---
title: "EU CSRD Timeline, Reporting Decision Flow, and ESRS Guides"
canonical_url: "https://www.sorena.io/artifacts/eu-csrd"
source_url: "https://www.sorena.io/artifacts/eu/corporate-sustainability-reporting-directive"
author: "Sorena AI"
description: "Use this CSRD hub to confirm scope, apply the stop the clock amendment correctly, build an ESRS reporting model, and prepare double materiality."
published_at: "2026-02-22"
updated_at: "2026-02-22"
keywords:
  - "EU CSRD"
  - "Directive (EU) 2022/2464"
  - "ESRS"
  - "CSRD deadlines"
  - "stop the clock CSRD"
  - "CSRD applicability"
  - "double materiality"
  - "value chain data"
  - "sustainability statement"
  - "limited assurance"
  - "ESEF sustainability reporting"
  - "Taxonomy Article 8"
  - "Assurance"
---
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# EU CSRD Timeline, Reporting Decision Flow, and ESRS Guides

Use this CSRD hub to confirm scope, apply the stop the clock amendment correctly, build an ESRS reporting model, and prepare double materiality.

![EU CSRD artifact preview](https://cdn.sorena.io/cdn-cgi/image/format=auto/cheatsheets/prod/sorena-ai-eu-csrd-timeline-small.jpg?v=cheatsheets%2Fprod)

*CSRD* *Free Resource*

## EU CSRD Timeline, reporting decision flow and ESRS guides

Use this artifact to determine whether Directive (EU) 2022/2464 applies, assign the correct reporting wave after the 2025 stop the clock amendment, and build a reporting system for double materiality, value chain data, ESRS disclosures, assurance, and digital publication.

The dates on many CSRD summaries are now stale. Wave one still started with financial years beginning on or after 1 January 2024. Directive (EU) 2025/794 pushed the second wave to financial years beginning on or after 1 January 2027 and the listed SME wave to financial years beginning on or after 1 January 2028.

[Plan CSRD reporting](/contact.md)

## What you can decide faster

- **Who reports when**: Confirm the entity category, the reporting boundary, and the current start year without relying on outdated wave charts.
- **What to disclose**: Route ESRS general, topical, value chain, and Taxonomy linked work into one data model.
- **What must be reviewable**: Prepare the evidence, markup, and assurance controls that can survive audit committee and external scrutiny.

By Sorena AI | Updated 2026 | No signup required

### Quick scan

*CSRD*

- **Wave check**: Use the stop the clock amendment before you set your first reporting year.
- **ESRS engine**: Build the double materiality, IRO, and value chain logic before drafting disclosures.
- **Assurance pack**: Link narrative, metrics, taxonomy KPIs, and digital files to one evidence model.

Start with the decision flow, then use the topic pages to build materiality, controls, value chain methods, and filing readiness.

| Value | Metric |
| --- | --- |
| FY 2024 | Wave 1 |
| FY 2027 | Wave 2 |
| FY 2028 | Wave 3 |
| 1 Oct 2026 | Assurance stds |

**Key highlights:** Double materiality | Value chain data | Assurance ready

## Topic Guides

- [EU CSRD Applicability Test | Current Scope and Reporting Waves](/artifacts/eu/corporate-sustainability-reporting-directive/applicability-test.md): Use this CSRD applicability test to determine whether your entity is in scope, whether a group exemption applies.
- [EU CSRD Assurance Ready Controls and Evidence | Limited Assurance Preparation](/artifacts/eu/corporate-sustainability-reporting-directive/assurance-ready-controls-and-evidence.md): Prepare CSRD reporting for limited assurance with controls that tie metrics, narratives, markup, and Taxonomy KPIs back to evidence.
- [EU CSRD Checklist | Practical Reporting and ESRS Checklist](/artifacts/eu/corporate-sustainability-reporting-directive/checklist.md): Use this CSRD checklist to move from scope to report delivery.
- [EU CSRD Compliance Guide | Reporting System, Controls, and Delivery Model](/artifacts/eu/corporate-sustainability-reporting-directive/compliance.md): Build a publication grade CSRD reporting system with the right scope memo, materiality process, ESRS data model, value chain logic, Taxonomy linkage.
- [EU CSRD Deadlines and Compliance Calendar | Current Waves, Quick Fix, and Assurance Dates](/artifacts/eu/corporate-sustainability-reporting-directive/deadlines-and-compliance-calendar.md): Track the current CSRD reporting waves, the July 2025 stop the clock amendment, the July 2025 ESRS quick fix.
- [EU CSRD Double Materiality Interview Question Bank | Practical Stakeholder Questions](/artifacts/eu/corporate-sustainability-reporting-directive/double-materiality-interview-question-bank.md): Use this CSRD question bank to run a stronger double materiality process.
- [EU CSRD Double Materiality Method | Building a Reviewable ESRS Methodology](/artifacts/eu/corporate-sustainability-reporting-directive/double-materiality-method.md): Build a reviewable double materiality method for the CSRD and ESRS.
- [EU CSRD ESRS Structure and Data Model | How to Organize ESRS Reporting](/artifacts/eu/corporate-sustainability-reporting-directive/esrs-structure-and-data-model.md): Understand how to organize ESRS reporting under the CSRD.
- [EU CSRD FAQ | Current Answers on Waves, ESRS, Assurance, and Taxonomy](/artifacts/eu/corporate-sustainability-reporting-directive/faq.md): Get grounded answers to common CSRD questions, including the current reporting waves after the stop the clock amendment, ESRS quick-fix reliefs.
- [EU CSRD Penalties and Fines | National Enforcement and Reporting Exposure](/artifacts/eu/corporate-sustainability-reporting-directive/penalties-and-fines.md): Understand how CSRD enforcement works in practice. This guide explains the role of national transposition, accounting and transparency law enforcement.
- [EU CSRD Requirements | Article by Article Reporting and Assurance Map](/artifacts/eu/corporate-sustainability-reporting-directive/requirements.md): Map the core CSRD requirements by workstream, including the sustainability statement, ESRS, double materiality, value chain reporting, Taxonomy linkage.
- [EU CSRD Scope and Phasing by Company Type | Current Wave Map by Entity Category](/artifacts/eu/corporate-sustainability-reporting-directive/scope-and-phasing-by-company-type.md): Review current CSRD phasing by company type, including wave one public interest entities, wave two large undertakings.
- [EU CSRD Value Chain Data and Estimation | Practical Method for ESRS Reporting](/artifacts/eu/corporate-sustainability-reporting-directive/value-chain-data-and-estimation.md): Build a defensible CSRD value chain method using ESRS rules and official guidance.
- [EU CSRD vs IFRS S1 and S2 | Double Materiality versus Investor Focused Disclosure](/artifacts/eu/corporate-sustainability-reporting-directive/csrd-vs-ifrs-s1-and-s2.md): Compare the EU CSRD and ESRS with IFRS S1 and IFRS S2 using official sources.
- [EU CSRD vs SEC Climate Disclosure Rule | Scope, Status, and Reporting Logic](/artifacts/eu/corporate-sustainability-reporting-directive/csrd-vs-sec-climate-disclosure-rule.md): Compare the EU CSRD and ESRS with the SEC climate disclosure rule using official sources.
- [EU CSRD vs Taxonomy Alignment | ESRS Reporting versus Article 8 KPIs](/artifacts/eu/corporate-sustainability-reporting-directive/csrd-vs-taxonomy-alignment.md): Compare CSRD reporting with EU Taxonomy alignment disclosures.

## Key dates for rollout, ESRS, and assurance

*CSRD Timeline*

Track the current wave dates, ESRS support acts, and assurance deadlines so finance, ESG, legal, and reporting teams work from one calendar.

## Does CSRD apply and what must you build first

*CSRD Decision Flow*

Follow the reporting decision flow to test scope, assign the right first reporting year, and route the result into ESRS, value chain, Taxonomy, assurance, and filing workstreams.

*Next step*

## Turn EU CSRD Timeline, reporting decision flow and ESRS guides into an ESG delivery workflow

EU CSRD Timeline, reporting decision flow and ESRS guides should be the shared entry point for your team. Route execution into ESG Compliance for live work and into SSOT when the artifact needs deeper research, evidence governance, or supporting analysis.

- Start from EU CSRD Timeline, reporting decision flow and ESRS guides and route the work by entity, product, team, or control owner.
- Use ESG Compliance to manage cross team sustainability work, reporting, and evidence from one workflow.
- Use SSOT to keep documents, evidence, and control records in one governed system.
- Move from artifact reading to accountable execution without rebuilding the guidance in separate files.

- [Open ESG Compliance](/solutions/esg-compliance.md): Manage cross team sustainability work, reporting, and evidence from one workflow for EU CSRD Timeline, reporting decision flow and ESRS guides.
- [Open SSOT](/solutions/ssot.md): Keep documents, evidence, and control records in one governed system from the same artifact.
- **Download decision flow**: Share scope and wave logic with finance and ESG.
- **Download timeline**: Align the reporting calendar with the current law.
- [Talk through EU CSRD Timeline, reporting decision flow and ESRS guides](/contact.md): Review your current process, evidence model, and next steps for EU CSRD Timeline, reporting decision flow and ESRS guides.

## Decision Steps

### STEP 1: Is your company an EU undertaking (formed under Member State law)?

*Reference: Directive (EU) 2022/2464; Directive 2013/34/EU (as amended)*

- CSRD introduces sustainability reporting obligations for certain EU undertakings and certain third-country undertakings through amendments to Directive 2013/34/EU.
- If yes: follow the EU track to determine whether you are a large undertaking, a listed SME (except micro), a small and non-complex credit institution, a captive insurer, or a parent of a large group.
- If no: follow the third-country track to check the Art. 40a thresholds (net turnover >EUR 150 million in the Union for each of the last two consecutive financial years, plus a qualifying EU subsidiary or branch).

- **YES** Does your company exceed the size criteria for a large undertaking?
- **NO** Does your non-EU company generate EUR 150M+ net turnover in the EU in each of the last two consecutive financial years?

### STEP 2: Does your company exceed the size criteria for a large undertaking?

*Reference: Art. 3(4) Directive 2013/34/EU*

- A large undertaking exceeds at least two of the following on its balance sheet date: (a) 250 employees; (b) EUR 20M balance sheet total; (c) EUR 40M net turnover.
- If yes: CSRD reporting applies starting FY 2025 (reports in 2026). Some companies already subject to NFRD start earlier (FY 2024, reports in 2025).
- If no but your securities are listed: check if you are a listed SME (next step).

- **YES** CSRD Applies (Large EU Company)
- **NO** Are your securities admitted to trading on an EU regulated market and are you an SME (not a micro-undertaking)?

### STEP 3: Are your securities admitted to trading on an EU regulated market and are you an SME (not a micro-undertaking)?

*Reference: Directive (EU) 2022/2464; Directive 2013/34/EU (as amended)*

- Listed SMEs (except micro-undertakings) must report under CSRD.
- Micro-undertaking (as defined for the Accounting Directive): does not exceed at least two of: EUR 350k balance sheet total; EUR 700k net turnover; 10 employees.
- Micro-undertakings are exempt.
- For financial years starting before 2028-01-01, listed SMEs may decide not to include sustainability reporting in their management report, but must briefly state why it was not provided (Directive 2013/34/EU, Art. 19a(7)).
- Listed SMEs report in accordance with sustainability reporting standards for SMEs adopted under Directive 2013/34/EU (Art. 29c).

- **YES** CSRD Applies (Listed SME)
- **NO** Are you a small/non-complex credit institution or a captive insurance undertaking?

### STEP 4: Are you a small/non-complex credit institution or a captive insurance undertaking?

*Reference: Art. 29a(2b) Directive 2013/34/EU*

- Small and non-complex credit institutions (as defined in CRD Art. 4(1)(145)) and captive insurance undertakings (Solvency II Art. 13(2)) are also subject to CSRD.
- Reporting starts for FY 2026 (reports in 2027), if in scope as large undertakings or as listed SMEs (as applicable).
- If yes: proceed to reporting obligations.
- If no: you are likely out of scope unless you are parent of a large group.

- **YES** CSRD Applies (Small Credit Institution / Captive Insurer)
- **NO** Are you a parent undertaking of a large group?

### STEP 5: Are you a parent undertaking of a large group?

*Reference: Art. 29a Directive 2013/34/EU*

- If your group (on a consolidated basis) exceeds the large undertaking thresholds (at least two of: 250 employees; EUR 20M balance sheet; EUR 40M turnover), you must prepare consolidated sustainability reporting.
- Subsidiary exemption: an EU subsidiary may be exempt from preparing its own sustainability statement if included in the consolidated report of its parent and certain conditions are met (Art. 19a(9)).
- If yes: consolidated reporting applies.

- **YES** CSRD Applies (Parent of Large Group)
- **NO** Out of Scope

### NON-EU TRACK: Does your non-EU company generate EUR 150M+ net turnover in the EU in each of the last two consecutive financial years?

*Reference: Art. 40a & 40b Directive 2013/34/EU*

- Non-EU companies must report if they have (a) net turnover > EUR 150M in the EU in each of the last two consecutive FYs, AND (b) at least one EU subsidiary meeting large/listed criteria OR an EU branch with net turnover > EUR 40M in the preceding FY.
- Reporting starts for FY 2028 (reports in 2029).
- If yes: check if you have an EU subsidiary or branch meeting the criteria.

- **YES** Do you have an EU subsidiary (large or listed) or an EU branch with EUR 40M+ turnover?
- **NO** Out of Scope

### NON-EU TRACK: Do you have an EU subsidiary (large or listed) or an EU branch with EUR 40M+ turnover?

*Reference: Art. 40a(1) Directive 2013/34/EU*

- If you have an EU subsidiary that is a large undertaking or listed company, OR an EU branch with net turnover exceeding EUR 40M in the preceding FY, you must publish a sustainability report.
- One EU subsidiary or the branch is designated to publish the report on behalf of the non-EU parent.
- If yes: proceed to non-EU reporting obligations.

- **YES** CSRD Applies (Non-EU Company)
- **NO** Out of Scope

## Reference Information

### Companies In Scope (Overview)

- EU large undertakings and parent undertakings of large groups are subject to sustainability reporting under Directive 2013/34/EU (as amended by CSRD).
- Listed SMEs (except micro-undertakings) and certain financial undertakings have later application dates, with a temporary opt-out for financial years starting before 2028-01-01 (Directive 2013/34/EU, Art. 19a(7)).
- Third-country undertakings can be in scope via EU subsidiaries or branches if thresholds in Art. 40a are met (net turnover >EUR 150 million in the Union for each of the last two consecutive financial years, plus a qualifying EU subsidiary or branch).

### Double Materiality Assessment

- ESRS uses a double materiality principle: sustainability matters are material if they are material from an impact perspective, a financial perspective, or both (ESRS 1, chapter 3).
- Impact materiality focuses on actual and potential impacts connected with the undertaking's business, including in its upstream and downstream value chain.
- Financial materiality focuses on sustainability-related risks and opportunities that trigger, or could reasonably be expected to trigger, material financial effects on the undertaking.

### ESRS Structure (Sector-Agnostic Standards)

- ESRS 1: General requirements (definitions, concepts, materiality, reporting principles).
- ESRS 2: General disclosures (mandatory for all companies; governance, strategy, impact/risk/opportunity management).
- Environmental standards: ESRS E1 (Climate change), E2 (Pollution), E3 (Water and marine resources), E4 (Biodiversity and ecosystems), E5 (Resource use and circular economy).
- Social standards: ESRS S1 (Own workforce), S2 (Workers in the value chain), S3 (Affected communities), S4 (Consumers and end-users).
- Governance standard: ESRS G1 (Business conduct: anti-corruption, bribery, political engagement, lobbying, payment practices).
- Topical ESRS disclosures are subject to the materiality assessment. Undertakings can omit a topical standard if the topic is not material, but ESRS E1 climate change requires a detailed explanation when concluded not material (ESRS 1; ESRS 2 IRO-2).
- Sector-specific ESRS and ESRS for SMEs are provided for under the Directive and developed via delegated acts.

### Core Reporting Areas (ESRS Disclosure Requirements)

- Governance (GOV): describe governance structure, roles and responsibilities of administrative/management/supervisory bodies, integration of sustainability into governance.
- Strategy (SBM): describe business model, strategy, and how material impacts, risks, and opportunities interact with strategy and business model; disclose interests and views of stakeholders.
- Impact, Risk, and Opportunity management (IRO): describe the process to identify, assess, and manage material sustainability matters; explain which ESRS disclosure requirements are covered by the sustainability statement.
- Metrics and Targets: for each material sustainability matter, disclose policies (MDR-P), actions (MDR-A), targets (MDR-T), and metrics specific to each ESRS (e.g., GHG emissions for E1, diversity metrics for S1, supply chain due diligence for S2, anti-corruption metrics for G1).
- Value chain reporting: determine at which level within own operations and the upstream and downstream value chain material sustainability matters arise, based on the impacts, risks and opportunities identified through double materiality.

### Assurance & Digital Tagging Requirements

- Sustainability reporting is subject to an assurance engagement under the amended EU audit framework (see CSRD amendments).
- CSRD provides for Commission action on assurance standards, including a deadline for limited assurance standards (no later than 2026-10-01).
- Digital tagging: CSRD links sustainability reporting to the EU single electronic reporting format framework. ESEF requires annual financial reports to be prepared in XHTML and IFRS consolidated financial statements to be marked up using Inline XBRL.

### Phase-In and Simplifications (First-Year Reporting)

- ESRS 1 Appendix C lists phase-in provisions for disclosure requirements and datapoints that may be omitted or that are not applicable in the first year(s) of ESRS reporting.
- First-year relief: undertakings are not required to disclose comparative information in the first year of preparation of the sustainability statement under ESRS.
- If an undertaking or group does not exceed 750 employees (average during the financial year), Appendix C allows omitting certain disclosures (examples: scope 3 and total GHG emissions datapoints under ESRS E1-6 in the first year; all ESRS E4 disclosure requirements for the first 2 years; and all ESRS S2, S3, and S4 disclosure requirements for the first 2 years).
- Appendix C also allows first-year omissions and (in some cases) qualitative-only disclosure for a limited period when quantitative disclosure is impracticable (examples: ESRS 2 SBM-3 anticipated financial effects; ESRS E1-9 anticipated financial effects; ESRS E2-6 and ESRS E3-5 anticipated financial effects).

### Subsidiary Exemption

- A subsidiary undertaking can be exempt from preparing sustainability reporting when it and its subsidiary undertakings are included in the consolidated management report of a parent undertaking drawn up in accordance with Articles 29 and 29a (group-level sustainability reporting).
- This also applies when the parent undertaking is established in a third country, if the consolidated sustainability reporting is carried out in accordance with ESRS (adopted under Article 29b) or in a manner equivalent to ESRS (equivalence determined via an implementing act under Directive 2004/109/EC).
- If exempted, the subsidiary's management report must include: the name and registered office of the parent; weblinks to the parent's consolidated management report (or consolidated sustainability reporting) and the assurance opinion; and a statement that the subsidiary is exempt.
- If the parent is established in a third country, additional publication conditions apply, and the Article 8 Taxonomy disclosures covering the activities of the exempted EU subsidiary and its subsidiary undertakings must be included either in the subsidiary's management report or in the parent's consolidated sustainability reporting.

### Value Chain Reporting (Practical Approach)

- CSRD requires sustainability information, where applicable, to cover the undertaking's own operations and its value chain, including products and services, business relationships, and supply chain.
- For the first 3 years of application, if not all necessary value chain information is available, the undertaking explains: the efforts made to obtain the information, the reasons why not all information could be obtained, and its plans to obtain the information in the future.
- ESRS requires disclosures about measurement uncertainty and assumptions, including where amounts depend on upstream and downstream value chain data availability and quality.
- If you use estimates or proxies, describe the assumptions, approximations, and judgements used, and improve data quality and coverage over time.

### Interoperability with Global Standards

- The ESRS delegated regulation notes that the Commission introduced modifications to support a high degree of interoperability with global standard-setting initiatives.
- ESRS allows undertakings to include, in addition to ESRS disclosures, information stemming from other legislation and from other generally accepted sustainability reporting standards and frameworks, as long as ESRS requirements are met (and partial application must be precisely referenced).
- If a sustainability matter is material but not covered by a topical ESRS, ESRS requires additional entity-specific disclosures, which may draw on available frameworks or reporting standards (examples mentioned in ESRS include IFRS industry-based guidance and GRI Sector Standards).
- For scenario analysis, ESRS application requirements cite external guidance such as TCFD scenario analysis publications as examples an undertaking may consider.

### Sector-Specific ESRS (Future Development)

- EU law provides for sustainability reporting standards that include both cross-sector (sector-agnostic) requirements and sector-specific requirements to reflect the sustainability-related risks and impacts that are common within sectors.
- Directive (EU) 2024/1306 postponed the deadline for adopting delegated acts for the sector-specific sustainability reporting standards from 30 June 2024 to 30 June 2026.
- Directive (EU) 2024/1306 also states that this postponement should not prevent the Commission from publishing sector-specific delegated acts earlier, and that the Commission should endeavor to adopt delegated acts containing eight sector-specific standards as soon as each is ready.
- Once adopted, sector-specific standards supplement the sector-agnostic ESRS.

### EU Taxonomy Disclosures (Article 8 Regulation (EU) 2020/852)

- CSRD references the disclosures laid down in Article 8 of Regulation (EU) 2020/852 (EU Taxonomy) and, in some cases, requires that those disclosures are included alongside sustainability reporting (for example, in certain exemption or third-country structures).
- Commission Delegated Regulation (EU) 2021/2178 specifies the content and presentation of the Article 8 disclosures and the methodology to comply with that disclosure obligation.
- Taxonomy reporting uses key performance indicators for non-financial undertakings, including turnover, capital expenditure (CapEx), and operating expenditure (OpEx), using the required templates and calculation rules.

### Climate Transition Plan (ESRS E1)

- ESRS E1 Disclosure Requirement E1-1 requires the undertaking to disclose its transition plan for climate change mitigation.
- ESRS application requirements explain that a transition plan disclosure is expected to provide a high-level explanation of how the undertaking will adjust its strategy and business model to ensure compatibility with the transition to a sustainable economy and with limiting global warming to 1.5 degrees C in line with the Paris Agreement, and the EU objective of climate neutrality by 2050.
- ESRS E1-1 includes disclosure about investments and funding supporting implementation of the transition plan, and can reference taxonomy-aligned CapEx key performance indicators where relevant.
- ESRS E1-1 includes disclosure about how the transition plan is embedded in and aligned with overall business strategy and financial planning, whether the plan is approved by the administrative, management and supervisory bodies, and progress in implementing the plan.
- If the undertaking does not have a transition plan, it must indicate whether and, if so, when it will adopt one.

### ESRS 2 General Disclosures (Mandatory for All)

- ESRS 2 disclosure requirements apply to all undertakings subject to CSRD, irrespective of the outcome of the materiality assessment.
- ESRS 2 includes general disclosures across governance (GOV), strategy and business model (SBM), and the process to identify and assess impacts, risks and opportunities (IRO).
- ESRS 2 includes minimum disclosure requirements for policies (MDR-P), actions and resources (MDR-A), and targets (MDR-T) related to material sustainability matters.
- Topical ESRS disclosures build on ESRS 2 and are determined through the materiality assessment (subject to specific always-applicable requirements listed in ESRS).

## Possible Outcomes

### [RESULT] CSRD Applies (Large EU Company)

Reporting starts FY 2025 (or FY 2024 if already NFRD)

- Prepare the sustainability reporting required under Directive 2013/34/EU (as amended by CSRD) in accordance with ESRS (Delegated Reg. (EU) 2023/2772).
- Determine disclosures using the ESRS double materiality principle (impact materiality and financial materiality).
- Apply the phase-in schedule in Art. 5(2): NFRD-type undertakings report first for FY 2024; other large undertakings report first for FY 2025.
- Obtain assurance on sustainability reporting as required by the amended EU audit framework (see CSRD amendments).

### [RESULT] CSRD Applies (Listed SME)

Reporting starts FY 2026 (with temporary opt-out before 2028)

- Listed SMEs (except micro-undertakings) are within scope for financial years starting on or after 2026-01-01 (Art. 5(2)).
- For financial years starting before 2028-01-01, listed SMEs may decide not to include sustainability reporting in their management report, but must briefly state why it was not provided (Directive 2013/34/EU, Art. 19a(7)).
- Listed SMEs report in accordance with sustainability reporting standards for SMEs adopted under Directive 2013/34/EU (Art. 29c).

### [RESULT] CSRD Applies (Small Credit Institution / Captive Insurer)

Reporting starts FY 2026

- Small and non-complex credit institutions and captive insurance and reinsurance undertakings can rely on a derogation that limits sustainability reporting to a defined set of information and must report in accordance with sustainability reporting standards for SMEs (Directive 2013/34/EU, Art. 19a(6) and Art. 29c).
- Application dates follow the CSRD phase-in schedule (Art. 5(2)).

### [RESULT] CSRD Applies (Parent of Large Group)

Consolidated sustainability reporting required

- Parent undertakings of large groups prepare consolidated sustainability reporting in the consolidated management report.
- Applies to groups exceeding at least two of: 250 employees (on average); EUR 20M balance sheet total; EUR 40M net turnover (on consolidated basis).
- Subsidiary exemption can apply where subsidiaries are included in consolidated sustainability reporting and the conditions in Directive 2013/34/EU are met (Art. 19a(9)).
- Consolidated report must cover all subsidiaries included in the consolidated financial statements.
- Consolidated reporting is prepared in accordance with ESRS adopted pursuant to Directive 2013/34/EU (Art. 29b).

### [RESULT] CSRD Applies (Non-EU Company)

Reporting starts FY 2028

- Non-EU companies with EUR 150M+ net turnover in the EU (in each of last two consecutive FYs) and an EU subsidiary (large/listed) or EU branch (EUR 40M+ turnover) must report.
- A designated EU subsidiary or the branch publishes the sustainability report on behalf of the non-EU parent.
- The sustainability report must be drawn up in accordance with standards adopted for third-country undertakings, or may be drawn up in accordance with ESRS or in a manner equivalent to ESRS (Art. 40a(2)). The deadline for adopting certain third-country reporting standards was revised by Directive (EU) 2024/1306.
- The sustainability report is published accompanied by an assurance opinion, or a statement if the assurance opinion is not made available (Art. 40a(3)).
- First reporting period: FY 2028 (reports in 2029).

### [RESULT] Out of Scope

CSRD does not directly apply

- Your company does not meet the CSRD scope criteria.
- You may still be impacted indirectly via contractual or supply chain demands from CSRD-regulated companies.
- Voluntary sustainability reporting frameworks may still be relevant for customers, lenders, and procurement.

## CSRD Application Timeline

| Date | Event | Reference |
| --- | --- | --- |
| 2022-12-14 | CSRD adopted | Directive (EU) 2022/2464 |
| 2022-12-16 | CSRD published in Official Journal (OJ L 322) | Directive (EU) 2022/2464 |
| 2023-01-05 | CSRD enters into force (20th day after publication) | Directive (EU) 2022/2464 |
| 2023-07-31 | First set of ESRS adopted by Commission | Delegated Reg. (EU) 2023/2772 |
| 2023-12-22 | ESRS published in Official Journal | Delegated Reg. (EU) 2023/2772 |
| 2024-07-06 | Member State transposition deadline for CSRD core provisions | Directive (EU) 2022/2464 Art. 5(1) |
| 2024-01-01 | Measures apply for FY starting on/after this date for companies already subject to NFRD (large PIE with 500+ employees) | Directive (EU) 2022/2464 Art. 5(2) |
| 2025-01-01 | Measures apply for FY starting on/after this date for other large undertakings and parent undertakings of large groups | Directive (EU) 2022/2464 Art. 5(2) |
| 2026-01-01 | Measures apply for FY starting on/after this date for listed SMEs (except micro) and certain financial undertakings | Directive (EU) 2022/2464 Art. 5(2) |
| 2028-01-01 | Measures apply for FY starting on/after this date for certain non-EU undertakings (third-country reporting) | Directive (EU) 2022/2464 Art. 5(2) |
| 2026-10-01 | Commission deadline to adopt limited assurance standards for sustainability reporting (no later than) | Directive (EU) 2022/2464 |
| 2026-06-30 | Revised deadline for adopting certain ESRS delegated acts (sector and certain third-country standards) | Directive (EU) 2024/1306 |

## Compliance Timeline

| Date | Event | Category | Reference |
| --- | --- | --- | --- |
| 2014-10-22 | Non-Financial Reporting Directive (NFRD) adopted | Legislative Milestones |  |
| 2020-06-11 | Public consultation on review of the NFRD closes | Consultations |  |
| 2021-03-08 | Commission publishes proposal for CSRD | Legislative Milestones |  |
| 2021-04-21 | Political agreement on CSRD reached | Legislative Milestones |  |
| 2022-06-22 | EFRAG publishes first set of draft ESRS | Reporting Standards (ESRS) |  |
| 2022-12-14 | CSRD (Directive (EU) 2022/2464) adopted | Legislative Milestones |  |
| 2022-12-16 | CSRD published in the Official Journal (OJ L 322) | Legislative Milestones |  |
| 2023-01-05 | CSRD enters into force | Legislative Milestones |  |
| 2023-06-09 | Public feedback opens on first set of draft sustainability reporting standards | Consultations |  |
| 2023-07-31 | Commission adopts ESRS Set 1 (Delegated Regulation (EU) 2023/2772) | Reporting Standards (ESRS) |  |
| 2023-12-22 | ESRS Set 1 published in the Official Journal | Reporting Standards (ESRS) |  |
| 2024-01-01 | ESRS start applying for financial years beginning on or after 1 January 2024 | Reporting Milestones |  |
| 2024-01-01 | CSRD starts applying (Wave 1 reporting for FY 2024) | Reporting Milestones |  |
| 2024-04-29 | Directive (EU) 2024/1306 adopted (extends deadlines for certain ESRS) | Legislative Milestones |  |
| 2024-06-30 | Original deadline for adopting certain third-country reporting standards | Reporting Standards (ESRS) |  |
| 2024-07-06 | Member State transposition deadline for CSRD core provisions | Legislative Milestones |  |
| 2024-08-07 | Commission publishes CSRD implementation FAQ | Implementation Guidance |  |
| 2025-01-01 | CSRD starts applying (Wave 2 reporting for FY 2025) | Reporting Milestones |  |
| 2025-07-11 | Commission adopts ESRS quick-fix delegated act | Reporting Standards (ESRS) |  |
| 2025-09-11 | Scrutiny period ends for ESRS quick-fix delegated act (no objections) | Reporting Standards (ESRS) |  |
| 2026-01-01 | CSRD starts applying (Wave 3 reporting for FY 2026) | Reporting Milestones |  |
| 2026-06-30 | Deadline for adopting certain sector and third-country standards (revised) | Reporting Standards (ESRS) |  |
| 2026-10-01 | Commission deadline to adopt limited assurance standards for sustainability reporting | Reporting Standards (ESRS) |  |
| 2028-01-01 | Reporting requirement for certain third-country undertakings applies from financial year 2028 | Reporting Milestones |  |

**Event details:**

- **2014-10-22 - Non-Financial Reporting Directive (NFRD) adopted**: Commission CSRD page timeline references adoption of the Non-Financial Reporting Directive on 22 October 2014 (Directive 2014/95/EU).
- **2020-06-11 - Public consultation on review of the NFRD closes**: Commission CSRD page timeline: public consultation on the review of the NFRD ended on 11 June 2020.
- **2021-03-08 - Commission publishes proposal for CSRD**: Commission CSRD page timeline references publication of the proposal for a Corporate Sustainability Reporting Directive (CSRD) on 8 March 2021.
- **2021-04-21 - Political agreement on CSRD reached**: Commission CSRD page timeline references a political agreement by the European Parliament and the Council on CSRD on 21 April 2021.
- **2022-06-22 - EFRAG publishes first set of draft ESRS**: Commission CSRD page timeline: first set of draft EU sustainability reporting standards published by EFRAG on 22 June 2022.
- **2022-12-14 - CSRD (Directive (EU) 2022/2464) adopted**: Date of the CSRD: 14 December 2022.
- **2022-12-16 - CSRD published in the Official Journal (OJ L 322)**: ESRS delegated regulation timeline references the Official Journal date for Directive (EU) 2022/2464: 16 December 2022.
- **2023-01-05 - CSRD enters into force**: CSRD enters into force on the twentieth day following its publication in the Official Journal (published 16 December 2022).
- **2023-06-09 - Public feedback opens on first set of draft sustainability reporting standards**: Commission CSRD page timeline: opening of a four-week public feedback period on draft sustainability reporting standards on 9 June 2023.
- **2023-07-31 - Commission adopts ESRS Set 1 (Delegated Regulation (EU) 2023/2772)**: Commission news and Delegated Regulation timeline: ESRS Set 1 adopted on 31 July 2023.
- **2023-12-22 - ESRS Set 1 published in the Official Journal**: Delegated Regulation (EU) 2023/2772 timeline: publication in the Official Journal on 22 December 2023.
- **2024-01-01 - ESRS start applying for financial years beginning on or after 1 January 2024**: Delegated Regulation (EU) 2023/2772 timeline: applies from 1 January 2024 for financial years beginning on or after 1 January 2024.
- **2024-01-01 - CSRD starts applying (Wave 1 reporting for FY 2024)**: Member States must apply CSRD measures for financial years starting on or after 1 January 2024 for large public-interest entities (and parent undertakings of large groups) exceeding 500 employees.
- **2024-04-29 - Directive (EU) 2024/1306 adopted (extends deadlines for certain ESRS)**: Directive (EU) 2024/1306 of 29 April 2024 amends time limits for adoption of sector standards and certain third-country standards (revising the 30 June 2024 deadline to 30 June 2026).
- **2024-06-30 - Original deadline for adopting certain third-country reporting standards**: CSRD legal text includes a 30 June 2024 deadline for adopting standards for sustainability reporting by third-country undertakings; this deadline was later revised to 30 June 2026 (Directive (EU) 2024/1306).
- **2024-07-06 - Member State transposition deadline for CSRD core provisions**: Member States must bring into force laws, regulations and administrative provisions necessary to comply with Articles 1 to 3 of CSRD by 6 July 2024.
- **2024-08-07 - Commission publishes CSRD implementation FAQ**: FAQ page timeline: publication date 7 August 2024.
- **2025-01-01 - CSRD starts applying (Wave 2 reporting for FY 2025)**: Member States must apply CSRD measures for financial years starting on or after 1 January 2025 for other large undertakings and parent undertakings of large groups not in Wave 1.
- **2025-07-11 - Commission adopts ESRS quick-fix delegated act**: Implementing and delegated acts page timeline: ESRS quick-fix delegated act adopted by the Commission on 11 July 2025.
- **2025-09-11 - Scrutiny period ends for ESRS quick-fix delegated act (no objections)**: Implementing and delegated acts page timeline: scrutiny period expired on 11 September 2025 with no objections by the European Parliament or the Council.
- **2026-01-01 - CSRD starts applying (Wave 3 reporting for FY 2026)**: Member States must apply CSRD measures for financial years starting on or after 1 January 2026 for listed SMEs (excluding micro-undertakings) and certain financial undertakings, with an opt-out possibility for listed SMEs for a transitional period.
- **2026-06-30 - Deadline for adopting certain sector and third-country standards (revised)**: Directive (EU) 2024/1306 timeline: revised time limit for adoption of delegated acts containing certain sustainability reporting standards is 30 June 2026.
- **2026-10-01 - Commission deadline to adopt limited assurance standards for sustainability reporting**: CSRD provides that the Commission shall adopt delegated acts on limited assurance standards no later than 1 October 2026.
- **2028-01-01 - Reporting requirement for certain third-country undertakings applies from financial year 2028**: Directive (EU) 2024/1306 timeline: reporting requirement for certain third-country undertakings applies as of financial year 2028.


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