CSRD reporting waves and Omnibus status

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 Stop-the-Clock Directive is a separate enacted postponement for companies that were previously required to report for the first time for financial years 2025 or 2026. The Commission's broader Omnibus simplification package is different: the grounding records a 26 February 2025 legislative package and a 9 December 2025 political agreement, but this page does not treat proposal-stage or political-agreement wording as final operative law.

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.

Where a source supports only a caveat, preserve the caveat. For example, the Commission overview supports that the Stop-the-Clock Directive postpones entry into application for wave two and wave three companies, but the page should not invent a replacement first-reporting date unless the final applicable source used by the company supplies it.

Use three labels in internal trackers and public summaries: enacted, final but awaiting application mechanics, and proposed or political agreement. The Commission overview records that the February 2025 Omnibus package proposed applying CSRD only to the largest companies, described there as those with more than 1000 employees, and later records a December 2025 political agreement on the Omnibus I simplification package.

That is not the same as saying every current CSRD threshold has already changed in every implementation context. If the reporting decision depends on the Omnibus package, cite the final legal act when available and keep proposal-stage wording out of definitive scope conclusions.

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.

A CSRD reporting-wave conclusion should be short, but it should not be bare. Keep enough evidence to show why the company treated a requirement as already applicable, postponed, or still dependent on final Omnibus legislation.

The evidence pack should be refreshed when the cited Commission overview, delegated-act page, EUR-Lex act, or company fact pattern changes. A proposal or political agreement can be a watch item, but the status conclusion should say when it is not yet the operative legal basis.