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FAQCSRDEU

CSRD omnibus stop-the-clock status What is enacted and what remains unfinished

Directive (EU) 2025/794 enacted the Stop-the-Clock delay; Directive (EU) 2026/470 later enacted the broader CSRD scope amendment.

This FAQ separates those legal changes from national transposition, the revised ESRS adopted by the Commission on 3 July 2026 but still subject to scrutiny, and other implementation steps.

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Author
Sorena AI
Published
May 9, 2026
Updated
Jul 25, 2026
Questions
4

Structured answer sets in this page tree.

Primary sources
8

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 25, 2026
Overview

The Corporate Sustainability Reporting Directive (CSRD) now has two enacted timing and scope amendments. The , Directive (EU) 2025/794, postponed the original wave-two and wave-three application dates by two years. later narrowed the main scope from financial years beginning in 2027. The Commission adopted (ESRS) on 3 July 2026, but they remain subject to Parliament and Council scrutiny and are not applicable until the legal adoption process is complete. National transposition, exemptions, and entity facts still require separate checks.

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4 of 4 questions
Question 1

What is the current CSRD stop-the-clock status?

Directive (EU) 2025/794 is the . It postponed by two years the application dates for undertakings that were originally due to report first for financial years 2025 or 2026. Directive (EU) 2024/1306 is a different act concerning deadlines for certain sustainability reporting standards.

is the later enacted Omnibus amendment. For financial years beginning in 2027, its main Articles 19a and 29a scope applies when an undertaking or parent group exceeds EUR 450 million net turnover and has more than 1,000 employees on average during the financial year.

  • Use Directive (EU) 2025/794 to explain the two-year delay of the original later waves.
  • Use for the amended scope from financial years beginning in 2027.
  • Keep national transposition, exemptions, reporting year, and ESRS delegated-act status next to every entity conclusion.
Citations
Recommended next step

Separate each enacted CSRD change from unfinished implementation

Maintain a cited CSRD status note that distinguishes the original waves, Stop-the-Clock delay, amended 2027 scope, national transposition, and draft standards.

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Review CSRD scope, source evidence, and open status questions with Sorena.

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Question 2

What did the stop-the-clock directive change, and what did it not change?

Directive (EU) 2025/794 changed timing for the affected later reporting waves. It did not itself enact the wider scope reduction; that was later enacted through .

also permits Member States to exempt an undertaking or issuer that does not exceed either EUR 450 million net turnover or an average of 1,000 employees, on a consolidated basis where applicable, from specified amended requirements for financial years beginning between 1 January 2025 and 31 December 2026. This is a national option, not an automatic EU-wide exemption.

Reporting teams therefore need separate fields for original wave, Stop-the-Clock effect, any national 2025-2026 transition derogation, current 2027 scope, national transposition, and standards status. Combining them into a single 'CSRD delayed' label can produce the wrong entity conclusion.

  • Enacted timing change: Directive (EU) 2025/794 for companies originally first due for financial years 2025 or 2026.
  • Enacted scope change: , applying the amended main scope from financial years beginning in 2027.
  • Optional national transition: check whether the relevant Member State used the derogation for financial years beginning in 2025 or 2026.
  • Still entity-specific: national transposition, group perimeter, turnover, employees, exemptions, and issuer or sector rules.
Citations
Question 3

How should a company update its CSRD plan now?

Start with the entity's original CSRD wave and reporting year. If it was previously first required to report for financial years 2025 or 2026, record the Directive (EU) 2025/794 postponement as history.

Then apply for financial years beginning in 2027. Record whether the undertaking or parent group exceeds both amended thresholds, which exemption is relied on, and which national measure implements the directive. Member States must transpose its CSRD amendments by 19 March 2027. Keep the in a pending-applicability field until the scrutiny period, Official Journal publication, entry into force, and application provisions are confirmed.

  • Identify whether the entity is a wave two or wave three company in the existing CSRD plan.
  • Record Directive (EU) 2025/794 as the source for the Stop-the-Clock timing change.
  • Record as the source for the current amended scope and related value-chain, assurance, and third-country changes.
  • Continue maintaining materiality, ESRS data, assurance-readiness, and governance evidence where the entity remains in scope or status is uncertain.
Citations
Question 4

What evidence should support a stop-the-clock status note?

Keep the evidence narrow and source-specific. The record should show the entity's original CSRD wave, whether the applied, the threshold result, and which implementation items remain pending.

Avoid generic statements such as "CSRD has been delayed" or "CSRD no longer applies" without naming the reporting year, legal source, thresholds, exemption, and national-law position.

  • Entity and group boundary used for the CSRD wave assessment.
  • Original first reporting year classification from the company's pre-stop-the-clock CSRD plan.
  • Source citations for Directives (EU) 2025/794 and 2026/470 and the applicable national measure.
  • Separate tracker entries for the revised ESRS delegated act, the voluntary standard, assurance standards, and other unfinished implementation measures.
  • Review owner and trigger for updating the note when a later enacted EU source changes the status.
Citations
Primary sources

References and citations

Commission adopts revised sustainability reporting standards
finance.ec.europa.eu
Referenced sections
  • Official status source for the Commission's 3 July 2026 adoption of revised ESRS and the voluntary standard, and the remaining Parliament and Council scrutiny.
"The revised ESRS and the voluntary reporting standard will now be submitted to the European Parliament and the Council for scrutiny."
Commission Delegated Regulation (EU) 2023/2772 on ESRS
data.europa.eu
Referenced sections
  • Primary ESRS source showing that the reporting standards remain the baseline for undertakings required to report under the CSRD framework.
"as regards sustainability reporting standards"
Directive (EU) 2026/470 amending CSRD-related requirements
eur-lex.europa.eu
Referenced sections
  • Current enacted source separating the amended scope from the earlier timing postponement and authorising the optional Member State transition derogation for specified requirements in financial years beginning in 2025 or 2026.
"For financial years starting on or after 1 January 2027"
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