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EU Omnibus updates – Corporate Sustainability Reporting Directive (CSRD) “quick fix” amendments adopted by European Commission

14 July 2025

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On 11 July 2025, the European Commission adopted a targeted “quick fix” for companies currently reporting under the Corporate Sustainability Reporting Directive (“CSRD”). The “quick fix” will apply to companies that started reporting for financial year 2024 (“Wave One companies”). The European Sustainability Reporting Standards (“ESRS”) currently allow Wave One companies to omit certain information on, amongst other things, anticipated financial effects of certain sustainability‑related risks. The “quick fix” will allow Wave One companies to continue applying these reliefs for financial years 2025 and 2026.

On 11 July 2025, the European Commission adopted a “quick fix” delegated act to revise the ESRS to give Wave One companies flexibility in choosing whether they want to report additional information for financial years 2025 and 2026 compared with what they reported for financial year 2024. It also extends the phase-in provisions which currently apply to Wave One companies with 750 or fewer employees to all Wave One companies.

The “quick fix” forms part of a wider European Commission vision to simplify reporting requirements under the CSRD and ESRS by changing the scope of the CSRD and the number of mandatory datapoints to be reported on (see here and here for more on this).

The “quick fix” amendments set out in Annex I to the delegated act are necessary because the “stop-the-clock” directive which delayed reporting until 2028 for companies required to report from financial years 2025 and 2026 (known as Wave Two and Three companies) did not apply to Wave One companies, leaving them subject to a phase of additional data points from financial years 2025 onwards.

The Commission’s delegated act, first announced in May (see here), disapplies the phasing-in of additional reporting requirements which would otherwise have been required for Wave One companies.

Therefore the phased-in requirements are amended as follows:

all Wave One companies (regardless of number of employees) are not required to disclose for financial years 2025 and 2026:

the anticipated financial effects of risks and opportunities relating to climate change (E1), pollution (E2), water and marine resources (E3); and
all information under biodiversity and ecosystems (E4), value chain workers (S2), affected communities (S3) and consumers and end-users (S4); and

additionally Wave One companies or groups with 750 or fewer employees are not required to disclose for financial years 2025 and 2026:

scope 3 emissions and total GHG emissions; and
all information under own workforce (S1); and

additionally Wave One companies or groups with more than 750 employees:

are only required to disclose certain information and datapoints relating to own workforce (S1) (for example training and skills development datapoints can be omitted from reporting until financial year 2027); and
where they use the temporary exemptions for a complete topical standard which they have identified as material, they are still required to report summarised information on the topic concerned.

The ”quick fix” delegated act will enter into force on the third day after its publication in the Official Journal and will apply for financial years beginning on or after 1 January 2025.

Stay tuned for further updates on CSRD, ESRS and the omnibus simplification package.

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This note is intended to be a general guide to the latest ESG developments. It does not constitute legal advice.

Authored by Rita Hunter, Emily Julier, and Julia Cripps.