EU carbon rules / Regulations / CSRD/CSDDD Deadline Postponement (stop-the-clock)
In force Directive Sustainability reporting & due diligence
CSRD/CSDDD Deadline Postponement (stop-the-clock)
Postpones deadlines only: CSRD second and third reporting waves each by two years, CSDDD transposition by one year (subsequently amended by 2026/470)
- Reference
- Directive (EU) 2025/794
- Key date
- 2025-04-17 entry into force
- Applies to
- CSRD second/third-wave reporting companies and companies in the first CSDDD scope (via Member State transposition)
01
Who the regulation applies to
This regulation applies to:
- This Directive is a ‘stop-the-clock’ postponement amendment: it creates no new substantive obligations and only postpones the application dates of certain provisions of Directive (EU) 2022/2464 (CSRD) and Directive (EU) 2024/1760 (CSDDD)
- Second wave of CSRD reporting undertakings (other large undertakings and large parent undertakings): reporting obligations postponed by two years, now applying to financial years beginning on or after 1 January 2027
- Third wave of CSRD reporting undertakings (listed SMEs, small non-complex credit institutions, captive insurance and reinsurance undertakings, etc.): reporting obligations postponed by two years, now applying to financial years beginning on or after 1 January 2028
- Companies in scope of the CSDDD: those with more than 3 000 average employees during the financial year and global net turnover exceeding EUR 900 000 000 in the preceding financial year apply from 26 July 2028; other companies apply from 26 July 2029; the reporting obligation under Article 16 applies from financial years 2029 and 2030 respectively
- (Addressees) Member States: must transpose this Directive into national law by 31 December 2025; the transposition deadline for the CSDDD is extended from 26 July 2026 to 26 July 2027
Directive (EU) 2025/794 is the ‘stop-the-clock’ postponement directive and changes dates only, not substantive obligations. The dates listed above were subsequently adjusted again by Directive (EU) 2026/470 (Omnibus I): the CSDDD thresholds were raised to more than 5 000 average employees and global net turnover exceeding EUR 1 500 000 000, the transposition deadline was changed to 26 July 2028, and the obligations apply uniformly from 26 July 2029 (Article 16 from financial year 2030); listed SMEs were removed from the scope of the CSRD (see omnibus-1).
The following provisions define its scope:
Article 1 — amended Article 5(2) of Directive (EU) 2022/2464 (CSRD)
Article 5(2) of Directive (EU) 2022/2464 is amended as follows:
(a) the first subparagraph is amended as follows:
(i) in point (b), the introductory wording is replaced by the following:
‘for financial years starting on or after 1 January 2027:’;
(ii) in point (c), the introductory wording is replaced by the following:
‘for financial years starting on or after 1 January 2028:’;
(b) the third subparagraph is amended as follows:
(i) in point (b), the introductory wording is replaced by the following:
‘for financial years starting on or after 1 January 2027:’;
(ii) in point (c), the introductory wording is replaced by the following:
‘for financial years starting on or after 1 January 2028:’.
Article 2 — replaced Article 37(1) of Directive (EU) 2024/1760 (CSDDD)
In Article 37(1) of Directive (EU) 2024/1760, the first and second subparagraphs are replaced by the following:
‘1. Member States shall adopt and publish, by 26 July 2027, the laws, regulations and administrative provisions necessary to comply with this Directive. They shall forthwith communicate the text of those measures to the Commission.
They shall apply those measures:
(a) from 26 July 2028 as regards companies referred to in Article 2(1), points (a) and (b), which are formed in accordance with the legislation of the Member State and that had more than 3 000 employees on average and generated a net worldwide turnover of more than EUR 900 000 000 in the last financial year preceding 26 July 2028 for which annual financial statements have been or should have been adopted, with the exception of the measures necessary to comply with Article 16, which Member States shall apply to those companies for financial years starting on or after 1 January 2029;
(b) from 26 July 2028 as regards companies referred to in Article 2(2), points (a) and (b), which are formed in accordance with the legislation of a third country and that generated a net turnover of more than EUR 900 000 000 in the Union, in the financial year preceding the last financial year preceding 26 July 2028, with the exception of the measures necessary to comply with Article 16, which Member States shall apply to those companies for financial years starting on or after 1 January 2029;
(c) from 26 July 2029 as regards all other companies referred to in Article 2(1), points (a) and (b), and Article 2(2), points (a) and (b), and companies referred to in Article 2(1), point (c), and Article 2(2), point (c), with the exception of the measures necessary to comply with Article 16, which Member States shall apply to those companies for financial years starting on or after 1 January 2030.’.
Article 3 — Transposition
1. Member States shall bring into force the laws, regulations and administrative provisions necessary to comply with this Directive by 31 December 2025. They shall immediately inform the Commission thereof.
When Member States adopt those measures, they shall contain a reference to this Directive or be accompanied by such a reference on the occasion of their official publication. The methods of making such reference shall be laid down by Member States.
2. Member States shall communicate to the Commission the text of the main measures of national law which they adopt in the field covered by this Directive.
Article 4 — Entry into force
This Directive shall enter into force on the day following that of its publication in the Official Journal of the European Union.
Article 5 — Addressees
This Directive is addressed to the Member States.
03
Key provisions
Article 1 — amended Article 5(2) of Directive (EU) 2022/2464 (CSRD)
Article 5(2) of Directive (EU) 2022/2464 is amended as follows:
(a) the first subparagraph is amended as follows:
(i) in point (b), the introductory wording is replaced by the following:
‘for financial years starting on or after 1 January 2027:’;
(ii) in point (c), the introductory wording is replaced by the following:
‘for financial years starting on or after 1 January 2028:’;
(b) the third subparagraph is amended as follows:
(i) in point (b), the introductory wording is replaced by the following:
‘for financial years starting on or after 1 January 2027:’;
(ii) in point (c), the introductory wording is replaced by the following:
‘for financial years starting on or after 1 January 2028:’.
Article 2 — replaced Article 37(1) of Directive (EU) 2024/1760 (CSDDD)
In Article 37(1) of Directive (EU) 2024/1760, the first and second subparagraphs are replaced by the following:
‘1. Member States shall adopt and publish, by 26 July 2027, the laws, regulations and administrative provisions necessary to comply with this Directive. They shall forthwith communicate the text of those measures to the Commission.
They shall apply those measures:
(a) from 26 July 2028 as regards companies referred to in Article 2(1), points (a) and (b), which are formed in accordance with the legislation of the Member State and that had more than 3 000 employees on average and generated a net worldwide turnover of more than EUR 900 000 000 in the last financial year preceding 26 July 2028 for which annual financial statements have been or should have been adopted, with the exception of the measures necessary to comply with Article 16, which Member States shall apply to those companies for financial years starting on or after 1 January 2029;
(b) from 26 July 2028 as regards companies referred to in Article 2(2), points (a) and (b), which are formed in accordance with the legislation of a third country and that generated a net turnover of more than EUR 900 000 000 in the Union, in the financial year preceding the last financial year preceding 26 July 2028, with the exception of the measures necessary to comply with Article 16, which Member States shall apply to those companies for financial years starting on or after 1 January 2029;
(c) from 26 July 2029 as regards all other companies referred to in Article 2(1), points (a) and (b), and Article 2(2), points (a) and (b), and companies referred to in Article 2(1), point (c), and Article 2(2), point (c), with the exception of the measures necessary to comply with Article 16, which Member States shall apply to those companies for financial years starting on or after 1 January 2030.’.