EC publishes “Quick Fix” Delegated Regulation in Official Journal

On 10 November 2025, the European Commission (the Commission) published a "quick fix" delegated regulation in the Official Journal.

The delegated regulation will enter into force on 13 November 2025 and applies retrospectively to financial years beginning on or after 1 January 2025.

By way of background, the "stop-the-clock" directive, introduced as part of the Omnibus I package, delays the application of Corporate Sustainability Reporting Directive (CSRD) for wave two and 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 have been required to report additional information for financial years 2025 and 2026.

As a result, the quick fix delegated act revises the first set of European Sustainability Reporting Standards (ESRS) under the CSRD for wave one companies already conducting corporate sustainability reporting for the 2024 financial year.

For our article on the Commission's adoption of the draft delegated regulation, see here.

What are the key "quick fix" changes?

The "quick fix" delegated regulation:

• delays by two years the requirement for wave one companies to report on the anticipated financial effects of sustainability-related risks until 2027.

• extends to all wave one companies (not only those with up to 750 employees) the phase-in provisions relating to 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.

Next steps

The Commission and EFRAG (European Financial Reporting Advisory Group) are working on separate legislation to simplify and clarify the ESRS Regulation.