As part of the EU Commission’s so-called “Omnibus package”, the “Stop-the-Clock” Directive was published in the Official Journal of the EU on 16 April 2025 – see here.
You can read more about the Omnibus package including the Stop-the-Clock Directive under the “Featured content” here or by searching the Sustainable Futures blog using the term “Omnibus”.
In particular, look at this tracker to follow key developments in the EU's efforts to simplify existing sustainability rules.
Member States must now transpose the Stop-the-Clock Directive into national law by 31 December 2025.
In the table below, we track the status of transposition in key EU jurisdictions, including any information about the stage the process is at, for example draft guidelines, any interim communications and any announcements on timing and next steps.
We will be updating this table approximately monthly, and the final column notes when the content was last updated.
Sitting alongside this Stop-the-Clock Transposition Tracker (see table below), we also maintain our CSRD transposition tracker.
| Member State | Transposed? Yes / No / In progress | Comments e.g. information about latest developments, timing updates, goldplating | Contact and date of last update |
| TRANSPOSED | |||
| France | Yes (for CSRD) | In early April 2025, the French legislator passed a law amending the Ordinance to align the implementation deadlines for the CSRD in French law with ‘Stop-the-clock’ Directive. This law also includes an exception regarding the publication of certain sustainability information that could seriously harm the company’s commercial position. Certain information could be omitted from the sustainability report upon a reasoned opinion from the board of directors, the executive board, or the manager, and would instead be submitted to the Autorite des marches financiers. The law was published in the Official Journal on 2 May 2025 and is now applicable. | 5 June 2025 |
| TRANSPOSITION IN PROGRESS | |||
| Denmark | In progress | The Danish Parliament introduced a draft bill on 26 May 2025 to transpose the ‘Stop-the-Clock’ Directive. The draft bill postpones the application deadlines for sustainability reporting under the CSRD for wave 1 and wave 2. It does not bring any changes to the content of the CSRD reporting obligation itself. Furthermore, a transitional arrangement is introduced for the deregistration of already appointed auditors or independent assurance providers. Lastly, the draft bill entails that companies in scope of the CSRD reporting requirements (as postponed) must continue to report in accordance with the former Section 99a of the Danish Financial Statements Act until they are required to report under the CSRD. The draft bill is open for public consultation until 27 June 2025 and is expected to enter into force on 31 December 2025. | (Gorrissen Federspiel) 10 June |
| Hungary | In progress | The Minister of National Economy has submitted a proposal to amend the ESG Act (the “Amendment”) to the legislature. According to the draft amendment shared for public consultation, it was expected that the threshold for determining large undertakings would be established in a ministerial decree (NGM Decree). However, it has now been incorporated into the Amendment. According to the Amendment, a large undertaking is defined as one whose main activity, in the two financial years preceding the current year, is classified in Annex 1 of the ESG Act as of the balance sheet date, and which exceeds the following thresholds:
Considering that the deadline for legislation can be influenced by several factors, such as whether any amendments to the Amendment will be proposed, we cannot predict in advance when the Amendment will be adopted. However, since the Amendment is included in the Act related to the government budget, and with the spring session ending on 10-11 June 2025, it is anticipated that it will be adopted relatively quickly. | Jan Lehký (Kinstellar) 10 June |
| Luxembourg | In progress | Amendments to the initial draft law n°8370 were published on 6 May 2025 by the Luxembourg government proposing amendments to reflect the new timelines under the Stop-the-Clock legislation and to include new provisions which, in their current version, confirm that in-scope entities whose financial year started on 1 January 2024 or after this date and closed before the entry into force of the law are not required to establish and publish sustainability information for said exercise. | 5 June |
| Norway | In progress | The Stop-the-Clock directive is pending final approval by the Ministry of Finance, following the conclusion of a consultation period this Spring. | Anne Katrine Ramstad (Wiersholm) 16 June |
| Slovakia | In progress | The Slovak Parliament is currently discussing amendments to the Securities Act and other acts (the Amendment), including amendments to the Accounting Act, which implemented the CSRD into Slovak law with effect from 1 June 2024. The purpose of the Amendment is to implement the “Stop the Clock Directive”, The proposed effective date of the Amendment is 10 July 2025. If this proposed effective date is to be approved, the Amendment would have to pass a second and third reading before the end of the regular session of parliament, which ends on 13 June. The next session of the Slovak parliament is scheduled for 9 September. | Jan Lehký (Kinstellar) 10 June |
| Sweden | In progress | The Swedish Ministry of Justice has produced a memorandum with proposals for the legislative amendments needed to implement the directive. The proposed amendments align with the directive and do not include any goldplating. It is proposed that the legislative amendments enter into force on 31 December 2025. The proposal has been referred to relevant bodies for consideration. | 13 June |
| NOT YET TRANPOSED / NO DEVELOPMENTS | |||
| Belgium | No | No developments yet | 6 June |
| Bulgaria | No | No developments yet | Jan Lehký (Kinstellar) 10 June |
| Croatia | No | The Croatian Ministry of Finance has announced that the Accounting Act and the Capital Market Act will be amended by the end of 2025 to align national legislation with the "Stop the Clock Directive” on sustainability reporting. | Jan Lehký (Kinstellar) 10 June |
| Czech Republic | No (with regards to CS3D) In progress (with regards to CSRD) | According to the Government Compatibility Office, the Ministry of Finance (gestor of the transposition of the Directive) has not yet provided specific information and that the Ministry of Finance is evaluating the steps. Several amendments have been proposed during the ongoing deliberations on the draft legislation implementing the second phase of the CSRD transposition in the Czech Republic. This phase concerns the second and subsequent groups of entities subject to the CSRD. The proposed amendments reflect the ESG Omnibus changes, particularly by anticipating the future expansion of the reporting obligation to companies with at least 1,000 employees. As a result, the "second wave" of reporting obligations under the CSRD would effectively be skipped. Additionally companies with fewer than 1,000 employees would be exempt from the reporting obligation for the 2025 reporting year. | Jan Lehký (Kinstellar) 10 June |
| Estonia | No | No developments yet | Karin Madisson (Sorainen) 10 June |
| Germany | No | No developments yet (As Germany has neither implemented the CSRD nor CSDDD, there is nothing to be implemented regarding ‘Stop-the-Clock’.) The German coalition partners announced their support for the EU Omnibus initiative, particularly advocating for a "bureaucratic-light solution" for SMEs. Read more on this here. | 16 June |
| Greece | No | No developments yet
| Michael Tsibris (Souriadakis Tsibris) 6 June |
| Ireland | No | The statutory instrument to give effect to the Stop-the Clock Directive is expected to be transposed into Irish law in the coming months, and in any event ahead of the transposition deadline of 31 December 2025. | Jill Shaw (A&L Goodbody LLP) 6 June |
| Italy | No | No developments yet | 8 May |
| Latvia | No | No developments yet | Agita Sprūde (Sorainen) 9 June |
| Lithuania | No | The Lithuanian Ministry of Finance is planning to transpose the ‘Stop-the-Clock’ into national laws in the spring Parliament session. | Vitalija Impolevičienė (Sorainen) 9 June |
| Netherlands | No | No developments yet. At a high level the Dutch legislator supports the proposed Omnibus I changes on the EU level. As they have yet to transpose the original CSRD, the Stop-the-Clock amendments are expected to be included in the current CSRD implementation drafts. Whilst the official transposition of the CSRD has commence, the collapse of the Dutch government at the start of June has impacted its development and created uncertainty about its timing. The election outcome in October will also impact the process. | 16 June |
| Poland | No | No developments yet | 8 May |
| Portugal | No | No developments yet | 16 June |
| Romania | No | No developments yet | Jan Lehký (Kinstellar) 10 June |
| Spain | No | No developments yet On 26 March 2025, CNMV’s Advisory Committee (a consultative body composed by market participants but with an independent opinion from the CNMV) published a feedback statement to the Commission welcoming the Omnibus Proposal for simplification and reduction of administrative burden while maintaining support for the environmental objectives of the EU. | 16 June |
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