Following an accelerated legislative process, the 'stop-the-clock' measures set out in the European Commission's Omnibus proposals for reform to sustainability reporting requirements (amongst other matters) have been enacted.
The new measures are set out in Directive (EU) 2025/794, which was published in the Official Journal of the European Union on 16 April 2025 (here).
Very briefly (for a more detailed discussion see our earlier briefing here), the effect of the new Directive is to postpone:
- by two years the entry into application of the Corporate Sustainability Reporting Directive's (CSRD)1 requirements for (i) large companies that have not yet started reporting, and (ii) listed SMEs; and
- by one year the transposition deadline and the first phase of the application (covering the largest companies) of the Corporate Sustainability Due Diligence Directive.2
The 'stop-the-clock' Directive came into force on 17 April 2025 and Member States are required to transpose it into national law by 31 December 2025. It seems likely that Ireland will do so relatively swiftly, as the Minister for Enterprise, Tourism and Employment (Peter Burke) had already indicated in an earlier press release that he will be "...focussed on quickly implementing the EU's 'Stop the Clock' proposal...".
The underlying purpose of the 'stop-the-clock' measures is to allow time for negotiation on the more substantive aspects of the European Commission's Omnibus proposals, which are aimed at significantly simplifying and alleviating the regulatory overheads associated with the EU's sustainability policy. For an outline and discussion of those proposed changes (with a focus on CSRD) see our earlier briefing here.
For many companies that have been preparing for CSRD, enactment of the 'stop-the-clock' Directive provides a helpful opportunity to pause that work, particularly if they may fall outside the scope of the revised regulatory regime that has been proposed by the European Commission. We can, however, expect those proposals to be vigorously debated and negotiated at an EU level and so it will be important to monitor the legislative process.
Footnotes
1. Directive 2022/2464/EU.
2. Directive 2024/1760/EU.
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