Stop-the-Clock — Directive (EU) 2025/794 deferring CSRD/CSDDD application dates
Directive (EU) 2025/794 deferring CSRD and CSDDD application dates for entities with first reporting in 2025-2026. In force from 17 Apr 2025. It does NOT amend the ESRS, only the dates.
Context
The Stop-the-Clock Directive is the first piece of the CSRD/CSDDD simplification package adopted by the Union: it defers application dates without altering the substantive content of the rules. It buys time for entities bound in waves 2 and 3 while the Omnibus (Directive (EU) 2026/470) is processed and while EFRAG reviews the ESRS.
Regulatory origin
Directive (EU) 2025/794 of the European Parliament and of the Council, published in the Official Journal of the European Union in the first four-month period of 2025. Canonical ELI `http://data.europa.eu/eli/dir/2025/794/oj`. Entry into force on 17 April 2025 according to recital 3 of Delegated Regulation (EU) 2025/1416 (QuickFix).
What the Stop-the-Clock defers
Defers the first-application dates of the CSRD for wave 2 entities (large non-listed companies) and wave 3 (listed SMEs).
Defers the transposition deadline of parts of the CSDDD (Directive (EU) 2024/1760).
Functions as a regulatory bridge until the definitive adoption of the 2026 Omnibus (Directive (EU) 2026/470) which recalibrates the subjective scope.
It does NOT amend ESRS Set 1 (Delegated Regulation (EU) 2023/2772): the technical review runs on separate tracks.
Timeline
Omnibus Simplification Package
The Commission presents COM(2025) 81 final as a legislative simplification proposal.
Stop-the-Clock enters into force
Directive (EU) 2025/794 published and in force.
ESRS QuickFix
Delegated Regulation (EU) 2025/1416 amends Annex I Appendix C of ESRS 1 (phase-in for entities up to 750 employees).
Omnibus 2026 published
Directive (EU) 2026/470 recalibrates the CSRD/CSDDD subjective scope.
Applied case
A large non-listed textile company in CSRD wave 2 reviews its reporting calendar following the entry into force of the Stop-the-Clock.
Before (original CSRD): first application to the 2025 financial year with a report published in 2026 including limited assurance.
After Stop-the-Clock (Dir. EU 2025/794 in force 17 Apr 2025): the date is deferred, gaining headroom to prepare methodology, data and an assurance provider.
After the 2026 Omnibus (Dir. EU 2026/470 recital 7): if the company does not exceed >1,000 employees AND >EUR 450,000,000, it falls directly OUTSIDE the mandatory scope for financial years beginning on or after 1 Jan 2027.
Decision: use the time gained by the Stop-the-Clock to validate size post-Omnibus, decide whether to report voluntarily under the VSME (Recommendation EU 2025/1710) and reallocate the assurance budget.
Common mistakes
The Stop-the-Clock does NOT reduce the universe of bound companies: it only defers dates.
The piece that recalibrates the CSRD/CSDDD subjective scope is the 2026 Omnibus (Directive (EU) 2026/470, recital 7 + Art. 19a amended). The Stop-the-Clock (Dir. (EU) 2025/794) only shifts first-application dates. A company that remains within the new DOUBLE AND CUMULATIVE threshold post-Omnibus remains bound, simply with an adjusted calendar.
The Stop-the-Clock does NOT amend the ESRS: the piece that amends them is the QuickFix.
The technical review of ESRS Set 1 runs on separate tracks. Delegated Regulation (EU) 2025/1416 ("QuickFix", 11 Jul 2025) is the one that amends Annex I Appendix C of ESRS 1. The Stop-the-Clock is a directive and only operates on the application dates of the CSRD and the CSDDD, not on the content of Del. Reg. 2023/2772.
The Stop-the-Clock is NOT the Omnibus.
They are two distinct directives. The Stop-the-Clock (Dir. (EU) 2025/794, in force 17 Apr 2025) is the temporary bridge piece. The 2026 Omnibus (Dir. (EU) 2026/470, adopted 24 Feb 2026, in force 18 Mar 2026) is the structural piece. Confusing them leads to poor internal calendar planning.
The Stop-the-Clock does NOT affect parallel material obligations.
The ESPR (Reg. (EU) 2024/1781), EUDR (Reg. (EU) 2023/1115), Reg. (EU) 2024/3015 on forced labour, ECGT (Dir. (EU) 2024/825), the Right to Repair Directive (Dir. (EU) 2024/1799) and the Spanish textile EPR scheme (RD 1055/2022) have their own calendars. The Stop-the-Clock only operates on the CSRD/CSDDD.
Frequently asked questions
What is the CSRD Stop-the-Clock?
Directive (EU) 2025/794 of the European Parliament and of the Council deferring the application dates of the CSRD (Dir. (EU) 2022/2464) and the CSDDD (Dir. (EU) 2024/1760) for entities that would report for the first time in the 2025 and 2026 financial years. Entry into force on 17 April 2025.
What exactly does the Stop-the-Clock defer?
First-application dates of the CSRD for waves 2 (large non-listed companies) and 3 (listed SMEs) in addition to the transposition deadline of parts of the CSDDD. It does NOT amend ESRS Set 1 (which is amended via Del. Reg. (EU) 2025/1416 QuickFix) nor recalibrate the subjective scope (which is recalibrated by the 2026 Omnibus, Dir. (EU) 2026/470).
Does the Stop-the-Clock exempt me from the CSRD?
Not on its own. The Stop-the-Clock only defers dates. The piece that excludes companies from the CSRD scope is the 2026 Omnibus (Dir. (EU) 2026/470 recital 7 + Art. 19a amended) via the DOUBLE AND CUMULATIVE threshold of >1,000 employees AND >EUR 450,000,000.
When did the Stop-the-Clock enter into force?
On 17 April 2025, per the verbatim citation of recital 3 of Delegated Regulation (EU) 2025/1416 (QuickFix, 11 Jul 2025): it defers application dates for entities that would report for the first time in financial years 2025 and 2026.
Is the Stop-the-Clock still in force after the 2026 Omnibus?
It fulfilled its function as a regulatory bridge. Following the entry into force of the 2026 Omnibus on 18 March 2026 (Art. 6 Dir. (EU) 2026/470), the consolidated calendar in force for companies that remain within the CSRD scope post-Omnibus is that of recitals 31 and 33 of the Omnibus: first application to financial years beginning on or after 1 January 2027.
Fuentes oficiales
- European Parliament and Council · OJEU17 abr 2025 (entrada en vigor)Directive in force
- European Commission · OJEU11 jul 2025Delegated act in force
- European Parliament and Council · OJEU24 feb 2026Directive in force
