On 16 September 2025, the Council of Ministers tabled a bill before Parliament to transpose the “Stop-the-Clock” Directive into Belgian law (see here).
The Council of Ministers has opted for a transposition without “goldplating” (i.e. without going beyond what the Directive requires). The bill provides for a two-year postponement in applying the upcoming CSRD requirements for:
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the “second wave” of companies and groups: large EU companies (i.e. companies satisfying at least two of the following criteria: more than 250 employees, annual net turnover above EUR 50 million, and a balance sheet total above EUR 25 million) and groups other than large public interest entities with more than 500 employees, which will be required to report in 2028 (instead of 2026) for financial year 2027 (instead of 2025); and
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the “third wave” of companies: SMEs with securities listed on an EU regulated market, which will be required to report in 2029 (instead of 2027) for financial year 2028 (instead of 2026).
The “first wave” of large public interest entities with more than 500 employees remain under an obligation to report under the CSRD for the first time this year (2025) for financial year 2024. Their reporting requirements are not postponed.
As the CSDDD has not yet been transposed into Belgian law, this bill solely aims to amend the national legislation transposing the CSRD.
For further details on the “Stop-the-Clock” Directive, see our previous article (available in English only).
