Introduction

The Omnibus Regulation introduced by the European Commission on 26 February 2025, is a legislative package designed to amend several key components of the European Green Deal. It targets three major sustainability frameworks: These are the Corporate Sustainability Reporting Directive (CSRD), the Corporate Sustainability Due Diligence Directive (CSDDD), and the Taxonomy Regulation. The overarching goal is to reduce the reporting burdens, especially for small and mid-sized companies, and increase efficiency and competitiveness in sustainability reporting, in response to a more growth-oriented regulatory environment in the EU.

Current State

In a surprising move on 22 October 2025, the European Parliament rejected the mandate to take the proposed Omnibus Regulation directly into trilogue negotiations. This decision delays the legislative process and sends the controversial sustainability reform package back to the plenary session scheduled for 11–13 November, where it will face a full vote and potential amendments. The rejection highlights growing political tensions around the future of EU sustainability legislation and raises critical questions about the direction of the European Green Deal.

On 22 October, the European Parliament voted against giving the green light to move the Omnibus compromise straight into trilogue negotiations. This decision has added a layer of uncertainty to the legislative process. Instead of fast-tracking the proposal, it now heads back to the plenary session in mid-November, where it will be debated and voted on in full. A new deadline for amendments will be set, which means parts of the compromise could be reopened, potentially reshaping the proposal. But this also risks delaying negotiations and unravelling sensitive agreements that had already been reached.

What the future holds

2026

EU commission to issue targeted assurance guidelines

The Commission will publish EU-wide guidelines for limited assurance on sustainability reporting under CSRD. These guidelines will harmonize practices across Member States until formal assurance standards are adopted. Reasonable assurance standards are expected later, possibly by 2028.

2027

Proposed application date for wave 2 companies under the stop the clock directive 

Large companies and parent companies of large groups (not in Wave 1) will begin CSRD reporting for financial years starting in 2027 (first reports due in 2028). This postponement was introduced to avoid unnecessary compliance costs during legislative revisions.

2028

CSDDD first wave of application for largest companies 

The Corporate Sustainability Due Diligence Directive (CSDDD) obligations will apply to the largest companies (EU companies with >5,000 employees and €1.5B turnover; non-EU companies with €1.5B EU turnover). This includes human rights and environmental due diligence across operations and value chains.

 

2028

Proposed application date for wave 3 companies under stop the clock directive

Listed SMEs, small and non-complex credit institutions, and captive insurers will start CSRD reporting for financial years beginning in 2028 (first reports due in 2029). This delay aims to ease compliance burdens for smaller entities.

Where we are at now

2025

Timeline for transposition

Member States must transpose the Stop-the-Clock Directive into national law by 31 December 2025, ensuring legal certainty for companies on delayed CSRD and CSDDD timelines.

Here’s the current transposition status for the Stop-the-Clock Directive across EU Member States (as of September 2025):

Member State Status Comments

Austria

In Progress

Draft legislation introduced; awaiting parliamentary approval.

Belgium

In Progress

Consultation held; draft law expected Q4 2025.

Bulgaria

Not Started

No official draft or consultation announced yet.

Croatia

Not Started

No updates published.

Cyprus

Completed

Legislation adopted and published.

Czech Republic

Not Started

No draft law introduced.

Denmark

In Progress

Draft law introduced; parliamentary debate ongoing.

Estonia

Completed

Adopted 19 June 2025; in force since 20 July 2025.

Finland

In Progress

Draft legislation introduced; expected adoption by December 2025.

France

Completed

Law published in Official Journal on 2 May 2025.

Germany

In Progress

Draft law introduced; Bundestag review ongoing.

Greece

Not Started

No official communication yet.

Hungary

Completed

Accounting Act and ESG Act amended on 20 June 2025.

Ireland

Completed

Legislation adopted; details published in national gazette.

Italy

Completed

Implementing law adopted; aligns with Stop-the-Clock deadlines.

Latvia

In Progress

Draft law introduced; awaiting parliamentary vote.

Lithuania

Completed

Legislation adopted and published.

Luxembourg

In Progress

Draft law introduced; adoption expected by year-end.

Malta

Not Started

No updates available.

Netherlands

In Progress

Draft law introduced; parliamentary debate ongoing.

Poland

Completed

Legislation adopted; aligns with EU directive.

Portugal

Not Started

No official draft yet.

Romania

Completed

Law adopted and published.

Slovakia

Completed

Legislation adopted; effective immediately.

Slovenia

Completed

Law adopted and published.

Spain

Not Started

No official communication yet.

Sweden

In Progress

Draft law introduced; adoption expected Q4 2025.

Frequently Asked Questions

Malta currently falls under the scope of the Non-Financial Reporting Directive (NFRD), as the Corporate Sustainability Reporting Directive (CSRD) has not yet been transposed into national law. This means that only companies meeting the NFRD criteria are currently required to report on non-financial matters.

However, following the adoption of the “Stop-the-Clock” principle under the EU Omnibus Package, all EU Member States—including Malta—are expected to transpose the revised CSRD timeline into national legislation by 31 December 2025. This delay provides companies with additional time to prepare for the expanded reporting requirements under the CSRD.

As of mid-2025, Malta has not yet published draft legislation to transpose the CSRD. However, Maltese companies that meet the CSRD thresholds should prepare for compliance, as the directive will apply once transposed.

However, following the adoption of the “Stop-the-Clock” principle under the EU Omnibus Package, all EU Member States—including Malta—are expected to transpose the revised CSRD timeline into national legislation by 31 December 2025. This delay provides companies with additional time to prepare for the expanded reporting requirements under the CSRD.

Following the adoption of the “Stop-the-Clock” principle, all EU Member States—including Malta—must transpose the revised CSRD timeline into national law by 31 December 2025. This ensures alignment with the updated reporting deadlines introduced under the Omnibus Package.

At present, the Omnibus proposal is still under discussion at EU level, particularly regarding reporting thresholds and the scope of non-financial disclosures. Final details will determine how these requirements are implemented locally.

Even if not yet legally required, businesses should focus on stability and preparedness:

  • Stay on course with CSRD readiness and due-diligence programmes.
  • Begin internal assessments using the double materiality framework
  • Review ESRS drafts and prepare systems for future reporting
  • Invest in reliable data systems and governance, which remain critical under any scenario.
  • Expect continued scrutiny from investors, lenders and supply-chain partners on ESG performance, regardless of shifting legal thresholds.

This principle requires companies to report:

  • Financial materiality: How sustainability issues affect the company’s financial performance.
  • Impact materiality: How the company’s activities affect society and the environment.
    This remains a core requirement under the CSRD, even with the Omnibus simplifications.

Most SMEs are excluded from mandatory CSRD reporting. However, a Voluntary SME Reporting Standard (VSME) is being developed to help SMEs align with sustainability goals without excessive burden.

Navigating the ESG Alphabet Soup

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