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31 December 2025
Directive (EU) 2025/794 amending Directives (EU) 2022/2464 and (EU) 2024/1760 as regards the dates from which Member States are to apply Certain Corporate Sustainability Reporting and Due Diligence Requirements

Synopsis

Directive (EU) 2025/794 amended the Corporate Sustainability Reporting Directive (CSRD) (EU) 2022/2464 and Corporate Sustainability Due Diligence Directive (CSDDD) (EU) 2024/1760.

Deadlines for mandatory corporate sustainability reporting and due diligence obligations will be deferred. EU Member States are required to transpose these changes into national law by 31 December 2025. 

Summary

This Directive amended the Corporate Sustainability Reporting Directive (CSRD) (EU) 2022/2464 and Corporate Sustainability Due Diligence Directive (CSDDD) (EU) 2024/1760.

Directive (EU) 2025/794 is required to be transposed into the national law of all EU Member States by 31 December 2025.

What will change?

The amending directive deferred deadlines for corporate sustainability reporting and due diligence obligations. This is intended to provide organisations with additional time to prepare.

Amendments to the Corporate Sustainability Reporting Directive (CSRD) (EU) 2022/2464

Large undertakings not previously subject to the Non-Financial Reporting Directive (NFRD) 2013/34/EU will now be required to report for financial years starting on or after 1 January 2027, deferred from the original 1 January 2025 date.

Listed small and medium-sized enterprises (SMEs), small and non-complex credit institutions and certain captive insurance and reinsurance undertakings will be required to report for financial years starting on or after 1 January 2028, postponed from the original 1 January 2026 date.

Amendments to the Corporate Sustainability Due Diligence Directive (CSDDD) (EU) 2024/1760

Directive (EU) 2025/794 deferred the deadline for the transposition of the CSDDD into national law to 26 July 2027. This defers the deadline by a year.

Directive (EU) 2025/794 also revises the thresholds and dates from which the CSDDD will apply to different classes of organisation:

  • Financial years starting from 1 January 2028: Companies with more than 5,000 employees and €1,500 million in turnover over the past two consecutive financial years. This was originally planned to apply from 1 January 2027.
  • Financial years starting from 1 January 2029: companies formed in accordance with the legislation of a third country with €900 million in turnover over the past two consecutive financial years. This was originally planned to apply from 1 January 2028.
  • Financial years starting from 1 January 2030 (deferred from 1 January 2029): All other companies in scope:
    • Companies with more than 1,000 employees and €450 million in turnover over the past two consecutive financial years, including those that meet this threshold as part of a group on a consolidated basis;
    • Companies formed in accordance with the legislation of a third country with €450 million in turnover over the past two consecutive financial years, those that are part of a group that meets this threshold on a consolidated basis.
    • Qualifying companies with franchising or licensing agreements in the EU with royalties exceeding €22.5 million (provided their worldwide net turnover exceeds €80 million).

 

 

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