July 15, 2025

EU Delays Key Sustainability Reporting Requirements Under CSRD

EU Delays Key Sustainability Reporting Requirements Under CSRD

At a glance
The European Commission has adopted a set of “quick fix” amendments to the European Sustainability Reporting Standards (ESRS), pausing the rollout of several new disclosure requirements for large companies already reporting under the Corporate Sustainability Reporting Directive (CSRD). This move is part of the broader Omnibus I initiative aimed at easing regulatory pressure on businesses and streamlining sustainability reporting.


These changes provide near-term relief for companies—especially those in the first reporting wave—by deferring upcoming disclosures related to biodiversity, Scope 3 emissions, value chain workers, and other complex topics.


Why this matters
The CSRD took effect in January 2024 for large public-interest companies with over 500 employees, with the first sustainability reports due in 2025. It was set to expand to companies with 250+ employees or €50 million in revenue in 2026, and listed SMEs in 2027. However, under the Omnibus initiative, the Commission now proposes raising the threshold to over 1,000 employees—effectively narrowing the scope of the CSRD. Some lawmakers are pushing for even higher thresholds.


The ESRS revisions are expected to reduce required datapoints by nearly two-thirds. This signals a meaningful pivot: from expansive, one-size-fits-all reporting to a more risk-based and proportionate approach.


Key changes for ‘wave one’ reporters

  • Deferment of new disclosures: Companies already subject to CSRD reporting will not need to implement the second- and third-year disclosure expansions originally planned—pending final outcomes of the ESRS review.

  • Delayed risk disclosure: All wave one companies can now postpone reporting the financial effects of certain sustainability risks by two years.

  • Extended phase-in for smaller companies:

    • Companies with <750 employees may omit disclosures on Scope 3 emissions, biodiversity, workforce, value chain workers, and affected communities through FY2026.

    • Companies with >750 employees are granted similar relief—with the exception that Scope 3 emissions remain required.


What about companies not yet in scope?

For companies originally slated to start reporting in 2026 or 2027, the EU adopted a "stop-the-clock" directive earlier this year, pausing new obligations until the CSRD revisions are finalized.


What’s next?

The Commission expects its full review of the ESRS to be completed by FY2027. In the meantime, companies should monitor developments closely and reassess internal readiness plans, particularly as scope thresholds and data expectations evolve.

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