CSRD Omnibus Update: Stop the Clock Transposition Continues and Substantive Changes Near Finalization

Viewpoints
December 23, 2025
1 minutes

Ropes & Gray – in conjunction with leading law firms across Europe – has published a new update of its monthly CSRD Transposition Tracker. The Tracker describes Corporate Sustainability Reporting Directive transposition and Omnibus activity across the 27 EU member states and three EEA EFTA countries. This update includes information and developments as of November 30, and for some countries into December, as well as additional commentary from the participating law firms.

The Tracker is available here.

Regarding the “Stop the clock” directive: 19 countries have adopted implementing legislation and five countries have introduced, but not yet adopted, legislation. For further details, see the Tracker.

The substantive changes to the Omnibus also are nearing finalization. The European Parliament and European Council reached provisional agreement on these changes in early December. That agreement was subsequently approved by the European Parliament and awaits final approval by the European Council and publication of the directive in the Official Journal, after which the directive will need to be transposed into law by EU member states. 

We discuss the agreement and proposed changes here. In addition, EFRAG submitted its technical advice to the European Commission on the draft simplified European Sustainability Reporting Standards in early December.

We will continue updating the Tracker to include further developments. To receive updates to the Tracker and other Ropes & Gray ESG, CSR and business and human rights compliance thought leadership, subscribe here.