On 12 September 2025, the Dutch State Secretary for Justice and Security submitted a revised draft CSRD implementing decree to both the House of Representatives and the Senate. The draft decree has been amended to incorporate the CSRD-related provisions of the “Stop-the-Clock” Directive, which postpones the application of current CSRD requirements for the "second wave" and "third wave" of companies by two years, from financial year 2025 to financial year 2027. The Stop-the-Clock Directive needs to be implemented by 31 December 2025, while the CSRD itself should have been implemented already. For further background on the Stop-the-Clock Directive, see our April 2025 article and our flowchart.

The revised draft decree also introduces certain editorial and technical adjustments – these are outlined in an accompanying letter to parliament.

Parliament may submit questions on the amendments until 13 October 2025, in line with the prescribed timeframe for the preliminary scrutiny procedure. If this preliminary scrutiny does not result in substantive changes, the draft decree will proceed to the Advisory Division of the Council of State for further review.

"First wave" companies

The deadline for the “first wave” of companies to report in compliance with the CSRD from the financial year starting on or after 1 January 2024 remains unchanged in the revised draft decree, so this obligation effectively applies with retroactive effect. This was also confirmed in the government's response published on 29 September 2025 (see below). As "first wave" companies are not covered by the Stop-the-Clock deferral, the State Secretary has emphasised that the Dutch government cannot change the obligations of these companies but will continue to push at the EU level for measures to reduce administrative burdens and provide greater legal certainty.

Implementing bill

As to the CSRD implementing bill, the bill was already amended in June 2025 to incorporate the CSRD-related elements of the Stop-the-Clock Directive. See our June 2025 article for more information. The government's response to the parliamentary questions raised in a report of 27 June 2025 was published on 29 September 2025. In the response, the government reiterated the government's commitment that the CSRD implementing act and the CSRD implementing decree will enter into force simultaneously, ensuring that there can be no uncertainty about the applicability of the obligations arising from the decree and the act. The government also noted that the Omnibus Proposal is to be implemented by 31 December 2026 at the latest.

The bill will now move to plenary debate in the House of Representatives. The Dutch general election scheduled for 29 October 2025 may affect the timing of the subsequent legislative process. However, the European Commission has already launched infringement proceedings against the Netherlands for missing the CSRD implementation deadline, and it has stressed that no further postponement is possible.