Stop-the-Clock Directive: Where Things Stand In Kinstellar Jurisdictions

Transposed?

Yes / No / In progress

Comments

e.g. information about latest developments, timing updates, goldplating

Neither the CSRD nor the CS3D has been implemented in Austria to date.

However, a draft for the national implementation of the CSRD in Austria is currently awaiting approval in the national parliament (see here). This draft dates from 27 March 2025, though, and it is not clear when or if it will be adopted.

According to the draft, there will be no "goldplating". Additionally, it should be noted that the draft still refers to the old CSRD without the updates of the "Stop the Clock" Directive.

On 19 February 2025 the Bulgarian Parliament adopted an amendment to the Accountancy Act by which the sustainability reporting, as required under the CSRD, has been delayed by one year. After these amendments, large public-interest companies that have more than 500 employees will now have to prepare their first sustainability reports for the year 2025 instead of 2024. Other large enterprises will follow with their first reports covering 2026 instead of 2025 and the last group covering small and medium enterprises will prepare their first sustainability reports covering 2027 instead of 2026. The amendments to the Accountancy Act have been promulgated in the Bulgarian State Gazette and entered into force on 28 February 2025.

Directive (EU) 2025/794 of the European Parliament and of the Council of 14 April 2025 amending Directives (EU) 2022/2464 and (EU) 2024/1760 as regards the dates from which Member States are to apply certain corporate sustainability reporting and due diligence requirements (the ""Stop the Clock" Directive") was adopted after the amendments to the Accountancy Act. With the "Stop the Clock" Directive, the reporting requirements are further delayed. At present, there have been no legislative proposals by the Bulgarian authorities to implement the "Stop the Clock" Directive.

With its resolution № 541 dated 11 August 2025, the Council of Ministers has approved its legislative programme for the second half of 2025, which includes implementation of the "Stop the Clock" Directive, the process for which is currently planned to begin in November 2025

CSRD

As the Czech transposition of the CSRD was divided in two phases, the second phase relating to the second and subsequent waves was being debated when the Stop-the-Clock Directive (Directive (EU) 2025/794) was adopted. This directive postponed key deadlines under both the CSRD and the CSDDD.

The Czech draft legislation was subsequently revised to reflect the changes introduced by the Stop-theClock Directive and the amendments proposed by the ESG Omnibus proposals. Notably, the applicability threshold for companies was raised from 500 to 1,000 employees, and the phased approach was removed. This impacted the applicability threshold for additional companies in anticipation of forthcoming changes to the EU-level ESG Omnibus. It also excluded further waves of companies from the legislative text. This effectively implements the 'stop-the-clock' measure of postponing the extension of CSRD obligations.

The revised legislation was approved by the Czech Parliament on 23 July 2025 and signed by the President on 21 August 2025, thus completing the legislative process. It is scheduled to be published and enter into force in the first half of September 2025.

CSDDD

As the Czech Republic has not yet transposed the CSDDD into national law, the Ministry of Justice, which is responsible for preparing draft legislation, has effectively paused work on transposing the legislation. According to the Ministry, further national legislative drafting would be premature until the revised EU framework is finalised.

Accounting Act

As of 20 June 2025, the Accounting Act has been amended by Act LIV of 2025, extending the deadlines for applying the sustainability reporting requirements as follows:

• From the 2027 financial year, the sustainability reporting requirements shall apply to:
  1. undertakings required to prepare a sustainability report (in Hungarian: fenntarthatósági jelentés) under the Accounting Act,
  2. parent undertakings preparing consolidated financial statements that are required to prepare a sustainability report under the Accounting Act.
• From the 2028 financial year, the sustainability reporting requirements shall apply to:
  1. non-micro undertakings whose transferable securities are admitted to trading on a regulated market in any EEA Member State,
  2. small and non-complex institutions as defined in Article 4(1)(145) of Regulation (EU) 575/2013 that are required to prepare a sustainability report under the Accounting Act,
  3. closed insurance undertakings as defined in Article 13(2) and closed reinsurance undertakings as defined in Article 13(5) of Directive 2009/138/EC that are required to prepare a sustainability report under the Accounting Act.

ESG Act

The ESG Act has been amended by Act LI of 2025 with the effect of 20 June 2025, introducing the following significant changes to the scope and ESG reporting obligations:

• Small and medium-sized undertakings of public interest are no longer required to prepare ESG reports.
• ESG reporting applies only if the undertaking operates in a high-impact sector (e.g. pharmaceuticals, energy, finance, manufacturing) and in two consecutive years exceeds both:
  1. HUF 90,000 million annual net revenue, and
  2. 500 employees on average.
• Large undertakings subject to ESG reporting are exempt from filing ESG reports and certificates with SZTFH for financial years starting in 2024–2026.
• Until 30 June 2027, micro and small undertakings cannot be required (or voluntarily commit) to provide ESG data.
• Medium-sized undertakings cannot contractually commit to ESG data provision until the same date.

Government Decree No. 276/2025. (VIII.21.)

• The Government has institutionalized transparent sanctioning rules in respect of violations of certain ESG obligations (such as the unauthorised pursuit of ESG intermediary activities, the obligation to make data available to the Authority (defined below), and the obligation to notify changes in data). These rules are proportionate to the gravity of the infringement and consider the economic circumstances of the parties concerned.
• The Decree designates the Szabályozott Tevékenységek Felügyeleti Hatósága (Supervisory Authority for Regulated Activities) (the "Authority") as the body competent to impose fines.
• In relation to specific infringements, the Authority may impose fines of up to fifty million forints, as defined in the Annex to the Decree. Penalties relating to the failure to submit the ESG report shall only become effective as of January 2026.
• The Decree shall enter into force on 6 September 2025.

Key Amendments to Certain ESG-Related Decrees

• Government Decree No. 244/2024. (VIII.8.)
  • The electronic register maintained by the Business Development Agency on accredited institutions providing training for ESG advisors shall henceforth be regulated by Government Decree rather than by a ministerial decree of the Nemzetgazdasági Minisztérium (Ministry for National Economy).
• Decree No. 30/2024. (VIII.8.) of the Ministry for National Economy (NGM)
  • The detailed rules governing training program fees and examination fees have been amended.
• Decree No. 29/2024. (8 August) of the Ministry for National Economy (NGM)
  • A prerequisite for accreditation as an ESG advisor shall now include the acquisition of the ESG Advisor qualification within the framework of training provided by an accredited ESG advisor training institution.
• Decree No. 11/2024. (8 August) of the Supervisory Authority for Regulated Activities (SZTFH)
  • Detailed provisions concerning the procedural rules of accreditation as an ESG advisor have been amended.

Order no. 85/2024 on sustainability reporting has been amended through this new Order no. 1421/2025. The deadlines once scheduled for 1 January 2025 are now moved to 1 January 2027, and those planned for 1 January 2026 have been pushed back to 1 January 2028.

As a result, companies will first be obliged to report on the 2027 financial year (with submissions due in 2028) instead of 2025, and then on the 2028 financial year (due in 2029) rather than 2026. The postponement of reporting obligations did not affect the entities whose sustainability reporting obligations commenced in the financial year beginning on January 1, 2024 (those with more than 500 employees).

On 10 June 2025, the Slovak Parliament approved the amendments to the Securities Act and other acts (the Amendment), including amendments to the Accounting Act, which implemented the CSRD into Slovak law with effect from 1 June 2024.

The Amendment implemented the "Stop the Clock Directive", which postponed ESG reporting obligations by two years i. e. from 2026 (for FYE2025) to 2028 (for FYE2027) and from 2027 (for FYE2026) to 2029 (for FYE2028).

The postponement of reporting obligations also affected the largest companies (those with more than 500 employees in the two immediately preceding accounting periods), i. e. postponement from 2025 (for FYE2024) to the accounting period beginning no earlier than 1 January 2025, but no later than during 2026.

The postponement provisions are effective as of 10 July 2025.

The Amendment also stipulates that individual and consolidated financial statements, auditors' reports, annual statements, sustainability reports (in Slovak: Správy o udrľateµnosti) and assurance reports (in Slovak: Správy o uistení v oblasti vykazovania informácií o udrľateµnosti) on sustainability reporting will have to be reported to the specialized portal operated by the Financial Directorate of the Slovak Republic. This obligation applies to the mandatory reporting of documents after 9 January 2028, and in the case of voluntary reporting, after 9 January 2030.