CSRD: a reprieve to refine CSR commitments

It took less than two months for the "Stop the clock" proposal, part of the Omnibus package of February 26, 2025, to be published in the Official Journal of the EU. It confirms the two-year postponement of the CSRD directive deadlines for companies subject to it from the 2025 financial year onwards. 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 the duty of care legislation (CS3D) has also been postponed (read our report Responsible purchasing ). In France, parliamentarians have already taken steps to adapt national law to this new timetable, with the original directive having been transposed in 2023.

CSRD: what are we talking about?

The Corporate Sustainability Reporting Directive (CSRD) aims to increase the transparency of European companies in terms of sustainability and encourage a responsible approach to their activities, based on ESG criteria (environmental, social, and governance). This translates into an obligation to publish an annual sustainability report, based on standardized information detailed in twelve major standards: the European Sustainability Reporting Standards (ESRS). This obligation will be phased in according to specific criteria (size, turnover, and balance sheet). All companies subject to this requirement must have their report verified by an auditor duly registered with the High Authority for Auditing (H2A), a service provided by AFNOR Certification. offers since January 1, 2025  as an accredited independent third-party organization.

Initially, the CSRD was intended to apply to more than 50,000 European companies. By lowering the threshold to 1,000 employees and $450 million in revenue, the new version of the directive adopted at the end of December 2025 reduces this number to around 9,000. Many of these companies were already required to publish a non-financial report, particularly in France under the DPEF (non-financial performance statement). However, until now, the choice of information to be included in these reports was relatively unrestricted, which made it more difficult to compare data.
 

The postponement, an opportunity to prepare

Before the European Council and Parliament revised the directive, producing a new version in December 2025, the "Stop the clock" text granted companies in waves 2 and 3 (large unlisted companies and listed SMEs) a two-year reprieve, i.e., initial publication in 2028 for 2027 data, and in 2029 for 2028 data. In the new version of the directive of December 2025, 2028 is retained as the starting point for all companies subject to the directive, i.e., those that are required to comply if they have 1,000 or more employees and €450 million in turnover, and smaller companies that will report on sustainability on a voluntary basis.
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 ESRS 12 standards therefore continue to apply, with a dual materiality analysis. However, the calendar postponement has given the European trilogue time to develop the scope of the standards and the granularity of the data to be collected within companies. EFRAG, the body that developed the ESRS, has proposed a simplified model, removing two-thirds of the data points required. A delegated act is expected to give it legal force. For voluntary reporting, the VSME model was confirmed in 2025. It is therefore set to become the benchmark for smaller companies wishing to continue their efforts, and for those that are asked by their larger clients to produce data.
 

Continue voluntary efforts with ISO 26000

For many observers, this drastic easing of ESRS requirements, coupled with the postponement of the timetable, runs counter to the CSRD's initial objective, which was to provide companies with a framework for improving the transparency and comparability of CSR data, thereby nipping any form of greenwashing in the bud. The CSRD is paying the price for a political sequence that began with the Draghi report at the end of 2024 and continued with the new US presidency, which equates any new CSR requirements with an obstacle to a company's economic competitiveness.

In any case, directive or no directive, delay or no delay, VSME or no VSME, sustainability is not an option. Regulatory ups and downs regarding reporting should not prevent voluntary initiatives from continuing. First and foremost, those based on ISO 26000, the parent standard for all CSR initiatives. De facto, companies that have obtained the AFNOR Certification CSR Commitment label , a recognition mark based on this international standard, are ahead of the curve and thus have an advantage in understanding the CSRD, demonstrating their CSR performance, and collecting their sustainability data. A white paper by AFNOR Certification, available for free download here , in fact, demonstrates this.

You can also obtain the documentation booklet. FD X30-058  May 2025, which provides tables showing the correspondence between ESRS families and ISO 26000 requirements. This demonstrates that a CSR approach implemented in accordance with the 2010 standard enables organizations to meet current and future reporting requirements.