Paused, Not Cancelled: Keeping CSRD on Track

CSRD “Stop the Clock”: A Strategic Window for Smarter ESG Reporting

In February 2025, the European Commission introduced an Omnibus package aimed at simplifying EU sustainability legislation, which contained two proposed Directives. One of these documents is the “Stop the Clock” Directive, which, among its measures, grants companies an additional two years to comply with the CSRD. For many businesses, particularly those that were originally part of “Wave 2”, this means the reporting obligation is now postponed from 2026 to 2028, based on 2027 data.

While this extension provides valuable time, it does not reduce the complexity of CSRD reporting. In this article, we explain why it is critical to start now and how to do so efficiently, drawing from our experience supporting companies across sectors on their CSRD journey.

In this article:

• Omnibus Packages: Key Changes to CSRD and ESG Reporting Scope
• Why the CSRD Reporting Delay Is Not a Reason to Pause ESG Preparations
• How to Build an Effective ESG Strategy During the CSRD Delay
• How Greenomy Supports Your CSRD Journey
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Omnibus Packages: Key Changes to CSRD and ESG Reporting Scope

The first document introduced by the Omnibus package is called the “Stop-the-Clock” Directive. It was adopted and published in the EU’s Official Journal in April 2025, introducing a temporary delay in the CSRD timeline. Member States are expected to transpose it into national law by the end of 2025. Until that happens, the current rules remain in place.

Meanwhile, the second proposal, which introduces substantive simplifications to the CSRD and EU Taxonomy, is still under negotiation. This includes reducing the scope of CSRD to companies with over 1,000 employees and either €50 million in turnover or €25 million in total assets. 

Over 840 pages of proposed amendments are currently being discussed in the European Parliament, with clearer outcomes expected by early 2026. Notably, the shift from a rules-based to a principle-based reporting approach is gaining traction, focusing less on rigid metrics and more on how companies govern ESG responsibilities in practice.

Why the CSRD Reporting Delay Is Not a Reason to Pause ESG Preparations

Although the CSRD deadline has been extended, the workload remains unchanged. Preparing an audit-ready report can take up to a year for a mid-sized company. Building a robust ESG reporting structure—assigning ownership, aligning teams, collecting quality data, and testing systems—takes time. And the closer you get to the deadline without taking action, the more resources you will need to compensate for missing data.

Additionally, regulatory deadlines may have shifted, but stakeholder expectations remain high. Studies from PwC, Deloitte, and Capgemini show that 

• 88% of institutional investors integrate ESG into decision-making, 
• 70% of employees seek purpose-driven employers, and 
• 62% of consumers prefer sustainable brands.

ESG remains a critical business priority, which will strengthen your external credibility, as investors, customers, and partners are still requesting ESG data regardless of the legal timeline.

Finally, we have discussed in a past article how delaying ESG compliance preparation presents risks of rushed, costly, and fragmented reporting. Acting early helps avoid bottlenecks, reduce long-term costs, and ensures smoother internal coordination overall. 

How to Build an Effective ESG Strategy During the CSRD Delay

Before turning to a practical example, let’s highlight our key recommendation for navigating this period of ESG reporting uncertainty: identify the ESG data points most strategically relevant to your organisation.

These may come from stakeholder expectations, industry benchmarks, data availability, and alignment with your strategic objectives. Prioritising this subset enables you to test data collection processes and governance frameworks in advance, without the pressure of an imminent deadline.

If you are starting CSRD from scratch in 2025, your priority should be conducting a Double Materiality Assessment and Gap Analysis to identify and prioritise your most strategic ESG data points. With those insights, you can structure 2026 into two phases: first, pilot a focused set of ESG disclosures; then, scale your efforts. Use 2027 to implement data systems and streamline collection processes. So that by 2028, you are ready to publish your first CSRD-compliant report.

If you have already conducted a DMA and Gap Analysis, you can move straight to creating a pilot report in 2025, focusing on a limited set of high-impact disclosures. In 2026, these findings can be used to refine systems and begin collecting a broader set of data, ready for full-year coverage in 2027 and publication in 2028.

Starting CSRD Reporting from Scratch in 2025: A Practical Example

To illustrate this strategy, let’s consider a practical example from an industrial manufacturing firm called Company A.

1. The DMA: After completing the DMA, Company A identifies the following ESRS as material:

2. Onboard your team: A multidisciplinary ESG reporting team is assembled and trained on the CSRD requirements.

3. Gap Analysis: After assessing all data points, a strategic selection is made; Company A assigns ownership to each data point, and a Gap Analysis provides the following insights: 

After looking internally, it turns out that 

• 12% of the required data is fully available and of acceptable quality. 
• Most gaps identified relate to quantitative metrics, such as energy consumption and accident rates.

4. Priorisation: After a strategic assessment, certain data is prioritised for drafting a pilot report.

For instance, the manufacturing sector is heavily regulated on pollution and workforce safety so these ESRS are selected:

• ESRS E3 Pollution
• ESRS S1-14 – Health and safety metrics

Company A receives increasing requests on its carbon footprint from its customers and investors so it selects these ESRS:

• ESRS E1-6 – Gross Scopes 1, 2, 3 GHG emissions

5. Data Collection: The ESG team begins collecting data for the prioritised data requirements. They reach out to data owners in various departments to track the status of each data point and input supporting documents.

6. Pilot Report: The collected data is structured according to CSRD formatting guidelines into a pilot sustainability report. It serves as a practical baseline for testing the company’s reporting readiness and gathering internal feedback.

7. Review & Adapt: After quality control, Company A identifies inconsistencies in narrative tone, and the scope 3 data does not follow the CSRD methodology. Monthly ESG meetings are established to align departments and track progress.

8. Extend: With a more structured process in place, Company A proceeds with the final steps:

• collect remaining data points
• update previously collected information to reflect the latest figures
• conduct a final consistency check across all disclosures
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How Greenomy Supports Your CSRD Journey

Partnering with Sustainability Experts like Greenomy can make all the difference in your CSRD Reporting journey. Our team provides tailored guidance to help you navigate the complexities of ESG Reporting, ensuring you not only meet regulatory expectations but also extract strategic value from the process.

Greenomy’s innovative CSRD solution streamlines data collection and reporting, laying a strong foundation for accurate, efficient disclosures. Complementing this, our Sustainability Advisory services offer expert-led support to kickstart and structure your Double Materiality Assessment with confidence and clarity.

Book a demo to explore how we can help you turn compliance into a catalyst for long-term sustainability impact.