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The first part of the EU Omnibus I Proposal, the so-called “Stop-the-Clock Directive,” (the “Directive”) was adopted on 3 April 2025 and entered into force on 16 April 2025. The Directive postpones the application deadlines for sustainability reporting under the CSRD for a large group of EU companies and must be transposed into national legislation by 31 December 2025.
As a result, the Danish Parliament has introduced a bill to transpose the directive, which has been submitted for public consultation on 26 May 2025.
The draft bill only postpones the application deadlines for sustainability reporting under the CSRD; it does not bring any changes to the content of the reporting obligation itself.
The draft bill postpones the reporting obligation pursuant to CSRD by two years. Large companies that have not yet started reporting will need to report in 2028 (in respect of the 2027 financial year) (second wave) and listed SMEs will need to report in 2029 (in respect of the 2028 financial year) (third wave).
Since the postponement solely concerns the reporting obligation for companies in waves two and three, listed companies and state-owned public limited companies with more than 500 employees will not be affected by the draft bill and must continue to report pursuant to the CSRD requirements.
The postponement allows more time for the EU Parliament and the Council to agree on the substantial changes to the CSRD based on the Commission’s proposal included in the Omnibuspackage, which are subject to a separate legislative process.
As a consequence of the postponement, the requirement for second and third waves companies to appoint an auditor or independent assurance provider to issue an assurance statement on the sustainability report is likewise postponed.
For companies that have already appointed a sustainability auditor or independent assurance provider, the auditor or independent assurance provider can be deregistrated without a separate resolution adopted at a general meeting, and the deregistration may be carried out without submission of further explanation.
This transitional arrangement only applies until the next annual general meeting. If deregistration has not been completed before the next annual general meeting, the deregistration of the auditor or independent assurance provider must follow the standard – and more cumbersome – procedure.
It is important to note that the draft bill entails that companies in scope of the CSRD reporting requirements (as postponed) must continue to report in accordance with the prior version of section 99a of the Danish Financial Statements Act until they become required to report in accordance with the CSRD requirements.
I.e. reporting on corporate social responsibility matters are not entirely postponed or removed. However the non-CSRD reporting requirements are significantly less comprehensive and less formalized.
The draft bill has been submitted for public consultation with a deadline of 27 June 2025. Subsequently, the draft bill may be amended based on the public consultation and will then be subject to the parliamentary proceedings.
The bill is expected to enter into force on 31 December 2025.
See the draft bill here: Link.
For further details on the Omnibus I Proposal, see our newsletters: Link and Link.