Joint Position Paper – Extending the ‘Stop-the-Clock’ Initiative to Wave 1 Companies

IOGP Europe, FuelsEurope, Euromines, and the International Copper Association Europe have co-signed a joint position paper calling on the European Commission to extend the scope of the "Stop-the-Clock" initiative to include Wave 1 companies under the Corporate Sustainability Reporting Directive (CSRD). 

While we fully support the EU’s objective to reduce administrative burden and improve the quality of sustainability reporting, the current proposal excludes large public-interest companies (Wave 1) from the deferral, despite these organizations facing the same structural, regulatory and operational challenges as others. 

This creates significant risks of: 

• Legal fragmentation across Member States 

• Unfair competitive disadvantages for first movers 

• Lower-quality reporting due to compressed timelines and limited assurance capacity 

In our joint paper, we set out five core reasons why Wave 1 companies should be granted the same deferral as other large undertakings: 

1. Ensure legal coherence and equal treatment 
2. Preserve a level playing field within EU markets 
3. Allow sufficient time for operational implementation 
4. Align compliance timelines with finalised EU guidance 
5. Improve consistency, comparability, and reporting quality 

We believe that extending the deferral to all large companies would not compromise the EU’s sustainability ambitions. On the contrary, it would help deliver a more coherent, realistic, and robust sustainability framework — in line with the Commission’s broader goals to reduce reporting burdens by 25%. 

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