CSRD reporting waves who reports first and what changed

Directive (EU) 2022/2464 set phased application dates by financial year. The first wave covered large public-interest entities and parent undertakings of large groups that exceeded the 500-employee condition. The second wave covered other large undertakings and parent undertakings of large groups. The third wave covered listed SMEs that are not micro-undertakings, plus listed small and non-complex institutions and captive insurance or reinsurance undertakings where the CSRD conditions are met.

The same directive also applied the third-country reporting provisions for financial years starting on or after 1 January 2028. That is a separate Article 40a route, not the same analysis as a normal EU large undertaking or listed SME wave.

No. The original CSRD wave rules still matter as the starting point for scoping. The Commission's CSRD page says the stop-the-clock Directive postpones the entry into application of reporting requirements for companies that were previously due to report for the first time for financial years 2025 or 2026, described there as wave two and wave three companies.

Do not turn that caveat into unsourced replacement reporting dates on this page. For a live entity assessment, keep the original CSRD wave, note whether the entity is in a wave affected by the stop-the-clock measure, and verify the Member State implementation or issuer rules that apply to the entity before changing a reporting plan.

Yes, but only for the listed SME category described by the Accounting Directive rules. The Commission FAQ explains that SMEs, excluding micro-undertakings, with transferable securities admitted to trading on an EU regulated market may decide not to report under Article 19a for financial years starting before 1 January 2028. If they use that opt-out, they must briefly state in the management report why the sustainability reporting was not provided.

The same Commission FAQ says this opt-out also applies to small and non-complex institutions and captive insurance or reinsurance undertakings where they are SMEs, excluding micro-undertakings, with transferable securities admitted to trading on an EU regulated market.

There are two different third-country questions. First, a third-country issuer with transferable securities admitted to trading on an EU regulated market can be caught by the issuer route under Articles 19a or 29a, excluding micro-undertakings; the Commission FAQ says those issuers include sustainability information in the management report as part of the annual financial report.

Second, Article 40a covers certain third-country groups with a qualifying EU subsidiary or branch footprint. The CSRD text sets the group-level EU net turnover condition at more than EUR 150 million for each of the last two consecutive financial years, and the branch route applies where the branch generated more than EUR 40 million in the preceding financial year and there is no qualifying subsidiary. The Article 40a reporting route applies from financial years starting on or after 1 January 2028.

CSRD is a directive. Directive (EU) 2022/2464 required Member States to bring national laws, regulations, and administrative provisions into force and communicate those measures to the Commission. That means an EU-level wave analysis is necessary but not always sufficient for filing, assurance-provider, register, publication, and sanction questions.

Local-law confirmation is especially important where an entity is near a size threshold, uses the listed SME opt-out, relies on a stop-the-clock delay, has securities admitted to trading on an EU regulated market, or publishes an Article 40a third-country report through an EU subsidiary or branch.