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 | |||
| Estonia | Yes | The draft law implementing the Stop-the-Clock into Estonian law was adopted on 19 June 2025 and entered into force on 20 July 2025. The reporting deadlines for large companies are 1 January 2027 and SME 1 January 2028. | Karin Madisson (Sorainen) 21 August |
| 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 |
| Ireland | Yes | The European Union (Corporate Sustainability Reporting) Regulations 2025 were published on 11 June 2025. These regulations implement the provisions of the Stop-the-Clock Directive ensuring that those Irish companies required to report for the first time in respect of their 2025 or 2026 financial years have their sustainability reporting obligations pushed out to their 2027 or 2028 financial years respectively. In addition, the regulations introduce amendments to Part 28 of the Companies Act which clarify several of the inconsistencies between CSRD and the Irish implementing legislation. | Jill Shaw (A&L Goodbody LLP) 20 August 2025 |
| Italy | Yes | On 9 August 2025, Law No. 118 of 8 August 2025 was published in the Official Gazette (General Series, no. 184). This law converts Decree-Law No. 95 of 30 June 2025 (the "Omnibus Decree") into law. Among other measures, Law No. 118/2025 amends the Omnibus Decree to the Stop-the-Clock Directive.
On a related point, the updated transposition decree had originally required the Ministry of Economy and Finance and Consob to conduct, within 18 months of the decree’s entry into force, a study on the potential benefits and costs of permitting independent assurance service providers (in addition to traditional auditors) to certify sustainability reports, as allowed under Article 34(4) of the Accounting Directive. The recent amendments extend the deadline for this study to 31 October 2028. Finally, the Omnibus Decree, as amended, introduces certain coordination measures to ensure that the postponed sustainability reporting requirements are aligned with the corresponding rules for auditors and audit firms regarding CSRD-related obligations. | 21 August |
| Lithuania | Yes | Parliament has adopted the Law on Reporting of Companies, the Law on Securities and Annex in implement the Stop-the-Clock directive on 25 June 2025. The laws have been signed by the President and came into force on 1 July 2025. | Vitalija Impolevičienė (Sorainen) 22 August |
| Norway | Yes | On 11 April 2025, the Ministry of Finance issued a consultation proposal regarding the implementation of the Stop-the-clock directive into Norwegian law. The proposal changes the transitional rules by postponing the implementation of reporting requirements for companies in wave 2 and 3. The proposed amendments were adopted on 3 July 2025, and entered into force on the same day. The amendments entail postponed reporting obligations for companies that have not yet reported under the CSRD, meaning that Norwegian companies will face the same application dates as companies in the EU. | (Wiersholm) 21 August |
| Poland | Yes | On 7 May 2025, a draft law to implement the Stop-the-Clock Directive was published. The Polish Parliament adopted the final draft on 9 July 2025, and the President signed it on 23 July 2025. The law came into force on 12 August 2025. The implementation of the Stop-the-Clock Directive in Poland postpones the application deadlines for sustainability reporting under the CSRD by two years. For the Second Wave, the deadline is shifted from financial years beginning after 31 December 2024 to financial years beginning after 31 December 2026. For the Third Wave, the deadline is deferred from financial years beginning after 31 December 2025 to financial years beginning after 31 December 2027. Simultaneously, the legislation eliminates the previous exemption for the Third Wave, which permitted a two-year deferral of reporting, as it has become redundant. The implementation does not introduce any other changes to the CSRD sustainability reporting obligations, particularly with respect to the deadlines for the First Wave or the scope and content of CSRD reporting requirements. | Wojciech Kobylinski (Addleshaws) 20 August 2025
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| 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 expected to enter into force on 31 December 2025. | (Gorrissen Federspiel) 8 July 2025 |
| Germany | In progress | On 10 July 2025, the Federal Ministry of Justice and Consumer Protection (BMJV) published a new draft bill for implementing the CSRD which takes into account the implementation of the ‘Stop-the-Clock’ Directive. | 16 July |
| 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 |
| 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. | 22 August |
| 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 |
| Greece | No | No developments yet
| Michael Tsibris (Souriadakis Tsibris) 6 June |
| Latvia | No | No developments yet | Agita Sprūde (Sorainen) 21 August |
| 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. | 21 August |
| 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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