CSRD: two-year postponement for sustainability reports
Sustainability remains a key objective
on the European agenda
The main argument for this postponement is clear: to avoid unnecessary costs and give companies time to prepare properly. Preparing reports under the CSRD standard involves significant investments in resources, training, technology and internal governance. For many organisations, especially large unlisted companies and small and medium-sized enterprises not excluded on specific grounds, the administrative burden posed an imminent challenge. In this sense, the new timetable is a pragmatic decision.
In addition, the directive keeps intact essential elements such as the threshold of 500 employees for mandatory reporting, which provides regulatory stability in the face of the more disruptive proposals that were contemplated under the ‘omnibus’ legislative package. This continuity is valued by market players, who were calling for certainty in the face of frequent regulatory adjustments.
However, this postponement can also be interpreted as a risky pause. Commitment to sustainability should not depend exclusively on mandatory compliance, but on a comprehensive and proactive business strategy. Delaying the obligation may slow down the adoption of responsible policies, particularly in companies that have not yet internalised sustainability as a strategic value. Therefore, the national transposition of this directive, scheduled for 31 December 2025, must be accompanied by support plans, incentives and even mild penalties for those who do not move forward on their own initiative.
New deadlines
Directive (EU) 2025/794 should be understood as a temporary readjustment without concessions on the objectives. Europe remains on course towards a more transparent and sustainable economy, but recognises the need to allow time to ensure effective and realistic implementation. The extension of deadlines should not be interpreted as a relaxation, but as an opportunity for companies to prepare adequately and meet the required standards without incurring unnecessary costs or implementation errors. In short, sustainability is not being postponed: it is being better organised.
CSRD TIMELINE
(According to fiscal year)
- 2024
2024
- 2027
2027
Phase 2: Large companies that meet two of the following criteria:
+ 250 employees
+ €50 million in turnover
+ €25 million in assets.
They must report sustainability information from 1 January 2027.
- 2028
2028
Phase 3: Listed SMEs
Except micro-SMEs
They must report sustainability information from 1 January 2028.
- 2029
2029
Companies from third countries:
Activities in the EU
+ €50 million in revenue
With subsidiaries or headquarters in SpainMust report sustainability information from 1 January 2029
- 2024
2024
- 2027
2027
Phase 2: Large companies that meet two of the following criteria:
+ 250 employees
+ €50 million in turnover
+ €25 million in assets.
They must report sustainability information from 1 January 2027.
- 2028
2028
Phase 3: Listed SMEs
Except micro-SMEs
They must report sustainability information from 1 January 2028.
- 2029
2029
Companies from third countries:
Activities in the EU
+ €50 million in revenue
With subsidiaries or headquarters in SpainMust report sustainability information from 1 January 2029
- 2024
2024
- 2027
2027
Phase 2: Large companies that meet two of the following criteria:
+ 250 employees
+ €50 million in turnover
+ €25 million in assets.
They must report sustainability information from 1 January 2027.
- 2028
2028
Phase 3: Listed SMEs
Except micro-SMEs
They must report sustainability information from 1 January 2028.
- 2029
2029
Companies from third countries:
Activities in the EU
+ €50 million in revenue
With subsidiaries or headquarters in SpainMust report sustainability information from 1 January 2029
Current situation in Spain
The Draft Law on Corporate Sustainability Information, published on 15 November 2024, aims to transpose Directive (EU) 2022/2464 into Spanish law. This regulation introduces the obligation for certain companies to disclose sustainability information, amending the Commercial Code, the Capital Companies Act and the Audit Act. It establishes that large companies, certain listed SMEs (excluding micro-enterprises), financial institutions and insurance companies, as well as subsidiaries of foreign companies with significant activity in the EU, must comply with this obligation.
The content of the report must include environmental, social and governance aspects, human rights, the fight against corruption, the business model, strategy, risks, climate objectives and the value chain.
Verification of this information will be mandatory and must be carried out by independent auditors or accredited entities, under the supervision of the ICAC. In addition, the report must be submitted in a standardised electronic format, published on the company's website for five years and approved by the general meeting of shareholders. This law reinforces the principle of double materiality and seeks to improve the transparency, reliability and comparability of non-financial information, now referred to as sustainability information.
As an EU member state, Spain must transpose Directive 2025/794, which amends the deadlines of Directive 2022/2464, by 31 December 2025.
How can we help you?
Our services range from compliance gap analysis and double materiality assessment to the definition of an ESRS-compliant reporting framework, the implementation of ESG data management systems and adaptation to XBRL, as well as technical training for teams and the development of sustainable transition strategies.
We support companies at every stage of the process: before, during and after implementation, ensuring that the additional time granted by Directive (EU) 2025/794 is used strategically.
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