Commission adopts ESRS “quick fix” for wave one companies under CSRD

On 11 July 2025, the European Commission adopted a "quick fix" delegated act to revise the first set of European Sustainability Reporting Standards (ESRS) under the Corporate Sustainability Reporting Directive (CSRD) for wave one companies already conducting corporate sustainability reporting for financial year 2024.

What's the background?

The "quick fix" delegated act can be seen in the context of the Commission's proposals under the Omnibus I package, which aim to simplify and streamline EU sustainability reporting and due diligence requirements. For more information on the Omnibus I package and its current status, see here and here.

The Omnibus I package includes the stop-the-clock directive which, amongst other things, delays the application of CSRD for wave two and wave three companies by two years.

However, the stop-the-clock directive does not delay the reporting requirements for wave one companies. This means that, without this new delegated act, wave one companies would be required to report additional information for financial years 2025 and 2026 pursuant to certain "phase-in" provisions within the ESRS even though they may subsequently be taken out of scope of the CSRD in light of the Omnibus proposals or these requirements may be subsequently altered by the revised and simplified ESRS.

What are the key "quick fix" changes?

The "quick fix" delegated act

• delays by two years the additional reporting requirements that wave one companies would otherwise be required to meet for financial years 2025 and 2026, meaning they will not have to report additional information compared to financial year 2024.

• extends to all wave one companies (not only those with up to 750 employees) the phase-in provisions regarding ESRS E4 (biodiversity and ecosystems), ESRS S2 (workers in the value chain), ESRS S3 (affected communities), and ESRS S4 (consumers and end-users).

• extends to all wave one companies the safeguard provision, which provides that where an undertaking uses temporary exemptions for a complete topical standard, it is still required to report summarised information on the relevant topic if it has concluded that the topic is material.

What's next?

Once the Commission has adopted a delegated act, the Council of the European Union and the European Parliament generally have two months to raise any objections.

If no objections are raised, the delegated act will be published in the Official Journal of the EU and will enter into force on the third day following its publication. It will apply with respect to the financial years beginning on or after 01 January 2025.