The Stop-the-Clock Directive (EU) 2025/794: Which CSRD Reports Were Postponed and to When

The directive amends a single provision, Article 5(2) of Directive (EU) 2022/2464, the Corporate Sustainability Reporting Directive, which sets the dates from which Member States apply the reporting requirements; it has been in force since 17 April 2025 (EUR-Lex). The reporting duties themselves stay those of the amended act, and the Corporate Sustainability Reporting Directive (CSRD) is explained on its own page.

Under Directive (EU) 2026/470 (Omnibus I), in force since 18 March 2026, the 2027 date stands with new criteria: a net turnover of more than EUR 450 million and an average of more than 1,000 employees, both exceeded, individually or for a group on a consolidated basis. The third wave is deleted. This page gives the amending point behind each date and the status as of 29 October 2026.

Table 1 gives the identity of the act and its status as of 29 October 2026.

What Did the Stop-the-Clock Directive Postpone?

The Stop-the-clock Directive postponed only application dates: Article 1 of Directive (EU) 2025/794 moved points (b) and (c) of Article 5(2), first and third subparagraphs, of the CSRD by two years, and these application dates are all that its Article 1 amends. The European Commission's corporate sustainability reporting page describes the effect as postponing by two years the reporting of companies previously due to report first for financial year 2025 or 2026, the second and third waves.

Recital 3 of Directive (EU) 2025/794 gives the reason: while the simplification initiatives were ongoing, and to avoid the undertakings due to report for financial years beginning on or after 1 January 2025 and 1 January 2026 "incurring unnecessary and avoidable costs", their reporting requirements were postponed by two years. Table 2 follows each group from the 2022 text through both amending directives.

The first years of all waves, also outside the postponement, are listed as every first financial year per wave on the CSRD timeline.

The Second Wave: From Financial Year 2025 to Financial Year 2027

The second wave, other large undertakings and parents of large groups, was due to report first for financial years starting on or after 1 January 2025 and now starts with financial years starting on or after 1 January 2027 (Article 1(a)(i) of Directive (EU) 2025/794). The management report that carries the sustainability statement is published at the latest 12 months after the balance sheet date (Article 30 of Directive 2013/34/EU). For a company with a calendar financial year, the first report therefore moved from 2026 (financial year 2025) to 2028 (financial year 2027). The dates of the other waves sit beside this one as the first financial year for each wave on the CSRD timeline.

The date counts by financial year, not by calendar year. A company whose financial year starts on 1 July has its first year under point (b) starting on 1 July 2027, because its year starting on 1 July 2026 begins before 1 January 2027.

The Third Wave: Listed SMEs, From Financial Year 2026 to 2028, Then Deleted

The third wave, listed SMEs other than micro undertakings, small and non-complex institutions and captive insurance and reinsurance undertakings, moved from financial years starting on or after 1 January 2026 to 1 January 2028 (Article 1(a)(ii) of Directive (EU) 2025/794). Directive (EU) 2025/794 did not touch the Article 19a(7) opt-out, which Directive (EU) 2026/470 later deleted together with the listed-SME scope.

Directive (EU) 2026/470 then deleted point (c) in the first and in the third subparagraph of Article 5(2) (Article 3(1)(a)(iii) and (b)(iii)), and the 2028 date went with it. Listed SMEs are no longer in the CSRD regime, and the wave-3 date of small and non-complex institutions and captive insurers is deleted as well. The position of listed SMEs after the deletion is covered under SMEs and listed SMEs under the CSRD.

Issuers on EU Regulated Markets: The Same Two-Year Shift

Issuers within the meaning of Article 2(1)(d) of Directive 2004/109/EC follow the third subparagraph of Article 5(2), and Directive (EU) 2025/794 moved their points (b) and (c) to the same dates, 1 January 2027 and 1 January 2028. Directive (EU) 2026/470 later applied the same test to them: more than EUR 450 million net turnover and an average of more than 1,000 employees (Article 5(2), third subparagraph, as amended by Article 3(1)(b)).

First-Wave Reporters and Non-EU Groups: Left Unchanged

The directive did not move the first wave, large public-interest entities with more than 500 employees that report from financial years starting on or after 1 January 2024, nor the Article 40a reports of non-EU groups, which start with financial years starting on or after 1 January 2028. The first wave sits in point (a) of the first subparagraph of Article 5(2), and the non-EU groups in its second subparagraph, which neither Directive (EU) 2025/794 nor Directive (EU) 2026/470 amended.

The relief that first-wave reporters received for financial years 2025 and 2026 came from a different act, the ESRS quick fix. Under Delegated Regulation (EU) 2025/1416, adopted on 11 July 2025 and in force since 13 November 2025, wave-one undertakings are not required to report additional information for financial years 2025 and 2026 compared with financial year 2024 (recital 4). The quick fix replaces the phase-in list in Appendix C of ESRS 1 of Delegated Regulation (EU) 2023/2772. Its content is set out under the first-wave relief in the ESRS quick fix, Delegated Regulation (EU) 2025/1416.

Article by Article: What Directive (EU) 2025/794 Contains

Directive (EU) 2025/794 is a short amending act whose reporting content sits in Article 1, with Article 3 on transposition and Article 4 on entry into force. The three provisions that concern CSRD reporting are listed below.

• Article 1 amends the introductory wording of points (b) and (c) in the first and third subparagraphs of Article 5(2) of Directive (EU) 2022/2464 to financial years starting on or after 1 January 2027 and 1 January 2028.
• Article 3(1) requires Member States to bring into force the measures needed to comply with the directive by 31 December 2025.
• Article 4 sets entry into force on the day following publication, 17 April 2025.

Article 2 of the same directive postponed dates of the EU due-diligence rules, which this site does not cover. Of its 10 recitals, recital 1 refers to the Commission communication of 11 February 2025, "A simpler and faster Europe", and recitals 9 and 10 explain the urgency.

EUR-Lex holds two consolidated versions of the CSRD, dated 17 April 2025 (after the Stop-the-clock Directive) and 18 March 2026 (after Directive (EU) 2026/470); consolidated versions are documentation tools without legal effect, and only the texts published in the Official Journal are authentic. The authentic text of Directive (EU) 2025/794 is on EUR-Lex.

How the Directive Was Adopted: Proposal, Urgent Procedure and Council Vote

The Commission proposed the postponement as COM(2025) 80 on 26 February 2025, the European Parliament adopted its position under the urgent procedure on 3 April 2025, and the directive was adopted on 14 April 2025, published on 16 April and in force on 17 April 2025. The proposal ran as procedure 2025/0044(COD). COM(2025) 81, presented on the same day as procedure 2025/0045(COD), was the separate content proposal that became Directive (EU) 2026/470.

Table 3 lists the seven dated steps from the proposal to the later content amendment.

The Council adopted the text on 14 April 2025, the date the act bears, and the procedure file is kept in the European Parliament's Legislative Observatory.

How the Later Content Amendment Replaced the Postponed Waves

Directive (EU) 2026/470 (Omnibus I), in force since 18 March 2026, kept the 1 January 2027 date that the Stop-the-clock Directive set in point (b) but replaced who it covers, and it deleted point (c) altogether. Point (b) of the first subparagraph of Article 5(2) now covers undertakings exceeding a net turnover of EUR 450 million and an average of 1,000 employees, and parents of groups on a consolidated basis (Article 3(1)(a)(ii) of Directive (EU) 2026/470). The same test sits in Article 19a(1) and Article 29a(1) of Directive 2013/34/EU, as replaced by Article 2(4)(a) and 2(5)(a) of Directive (EU) 2026/470, whose text is on EUR-Lex.

The content amendment also closed the first wave. Article 3(1)(a)(i) limits point (a) to financial years starting between 1 January 2024 and 31 December 2026, and Article 3(1)(c) adds an option for financial years starting between 1 January 2025 and 31 December 2026: Member States may exempt wave-1 undertakings or issuers not exceeding EUR 450 million net turnover or an average of 1,000 employees. Member States must transpose Articles 1 to 3 of Directive (EU) 2026/470 by 19 March 2027 (Article 5(1)), and until then a company applies the dates and criteria of its national law. The full list of changes is set out under how the Omnibus content amendment changed the CSRD.

Postponed Companies That the New Thresholds Leave Out

A large undertaking that the Stop-the-clock Directive moved to financial year 2027 reports for that year when it exceeds both a net turnover of EUR 450 million and an average of 1,000 employees, individually or as a group on a consolidated basis; an undertaking that does not exceed both values is outside the scope. Before Directive (EU) 2026/470, the second wave was defined by the large-undertaking values of Article 3(4) of Directive 2013/34/EU as amended by Delegated Directive (EU) 2023/2775, from financial year 2024 where transposed: exceeding two of three criteria, a balance sheet total of EUR 25 million, a net turnover of EUR 50 million and 250 employees.

Those values no longer decide CSRD scope, and the former third wave left the mandatory scope with point (c).

Transposition: The 31 December 2025 Deadline and National Measures

Member States had to bring into force the laws needed to comply with Directive (EU) 2025/794 by 31 December 2025 (Article 3(1)), and companies apply the postponed dates through their national law, not through the directive itself.

As of 29 October 2026, France transposed the postponement by Article 7 of loi n° 2025-391 of 30 April 2025, in force since 3 May 2025, which moves the second wave to financial years opened from 1 January 2027 and the third to those opened from 1 January 2028. Belgium transposed it by the law of 12 December 2025, in force since 23 December 2025. Sweden transposed it by Lag (2025:1297), in force since 31 December 2025.

EUR-Lex records national measures for Directive (EU) 2025/794 from 21 Member States as of 29 October 2026, all except Czechia, Germany, Spain, Luxembourg, the Netherlands and Portugal; a record is not a completeness assessment. As of 29 October 2026 Germany has not transposed the CSRD: the government bill (BT-Drs. 21/1857) has been referred to committee and not adopted, and the CSR-RUG rules (the German act of 2017 that transposed Directive 2014/95/EU) still apply; Directive (EU) 2025/794 is not transposed in Germany either. Each country's acts and dates are listed among the national Stop-the-clock measures in the CSRD transposition tracker.

How to Plan a First Report for Financial Year 2027

For a company that the postponement moved to 2027, plan in six steps and keep the article behind each one on file. The six steps are listed below in order.

1. Test both CSRD thresholds of more than 1,000 employees and EUR 450 million net turnover, individually and, for a parent, on a consolidated basis.

2. Check the national law that applies in the CSRD transposition tracker by Member State.

3. Fix the first financial year starting on or after 1 January 2027 and its publication date, at the latest 12 months after the balance sheet date (Article 30 of Directive 2013/34/EU).

4. Plan for the revised (simplified) ESRS from financial year 2027, Delegated Regulation (EU) 2026/1563.

5. Prepare value-chain requests within the value-chain cap for suppliers with up to 1,000 employees.

6. Run the CSRD scope check and follow the CSRD compliance plan after the Omnibus.

The reporting steps for a first financial year are set out in our CSRD compliance steps after the Omnibus.

Where Stop-the-Clock Sits in the Omnibus Package

The Stop-the-clock Directive was the first of two directives from the Commission's Omnibus package of 26 February 2025: it moved the dates, and the separate content proposal, COM(2025) 81, became Directive (EU) 2026/470 on 24 February 2026. The first changed when the second and third waves report; the second changed who reports, listed SMEs, non-EU groups, the value chain and assurance.

Two delegated regulations on the standards sit beside the two directives. Delegated Regulation (EU) 2025/1416, the quick fix, amended the first set of ESRS, and Delegated Regulation (EU) 2026/1563 of 3 July 2026 holds the revised (simplified) ESRS for financial years beginning on or after 1 January 2027. Every change of the Omnibus package, from the scope test to assurance, is collected under the Sustainability Omnibus package.

Stop-the-Clock Questions

Five questions recur about the postponement.

Is the stop-the-clock directive still in force after the content amendment?

Yes: Directive (EU) 2025/794 has been in force since 17 April 2025, and its amendment is part of the consolidated CSRD text of 18 March 2026. In the consolidated CSRD on EUR-Lex, its 2027 date applies under point (b) with the criteria of Directive (EU) 2026/470; its 2028 date fell with point (c).

Did the postponement change anything for first-wave reporters?

No: the first wave kept financial years starting on or after 1 January 2024. Its relief for financial years 2025 and 2026 comes from Delegated Regulation (EU) 2025/1416, and the end of its period after financial year 2026 comes from Directive (EU) 2026/470.

Did listed SMEs get a two-year delay?

Yes, from financial years starting on or after 1 January 2026 to 1 January 2028, but Directive (EU) 2026/470 then deleted that point, and listed SMEs are no longer in the mandatory CSRD scope. A listed SME may still report on its sustainability voluntarily.

Does a postponed company report from financial year 2027?

Yes, when it exceeds both EUR 450 million net turnover and an average of 1,000 employees, individually or on a consolidated basis, for financial years starting on or after 1 January 2027. Its first report then follows in 2028 for a calendar financial year.

Does the directive apply directly to companies?

No: like the CSRD, Directive (EU) 2025/794 is addressed to Member States, which had to transpose it by 31 December 2025. Companies follow the national law that applies to them, and that law must also take over Directive (EU) 2026/470 by 19 March 2027.