The EU “Stop-the-Clock” Directive under the CSRD is implemented under Belgian law. Second and third waves of the targeted companies now postponed by two years.

On 23 December 2025, the Belgian Official Gazette published the law of 12 December 2025 that postpones the entry into force of sustainability reporting obligations under CSRD. This is the implementation of the EU “Stop-the-Clock” Directive that aimed to provide companies with sufficient time to prepare, avoid unnecessary costs, and maintain legal coherence with the EU framework. 

The law of 12 December 2025, amending the provision regarding the entry into force of the law of 2 December 2024 which implemented the Corporate Sustainability Reporting Directive (CSRD) under Belgian law, has been published in the Belgian Official Gazette. This law implements the EU “Stop-the-Clock” Directive, whose purpose is to make the implementation of EU regulatory obligations regarding the reporting on environmental  and social sustainability more gradual and realistic, taking into account the operational needs and timeframes of companies for implementation. The implementation has been made just in time, as the “Stop-the-Clock” Directive had to be transposed into national law by 31 December 2025 at the latest. Belgian law is now aligned with the updated European timetable. 

In practice, the Belgian law postpones by two years the sustainability reporting obligations for large companies and for listed SMEs, granting them additional time to prepare: large companies that are not public-interest entities, corresponding to the second wave of reporting, will now be required to report for the financial year beginning in 2027 (instead of 2025), and listed SMEs (forming the third wave), will need to report for the financial year beginning in 2028 instead of 2026. 

The first wave of companies is already subject to CSRD (listed companies, banks, insurance and reinsurance companies): they had to report on sustainability for the financial year beginning on 1 January 2024. 

The financial year starting 1 January 2028 (or a later date) remains unchanged for third-country companies. 

These adjustments provide companies with additional time to implement the necessary internal reporting systems, data collection processes, and assurance mechanisms, ensuring compliance with both Belgian law and EU requirements.

Overall, this amendment ensures that the Belgian reporting calendar is aligned with the revised EU timetable, providing predictability, proportionality and legal certainty, while avoiding the risk of an earlier application of CSRD obligations at national level than at EU level.

Key message

Companies should carefully assess which reporting category they fall into under CSRD framework, as the postponement primarily applies to certain large companies and listed SMEs. 

Strategic planning during the additional preparation period is recommended, including strengthening internal sustainability reporting processes, governance structures, and assurance mechanisms, so that the first reports for the financial years 2027 or 2028 are compliant, accurate, and reliable.

Since sustainability notably includes social and governance aspects, our experts can help you with any questions this may raise.