---
title: "EU CSRD Scope and Phasing by Company Type"
canonical_url: "https://www.sorena.io/artifacts/eu/csrd/scope-and-phasing-by-company-type"
source_url: "https://www.sorena.io/artifacts/eu/csrd/scope-and-phasing-by-company-type"
author: "Sorena AI"
description: "Review current CSRD phasing by company type, including wave one public interest entities, wave two large undertakings."
keywords:
  - "EU CSRD scope and phasing"
  - "CSRD company type waves"
  - "CSRD public interest entity wave"
  - "CSRD listed SME wave"
  - "CSRD third country undertaking wave"
  - "stop the clock CSRD phasing"
  - "EU CSRD"
  - "Scope"
  - "Phasing"
  - "Company type"
  - "Directive (EU) 2025/794"
---
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# EU CSRD Scope and Phasing by Company Type

Review current CSRD phasing by company type, including wave one public interest entities, wave two large undertakings.

*EU CSRD* *Phasing*

## 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.

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.

## 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.

## 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- Original earlier wave timing is superseded.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.

## 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.

## 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.

*Recommended next step*

*Placement: after the timeline or milestone section*

## Use EU CSRD (Directive (EU) 2022/2464) Scope and phasing by company type as a cited research workflow

Research Copilot can take EU CSRD (Directive (EU) 2022/2464) Scope and phasing by company type from planning deadlines, owners, and milestones from this page to a reusable workflow inside Sorena. Teams working on EU CSRD (Directive (EU) 2022/2464) can keep owners, evidence, and next steps aligned without copying this guide into separate documents.

- [Open Research Copilot for EU CSRD (Directive (EU) 2022/2464) Scope and phasing by company type](/solutions/research-copilot.md): Start from EU CSRD (Directive (EU) 2022/2464) Scope and phasing by company type and answer scope, timing, and interpretation questions with cited outputs.
- [Talk through EU CSRD (Directive (EU) 2022/2464)](/contact.md): Review your current process, evidence gaps, and next steps for EU CSRD (Directive (EU) 2022/2464) Scope and phasing by company type.

## Primary sources

- [Directive (EU) 2022/2464 - Official Journal](https://eur-lex.europa.eu/eli/dir/2022/2464/oj/eng?ref=sorena.io) - Primary legal text for scope, phased application, management report sustainability statements, assurance, and digital markup requirements.
- [Directive (EU) 2025/794 - stop the clock amendment](https://eur-lex.europa.eu/eli/dir/2025/794/oj/eng?ref=sorena.io) - Current law for the two year postponement of the second and third CSRD reporting waves.
- [Directive (EU) 2024/1306 - ESRS sector-specific and third-country deadline delay](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024L1306&ref=sorena.io) - Moved the deadline for sector-specific and third-country ESRS delegated acts to 30 June 2026.
- [European Commission - Corporate sustainability reporting](https://finance.ec.europa.eu/capital-markets-union-and-financial-markets/company-reporting-and-auditing/company-reporting/corporate-sustainability-reporting_en?ref=sorena.io) - Official implementation overview for the CSRD, ESRS, quick fix, and related Omnibus developments.

## Related Topic Guides

- [EU CSRD Applicability Test | Current Scope and Reporting Waves](/artifacts/eu/csrd/applicability-test.md): Use this CSRD applicability test to determine whether your entity is in scope, whether a group exemption applies.
- [EU CSRD Assurance Ready Controls and Evidence | Limited Assurance Preparation](/artifacts/eu/csrd/assurance-ready-controls-and-evidence.md): Prepare CSRD reporting for limited assurance with controls that tie metrics, narratives, markup, and Taxonomy KPIs back to evidence.
- [EU CSRD Checklist | Practical Reporting and ESRS Checklist](/artifacts/eu/csrd/checklist.md): Use this CSRD checklist to move from scope to report delivery.
- [EU CSRD Compliance Guide | Reporting System, Controls, and Delivery Model](/artifacts/eu/csrd/compliance.md): Build a publication grade CSRD reporting system with the right scope memo, materiality process, ESRS data model, value chain logic, Taxonomy linkage.
- [EU CSRD Deadlines and Compliance Calendar | Current Waves, Quick Fix, and Assurance Dates](/artifacts/eu/csrd/deadlines-and-compliance-calendar.md): Track the current CSRD reporting waves, the July 2025 stop the clock amendment, the July 2025 ESRS quick fix.
- [EU CSRD Double Materiality Interview Question Bank | Practical Stakeholder Questions](/artifacts/eu/csrd/double-materiality-interview-question-bank.md): Use this CSRD question bank to run a stronger double materiality process.
- [EU CSRD Double Materiality Method | Building a Reviewable ESRS Methodology](/artifacts/eu/csrd/double-materiality-method.md): Build a reviewable double materiality method for the CSRD and ESRS.
- [EU CSRD ESRS Structure and Data Model | How to Organize ESRS Reporting](/artifacts/eu/csrd/esrs-structure-and-data-model.md): Understand how to organize ESRS reporting under the CSRD.
- [EU CSRD FAQ | Current Answers on Waves, ESRS, Assurance, and Taxonomy](/artifacts/eu/csrd/faq.md): Get grounded answers to common CSRD questions, including the current reporting waves after the stop the clock amendment, ESRS quick-fix reliefs.
- [EU CSRD Penalties and Fines | National Enforcement and Reporting Exposure](/artifacts/eu/csrd/penalties-and-fines.md): Understand how CSRD enforcement works in practice. This guide explains the role of national transposition, accounting and transparency law enforcement.
- [EU CSRD Requirements | Article by Article Reporting and Assurance Map](/artifacts/eu/csrd/requirements.md): Map the core CSRD requirements by workstream, including the sustainability statement, ESRS, double materiality, value chain reporting, Taxonomy linkage.
- [EU CSRD Value Chain Data and Estimation | Practical Method for ESRS Reporting](/artifacts/eu/csrd/value-chain-data-and-estimation.md): Build a defensible CSRD value chain method using ESRS rules and official guidance.
- [EU CSRD vs IFRS S1 and S2 | Double Materiality versus Investor Focused Disclosure](/artifacts/eu/csrd/csrd-vs-ifrs-s1-and-s2.md): Compare the EU CSRD and ESRS with IFRS S1 and IFRS S2 using official sources.
- [EU CSRD vs SEC Climate Disclosure Rule | Scope, Status, and Reporting Logic](/artifacts/eu/csrd/csrd-vs-sec-climate-disclosure-rule.md): Compare the EU CSRD and ESRS with the SEC climate disclosure rule using official sources.
- [EU CSRD vs Taxonomy Alignment | ESRS Reporting versus Article 8 KPIs](/artifacts/eu/csrd/csrd-vs-taxonomy-alignment.md): Compare CSRD reporting with EU Taxonomy alignment disclosures.


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