Legal Evolution in the Field of Sustainability

Transposition of the “Stop the clock” directive in Belgium

On 4 December 2025, Belgium transposed the “Stop the clock” directive, offering a delay to report of 2 years for wave 2 and wave 3 companies and thereby ensuring legal certainty for the reporting of 2025 in 2026. 
 

Delay for the implementation of the EUDR

On 17 December 2025, the European Parliament voted for a 12-month delay of the EUDR implementation. The new text introduces a “simplification review” to be conducted in early 2026 by the European Commission to potentially propose further changes to the EUDR.

Final vote of the European Parliament on the Omnibus

After the trilogue between European Commission, Council and Parliament, the EU Parliament voted on the final Omnibus position on December 16th, 2025. The new thresholds and principles are as follows:

CSRD

The Corporate Sustainability Reporting Directive

• Will only apply to EU companies with over 1,000 employees and annual turnover above € 450 mio
• Same € 450 mio threshold for non-EU companies generating turnover in the EU
• Reporting will become more quantitative, and sector-specific reporting will be voluntary
• Smaller companies (<1,000 employees) are protected from additional reporting obligations
• Additional digital support will become available through a digital portal
   

CSDDD

The Corporate Sustainability Due Diligence Directive

• Only large corporations with over 5,000 employees and annual turnover above € 1.5 billion  must conduct due diligence on adverse impacts
• Applies to non-EU companies with the same EU turnover threshold
• A transition plan aligned with the Paris Agreement is not required anymore
• Non-compliance will be sanctioned at national level, with fines up to 3% of global turnover

New ESRS standards proposed by EFRAG

Following the Omnibus proposal in February 2025, EFRAG was requested by the European Commission to deliver technical advice on how to simplify the delegated act on the European Sustainability Reporting Standards (ESRS) by End of November 2025.
 

Building on CSRD ‘Wave 1’ review and the feedback from stakeholders gathered from the public consultations, EFRAG completed this simplification exercise at the end of November and published the Amended ESRS on 3 December 2025.

The main changes cover:

• Clearer standards (restructuring of application requirements in the standards themselves)
• Fewer datapoints (removal of 61% of “required when material disclosures” and removal of all voluntary disclosures)
• Focus on relevant information and fair presentation (Explicit emphasis on ‘Fair presentation’, with strong link to the materiality filter and alignment with IFRS S1)
• More flexibility in reporting presentation internally by the undertaking
• Simplified materiality assessment (Materiality assessment process simplified and dedicated Chapter (Chapter 3, ESRS 1) restructured for better readability and understandability of the process. This should help companies focus on what really matters.
• Flexible granularity of reporting: by topic or by specific impacts/risks/opportunities as managed
• Broad use of ‘undue cost or effort’ principle including beyond IFRS scope of application
• Reliefs without time limits but with transparency mechanism and expectation to see coverage improved over time
• Less pressure to collect direct data on value chain
• Better interoperability with IFRS-S.

If you would like guidance on how to start preparing your legal or voluntary sustainability report that focuses on the most relevant topics, contact one of our experts.