What softened EU sustainability reporting requirements mean for businesses

Proposed amendments to CSRD reflect a more sustainable approach to sustainability

July 17, 2025

Key takeaways

The EU’s “stop-the-clock” directive temporarily delays certain CSRD and CSDDD obligations.

Companies with fewer than 1,000 employees may be excluded from CSRD obligations.

CSDDD compliance for very large EU companies is delayed by one year.

#
ESG

Originally published Feb. 27, 2025; updated July 17, 2025

In April 2025, the European Union (EU) adopted the “stop-the-clock” directive, introducing a temporary pause on certain sustainability reporting and due diligence obligations under the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD). EU member states are required to transpose the new directive into their national laws by Dec. 31, 2025.

This move reflects the EU’s broader effort to recalibrate its sustainability framework, offering businesses more time to prepare for compliance while the European Commission streamlines and simplifies the reporting standards.

Here are the CSRD reporting timeline adjustments:

  • Wave 1 (large public-interest entities already reporting under the Non-financial Reporting Directive [NFRD]): No changes. These companies must continue reporting as originally scheduled.
  • Wave 2 (large undertakings not previously subject to the NFRD): Reporting is postponed for two years. These companies will now begin reporting in 2028 for the 2027 financial year. Additionally, under proposed revisions to the CSRD, companies with fewer than 1,000 employees may be excluded from the directive’s scope.
  • Wave 3 (listed small and medium-sized enterprises, small and noncomplex credit institutions, and captive insurers): Reporting is postponed for two years. Reporting will now begin in 2029 for the 2028 financial year. Many of these entities may also fall outside the revised scope if they do not meet the updated employee threshold.
  • Wave 4 (non-EU companies with significant EU operations): No delay. These companies are to begin reporting in 2029 for FY 2028.

Here are the CSDDD compliance timeline adjustments:

  • Wave 1 (very large EU companies): Compliance deadline extended by one year to July 26, 2028.
  • Wave 2 (large EU companies): No change. Compliance is due by July 26, 2028.
  • Wave 3 (non-EU companies meeting the threshold): No change. Compliance is due by July 26, 2029.

These changes offer a critical window for companies to reassess their readiness, refine their sustainability strategies and align with evolving EU expectations. While the directive provides temporary relief, it also underscores the importance of staying proactive in sustainability planning and reporting.


The following was originally published in February 2025: The European Union is making a significant course correction in its sustainability reporting framework, acknowledging the need for a more pragmatic and business-friendly approach. Recent proposed amendments to the Corporate Sustainability Reporting Directive (CSRD), Corporate Sustainability Due Diligence Directive (CSDDD) and EU Taxonomy Regulation reflect a broader recalibration of regulatory expectations, easing compliance burdens while maintaining core sustainability objectives.

While the EU has proposed adjusted key compliance thresholds and deadlines, the general alignment to the Green Deal objectives remains intact, ensuring that sustainability transparency and corporate due diligence obligations continue to align with this objective.

For global companies—including those in Canada and the U.S.—these proposed changes, if passed, may offer a reprieve, reducing complexity and providing additional time to adapt. As the EU finalizes these revisions, Canadian and American businesses should stay ahead by assessing whether they would remain in scope, leveraging voluntary sustainability reporting and optimizing compliance strategies.

Key changes to sustainability reporting requirements: A move toward practicality

The amendments proposed in February 2025 introduce delays, scope reductions, and flexibility in compliance measures. The proposed adjustments respond to growing concerns about administrative burdens, reporting complexity, competitiveness concerns and potential unintended consequences for businesses in the EU and beyond. What do these changes mean for U.S. and Canadian companies that have operations in the EU?

Higher thresholds and extended timelines

  • The CSRD now only applies to large undertakings with more than 1000 employees and either a turnover above 50 million euros or a balance sheet above 25 million euros. (Previously defined as companies with above two out of the following three criteria: 250 employees, 50-million-euro turnover or 25-million-euro balance sheet total)
  • U.S. and Canadian businesses with large undertakings in the EU with less than 1000 employees are no longer required to report against the CSRD.
  • EU entities of U.S. and Canadian companies that are still required to report are given proposed postponement of two additional years to prepare.
  • For global reporting, the threshold for non-EU companies has been raised from having generated revenue in the EU of 150 million euros to 450 million euros and having a large undertaking with the new proposed criteria or a branch with a newly proposed adjusted net turnover of 50 million euros from the current 40 million euros.

These changes would significantly reduce the number of companies required to comply, alleviating concerns for midsized U.S. and Canadian businesses and providing breathing room for those still in scope.

Reduced reporting and assurance obligations

  • The transition to reasonable assurance audits are expected to be scrapped, ensuring that companies will need only limited assurance on sustainability reports.
  • The proposal is expected to provide clarity with proposed targeted guidance regarding audit standards. 

The proposal provides businesses with greater flexibility in how they meet compliance obligations while still maintaining transparency.

Lower compliance burdens for global firms

  • The requirement for the EU Commission to develop sector-specific sustainability reporting standards are removed.
  • Due diligence obligations for CSDDD are now focused on direct suppliers only, rather than the entire value chain, reducing the regulatory trickle-down effect.
  • Liability risks are eased, with the removal of mandatory business relationship termination for non-compliance.

These refinements reflect an EU effort to strike a balance between ambition and feasibility, ensuring that sustainability standards remain effective without imposing excessive burdens on companies, particularly those headquartered outside of Europe.

Implications for Canadian and U.S. companies

For Canadian and American businesses operating in Europe, the recalibrated CSRD and CSDDD frameworks offer several strategic advantages:

  • Fewer companies are in scope: Decreasing the number of companies that will need to report.
  • Lower compliance costs: Reporting and assurance obligations are reduced.
  • More preparation time: Extended deadlines provide additional runway to adapt.
  • Reduced risk exposure: Loosened liability provisions lessen the stakes for non-compliance.

However, large Canadian and American firms will still need to comply. These companies should leverage the extended timeline to refine sustainability strategies, streamline data collection and establish internal assurance processes that align with evolving EU expectations.

A pragmatic shift without abandoning sustainability goals

Despite these adjustments, the EU has stated it remains committed to sustainability and corporate accountability. Rather than rolling back its Green Deal ambitions, the bloc is recognizing that effective regulation must balance ambition with practicality.

The revised CSRD and CSDDD frameworks reflect a more flexible, business-aligned approach that ensures sustainability remains a central corporate priority—without stifling economic competitiveness.

As the EU finalizes these revisions, Canadian and U.S. businesses should stay ahead by:

  • Assessing their EU footprint to determine if they remain in scope.
  • Leveraging voluntary reporting to maintain ESG leadership and investor confidence.
  • Optimizing compliance strategies using the additional time granted.

The EU’s recalibration signals a new era of pragmatism in sustainability regulation—one that businesses should view not as a retreat, but as an opportunity to build smarter, more efficient ESG reporting frameworks that align with both regulatory and market expectations.

Special Report

The RSM Middle Market Sustainability Survey 2024: U.S. and Canada

Numerous regulations are making sustainability a larger compliance issue.

Tax incentives are one part of companies’ broader decarbonization efforts.

Training is the most common action taken toward compliance, but also the top hurdle.

Sustainability and ESG insights

Sustainability and ESG services

Consulting

At RSM, we guide companies through every step of their ESG journey, from assessing current practices to integrating ESG metrics into corporate decisions. We offer ESG services, including regulatory compliance, risk assessments, and reporting. Additionally, we provide internal audits to help ensure accurate ESG data collection and compliance with global regulations.

Learn more about each of our unique sustainability and ESG consulting services:

Tax

As companies develop their ESG profiles, they often find that ESG and sustainability outcomes align with broader business objectives. Tax benefits can connect business growth with positive ESG outcomes.

Our ESG tax professionals can help you align your ESG and growth goals with tailored strategies. With a presence in over 120 countries, we offer global resources and local specialization to support your sustainability strategy and create long-term value for your stakeholders.

Assurance

As stakeholder demand for ESG information has intensified, business responsibility has become imperative, driven by increased scrutiny and regulation. Verified data by independent assurance specialists strengthens credibility and supports strategic decision-making, while avoiding fines and reputational damage.

RSM understands how companies align with societal and regulatory shifts toward sustainability and accountability.

Meet our ESG and sustainability leaders

Contact our sustainability and ESG team

Our sustainability and ESG professionals are here to help you succeed

"