Global | Publication | April 2025
Following publication by the European Commission of the ‘Omnibus package’ (the Omnibus) on 26 February 2025 (see our previous publication on this here), the ‘Stop the Clock Directive’ which seeks to postpone certain dates for implementation of the EU Corporate Sustainability Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CS3D) has now come into force.
However, the second Omnibus proposal seeking to introduce substantive changes to CSRD and CS3D is still in draft form and going through the EU’s legislative procedure.
CSRD
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Previous position |
New position |
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In-scope large EU companies |
Reporting required for financial years starting from 1 January 2025 (with first reports due in 2026) |
Reporting required for financial years starting from 1 January 2027 (with first reports due in 2028) |
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In-scope large non-EU companies with securities admitted to trading on EU regulated market |
Reporting required for financial years starting from 1 January 2025 (with first reports due in 2026) |
Reporting required for financial years starting from 1 January 2027 (with first reports due in 2028) |
|
Listed SMEs |
Reporting required for financial years starting from 1 January 2026 (with first reports due in 2027) |
Reporting required for financial years starting from 1 January 2028 (with first reports due in 2029) |
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Non-EU parent companies of large EU companies |
Reporting required for financial years starting from 1 January 2028 (with first reports due in 2029) |
Unchanged |
* ‘Wave 1’ companies (i.e., large EU public interest entities with more than 500 employees and large non-EU companies with securities admitted to trading on an EU regulated market) are still required to report for financial years starting from 1 January 2024 (with first reports due in 2025).
CS3D
The Stop the Clock Directive postpones the transposition deadline for CS3D from 26 July 2026 to 26 July 2027.
In addition, the first phase of application of the CS3D to in-scope companies is also postponed by one year (from 26 July 2027 to 26 July 2028):
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Previous position |
New position |
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EU companies with: (i) more than 5,000 employees; and (ii) an annual net worldwide turnover over €1.5 billion Non-EU companies with an annual net turnover in the EU in excess of €1.5 billion |
Obligations apply from 26 July 2027 |
Obligations apply from 26 July 2028 |
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EU companies with more than 3,000 employees and an annual net worldwide turnover in excess of €900 million Non-EU companies with an annual net turnover in the EU over €900 million |
Obligations apply from 26 July 2028 |
Unchanged |
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EU companies with more than 1,000 employees and an annual net turnover in excess of €450 million Non-EU companies with an annual net turnover of €450 million generated in the EU |
Obligations apply from 26 July 2029 |
Unchanged |
The Stop the Clock Directive requires Member States to transpose the changes into domestic legislation by 31 December 2025 at the latest. Therefore, the timing of these changes coming into effect at the local level of each Member State may be affected by how quickly the various countries transpose the requirements.
Norton Rose Fulbright will continue to monitor the progress of the substantive Omnibus proposals as they undergo the legislative process and will provide an update in due course.
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Publication
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