Stop The Clock, Start The Strategy – How Liechtenstein’s Two-Year CSRD Deferral Recalibrates ESG Timelines And Why Early Movers Will Outperform

Josef Bergt

2025

1 From sprint to carefully-paced marathon

When Liechtenstein transposed the Corporate Sustainability Reporting Directive (“CSRD”) on 1 July 2024, it locked thousands of undertakings into a frenetic implementation sprint; however, the Government’s Bill 51/2025, issued on 8 July 2025, now leverages the EU’s so-called “Stop the Clock” Directive (EU) 2025/794, embedded in the broader Omnibus I simplification package, to postpone the first mandatory sustainability reports for Wave 2 and Wave 3 companies by exactly two financial years, thereby transforming a regulatory cliff-edge into a manageable glide path.

This tactical pause is anything but a retreat: Brussels openly frames the measure as a competitiveness booster designed to trim red tape while preserving the Green Deal trajectory; Vaduz, eager to convert relief into strategic advantage, has opted for immediate incorporation through amendments to the Personen- und Gesellschaftsrecht (PGR; Persons and Companies Law) and the Offenlegungsgesetz (OffG; Disclosure Act) that will enter into force the day after publication.

2 New calendar – same ambition

Parallel provisions in the OffG shift identical dates for capital-market issuers.

For the equally headline-grabbing Corporate Sustainability Due Diligence Directive (CSDDD), the Liechtenstein draft mirrors Brussels by moving the first application forward by twelve months.

3 Implications that go far beyond “extra time”

• Resource re-allocation – Finance and legal teams may defer external-assurance budgets, yet IT architects should seize the window to integrate ESG data flows into ERP backbones rather than relying on tactical spreadsheets.
• Reporting perimeter creep – The Commission is simultaneously negotiating COM (2025) 81, a proposal to narrow the CSRD’s scope further; prudent boards will scenario-test both the deferral and a potential downsizing of obliged entities to avoid “double planning” fatigue.
• Capital-markets signalling – Investors already accustomed to SFDR look-through will scrutinise voluntary disclosures; early voluntary adoption may reduce the cost of capital even while the statutory clock is paused.
• Supply-chain interplay – Because the CSDDD shift is only one year, large groups should treat due-diligence mapping and ESRS data-gathering as twin projects rather than sequential endeavours.
• Audit trail synchronisation – Book-keeping records must be retained for ten years; aligning that horizon with the postponed ESG report cycle minimises storage risk and GDPR overhead.

4 Action plan: turning postponement into competitive leverage

1. Update the critical path – embed 2027/2028 milestones into enterprise-risk registers and integrate with budgeting cycles.
2. Refine double-materiality assessments – the methodology, not the publication date, drives stakeholder trust; pilot runs in FY 2025-2026 will de-risk mandatory filings.
3. Re-draft contractual ESG clauses – suppliers and portfolio targets should warrant readiness for the revised timeline to avoid late surprises during transactions.
4. Educate the C-suite – shorter briefings focusing on the strategic upside of voluntary front-running will outclass generic compliance memos.
5. Leverage supervisory dialogue – the FMA welcomes pre-consultations; early adopters often obtain interpretative guidance that later becomes de-facto market standard.

Sources: Report And Motion Concerning THE AMENDMENT TO THE LAW OF MARCH 7, 2024, ON THE AMENDMENT OF PERSONAL AND COMPANY LAW AND THE LAW OF MARCH 7, 2024, ON THE AMENDMENT OF THE DISCLOSURE LAW, No. 51/2025.

Key findings & core statements

• Two-year deferral: Wave 2 sustainability reporting starts with FY 2027, Wave 3 with FY 2028, granting firms additional preparation bandwidth.
• No change for Wave 1: PIEs above 500 employees remain on the original CSRD schedule.
• CSDDD shifted by one year, aligning due diligence with a 2028 kick-off
• Goal is competitiveness, not rollback: the deferral is part of the EU’s Omnibus I programme to streamline reporting and stimulate growth
• Liechtenstein implements at high speed, laws entering into force immediately upon publication to maximise corporate relief
• Strategic opportunity: companies that invest early in robust ESG infrastructure will secure investor confidence and supervisory goodwill before peers.

Our cross-disciplinary team of lawyers and network of chartered accountants and former regulators—has already assisted listed and non-listed groups in mapping ESRS datapoints, engineering assurance-ready governance and negotiating transition relief with auditors. Engage us now to convert regulatory breathing space into shareholder value.