Advisory

Stop the Clock Vote

Isabel Derison
By:
green clock
Contents

On February 26, 2025, the European Commission (EC) issued a press release and a new package of proposals (Omnibus) to change some of the key pillars of the European Green Deal. The Omnibus Proposal was created based on the Draghi “EU competitiveness report” in order to promote the prosperity of the European economy. The Commission proposed two “Omnibus packages” to simplify existing legislation in the areas of sustainability and investment, respectively.

Today, April 1, 2025, the European Parliament voted on the “Stop the Clock” directive of the Omnibus I proposal. This directive proposed a two-year delay for the Corporate Sustainability Reporting Directive (CSRD) for entities that would normally be required to report from 2026 or 2027. 

Want more information on the Omnibus proposal packages? Also read our previous article.

What did the European Parlement decide? 

Member State representatives (Coreper) had already approved the Council's position (“negotiating mandate”) on one of the Commission's proposals to simplify EU rules to boost EU competitiveness on the 26th of March.

The EU has officially approved the "Stop the Clock" directive, requiring member states to complete transposition by December 31, 2025. Furthermore, the proposal postpones sustainability reporting obligations for companies in waves 2 and 3 until 2028. It is important to emphasize that this suspension does not apply to large-listed companies and other companies in “Wave 1”, which must report as of this year. 

Overview revised timeline CSRD

Wave 1 entities

Entities subject to NFRD  
Required to publish CSRD report in 2025, over FY2024  

Wave 2 entities

Large undertakings with more than 1000* employees 
AND
more than € 25m total assets
OR
more than € 50m annual revenue ​  
Required to publish CSRD report in 2028, over FY2027  

Wave 3 entities

Listed SME’s  
Required to publish CSRD report in 2029, over FY2028  

*If Omnibus II is confirmed the scope will broaden to 1000 employees. If not, the scope remains 250 employees. 

 

What is the next step? What is certain in these uncertain times?

While the delay gives companies in Waves 2 and 3 more time to prepare, sustainability remains a strategic priority. We must continue to build transparency and accountability regardless of the pace of regulation. We are happy to share some of our recommendations to strengthen resilience and maintain focus. 

Our recommendations 

  1. Prioritize a dual materiality analysis (DMA). This analysis will remain an essential even under the Omnibus proposal. Effective sustainability information for strategic planning, reporting, and decision-making emphasizes the key risks and opportunities related to sustainability that impact the organization externally, as well as the topics where the organization exerts the most significant influence on people and the environment. Performing a dual materiality assessment will contribute to resilience and facilitate to focus on the most important topics. 

  2. Map the value chain. Mapping out the company’s value chain remains applicable under the Omnibus proposal. Engaging with stakeholders and value chain partners provides useful and relevant information that contributes to better risk management and insight into new strategic opportunities.

  3. Track and measure ambitions, goals and actions. The more defined sustainability policies and measurable objectives a company sets, the clearer the remaining tasks become. This clarity allows for the efficient allocation of time and resources, particularly when mandatory reporting demands less focus. 

  4. Measure to manage. Maintain a consistent focus on gathering and tracking relevant ESG data. Insights into critical areas such as energy usage, diversity, employee engagement, and resource attributes are essential for informed decision-making. Understanding dependencies is crucial, as effective management cannot be achieved without reliable data.

  5. Reporting helps internally and externally. Reporting serves as a valuable tool for demonstrating progress and sharing essential business information with stakeholders, just like communication about financial results. . With the initial CSRD reports now released, it is widely anticipated that CSRD will continue to be regarded as the benchmark for excellence.

Develop a future-proof sustainability strategy 

Even with delay, it is crucial to be prepared. The CSRD framework remains not only a compliance tool, but is a guideline for resilience and long-term corporate responsibility. Grant Thornton remains committed to guiding companies through this transition.

Need guidance?

Our specialists are ready to help. Contact us to discuss your next steps!