---
title: "CSRD reporting waves FAQ: who reports first and what changed"
canonical_url: "https://www.sorena.io/artifacts/eu/corporate-sustainability-reporting-directive/faq/reporting-waves"
source_url: "https://www.sorena.io/artifacts/eu/corporate-sustainability-reporting-directive/faq/reporting-waves"
author: "Sorena AI"
description: "FAQ on original CSRD reporting waves, stop-the-clock caveats, listed SME opt-out, third-country reporting, and why local transposition law still matters."
published_at: "2026-05-09"
updated_at: "2026-05-09"
keywords:
  - "CSRD reporting waves"
  - "CSRD stop-the-clock"
  - "listed SME opt-out"
  - "third-country CSRD reporting"
  - "ESRS"
  - "CSRD"
  - "reporting waves"
  - "listed SMEs"
  - "third-country undertakings"
  - "sustainability reporting"
---
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---

# CSRD reporting waves FAQ: who reports first and what changed

FAQ on original CSRD reporting waves, stop-the-clock caveats, listed SME opt-out, third-country reporting, and why local transposition law still matters.

*FAQ* *CSRD* *EU*

## CSRD reporting waves who reports first and what changed

Use this FAQ to separate the original CSRD application waves from later stop-the-clock and standards-timing changes.

The practical check is entity-specific: identify the legal entity, listing status, group status, EU branch or subsidiary footprint, financial year, and national implementing law.

CSRD reporting waves answer when an entity first falls into mandatory sustainability reporting. The original CSRD phased in public-interest entities, other large undertakings, listed SMEs and similar regulated entities, and certain third-country groups. Later EU measures affected parts of that schedule, so teams should keep the original wave analysis but confirm current national implementation before relying on a delayed start.

## What were the original CSRD reporting waves?

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.

- Financial years starting on or after 1 January 2024: large public-interest entities and large-group parents above the 500-employee condition.
- Financial years starting on or after 1 January 2025: other large undertakings and other parent undertakings of large groups.
- Financial years starting on or after 1 January 2026: listed SMEs that are not micro-undertakings, plus qualifying listed small and non-complex institutions and captive insurance or reinsurance undertakings.
- Financial years starting on or after 1 January 2028: the CSRD third-country reporting route introduced through Article 40a.

Sources for this answer:

- [Directive (EU) 2022/2464 on corporate sustainability reporting](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32022L2464&ref=sorena.io) - Supports the original CSRD phased application years, the affected entity categories, the transposition obligation, and the third-country Article 40a application date.
- [European Commission corporate sustainability reporting overview](https://finance.ec.europa.eu/capital-markets-union-and-financial-markets/company-reporting-and-auditing/company-reporting/corporate-sustainability-reporting_en?ref=sorena.io) - Confirms that the first CSRD companies applied the new rules for the 2024 financial year and published reports in 2025.

## Did the stop-the-clock measure erase the original waves?

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.

- Wave one companies are not described in the Commission source as the stop-the-clock target; the same page separately notes a quick-fix delegated act giving additional ESRS flexibility to wave one companies for financial years 2025 and 2026.
- Wave two and wave three companies need a current-law check because the EU-level caveat changes entry into application, but local implementation can still control the practical filing analysis.
- A reporting-wave memo should record the original CSRD wave, any stop-the-clock reliance, the Member State or issuer regime checked, and the source date used for the conclusion.

Sources for this answer:

- [European Commission corporate sustainability reporting overview](https://finance.ec.europa.eu/capital-markets-union-and-financial-markets/company-reporting-and-auditing/company-reporting/corporate-sustainability-reporting_en?ref=sorena.io) - Supports the stop-the-clock caveat for wave two and wave three companies and the separate quick-fix flexibility note for wave one companies.
- [Stop-the-clock Directive (EU) 2025/794](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025L0794&ref=sorena.io) - Official EUR-Lex source identified by the Commission page for the stop-the-clock directive affecting CSRD entry into application.

## Can listed SMEs opt out of CSRD reporting before 2028?

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.

- Confirm the entity is an SME and not a micro-undertaking.
- Confirm its transferable securities are admitted to trading on an EU regulated market.
- If the opt-out is used, include the required short explanation in the management report rather than simply omitting the sustainability statement silently.
- Do not treat the listed SME opt-out as a general exemption for private SMEs or for large listed entities.

Sources for this answer:

- [European Commission FAQ on implementation of EU corporate sustainability reporting rules](https://finance.ec.europa.eu/publications/frequently-asked-questions-implementation-eu-corporate-sustainability-reporting-rules_en?ref=sorena.io) - Supports the listed SME opt-out, the exclusion of micro-undertakings, the pre-2028 financial-year condition, and the management-report explanation requirement.
- [Directive (EU) 2022/2464 on corporate sustainability reporting](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32022L2464&ref=sorena.io) - Contains the Article 19a(7) opt-out text for small and medium-sized public-interest entities before financial years starting on 1 January 2028.

## How do CSRD reporting waves work for third-country undertakings?

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.

- Check whether the third-country company is an EU-regulated-market issuer before using the Article 40a branch or subsidiary route.
- For Article 40a, identify the EU subsidiary or branch that would publish and make the report accessible.
- Check the EU turnover and branch turnover facts against audited or management-reporting records.
- If a third-country undertaking withholds the required assurance opinion for an Article 40a report, the EU subsidiary or branch must issue a statement indicating that fact.

Sources for this answer:

- [Directive (EU) 2022/2464 on corporate sustainability reporting](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32022L2464&ref=sorena.io) - Supports Article 40a third-country group scope, the EUR 150 million Union net turnover condition, the EUR 40 million branch condition, publication responsibility, and the 2028 application point.
- [European Commission FAQ on implementation of EU corporate sustainability reporting rules](https://finance.ec.europa.eu/publications/frequently-asked-questions-implementation-eu-corporate-sustainability-reporting-rules_en?ref=sorena.io) - Supports the distinction between third-country issuers under Articles 19a/29a and the assurance-opinion statement for Article 40a reports.

## Why should teams confirm local law before relying on a CSRD wave answer?

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.

- Record the Member State law or issuer home Member State checked.
- Confirm whether national law changes the practical publication channel, assurance-provider rules, or enforcement exposure.
- Keep the CSRD source, the national-law source, the entity classification evidence, and the reporting-year conclusion together.

Sources for this answer:

- [Directive (EU) 2022/2464 on corporate sustainability reporting](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32022L2464&ref=sorena.io) - Supports the Member State transposition requirement and the need to check national implementing measures for practical application.
- [European Commission FAQ on implementation of EU corporate sustainability reporting rules](https://finance.ec.europa.eu/publications/frequently-asked-questions-implementation-eu-corporate-sustainability-reporting-rules_en?ref=sorena.io) - Supports local-law checks for areas where the FAQ identifies Member State rules or national regimes as relevant to implementation.

## Primary sources

- [Directive (EU) 2022/2464 on corporate sustainability reporting](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32022L2464&ref=sorena.io) - Primary legal source for the original CSRD reporting waves, Article 19a listed SME opt-out text, Article 40a third-country reporting scope, and Member State transposition duties.
  - Quote: "for financial years starting on or after 1 January 2024"
- [European Commission corporate sustainability reporting overview](https://finance.ec.europa.eu/capital-markets-union-and-financial-markets/company-reporting-and-auditing/company-reporting/corporate-sustainability-reporting_en?ref=sorena.io) - Commission overview used for the first-reporting-year context, stop-the-clock caveat, and quick-fix ESRS flexibility note.
  - Quote: "reports published in 2025"
- [European Commission FAQ on implementation of EU corporate sustainability reporting rules](https://finance.ec.europa.eu/publications/frequently-asked-questions-implementation-eu-corporate-sustainability-reporting-rules_en?ref=sorena.io) - Commission FAQ used for listed SME opt-out, third-country issuer treatment, Article 40a assurance-opinion statement, and national-rule caveats.
  - Quote: "scope, application dates, and exemptions"
- [Stop-the-clock Directive (EU) 2025/794](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025L0794&ref=sorena.io) - Official EUR-Lex source identified by the Commission page for the stop-the-clock measure affecting wave two and wave three entry into application.
  - Quote: "stop-the-clock Directive"
- [Directive (EU) 2024/1306 on ESRS timing](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024L1306&ref=sorena.io) - Supports the separate postponement of Commission deadlines for sector-specific ESRS and certain third-country undertaking ESRS, which should not be confused with entity reporting waves.
  - Quote: "replaced by '30 June 2026'"

## Topic Guides

- [CSRD and ESRS Compliance Obligations](/artifacts/eu/corporate-sustainability-reporting-directive/compliance.md): Grounded CSRD and ESRS compliance guide covering scope checks, sustainability statements, double materiality, value-chain data, assurance, and digital tagging.
- [CSRD and ESRS FAQ: scope, materiality, assurance, tagging, and value chain](/artifacts/eu/corporate-sustainability-reporting-directive/faq.md): CSRD and ESRS FAQ hub covering company scope, reporting waves, ESRS structure, double materiality, assurance, digital tagging, Taxonomy Article 8, and value chain data.
- [CSRD and ESRS Reporting Checklist](/artifacts/eu/corporate-sustainability-reporting-directive/checklist.md): A practical CSRD and ESRS checklist for confirming reporting scope, sustainability statement content, double materiality, value-chain evidence, assurance readiness, and digital tagging.
- [CSRD and ESRS requirements: scope, reporting, assurance, and evidence](/artifacts/eu/corporate-sustainability-reporting-directive/requirements.md): Grounded guide to CSRD and ESRS requirements: who reports, what the sustainability statement must cover, double materiality, value-chain data, assurance, publication, digital tagging, and controls.
- [CSRD and ESRS value-chain data, estimates, proxies, and evidence](/artifacts/eu/corporate-sustainability-reporting-directive/value-chain-data-and-estimation.md): How to handle ESRS value-chain information when supplier or customer data is incomplete: reasonable efforts, estimates, limitations, controls, and assurance evidence.
- [CSRD Applicability Test for EU and Non-EU Company Groups](/artifacts/eu/corporate-sustainability-reporting-directive/applicability-test.md): Check whether CSRD and ESRS reporting may apply by testing undertaking size, listed status, group reporting, non-EU branches or subsidiaries, and phase-in evidence.
- [CSRD Article 40a third-country group reporting FAQ](/artifacts/eu/corporate-sustainability-reporting-directive/faq/third-country-groups.md): FAQ on when CSRD Article 40a applies to third-country groups, which EU subsidiary or branch publishes the report, and what happens with assurance and missing information.
- [CSRD assurance and ESRS digital tagging evidence](/artifacts/eu/corporate-sustainability-reporting-directive/assurance-and-digital-tagging-evidence.md): Evidence checklist for CSRD assurance readiness, ESRS datapoint traceability, and digital tagging preparation under the ESRS XBRL and ESEF reporting framework.
- [CSRD assurance evidence FAQ: what to keep for limited assurance](/artifacts/eu/corporate-sustainability-reporting-directive/faq/assurance-evidence.md): What CSRD and ESRS assurance evidence should support: management-report publication, the assurance report, national assurance procedures, and EU limited assurance milestones.
- [CSRD assurance evidence pack workflow for ESRS reporting](/artifacts/eu/corporate-sustainability-reporting-directive/assurance-evidence-pack-workflow.md): A CSRD and ESRS workflow for building an assurance-ready evidence pack covering scope, double materiality, ESRS datapoints, controls, estimates, and digital tagging.
- [CSRD assurance-ready controls and evidence for ESRS reporting](/artifacts/eu/corporate-sustainability-reporting-directive/assurance-ready-controls-and-evidence.md): Build CSRD and ESRS evidence around GOV-5 controls, double materiality, IROs, value-chain data, assurance files, and XBRL tagging checks.
- [CSRD data point inventory FAQ for ESRS disclosure readiness](/artifacts/eu/corporate-sustainability-reporting-directive/faq/data-point-inventory.md): How to build an ESRS data point inventory for CSRD reporting: disclosure requirements, materiality filters, evidence ownership, value-chain data, XBRL readiness, and assurance support.
- [CSRD deadlines and ESRS compliance calendar](/artifacts/eu/corporate-sustainability-reporting-directive/deadlines-and-compliance-calendar.md): A grounded CSRD and ESRS calendar covering the original reporting waves, enacted postponement caveats, publication duties, assurance, and digital reporting workstreams.
- [CSRD digital tagging and XBRL readiness FAQ](/artifacts/eu/corporate-sustainability-reporting-directive/faq/digital-tagging-xbrl.md): What CSRD teams should do now about XHTML, Inline XBRL, ESRS taxonomy materials, tagging controls, and limits before final digital taxonomy rules apply.
- [CSRD Double Materiality Interview Question Bank for ESRS](/artifacts/eu/corporate-sustainability-reporting-directive/double-materiality-interview-question-bank.md): Interview prompts for ESRS double materiality work: context, affected stakeholders, value chain IROs, impact materiality, financial materiality, thresholds, and evidence.
- [CSRD double materiality method under ESRS](/artifacts/eu/corporate-sustainability-reporting-directive/double-materiality-method.md): A grounded method for ESRS double materiality assessment: impact materiality, financial materiality, value-chain coverage, thresholds, evidence, and documentation.
- [CSRD double materiality scoring: IRO assessment and ESRS data points](/artifacts/eu/corporate-sustainability-reporting-directive/double-materiality-scoring.md): A grounded scoring guide for CSRD and ESRS double materiality: impact materiality, financial materiality, thresholds, evidence, governance, and disclosure mapping.
- [CSRD Double Materiality Workflow for ESRS Assessment](/artifacts/eu/corporate-sustainability-reporting-directive/double-materiality-workflow.md): A CSRD and ESRS workflow for running a double materiality assessment, from value-chain scoping and stakeholder inputs to IRO scoring, governance approval, and audit trail evidence.
- [CSRD omnibus stop-the-clock status: enacted delay vs proposed scope changes](/artifacts/eu/corporate-sustainability-reporting-directive/faq/omnibus-stop-the-clock-status.md): FAQ on the CSRD stop-the-clock directive, the separate Omnibus proposal, and how reporting teams should treat enacted and proposed changes.
- [CSRD penalties and fines: Member State enforcement, controls, and evidence](/artifacts/eu/corporate-sustainability-reporting-directive/penalties-and-fines.md): A conservative guide to CSRD penalty exposure: why fines depend on Member State implementation, which reporting failures create risk, and what evidence teams should keep.
- [CSRD reporting waves and Omnibus status](/artifacts/eu/corporate-sustainability-reporting-directive/reporting-waves-and-omnibus-status.md): Track what is enacted, postponed, final, or still in the Omnibus process for CSRD reporting waves, ESRS reporting, and Stop-the-Clock changes.
- [CSRD scope and phasing by company type](/artifacts/eu/corporate-sustainability-reporting-directive/scope-and-phasing-by-company-type.md): Map CSRD reporting scope by company category, original Article 5 wave, listed SME opt-out, third-country group rules, and stop-the-clock caveats.
- [CSRD topical ESRS scoping: what must be reported?](/artifacts/eu/corporate-sustainability-reporting-directive/faq/topical-esrs-scoping.md): FAQ on CSRD topical ESRS scoping: ESRS 2, double materiality, topical disclosure requirements, omitted topics, climate, and Appendix B datapoints.
- [CSRD value chain data and estimation methodology under ESRS](/artifacts/eu/corporate-sustainability-reporting-directive/value-chain-estimates.md): How ESRS lets CSRD reporters use sector averages, proxies, and other estimates when direct value-chain data is not available after reasonable effort.
- [CSRD vs CSDDD: Reporting vs Due Diligence](/artifacts/eu/corporate-sustainability-reporting-directive/csrd-vs-csddd.md): Compare CSRD sustainability reporting with CSDDD human rights and environmental due diligence, including scope, evidence, assurance, penalties, and overlap.
- [CSRD vs EU Taxonomy Article 8](/artifacts/eu/corporate-sustainability-reporting-directive/csrd-vs-taxonomy-alignment.md): Compare CSRD and ESRS sustainability reporting with EU Taxonomy Article 8 KPI disclosures, including scope, evidence, tagging, and reuse limits.
- [CSRD vs GRI: ESRS Interoperability](/artifacts/eu/corporate-sustainability-reporting-directive/csrd-vs-gri.md): Compare CSRD/ESRS reporting with GRI-based reporting using grounded ESRS interoperability, materiality, value-chain, and disclosure-reuse rules.
- [CSRD vs IFRS S1 and S2 Comparison](/artifacts/eu/corporate-sustainability-reporting-directive/csrd-vs-ifrs-s1-and-s2.md): Compare CSRD and ESRS with IFRS S1 and S2 across scope, materiality, disclosures, value chain reporting, assurance, digital tagging, and interoperability.
- [CSRD vs SEC Climate Disclosure Rule](/artifacts/eu/corporate-sustainability-reporting-directive/csrd-vs-sec-climate-disclosure-rule.md): Grounded comparison notes for CSRD and the SEC climate disclosure rule, focused on CSRD and ESRS duties and conservative limits where SEC facts are not sourced.
- [CSRD vs SFDR: ESRS and Financial Disclosures](/artifacts/eu/corporate-sustainability-reporting-directive/csrd-vs-sfdr.md): Compare CSRD/ESRS corporate sustainability reporting with SFDR financial-market disclosures, including scope, materiality, PAI data, assurance, tagging, and reuse limits.
- [CSRD XBRL Tagging Checklist for ESRS and Article 8 Readiness](/artifacts/eu/corporate-sustainability-reporting-directive/xbrl-tagging-checklist.md): A grounded CSRD XBRL tagging readiness checklist for XHTML, Inline XBRL, ESRS taxonomy mapping, Article 8 taxonomy mapping, ESEF validation, and source-controlled review.
- [ESRS 1 and ESRS 2 structure under CSRD](/artifacts/eu/corporate-sustainability-reporting-directive/esrs-1-and-esrs-2-structure.md): A grounded explanation of how ESRS 1 sets the reporting architecture and how ESRS 2 provides the mandatory general disclosures for CSRD sustainability statements.
- [ESRS data point inventory workflow for CSRD reporting](/artifacts/eu/corporate-sustainability-reporting-directive/esrs-data-point-inventory-workflow.md): Build an ESRS data point inventory that links disclosure requirements, materiality outcomes, evidence owners, XBRL tagging readiness, and assurance controls.
- [ESRS structure and data model for CSRD reporting](/artifacts/eu/corporate-sustainability-reporting-directive/esrs-structure-and-data-model.md): Map ESRS architecture, disclosure requirements, datapoints, materiality, XBRL taxonomy, Article 8 tagging, and report data ownership for CSRD reporting.
- [FAQ: CSRD double materiality scoring — thresholds, weighting, and evidence](/artifacts/eu/corporate-sustainability-reporting-directive/faq/double-materiality-scoring.md): How to score CSRD double materiality under ESRS without invented thresholds: impact materiality, financial materiality, evidence, and documentation.
- [FAQ: CSRD value chain estimates — methods and proportionality under ESRS](/artifacts/eu/corporate-sustainability-reporting-directive/faq/value-chain-estimates.md): When ESRS permits value chain estimates, what to disclose about assumptions, accuracy, limits, and improvement plans.
- [How do ESRS 1 and ESRS 2 structure CSRD reporting?](/artifacts/eu/corporate-sustainability-reporting-directive/faq/esrs-1-and-2-structure.md): FAQ explaining how ESRS 1 general requirements and ESRS 2 general disclosures fit into CSRD reporting, materiality, and topical ESRS disclosures.
- [LSME and VSME under EU CSRD: what SMEs should know](/artifacts/eu/corporate-sustainability-reporting-directive/faq/lsme-and-vsme.md): FAQ on LSME and VSME under the EU CSRD: listed SME reporting, the temporary opt-out, voluntary SME reporting, and value-chain requests.
- [Taxonomy Article 8 KPIs for CSRD reporting](/artifacts/eu/corporate-sustainability-reporting-directive/taxonomy-article-8-kpis.md): Grounded guide to Article 8 Taxonomy KPI disclosures in CSRD sustainability statements, including KPI templates, ESRS links, XBRL readiness, and evidence controls.
- [Taxonomy Article 8 KPIs under CSRD and ESRS](/artifacts/eu/corporate-sustainability-reporting-directive/faq/taxonomy-article-8-kpis.md): FAQ explaining how EU Taxonomy Article 8 KPI disclosures relate to CSRD, ESRS, and the Article 8 XBRL taxonomy.

*Recommended next step*

*Placement: after local-law section*

## Check the CSRD wave before changing your reporting plan

Use the reporting-wave analysis to document entity classification, listed SME opt-out status, third-country exposure, stop-the-clock reliance, and local-law confirmation before changing CSRD reporting work.

- [Open Research Copilot](/solutions/research-copilot.md): Research CSRD wave questions with cited EU and national-law source material.
- [Discuss CSRD reporting scope](/contact.md): Review CSRD entity classification, reporting-wave evidence, and implementation next steps with Sorena.


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