What the 'Stop the Clock' Directive Means for Hotel CSRD Reporting

The recent adoption of the Stop the Clock Directive by the European Commission has introduced some updated timelines to the EU’s Corporate Sustainability Reporting Directive (CSRD). While it doesn’t reverse the CSRD, it adjusts the timeline for some of the reporting for sustainability data. 

What does this mean for hotels? In this blog, we break down what the Stop the Clock Directive actually changes, what it doesn’t, and how Alkimii Insights can give your hotel a strategic advantage during the transition. 

What Is the Stop the Clock Directive? 

The Stop the Clock Directive, adopted by the European Commission in June 2024, allows companies to defer reporting on some of the more challenging data points required under the European Sustainability Reporting Standards (ESRS). 

It offers temporary opt-outs for the first year of CSRD reporting (2025 for most large hotels), particularly where data is difficult to obtain or verify - such as Scope 3 greenhouse gas emissions or value chain workforce metrics. 

FAQ 1: What constitutes a large hotel in CSRD reporting criteria? 

Under the CSRD, a hotel group is considered “large” if it meets two or more of the following criteria: 

• More than 250 employees 

• More than €40 million in annual turnover 

• More than €20 million in total assets 

If your group exceeds these thresholds at a consolidated level, you are considered in-scope for the earlier CSRD waves. These criteria align with the EU Accounting Directive’s definition of large undertakings. 

Key points for hotels: 

• Your CSRD reporting date stays the same based on your company size and listing status. 

• You can defer some datapoints until later years but must explicitly declare that you are using the opt-out. 

• The opt-out is time-limited, only valid for the first year of reporting, and does not cover core topics like governance, double materiality, or business strategy. 

What Remains Mandatory for Hotels? 

Even with the new flexibility, several CSRD requirements still apply: 

• Double Materiality Assessment: Hotels must assess both how sustainability issues impact the business and how the business impacts people and planet. 

• Strategy & Governance Disclosure: You must show how sustainability is embedded in your strategy and overseen by leadership. 

• Core Workforce Metrics: Foundational data such as pay, employee turnover, and working conditions must be included. 

• Third-Party Assurance: Sustainability data will still be subject to independent audit from your first reporting year. 

FAQ 2: What is a Double Materiality Assessment? 

A Double Materiality Assessment (DMA) is a cornerstone of CSRD reporting. It means assessing sustainability topics from two perspectives: 

You must identify which Environmental, Social, and Governance (ESG) topics are material under each lens—and explain your reasoning. 

Why Hotels Should Not Delay 

Delaying preparations entirely risks falling behind. Here’s why: 

• Large travel groups may still request supplier data, regardless of your opt-out status. 

• Data readiness takes time, especially for HR metrics like pay rates, diversity, and turnover that require coordination across properties. 

• Your sustainability reputation is already in the spotlight, and being transparent now strengthens brand trust. 
• Non-compliance penalties are still on the table after the first year if foundational standards are ignored. 

Source: European Union, Directive (EU) 2025/794 

📊 How Alkimii Insights Helps with CSRD Reporting 

Alkimii Insights gives hotel groups the power to meet CSRD obligations confidently, with intuitive dashboards that transform operational data into structured, auditable reporting. 

✅ Workforce Composition & Headcount Visibility 

Your CSRD dashboard includes real-time breakdowns of: 

• Total, permanent, and temporary headcount 

• Headcount by country, site, gender, and nationality 

These data points are essential for ESRS S1 (Own Workforce), particularly for disclosing gender balance, diversity, and employment stability across regions. 

💼 Turnover & Mobility Reporting 

Alkimii’s turnover tracking covers: 

• Overall, voluntary, and involuntary turnover percentages 

• Drilldowns by dismissal vs redundancy 

• Customisable date filters 

These insights support both risk disclosures and social capital metrics under CSRD, such as workforce retention and internal mobility. 

💶 Pay Transparency & Gender Pay Comparisons 

The Pay Rates dashboard gives granular insight into compensation across your organisation: 

• Average basic hourly rate of pay by gender, site, and currency 

• Lowest and highest pay rates by country 

• Comparisons across Euro and Pound zones 

• Filters by contract type and country 

This supports equitable pay reporting under ESRS S1 and helps expose gaps that may affect social equity metrics or investor perception. 

⏱ Hours Worked & Shifts 

To meet transparency expectations around working conditions: 

• Total hours worked by country and gender 

• Total shifts scheduled 

📊 Benchmarking for Accountability 

The Alkimii Benchmark lets you compare your organisation’s data to industry averages. Use it to track fairness in pay, address high turnover locations, or identify emerging risks in your workforce strategy. 

Alkimii’s Gender Pay Gap Report 

Pay transparency is a critical requirement under the European Sustainability Reporting Standards (ESRS S1 - Own Workforce), and it’s a key area where hotels can lead with data. Alkimii’s Gender Pay Gap Report empowers hotel leadership with organised, actionable data ready to export and analyse. 

With CSRD now requiring workforce-related disclosures to be auditable and specific, Alkimii’s report ensures you are already aligned. 

What Hotels Should Do Now 

• Familiarise yourself with the latest EU regulations and what is relevant to your hotel. 
• Continue your double materiality assessment to define what’s most important to disclose. 
• Use the opt-out where justified but keep track of deferred datapoints for future inclusion. 
• Standardise your workforce data now using Alkimii, so you are audit-ready when full disclosure resumes. 
• Benchmark your current performance and identify where improvements are most needed. 

Conclusion 

The Stop the Clock Directive is a helpful adjustment, not a reason to slow down. With Alkimii Insights, hotels can build a foundation for long-term sustainability reporting - and use this breathing space to lead the way in transparency, fairness, and data-led decision-making. 

Alkimii user and want to get ahead of CSRD reporting? 

 
Reach out to our Customer Success team at hello@alkimii.com with any queries you may have about pulling information from Alkimii. 

Not yet an Alkimii user? Book a demo today!

Disclaimer: This article is provided for general informational purposes only and does not constitute legal, financial, or sustainability reporting advice. While efforts have been made to ensure the accuracy of the information at the time of publication, regulations such as the CSRD and associated directives may evolve. Hotels are encouraged to consult with qualified legal or ESG advisors to assess their specific obligations under EU law.