[updated version of an article previously published on 9 October 2025]
On 23 December 2025, the act of 12 December 2025 transposing the “Stop-the-Clock” Directive was published in the Belgian Official Gazette. It entered into force on the same day (see here).
The Belgian legislator has opted for a transposition without “goldplating” (i.e. without going beyond what the Directive requires). The act postpones the application of the upcoming CSRD-requirements for two years 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 are now 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 are now 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 remains (for the time being) under an obligation to report under the CSRD. Their reporting requirements are not postponed.
As the CSDDD has not yet been transposed into Belgian law, the act solely aims to amend the national legislation transposing the CSRD.
For more details on the scope of the CSRD (and the CSDDD) following the recently adopted Omnibus I Directive, please consult our article (available in English only). This article also discusses the option for Member States to derogate from the current reporting obligations for the “first wave” of large public interest entities with more than 500 employees.
