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.