CSRD postponed to 2028: what it means for your business

Anyone who has heard of the "Stop-the-Clock" directive in recent months is rightly wondering: Does this mean I can forget about the sustainability report for now? The short answer: For direct CSRD compliance, yes; for the pressure from your supply chain, no. This article clarifies what is actually changing.

How this feels in practice for suppliers

An example: An automotive supplier delivers to an OEM that would originally have been subject to CSRD reporting for 2026. Due to the postponement, the OEM now only reports for the 2027 financial year. For the supplier, this does not necessarily mean the all-clear: The OEM has announced that it will nevertheless start building its supplier database from 2026 in order to be prepared for 2028. The customer request therefore remains real, only the formal legal deadline in the background has shifted – a difference that is barely noticeable in the supplier's daily practice.

Why this news can still bring reassurance

For medium-sized companies that would never have fallen under the CSRD obligation themselves, the postponement changes little in their own situation – but it confirms that overall regulatory pressure is decreasing rather than increasing. This at least removes the concern that medium-sized businesses themselves could slip into a direct CSRD obligation in the foreseeable future.

The background: why the postponement happened in the first place

Even before entering into force, the original CSRD schedules were criticized by many companies as too ambitious – especially the short lead time for second-wave companies that should have reported for the first time for the 2025 financial year. As part of the larger Omnibus package, which aims to simplify and relieve companies, the EU decided on two parallel measures: raising the thresholds (fewer companies are affected at all) and postponing the initial publication via the Stop-the-Clock directive (the remaining companies get more preparation time).

Timeline at a glance

The postponement exclusively affects the left column – the direct legal CSRD obligation of large companies. The right column, in particular the VS 2026 and the associated Value Chain Cap, remains unaffected and is already legally anchored.

What large companies are nevertheless doing already

An important, often overlooked point: Even though the legal deadline has been postponed to 2028, many of the affected large companies are already preparing internally – including data collection from their suppliers. The reason is simple: A complete CSRD reporting with Scope 3 data from the entire supply chain cannot be set up at short notice. Experience shows that those who have to report in 2028 often start collecting data from suppliers 12–24 months in advance – this explains why some SMEs are already receiving concrete inquiries despite the postponement of the deadline.

What the Stop-the-Clock directive specifically regulates

Originally, "second wave" companies were supposed to publish their first CSRD reports in 2026 for the 2025 financial year. With the Stop-the-Clock directive, this was postponed by two years – to 2028 for the 2027 reporting year. Together with the thresholds raised by the Omnibus package (now over 1,000 employees and over €450 million in turnover, cumulative), significantly fewer companies fall under the direct CSRD obligation than originally planned – and those that are affected have more time.

What this does NOT mean

The most important point for you as a medium-sized company: This postponement affects the direct legal reporting obligation of large companies – not the pressure that arrives at you as a supplier via the market. Three things remain unchanged:

• Major customers who are themselves (still) subject to CSRD or will become so in 2028 will continue to request data from their suppliers at an early stage – lead time for their own reporting is a common reason.

• EcoVadis, voluntary questionnaires and bank inquiries are completely unaffected by the CSRD postponement. They follow their own, company-internal schedules, not the CSRD calendar.

• The Value Chain Cap and the VS 2026 remain in force unchanged – the postponement only affects the initial CSRD publication of large companies, not the voluntary standard for medium-sized businesses.

The opportunity behind the postponement

Paradoxically, the postponement makes voluntary reports more attractive for medium-sized businesses, not superfluous: Those who are already building up a clean VS 2026 database now have a knowledge advantage over competitors who are waiting for the legal obligation – and are ready when the first major customer (even without their own CSRD obligation) asks for data. The postponement takes away time pressure, but not the strategic reason to act now.

How strait helps regardless of the CSRD calendar

strait is deliberately designed not for a specific reporting deadline, but for continuous, always up-to-date data collection. Whether your first report is triggered by a customer inquiry in 2026 or only by a CSRD obligation in 2028 – the database is already in place when the occasion arises.

Not sure if you should act now? The Sustainability Readiness Check shows you where you stand in three minutes – regardless of the CSRD schedule.

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