 2029.
- From 2028 onwards: Non-EU companies that have an over MEUR 150 net turnover in the EU and a subsidiary or branch in the EU. Reporting starts in 2029.
Additionally, the ‘Stop-the-Clock’ directive delays the initial phase of implementation — targeting the largest companies — as well as the transposition deadline for the Corporate Sustainability Due Diligence Directive (CSDDD) by one year. Member States are required to transpose the ‘Stop-the-Clock’ directive into national law by 31 December 2025.
Further changes are anticipated, as the EU intends to reach an agreement on substantive revisions to both the CSRD and the CSDDD, as proposed by the Commission within the broader ‘Omnibus I’ package on sustainability.
For more information, please contact Anders Floman and Saara Sorvaniemi.