Stop the clock, Omnibus 1 and CSRD

Stop the Clock, or Taking Your Time?

🟦The European Union hits pause: what the stop-the-clock vote changes (and doesn’t) for businesses

On April 4, 2025, the European Parliament voted in favor of the stop-the-clock proposal, a key measure in the Omnibus I package put forward by the European Commission.

This vote offers a breath of fresh air to companies navigating a complex sustainability regulatory timeline. But this pause is not the end of the road.

On the contrary—it opens a new phase of strategic adjustment.

🔁 A Targeted Delay, Not a Rollback of the Transformation

The stop-the-clock proposal includes:

A 2-year delay in the application of the CSRD (Corporate Sustainability Reporting Directive) and the EU Taxonomy for companies not yet under scope
A 1-year delay for the CSDDD (Corporate Sustainability Due Diligence Directive)

This delay does not apply to companies already subject to the CSRD since 2024, notably large publicly listed companies. For others, it offers a strategic breather.

🧭What the CSRD Still Requires – No Change There

CSRD

To recap, the CSRD is progressively replacing the NFRD (Non-Financial Reporting Directive) and requires more structured, standardized, and verifiable reporting. Key requirements that remain unchanged include:

✅ Double materiality: companies must report both the impact of their activities on the environment and society (impact materiality), and the impact of ESG issues on their financial performance (financial materiality).
✅ Use of harmonized standards (ESRS) defined by EFRAG
✅ Mandatory assurance by an external auditor
✅ A progressively expanded scope, eventually covering non-EU subsidiaries of EU-based groups

In other words: Europe’s strategic direction on sustainability reporting remains fully intact.

🧩 What’s Still Under Negotiation in the Omnibus Package?

The Omnibus I package goes well beyond a simple delay. It opens the door to a potential in-depth revision of the regulatory framework.

Ongoing discussions include:

🔄 Reducing the number of companies concerned: a proposed threshold for the Taxonomy is high (1,000 employees and €450M in revenue), which would exclude a large portion of the economic fabric.

📉 Streamlining reporting content: removing requirements deemed “low in materiality,” refocusing on quantitative data.

🛡️ Debates on the scope of sanctions and role of third-party audits: the ECB, in particular, has raised concerns about weakening safeguards against greenwashing.

🤝 Strong political divisions: some MEPs view the proposal as excessive deregulation; others push for further administrative simplification.

The current Omnibus text is neither finalized nor guaranteed. It may evolve significantly in the coming months, under combined pressure from Member States, EU institutions, businesses, and NGOs.

⏱️ What Companies Should Do Now

If you are not yet within the CSRD’s scope, you now have until 2028 to comply. But this reprieve is not a time to slow down—it’s a strategic opportunity.

We recommend:

✅ Mapping your obligations: are you affected in the short, medium, or long term? By the CSRD? The Taxonomy? The CSDDD?
✅ Establishing strong ESG governance: this is the foundation for any credible reporting framework.
✅ Anticipating double materiality: this cornerstone of the CSRD is not going away. Begin your assessments now.
✅ Structuring your ESG data: centralization, reliability, auditability—this takes time.
✅ Monitoring regulatory developments: including new ESRS standards expected by the end of 2025 and applicable starting in 2027.

🧩 In Conclusion: A Tactical Pause, Not a Change of Course

The stop-the-clock vote acknowledges the implementation challenges many companies face. It provides time—but it is not a step back.

Europe’s ambition on sustainability remains steadfast. It is rooted in long-term competitiveness, capital market attractiveness, and extra-financial risk prevention. Companies that anticipate and adapt intelligently will be best positioned to navigate the coming transitions.

🧭 Want Clarity on the Road Ahead?

Contact us to build a roadmap that makes the most of this pause—and, more than ever, activates the levers of decarbonization and the shift to a more sustainable model, to make your company economically stronger and more resilient.

Rong Yi Solutions is your partner in this journey—helping the industry move forward through a structured transformation pathway, built around key pillars:

Double materiality analysis, to enable effective prioritization
Bilan Carbone®, to operationalize GHG emissions reduction
Life Cycle Assessment (LCA), for broader impact and constraint mapping
ACT (Accelerate Climate Transition®), to align corporate strategy in a changing world
HazClim®, to assess exposure to climate risk and build adaptation and resilience plans

Our team closely monitors changes to the European regulatory framework and supports you in turning constraint into opportunity.