CSRDReporting wavesEU

CSRD reporting waves and Omnibus status

Separate the original CSRD waves and enacted Stop-the-Clock delay from the now-enacted Omnibus scope amendment in Directive (EU) 2026/470.

As of 24 July 2026, the broader scope change is enacted. The amended main scope applies from financial years beginning in 2027. Revised ESRS were adopted by the Commission on 3 July 2026 but are not in force until Official Journal publication.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 24, 2026
Overview

CSRD timing has four legal layers. The first companies reported for financial year 2024. The , Directive (EU) 2025/794, postponed the original wave-two and wave-three dates. Directive (EU) 2026/470 then enacted the narrower Articles 19a and 29a scope for financial years beginning in 2027. The Commission adopted revised ESRS on 3 July 2026, but its acts page states that they are not in force until Official Journal publication. Apply the ESRS legally in force for the reporting period and keep adoption, scrutiny, publication, and application dates separate.

Section 1

Current status at a glance

For CSRD wave planning, the most important control is the status label attached to each source. The CSRD itself and the first set of ESRS are enacted. The Commission also states that the first CSRD companies had to apply the rules for financial year 2024, for reports published in 2025.

The remains an enacted timing change for companies previously due to report for financial years 2025 or 2026. Directive (EU) 2026/470 also allows Member States to exempt certain undertakings below either the EUR 450 million turnover threshold or the 1,000-employee threshold for financial years starting in 2025 or 2026. Its main narrowed scope applies from financial years beginning in 2027, subject to national transposition, group-level calculation where applicable, and entity-specific exemptions.

  • Enacted baseline: CSRD amended the EU reporting framework and ESRS apply to companies subject to CSRD reporting.
  • First reporting already started: the Commission states that first CSRD companies applied the new rules for financial year 2024, with reports published in 2025.
  • Enacted postponement: the postpones entry into application for companies previously due to report for financial years 2025 or 2026.
  • Final ESRS quick-fix: Commission Delegated Regulation (EU) 2025/1416 was published in the Official Journal on 10 November 2025 and is in force.
  • Enacted 2027 scope: Articles 19a and 29a apply where the undertaking or parent group exceeds EUR 450 million net turnover and an average of 1,000 employees during the financial year.
  • Adopted but not yet in force: the Commission adopted revised ESRS and a voluntary standard on 3 July 2026; its acts page says both await Official Journal publication.
Section 2

What to record for each reporting wave

Do not maintain a single undated answer such as 'CSRD applies' or 'Omnibus delays CSRD'. A defensible wave record should identify the entity, the original CSRD wave assessment, whether the entity was in the group previously due for financial year 2025 or 2026 reporting, and the current legal status of any postponement or proposal being relied on.

Preserve the original wave as history, then record the current-law result separately. For a financial year beginning in 2027 or later, apply Directive (EU) 2026/470 rather than stopping at the two-year delay. A final conclusion still needs the applicable national transposition, reporting perimeter, exemptions, and local publication timetable.

  • Entity identifier: legal entity, group position, EU listing status if relevant, and reporting perimeter.
  • Original wave assessment: why the entity was treated as first-wave, previously financial-year-2025, previously financial-year-2026, or outside CSRD reporting.
  • Stop-the-Clock history: whether the entity was in a wave postponed by Directive (EU) 2025/794.
  • Current-law adjustment: whether the undertaking or parent group exceeds EUR 450 million net turnover and an average of 1,000 employees, on a consolidated basis where applicable, from financial year 2027.
  • Evidence date: date the source was reviewed and whether the source is a directive, delegated regulation, Commission overview, political agreement, or proposal.
Section 3

How to describe enacted Omnibus changes and pending ESRS application

Use five labels in internal trackers and public summaries: enacted EU law, national transposition or application pending, Commission-adopted delegated act awaiting publication, in-force delegated act, and draft or consultation. Directive (EU) 2026/470 is enacted; its 2027 application and Member State implementation remain separate questions.

The 2025 proposal and political agreement are history, not the current authority for scope. Cite Directive (EU) 2026/470 for the amended scope. The revised ESRS and voluntary standard are no longer drafts: the Commission adopted them on 3 July 2026, but they remain not in force until Official Journal publication.

  • Use 'enacted' for CSRD, ESRS Delegated Regulation 2023/2772, and the when those are the sources being applied.
  • Use 'in-force delegated act' for the 2025 ESRS quick-fix published in the Official Journal as Commission Delegated Regulation (EU) 2025/1416.
  • Use 'proposal' and 'political agreement' only for the 2025 historical milestones.
  • Use 'enacted' for Directive (EU) 2026/470 and state its financial-year application point separately.
  • Use 'Commission-adopted but not yet in force' for the 3 July 2026 revised ESRS and voluntary standard until their Official Journal status changes.
  • Avoid treating the EU directive alone as proof that a specific entity has satisfied national transposition, exemption, and filing analysis.
Section 4

ESRS reporting is a separate layer from wave timing

Once an entity is in an applicable CSRD reporting wave, the reporting content question is not answered by the wave itself. The Commission overview states that companies subject to CSRD have to report according to ESRS, and Delegated Regulation (EU) 2023/2772 sets out the first set of sustainability reporting standards.

For wave-status work, keep ESRS scoping and disclosure readiness in a separate evidence lane from the legal timing lane. That prevents a team from treating an Omnibus timing note as a reason to ignore ESRS data, assurance preparation, or prior first-wave reporting obligations.

  • Wave lane: entity scope, original wave, Stop-the-Clock relevance, Omnibus status, and source date.
  • ESRS lane: materiality assessment, material impacts, risks and opportunities, disclosure requirements, phase-ins, and quick-fix applicability.
  • Assurance lane: which report year and reporting perimeter the assurance team is reviewing.
  • Publication lane: annual report, sustainability statement, digital filing, and any local transposition requirements.
  • Change lane: source update that changed a conclusion, owner approval, and replacement citation.
Section 5

Evidence pack for a defensible status conclusion

A CSRD status conclusion should be short, but it should not be bare. Keep enough evidence to show the original wave, any Stop-the-Clock effect, the Directive (EU) 2026/470 threshold test, the national-law position, and the reporting year.

Refresh the evidence pack when national transposition, Official Journal publication or application of delegated ESRS, assurance standards, or the company fact pattern changes. Historical proposal and political-agreement records can remain in the chronology, but the current scope conclusion should cite the enacted legal act.

  • One-page entity scope memo with the original CSRD wave conclusion and source citations.
  • Stop-the-Clock assessment showing whether the entity was previously in the financial-year-2025 or financial-year-2026 group.
  • Directive (EU) 2026/470 test showing turnover, employee, group, exemption, and application-year evidence.
  • ESRS readiness line showing whether reporting content work continues despite timing or scope uncertainty.
  • Approval record from finance reporting, legal, sustainability, and assurance owners.
  • Change log recording source URL, review date, conclusion changed, and what was not changed because the source did not support it.
  • Reassessment trigger: rerun the scope and standards analysis after a change in financial year, turnover, average employees, group perimeter, listing status, national transposition, exemption, or the legal status of the applicable ESRS.
Recommended next step

Convert CSRD status into a cited wave record

This page separates enacted CSRD scope and Stop-the-Clock changes from in-force ESRS, Commission-adopted acts awaiting publication, and entity-specific national-law checks.

Primary sources

References and citations

finance.ec.europa.eu6 citations
Referenced sections
  • Primary source for CSRD first application, ESRS reporting obligation overview, Stop-the-Clock postponement wording, Omnibus proposal status, and Omnibus political-agreement timeline.
  • Supports the first CSRD application statement, the Stop-the-Clock description, and the Omnibus proposal and political-agreement status.
  • Supports the distinction between the enacted Stop-the-Clock postponement and the wider Omnibus simplification package.
Show 3 more
  • Supports the February 2025 Omnibus proposal description and the December 2025 political-agreement timeline entry.
  • Supports the statement that companies subject to CSRD report according to ESRS.
  • Supports the status categories used in the evidence pack: CSRD first application, Stop-the-Clock postponement, Omnibus proposal, and political agreement.
"EU rules require large companies and listed companies"
More quoted passages
"first time in the 2024 financial year"
"previously required to report for the first time"
"Legislative package - Simplification omnibus"
"have to report according to European Sustainability Reporting Standards"
"Policy making timeline"
eur-lex.europa.eu3 citations
Referenced sections
  • Current legal source for the enacted Omnibus scope amendment and related CSRD changes.
  • Current legal source for the enacted scope amendment, value-chain cap, assurance timetable, and third-country thresholds.
  • Final legal act that followed the 2025 Omnibus proposal and political agreement.
"Directive (EU) 2026/470"
More quoted passages
"financial years starting on or after 1 January 2027"
data.europa.eu2 citations
Referenced sections
  • Official legal source for the first set of European Sustainability Reporting Standards.
  • Supports that the first ESRS set is adopted by delegated regulation and applies to undertakings preparing CSRD sustainability reporting according to the directive timetable.
"sustainability reporting standards"
finance.ec.europa.eu2 citations
Referenced sections
  • Supports the 2025 quick-fix status and the 3 July 2026 adoption and not-yet-in-force status of the revised ESRS and voluntary standard.
  • Supports keeping delegated-act status separately from CSRD wave timing and Omnibus scope proposals.
"implementing and delegated acts"
eur-lex.europa.eu2 citations
Referenced sections
  • Official legal source for the enacted CSRD baseline amending EU corporate sustainability reporting rules.
  • Supports the enacted CSRD baseline that amended the EU reporting framework for corporate sustainability reporting.
"as regards corporate sustainability reporting"
eur-lex.europa.eu2 citations
Referenced sections
  • Official EUR-Lex URL cited in the Commission overview for the directive postponing reporting-requirement application for companies previously due to report for financial years 2025 or 2026.
  • Cited from the Commission CSRD overview as the legal act postponing reporting-requirement application for companies previously due to report for financial years 2025 or 2026.
"as regards the dates from which Member States are to apply certain corporate sustainability reporting and due diligence requirements"
eur-lex.europa.eu
Referenced sections
  • Binding 2025 ESRS quick-fix delegated regulation, published in the Official Journal on 10 November 2025 and in force.
"postponement of the date of application of the disclosure requirements for certain undertakings"
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