Sustainability Reporting: ”Stop-the-Clock” Directive (Omnibus) finally adopted

On 16 April 2025, the Directive that is generally referred to as the “Stop-the-Clock” Directive was published in the Official Journal of the EU, thereby officially postponing the application deadlines for sustainability reporting under the CSRD and due diligence requirements under the CSDDD for a large group of EU companies. Transposition into national law must be completed by 31 December 2025.

The ”Stop-the-Clock” Directive is part of the EU Omnibus I Proposal aiming to simplify certain sustainability requirements across the EU and to deliver on the EU Commission’s ambition to boost competitiveness and reduce burdens on European businesses.

Member States must transpose the “Stop-the-Clock” Directive into national law by 31 December 2025.

The “Stop-the-Clock” Directive postpones:

• the reporting obligation pursuant to the Corporate Sustainability Reporting Directive (CSRD) by two years (until 2028) for large companies that have not yet started reporting, as well as listed SMEs that would otherwise have been required to report as of 2026 and 2027 (wave 2 and wave 3), and
• the transposition deadline (to 26 July 2027) and the first phase of the application (covering the largest companies) of the Corporate Sustainability Due Diligence Directive (CSDDD) by one year. The due diligence requirements will apply to the first group of companies (companies with more than 3,000 employees and a net worldwide turnover of more than EUR 900 million) from 26 July 2028 and to all other in-scope companies (companies with more than 1,000 employees and a net worldwide turnover of EUR 450 million) from 26 July 2029.

The Directive allows more time for the EU Parliament and the Council to agree on the more substantial changes to the CSRD and CSDDD proposed by the Commission as part of the Omnibus I Proposal, which are subject to a separate legislative process.

See the adopted Directive here: Link.

For further details in the Omnibus Proposal, see our newsletter: EU Commission Proposes Simplified Sustainability Reporting and Due Diligence Rules (Omnibus) – Gorrissen Federspiel.

How Gorrissen Federspiel can assist

Gorrissen Federspiel closely follows the development of the EU Omnibus Proposal, and we stand ready to advise companies on any potential implications of the contemplated changes for their sustainability reporting and due diligence obligations.

If you have any questions, please feel free to reach out to a member of our dedicated Compliance & Sustainability team.