The European Union’s “stop-the-clock” Directive postponed the first reporting dates for companies that had been in the second and third waves of the Corporate Sustainability Reporting Directive. Separately, the EU institutions reached a political agreement on the Omnibus I simplification package in December 2025.
Timelines and scope may change, but the underlying business need for reliable sustainability information has not disappeared. Customers, lenders, investors, parent companies, and procurement teams may still request emissions and sustainability data.
The strongest response is to separate no-regret data work from requirements that are still changing.
Reconfirm scope instead of relying on an old assessment
Document the entities, employee counts, financial thresholds, securities, and EU or non-EU status used in your assessment. Identify the national law relevant to each entity and record the date and source of the conclusion.
Do not assume that a group-wide answer applies identically to every subsidiary. Also distinguish direct reporting obligations from value-chain information requests. A company outside mandatory scope may still need a proportionate response to customer or lender questionnaires.
The European Commission’s corporate sustainability reporting page maintains the official policy timeline and links to adopted acts.
Continue the work that improves any disclosure
Several capabilities remain useful across CSRD, ISSB-aligned requirements, customer requests, and voluntary reporting:
- A documented reporting boundary and entity register.
- A complete Scope 1 and Scope 2 inventory with controlled methods.
- A Scope 3 screening that identifies material value-chain categories.
- Named data owners and evidence-retention rules.
- A risk and opportunity process connected to business planning.
- Governance records showing review, challenge, and approval.
- A cross-reference between source data and reported disclosures.
These foundations are expensive to recreate under deadline pressure and valuable even when a specific datapoint changes.
Make materiality evidence reusable
Keep the evidence behind the materiality process: stakeholder inputs, impacts, risks, opportunities, scoring criteria, thresholds, challenge sessions, and approvals. Store source evidence separately from the presentation layer.
If a standard changes, the team can remap well-governed evidence more efficiently than it can reconstruct undocumented decisions. This is also important for assurance, where the reviewer needs to understand how a conclusion was reached—not only see the conclusion.
Avoid collecting every possible datapoint
Delay is not an invitation to build the largest possible questionnaire. Focus on information tied to material topics, current business decisions, likely reporting needs, or recurring stakeholder requests.
Classify fields as required now, likely future need, voluntary management metric, or deferred pending final rules. This reduces supplier fatigue and helps teams concentrate controls on information that will actually be used.
Use the time to fix ownership and controls
Many reporting problems are operating-model problems: nobody owns the source, definitions vary by region, evidence is stored in email, or adjustments are not approved.
Use the extended runway to assign owners, standardize definitions, test data submissions, set variance thresholds, document estimations, and run a dry close. These changes improve both efficiency and the credibility of any eventual report.
Rules should be reassessed at each reporting decision point. Preserve an audit trail of the official sources and legal advice used. This article reflects information available on February 19, 2026 and provides general information, not legal advice.
Sources
See how Carbon Impact supports CSRD reporting — from data collection to disclosure.