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25 March 2026

CSRD, Stop-the-clock And Amendment Directive Transposition Tracker

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Herbert Smith Freehills Kramer LLP

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The Corporate Sustainability Reporting Directive (CSRD) updates the EU’s sustainability reporting framework, expanding the scope of the Non-Financial Reporting Directive (NFRD).
United Kingdom Corporate/Commercial Law
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The Corporate Sustainability Reporting Directive (CSRD) updates the EU’s sustainability reporting framework, expanding the scope of the Non-Financial Reporting Directive (NFRD). It requires more companies to disclose detailed sustainability information through the European Sustainability Reporting Standards (ESRS). 

As part of the EU's Omnibus Package (see our detailed briefing here), three key measures which introduce amendments to the CSRD were adopted: 

  • the Stop-the-clock Directive, which postpones the CSRD reporting deadlines for certain companies;
  • the Quick Fix Regulation, which deferred certain of the reporting requirements for Wave 1 companies; and
  • the Amendment Directive, which includes substantive amendments to the CSRD regarding scope, limiting trickle down effects for smaller companies and tasking the European Commission to revise the ESRS. 

The deadline for transposing CSRD into national law was 6 July 2024, with flexibility for Member States to introduce additional requirements ("goldplating"). The changes introduced by the Stop the Clock Directive had to be implemented by Member States by 31 December 2025 and those introduced by the Amendment Directive in relation to the CSRD need to be implemented by Member States by 19 March 2027.

This briefing provides an update on the current status of CSRD implementation across EU member states, highlights any additional requirements introduced at national level, and tracks the transposition of the Stop-the-clock Directive and the Amendment Directive.

Download our CSRD Transposition Tracker

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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