Beyond the GAAP no. 198 – April 2025

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Following the publication in the EU Official Journal of the "Stop the clock" Directive on 16 April, European entities in "waves 2 and 3" are now certain that they will not have to publish sustainability information for the 2025 and 2026 financial reporting periods. The Directive must now be transposed before 31 December. Regarding the ongoing negotiations on the draft "Content" Directive, the positions expressed in the Council and Parliament show, unsurprisingly, that it will not be easy to reach rapid agreement among co-legislators particularly on the scope of the CSRD.

Beyond this two-year deferral, the European Commission is also working on an amendment to the Set 1 of the ESRS expected to be adopted in June, to ease the reporting burden on entities in “wave 1” pending the adoption of simplified ESRS. According to this amendment, wave 1 entities would be allowed to prepare their sustainability reports for the 2025 and 2026 financial periods using the same transitional provisions as those applicable to the 2024 financial period. Besides, EFRAG has adopted the work plan that will enable it to submit its technical advice to the Commission no later than 31 October. A public consultation on the draft standards is therefore planned for this summer, for a very limited period. Stakeholders would be well advised to keep a close eye on EFRAG's discussions over the coming weeks so as to prepare as effectively as possible for this consultation.