The omnibus stop: "stop the clock" comes into effect

16 April 2025

The "stop the clock" portion of the Omnibus Package has now been approved by EU co-legislators and was published in the Official Journal of the European Union on 16 April 2025, making this effective.

By way of reminder, the so-called 'stop-the clock' proposal provides delays to the coming into force of CSRD and CS3D for several categories of users (see below and read our detailed analysis of the Omnibus Package here).

The proposal was split out and fast-tracked to give companies and EU regulators some breathing space and certainty while the main substantive amendments to CSRD and CS3D contained in "Proposal 2" of the Omnibus Package are negotiated.

Member States will have until 31 December 2025 to transpose the text into their national laws. Speed of transposition will likely vary (as seen by the varied approaches to transposing CSRD). Crucially, where CSRD has been transposed into national law (18 EU and EEA Member States), the amendments to delay CSRD reporting won't apply to companies until they are enacted by the national government of their relevant jurisdiction.

Member States that have not yet transposed CSRD into national law - including Germany, Netherlands and Spain (and therefore CSRD does not apply in such jurisdiction), may consider waiting with the transposition of Proposal 1 until an agreement is reached on Proposal 2.

What next on the Omnibus' journey forward?

Now that the 'stop-the clock' has been finalised, legislators will focus their efforts on the substantive amendments CSRD and CS3D. While the expected timelines are less clear, we know so far that:

The Polish EU Council is treating the Omnibus Package as a priority and has announced plans to disclose a first draft of the negotiating text by the end of April and a second draft by mid-May.
Conversations on the proposal will start within the European Parliament this month, with the first draft negotiating text expected to be presented by JURI committee by the end of June. Other committees are to provide their opinions by the end of August, with a vote scheduled in October 2025.
Separately, the EU Commission has instructed EFRAG, the standard setting body that has developed the European Sustainability Reporting Standards ("ESRS") complementing CSRD, to provide technical advice on revisions to the ESRS with final technical opinions due by 31 October 2025. In response to this, EFRAG published an ESRS Revision Workplan on 11 April 2025, confirming that it will consult on the revisions during Spring 2025 (consultation open until 6 May 2025) with the aim to publish Exposure Drafts by the end of July 2025.

Reminder: How does the 'stop-the-clock' impact the timelines for CSRD and CS3D?

	Original timeline for application	Updated timeline for application
Corporate Sustainability Reporting Directive (CSRD)	CSRD originally applied:	CSRD will now apply:
	FY24 (reporting in 2025) for large listed companies ("Wave 1");	Unchanged: FY24 (reporting in 2025) for large listed companies ("Wave 1");
	FY25 (reporting in 2026) for other large companies or parents of large groups ("Wave 2");	FY27 (reporting in 2028) for other large companies or parents of large groups ("Wave 2");
	FY26 (reporting in 2027) for listed SMEs ("Wave 3"); and	FY28 (reporting in 2029) for listed SMEs ("Wave 3"); and
	FY28 (reporting in 2029) for non-EU third country parents of large EU companies, which come in scope through the extraterritorial reach of CSRD.	Unchanged: FY28 (reporting in 2029) for non-EU third country parents of large EU companies, which come in scope through the extraterritorial reach of CSRD.
Corporate Sustainability Due Diligence Directive (CS3D)	CS3D originally applied:	CS3D will now apply:
	From July 2027, for EU-incorporated companies with an average of more than 5000 employees, and a net worldwide turnover of > €1,500 million; and non-EU-incorporated companies which generated a net turnover of > €1,500 million in the EU;	From July 2028, for EU-incorporated companies with an average of more than 5000 employees, and a net worldwide turnover of > €1,500 million; and non-EU-incorporated companies which generated a net turnover of > €1,500 million in the EU;
	From July 2028, for EU-incorporated companies with an average of more than 3000 employees, and a net worldwide turnover of > €900 million; and non-EU-incorporated companies which generated a net turnover of > €900 million in the EU; and	Unchanged: From July 2028, for EU-incorporated companies with an average of more than 3000 employees, and a net worldwide turnover of > €900 million; and non-EU-incorporated companies which generated a net turnover of > €900 million in the EU; and
	From July 2029 for all other EU-incorporated companies with an average of more than 1000 employees, and a net worldwide turnover of > €450 million; and all other non-EU incorporated companies which generated a net turnover of > €450 million in the EU.	Unchanged: July 2029 for all other EU-incorporated companies with an average of more than 1000 employees, and a net worldwide turnover of > €450 million; and all other non-EU incorporated companies which generated a net turnover of > €450 million in the EU.

Article tags

EU Council Omnibus CSRD cs3d

Related categories

Europe Sustainability ESG

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