The European Commission adopted a delegated act amending the first set of European Sustainability Reporting Standards (ESRS) to provide targeted relief for ‘wave 1’ CSRD reporters (first reporting for FY2024). The amendments extend certain ESRS phase-ins so companies can continue omitting specific disclosures in FY2025 and FY2026 (e.g., anticipated financial effects; and for certain undertakings, additional reliefs for Scope 3/total GHG and selected topical standards/datapoints) to avoid a step-up in disclosure requirements compared with FY2024. Compliance teams should reassess FY2025–FY2026 ESRS disclosure plans, internal data-collection roadmaps, and assurance readiness against the amended ESRS provisions.
The European Commission adopted a delegated act on July 11, 2025 extending phase-in provisions for Wave 1 companies already reporting under CSRD who were not covered by the Stop-the-Clock Directive. The quick-fix allows Wave 1 companies to omit anticipated financial effects and certain disclosures (ESRS S3 on affected communities, ESRS S4 on consumers and end-users) for financial years 2024-2026, and extends the biodiversity reporting phase-in (ESRS E4) to FY 2026 for companies with more than 750 employees. This addresses the gap where Wave 1 companies would have faced full reporting requirements while Wave 2 and Wave 3 companies received postponement relief.
The European Commission adopted a targeted ‘quick-fix’ delegated act amending the first set of ESRS (via an amendment to Delegated Regulation (EU) 2023/2772). The change is intended to reduce incremental reporting burden for companies already reporting under CSRD/ESRS (Wave 1) by extending certain phase-in/transitional provisions into FY2025 and FY2026 (e.g., continued ability to omit specified disclosures and broader access to phase-ins that previously depended on employee thresholds). Compliance teams should reassess FY2025–FY2026 ESRS data-collection scope, internal controls, and assurance planning to align with the amended phase-in requirements and relief measures.
Commission Delegated Regulation (EU) 2025/1416 of 11 July 2025 amends Delegated Regulation (EU) 2023/2772 to postpone certain reporting dates for CSRD Wave 1 companies. The regulation extends phase-in provisions through 2026, providing flexibility on Scope 3 and biodiversity reporting for companies that began reporting under the first wave of CSRD implementation.
Ireland has transposed the EU Stop-the-Clock Directive into national law through the European Union (Corporate Sustainability Reporting) Regulations 2025. This postpones by two years the CSRD sustainability reporting requirements for Wave 2 companies (large undertakings) and Wave 3 companies (listed SMEs and non-EU companies) while the Omnibus package negotiations proceed at EU level. Wave 2 companies now report in 2028 for FY2027; Wave 3 companies report in 2029 for FY2028.
Directive (EU) 2025/794 (published in OJ L on 16 April 2025) amends the CSRD framework as regards application dates (commonly referred to as the CSRD ‘stop-the-clock’ mechanism). This legally underpins postponements of certain CSRD reporting timelines (notably for later ‘waves’ of companies) and requires companies to reassess their first reporting year and internal readiness plans in light of the updated application schedule and Member State implementing measures.
Directive (EU) 2025/794 postpones CSRD sustainability reporting requirements by two years for Wave 2 and Wave 3 companies. Wave 2 companies (large companies previously due to report for FY2025) now report in 2028 on FY2027 data. Wave 3 companies (listed SMEs, previously due to report for FY2026) now report in 2029 on FY2028 data. Wave 1 companies (large public interest entities already reporting) must continue as planned. Member States must amend national laws by December 31, 2025.
The European Commission published an ‘Omnibus package’ update describing a simplification initiative that includes proposed changes impacting CSRD (e.g., potential scope recalibration and ESRS simplification). This is an official policy/proposal communication (not the final legal text). Compliance teams should treat this as proposal-stage and monitor the legislative process and subsequent Official Journal publication for any adopted amendments.