- Directive (EU) 2025/794 entered into force on 17 April and delays by two years the sustainability reporting of many companies.
- It also postpones by one year the transposition of due diligence rules and delays their application to the companies concerned.
- The substantive obligations do not disappear: what changes is the timetable, and negotiation on the content remains open.
On 16 April 2025 Directive (EU) 2025/794 was published in the Official Journal of the European Union, approved by the Council on 14 April, and it entered into force the following day, 17 April. It is the so-called “stop-the-clock” directive, part of the omnibus simplification package the Commission presented on 26 February. It delays the deadlines of the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD).
The stated aim is to give companies and legislators time while a reform of substance is negotiated, so that companies that had not yet started do not invest in processes that may change. For those already preparing, the news does not erase the work done, but it does reorder priorities and the timetable for the next two years, and it is worth understanding exactly what is postponed and what is not.
What is postponed in sustainability reporting
Under the CSRD, large companies that had not yet started reporting and parent companies of large groups will have to do so for financial years starting on or after 1 January 2027, two years later than planned. Listed small and medium-sized companies, excluding micro-enterprises and certain small and non-complex financial institutions, will do so for financial years starting on or after 1 January 2028.
Companies in the first wave, that is, those already required to report on 2024, are not affected and keep their obligations. That difference matters: the large groups already reporting will keep asking their suppliers for sustainability data, even if the suppliers’ own legal obligation is postponed. In practice, many small businesses will keep receiving questionnaires from their customers.
What changes in due diligence
The CSDDD requires large companies to identify and prevent the adverse effects of their activity and value chain on human rights and the environment. The new directive extends the transposition deadline by a year, to 26 July 2027, and delays application to the largest companies, those with more than 3,000 employees and EUR 900 million of net worldwide turnover, until 26 July 2028.
For the other companies in scope, application moves to 26 July 2029, and the climate transition plan measures will apply from financial years starting on or after 1 January 2029 or 2030, depending on the group. States that had already transposed the CSDDD must adjust their dates. This directive must be incorporated into national law by 31 December 2025, and it was approved through an accelerated procedure precisely to prevent companies from reaching obligations whose content was going to change.
What to review
A postponement is not a waiver. Companies can use the extra time to identify which sustainability data they already collect, who is responsible for it and what systems would be needed, without rushing into investments that depend on the final content of the reform, still under negotiation. Maintaining a reasonable level of preparation avoids improvising when the timetable becomes firm.
It is also worth reviewing contracts with large customers and financial institutions, which often include environmental and social information or compliance clauses, and following transposition in Spain, where each State must bring the directive into domestic law. This information is general; consult your adviser on how it affects your company or group.
In corporate sustainability, gaining time only helps if it is used to prepare better.
This article is general information. It is not legal, tax or investment advice, and it does not take anyone’s particular circumstances into account.
