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EU: Omnibus "Stop-the-Clock" Directive published in Official Journal of the EU

The “Stop-the-Clock” Directive was published in the Official Journal of the EU on 16 April 2025 - see here.  

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

The Stop-the-Clock Directive - which forms part of the first Omnibus package to simplify EU sustainability legislation - delays: 

  • the entry into application of the Corporate Sustainability Reporting Directive (CSRD) requirements for large companies that have not yet started reporting, as well as listed SMEs, by two years; and 
  • the transposition deadline and the first phase of the application (covering the largest companies) of the Corporate Sustainability Due Diligence Directive (CSDDD) by one year.

CSRD - "Second wave" companies which were due to report in 2026 (in respect of the 2025 financial year) will now need to report in 2028 (in respect of the 2027 financial year). "Third wave" companies which were due to report in 2027 (in respect of the 2026 financial year) will now need to report in 2029 (in respect of the 2028 financial year). 

CSDDD / CSD3D - The deadline for transposition into national law is now 26 July 2027 (instead of 2026) and the first wave of companies will have to comply from 26 July 2028 (instead of 2027). 

The Commission’s Omnibus I package also includes a separate proposal - the “Requirements” proposal - making more substantial changes to the reporting and due diligence requirements in the CSRD and CSDDD. It does not look like the Requirements proposal will be fast-tracked so that proposal will need to go through the normal “ordinary legislative procedure” which normally takes around 18 months from the initial publication.  

For further details of the first Omnibus package, see our CSRD demystified materials

 

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