CSRD: a reprieve to fine-tune its CSR commitments
It took less than two months for the so-called “Stop the clock” proposal from the February 26, 2025 Omnibus package to be published in the EU’s Official Journal. It ratifies a two-year postponement of the CSRD deadlines for companies subject to the directive from the 2025 financial year. The proposal does not apply to large listed companies, which are currently submitting their first sustainability reports. It should be noted that the application of legislation on duty of care (CS3D) has also been deferred (see our Responsible Purchasing dossier). In France, parliamentarians have already taken steps to adapt national law to this new timetable, the original directive having been transposed in 2023.
CSRD: what are we talking about?
The CSRD(Corporate Sustainability Reporting Directive) aims to increase the transparency of European companies in terms of sustainability, and to encourage a responsible approach to their activities, based on ESG (environmental, social and governance) criteria. This translates into an obligation to publish an annual sustainability report, drafted on the basis of standardized information, which is detailed in twelve major reference frameworks: the ESRS (European Sustainability Reporting Standards). The obligation is phased in according to specific criteria (size, sales and balance sheet). All companies subject to this requirement must have their reports verified by an auditor duly registered with the French High Audit Authority (H2A), a service which AFNOR Certification has been offering since January1, 2025 as an accredited independent third-party body.
Initially, the CSRD was intended to apply to over 50,000 European companies. Many of these companies were already obliged to publish an extra-financial report, particularly in France as part of the DPEF (déclaration de performance extra-financière). Until now, however, the choice of information to be included was relatively free, making data comparability more difficult.
Postponement, an opportunity to prepare
What new timetable does the “Stop the clock” text set? For large listed companies, those in wave 1 (meeting two of the following criteria: over 500 employees, sales in excess of €50 million, balance sheet total in excess of €25 million), there is no change: they must comply now. The others, mainly large unlisted companies and listed SMEs (waves 2 and 3), are given extra time. In this case, a two-year deferral, i.e. a first publication in 2028 on 2027 data, and in 2029 on 2028 data.
Important point: the Stop the Clock Directive only affects the timetable; it does not affect the content of the information to be included in sustainability reports. The current 12 ESRS standards will therefore continue to apply, with double materiality analysis. However, the postponement gives the European trialogue time to develop the scope of the standards and the granularity of the data to be collected. EFRAG, the body that developed the ESRS, has been asked to simplify these ” datapoints ” and to submit its copy by October 31, 2025. One way forward would be to move towards the so-called VSME model, an ESRS-inspired repository for small and medium-sized companies, deemed more readable and accessible. Ultimately, this lighter model could perhaps replace the ESRS for all companies with fewer than 1,000 employees, if the European trialogue called upon to rework the content of the directive validates this approach and this new threshold (the highest threshold is currently 500 employees). Larger companies would continue to use the original ESRS.
Pursuing voluntary ISO 26000 initiatives
For many observers, this prospect of a drastic reduction in the ESRS, coupled with the postponement of the timetable, runs counter to the CSRD’s initial objective, i.e. to offer companies a framework for improving the transparency and comparability of CSR data, and thus nip in the bud any form of greenwashing. Here, the CSRD is bearing the brunt of a political sequence that began with the Draghi report at the end of 2024, followed by the new American presidency, equating any further notching up of CSR approaches with an obstacle to a company’s economic competitiveness.
Whatever the case, directive or no directive, time lag or no time lag, VSME or no VSME, sustainability is not an option. The ups and downs of regulatory reporting should not prevent voluntary initiatives from continuing. First and foremost those based on ISO 26000, the mother standard of all CSR initiatives. In fact, companies that have obtained the Engagé RSE label from AFNOR Certification , a sign of recognition based on this international standard, appear to be ahead of the game, and thus at an advantage when it comes to understanding CSRD, demonstrating their CSR performance and collecting their sustainability data. A white paper by AFNOR Certification, which can be downloaded free of charge from , demonstrates this.
