EU CSRDPhasing

EU CSRD (Directive (EU) 2022/2464) Scope and phasing by company type

This page is for teams that need the cleanest possible wave map by entity category.

Use it to build the cover note for the reporting program and the reporting calendar.

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Author
Sorena AI
Published
Feb 22, 2026
Updated
Feb 22, 2026
Sections
4

Structured answer sets in this page tree.

Primary sources
4

Cited legal and guidance references.

Publication metadata
Sorena AI
Published Feb 22, 2026
Updated Feb 22, 2026
Overview

The current CSRD phasing logic only makes sense when company types are separated correctly. The categories below are the ones that matter most in practice for assigning the first reporting year under the current law.

Section 1

Category 1: legacy NFRD style public interest entities

These entities entered first. They include large public interest entities exceeding 500 employees and the matching parent undertaking category. Their reporting already starts with financial years beginning on or after 1 January 2024.

They should also check the 2025 quick fix because the relief affects their early ESRS cycles.

  • Current start year: 1 January 2024.
  • This wave was not postponed.
  • Quick fix may reduce some datapoint burden temporarily.
Section 2

Category 2: other large undertakings and other large groups

This is the delayed second wave. Under the stop the clock amendment, these entities now start for financial years beginning on or after 1 January 2027.

This group should use the extra time to harden the reporting system rather than to postpone all preparation.

  • Current start year: 1 January 2027.
  • Original earlier wave timing is superseded.
  • Scope and reporting boundary work should still start well before first live reporting.
Section 3

Category 3: listed SMEs and certain special financial or insurance categories

The listed SME wave now starts with financial years beginning on or after 1 January 2028. This category also includes certain small and non-complex institutions and certain captive insurance or reinsurance undertakings where the legal conditions are met.

A listed SME may have transitional options, but that does not remove the need for governance and data planning.

  • Current start year: 1 January 2028.
  • Check opt out availability and how it interacts with group or market expectations.
  • Keep a separate file for listed status and market publication needs.
Section 4

Category 4: third-country undertaking route

The third-country undertaking route is separate from the Union incorporated wave map. It applies to certain non-EU undertakings with significant Union turnover and the required subsidiary or branch link. The reporting path is tied to the financial year 2028 framework.

Treat this as its own scoping project because publication responsibility and standards logic differ from the main entity wave map.

  • Track third-country turnover and EU presence separately.
  • Identify the responsible EU subsidiary or branch early.
  • Watch for third-country ESRS delegated acts and equivalent reporting developments.
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Primary sources

References and citations

Directive (EU) 2022/2464 - Official Journal
eur-lex.europa.eu
Referenced sections
  • Primary legal text for scope, phased application, management report sustainability statements, assurance, and digital markup requirements.
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