Stop the clock: CSRD and CS3D officially postponed
Postponement of the applicability of new rules on sustainability and due diligence has been approved
29 Apr 2025On April 16, 2025, Directive (EU) 2025/794 was published in the Official Journal of the European Union. The directive defers the EU obligations related to due diligence and sustainability reporting. Referred to as the "Stop the clock" Directive, it is part of the larger “Omnibus I” package aimed at enhancing the EU’s competitiveness.
In the context of the CSRD (Corporate Sustainability Reporting Directive), the directive postpones the entry into force of reporting obligations by two years:
|
Enterprise classification |
Changes introduced by the "Stop the clock" Directive |
Applicability date |
|
Large companies already subject to NFRD (public interest entities, >500 employees) |
No changes |
Reporting in 2025 for the 2024 reference year |
|
Large companies not subject to NFRD (>250 employees, €40M turnover or €20M total assets) |
2-year postponement |
Reporting in 2028 for the 2027 reference year |
|
Listed SMEs (excluding micro-enterprises) |
2-year postponement |
Reporting in 2029 for the 2028 reference year |
As for the CS3D (Corporate Sustainability Due Diligence Directive), EU countries will have until July 26, 2027—one year later than originally planned—to transpose the directive into national law. The applicability of the directive is also postponed by one year:
|
Enterprise classification |
Changes introduced by the "Stop the clock" Directive |
Applicability date |
|
EU and non-EU companies with >5000 employees and annual turnover of €1.5B |
1-year postponement |
2028, with reporting obligations starting January 1, 2029 |
|
EU companies with >3000 employees and turnover of €900M; Non-EU companies with turnover of €900M |
1-year postponement |
2028, with reporting obligations starting January 1, 2029 |
|
EU companies with at least 1000 employees and turnover of €450M; Non-EU companies with turnover of €450M; EU or non-EU companies with franchising or licensing agreements in the EU >€22.5M and annual turnover >€80M |
1-year postponement |
2029, with reporting obligations starting January 1, 2030 |
The deadline for Member States to transpose these changes is December 31, 2025.
The “Stop the clock” Directive is designed to support companies in managing reporting obligations by granting them the necessary time to organize, gather information, and prepare for the applicable deadlines. It is essential, however, not to slow down on the path to corporate sustainability, but rather to seize this opportunity with the awareness that the journey towards a sustainable economy is already underway. Despite the deviations and simplifications the EU is offering to accommodate businesses, the ultimate goal remains unchanged.