CSRD Timeline after the Omnibus: Wave 1 from FY2024, Large Companies from FY2027, Non-EU Groups from FY2028

Directive (EU) 2022/2464 set the dates, Directive (EU) 2025/794 (the Stop-the-clock Directive) moved them, and Directive (EU) 2026/470 (Omnibus I) changed who reports. These directives bind the Member States; a company follows its national law, which until transposition can still carry the earlier text. What the regime requires beyond its dates is covered where the Corporate Sustainability Reporting Directive (CSRD) is explained.

Every status on this page is given as of 29 October 2026.

Every CSRD Date from Adoption to the 2031 Review

From its signature on 14 December 2022 to the scope review due by 30 April 2031, the CSRD timeline runs through the dates in the table below, each with the act and article that sets it and its status as of 29 October 2026. Superseded dates stay in the table and name the act that replaced them; EU dates that reach companies through national law carry "where transposed".

How the First Reporting Year Is Fixed

The CSRD applies from a financial year, not from a calendar date: Article 5(2) of Directive (EU) 2022/2464 ties each group of companies to the financial years starting on or after a given date. The report on that financial year is published in the following year, within the limit set by the Accounting Directive.

Financial Years Starting On or After a Date

A company's first CSRD year is the first financial year whose start date falls on or after the date in Article 5(2), which for a calendar-year company in the new scope is financial year 2027. Wave 1 is the exception: after Article 3(1)(a)(i) of Directive (EU) 2026/470, it covers only financial years starting between 1 January 2024 and 31 December 2026.

A wave 1 financial year that starts on 1 July 2026 starts before 1 January 2027 and is still a wave 1 year. For a company above both new values whose financial year starts on 1 April, the first new-scope year runs from 1 April 2027 to 31 March 2028. The table works through four cases.

Calculated from Article 5(2) of Directive (EU) 2022/2464 and Articles 30 and 40d of Directive 2013/34/EU; illustrations, not statements about any company.

Publication: Twelve Months after the Balance Sheet Date

The sustainability statement sits in the management report, which Article 30(1) of Directive 2013/34/EU requires to be published within a reasonable period not exceeding 12 months after the balance sheet date. Issuers whose securities are admitted to trading on an EU regulated market publish their annual financial report within four months under Article 4(1) of Directive 2004/109/EC (Commission Notice C/2024/6792, FAQ 39). For a calendar financial year 2027, the statement is therefore published at the latest by 31 December 2028, and an issuer publishes by 30 April 2028 (calculated).

From Proposal to Entry into Force: 2021 to 2024

The CSRD went from proposal to signature between 21 April 2021 and 14 December 2022: the Commission proposed it as COM(2021) 189, the European Parliament adopted its first-reading position on 10 November 2022 and the Council adopted the act on 28 November 2022. Directive (EU) 2022/2464 was published in OJ L 322 on 16 December 2022 and entered into force on 5 January 2023 (Article 7). Article 5(1) set 6 July 2024 for transposing Articles 1 to 3.

The first set of standards, due by 30 June 2023 under Article 29b(1) of Directive 2013/34/EU, was adopted on 31 July 2023 as Delegated Regulation (EU) 2023/2772 and has been in force since 25 December 2023. For wave 1, the CSRD replaced the regime of Directive 2014/95/EU from financial year 2024 where a Member State had transposed it. The amended act is the legal text of Directive (EU) 2022/2464 in force today.

Wave 1: Financial Years 2024 to 2026

Wave 1 covers large public-interest entities with an average of more than 500 employees, and public-interest parents of large groups above 500 employees on a consolidated basis, for financial years starting between 1 January 2024 and 31 December 2026 only. Before Directive (EU) 2026/470, Article 5(2)(a) of Directive (EU) 2022/2464 set no end date, only financial years starting on or after 1 January 2024. Directive (EU) 2026/470 added the end date in Article 3(1)(a)(i). The first wave 1 reports, on financial year 2024, were published in 2025.

From financial years starting on or after 1 January 2027, a wave 1 company reports only if it exceeds both new values. Recital 31 of Directive (EU) 2026/470 states that wave 1 undertakings below the new thresholds fall outside the scope for those years.

The Member State Option for 2025 and 2026

Member States may exempt wave 1 undertakings and issuers that do not exceed a net turnover of EUR 450 million or an average of 1,000 employees, on a consolidated basis where applicable, for financial years starting between 1 January 2025 and 31 December 2026. The option sits in the last subparagraph of Article 5(2) of Directive (EU) 2022/2464, added by Article 3(1)(c) of Directive (EU) 2026/470, with recital 31 as its reason. It does not cover the obligations under Article 40a, which the provision excepts.

The option belongs to the Member States, so a company's national law decides whether financial years 2025 and 2026 are exempt. Its basis is Directive (EU) 2026/470, not the Stop-the-clock Directive, which did not change wave 1.

Wave 2 and the New Size Test: Financial Year 2027, Reports in 2028

Undertakings and parents of groups that exceed a net turnover of EUR 450 million and an average of 1,000 employees report for financial years starting on or after 1 January 2027, with their first reports in 2028. The rule is point (b) of the first subparagraph of Article 5(2) of Directive (EU) 2022/2464: Article 1(a)(i) of Directive (EU) 2025/794 set the date, and Article 3(1)(a)(ii) of Directive (EU) 2026/470 set the criteria. "Exceed" means more than, and issuers follow the same test under the third subparagraph. Counting is explained under the CSRD thresholds that start in financial year 2027.

Two further starts share financial year 2027: the revised ESRS become mandatory (Article 3 of Delegated Regulation (EU) 2026/1563), and under Delegated Regulation (EU) 2026/1560 of 3 July 2026, in force since 24 September 2026, the value-chain cap list of Annex II applies from financial years beginning on or after 1 January 2027. The three-year transition for value-chain information in Article 19a(3) of Directive 2013/34/EU, as amended by Directive (EU) 2026/470, starts with the first year the undertaking is subject to reporting (recital 13).

How the Original 2025 Start Moved Twice

Wave 2 was first set for financial years starting on or after 1 January 2025, covering every other large undertaking and parent of a large group, and that date moved to 1 January 2027 before its population was redefined. Directive (EU) 2025/794 moved it, and its recital 3 gives the reason: while the simplification initiatives were ongoing, and to avoid the undertakings due to report for financial years beginning on or after 1 January 2025 and 1 January 2026 "incurring unnecessary and avoidable costs", their reporting requirements were postponed by two years.

Directive (EU) 2026/470 kept financial year 2027 and replaced the "large undertaking" criterion (the test before Directive (EU) 2026/470) with more than EUR 450 million net turnover and more than 1,000 employees. The first move is explained in how the Stop-the-clock Directive moved the 2025 start.

Wave 3: Moved to 2028, Then Deleted

Wave 3, which covered listed SMEs other than micro-undertakings, small and non-complex institutions and captive insurance and reinsurance undertakings, never started: its financial year 2026 start moved to 2028 under Article 1(a)(ii) of Directive (EU) 2025/794 and was deleted by Article 3(1)(a)(iii) and (b)(iii) of Directive (EU) 2026/470. Before Directive (EU) 2026/470, listed SMEs could also opt out for financial years starting before 1 January 2028. No reporting date for listed SMEs remains in Article 5(2).

Article 40a Reports: Financial Year 2028 for Non-EU Groups

Non-EU groups that meet the Article 40a test report through their EU subsidiary or branch for financial years starting on or after 1 January 2028, a date that neither amending directive changed. The date sits in the second subparagraph of Article 5(2) of Directive (EU) 2022/2464, and Article 40d(1) of Directive 2013/34/EU requires publication within 12 months of the balance sheet date (by 31 December 2029 for a calendar year).

The test under Article 40a(1), as amended by Article 2(13) of Directive (EU) 2026/470, combines a Union net turnover of more than EUR 450 million in each of the last two consecutive financial years with an EU subsidiary or branch above EUR 200 million net turnover in the preceding financial year. The Article 40b standards were first due by 30 June 2024, a date that Directive (EU) 2024/1306 moved to 30 June 2026. Who files is set out under the Article 40a test for non-EU groups.

Which ESRS Set Applies in Each Financial Year

The ESRS set follows the financial year: the 2023 set applies to financial years 2024 and 2025, financial year 2026 allows a choice, and the revised ESRS are mandatory for financial years beginning on or after 1 January 2027. Delegated Regulation (EU) 2026/1563 replaces Annexes I and II of Delegated Regulation (EU) 2023/2772; it does not repeal it.

12 standards in both sets (Delegated Regulations (EU) 2023/2772 and 2026/1563).

The Choice for Financial Year 2026

For financial years beginning between 1 January and 31 December 2026, Article 2 of Delegated Regulation (EU) 2026/1563 lets an undertaking apply the 2023 set as amended by Delegated Regulation (EU) 2025/1416, the revised set, or the 2023 set with eight listed reliefs from the revised ESRS 1. Under Article 2(2), the sustainability statement must state which version the undertaking applies.

Delegated Regulation (EU) 2026/1563 was adopted on 3 July 2026, published in the Official Journal on 21 September 2026 and enters into force on 10 November 2026 (Article 3). It meets recital 18 of Directive (EU) 2026/470, under which the Commission was to revise the first set within six months of that directive's entry into force. The options and reliefs are compared under the revised (simplified) ESRS for financial year 2026.

How the 2025 and 2026 Amending Directives Set the Dates

Two directives changed the CSRD dates after 2022: Directive (EU) 2025/794 postponed the later waves, and Directive (EU) 2026/470 (Omnibus I) ended wave 1 after 2026, redefined the scope from 2027 and deleted wave 3. The Commission proposed both on 26 February 2025: COM(2025) 80 for the dates and COM(2025) 81 for the content.

Directive (EU) 2025/794 followed an urgent procedure: the European Parliament adopted its position on 3 April 2025, the act was adopted on 14 April 2025, published on 16 April 2025 and entered into force on 17 April 2025 (Article 4). Member States had to transpose it by 31 December 2025 (Article 3(1)).

The Commission dates the political agreement to 9 December 2025 (press release IP/25/2981), the European Parliament adopted its first-reading position on 16 December 2025 (T10-0324/2025) and the act was signed on 24 February 2026. Published on 26 February 2026, Directive (EU) 2026/470 entered into force on 18 March 2026, the twentieth day after publication (Article 6). The full set of changes is set out in what Omnibus I changed in the CSRD dates.

Deadlines Still Ahead, 2026 to 2031

As of 29 October 2026 the next CSRD dates are the entry into force of the revised ESRS on 10 November 2026, the first financial year of the new scope on 1 January 2027 and the transposition deadline of Directive (EU) 2026/470 on 19 March 2027. The table lists each later date, who must act and the provision behind it; the Commission's CSRD page summarises the rules.

National Transposition by 19 March 2027

Member States must bring into force the laws that transpose Articles 1 to 3 of Directive (EU) 2026/470 by 19 March 2027 (Article 5(1)). Until a Member State's law changes, its national rules can still carry the earlier text of the Accounting Directive. The two earlier deadlines were 6 July 2024 for the CSRD itself and 31 December 2025 for the Stop-the-clock Directive.

The EU deadline says nothing about the status of any single state. Dated national status for each Member State is kept in the CSRD transposition tracker for the 2027 deadline.

The EU Limited-Assurance Standard Due by 1 July 2027

The Commission must adopt the EU standard for limited assurance of sustainability reporting by delegated act by 1 July 2027 under Article 26a(3) of Directive 2006/43/EC as replaced by Article 1(3) of Directive (EU) 2026/470; before Directive (EU) 2026/470, the date was 1 October 2026. The standard is not adopted as of 29 October 2026 (due by 1 July 2027); until the Commission adopts one, Member States may apply national assurance standards (Article 26a(2)).

ISSA 5000, issued by the IAASB in November 2024, is effective for periods beginning on or after 15 December 2026 and is not EU law. The CEAOB technical advice of 25 September 2026 (CEAOB 2026-026) proposes an EU standard effective for periods beginning on or after 15 December 2027, as advice only.

Review Reports in 2029 and 2031

The Commission reports on the CSRD by 30 April 2029 and on extending its scope by 30 April 2031, then every three years (Article 6(1) of Directive (EU) 2022/2464 as amended by Article 3(2) of Directive (EU) 2026/470). These are Commission duties, not company deadlines. A separate Commission report on technological solutions for sustainability reporting is due by 19 March 2028 under Article 29f of Directive 2013/34/EU, inserted by Directive (EU) 2026/470.

How to Plan Reporting against the Timeline

Plan backwards from the first financial year that falls under the CSRD, because the data for that year is collected while the year runs and the statement is published in the year after. The five planning steps are listed below.

1. Confirm the company type and size against who must report under the CSRD.
2. Fix the first financial year from its start date.
3. Note which ESRS set applies to that year.
4. Check the national law and the transposition deadline of 19 March 2027.
5. Diarise the publication limit and run the CSRD scope check.

Once the first financial year is fixed, the reporting steps are set out in our CSRD compliance plan.

How the Dates Can Still Change

The EU dates are fixed in law as of 29 October 2026, but they reach companies through national law, and three further sources can still add dates: the national transposition laws, the EU limited-assurance standard and the Commission's review reports. Until a Member State transposes Directive (EU) 2026/470, its law can still apply the earlier text.

The review reports under Article 6(1) of Directive (EU) 2022/2464 are reports of the Commission, not amendments; a date changes only if a later act amends the directive that sets it. The provisions behind each date are set out in the CSRD articles that set and can change the dates.

Timeline Questions

Five questions recur about the CSRD timeline.

From which year does a company outside wave 1 report?

From its first financial year starting on or after 1 January 2027, if it exceeds both a net turnover of EUR 450 million and an average of 1,000 employees, individually or as a group. A non-EU group reports under Article 40a from financial years starting on or after 1 January 2028.

Do former wave 2 companies report for financial year 2025?

No: Directive (EU) 2025/794 moved the former wave 2 start from financial year 2025 to financial years starting on or after 1 January 2027, and Directive (EU) 2026/470 limited it to companies above both new values.

When did the CSRD enter into force?

Directive (EU) 2022/2464 entered into force on 5 January 2023, the twentieth day after its publication in the Official Journal on 16 December 2022 (Article 7).

Is reasonable assurance still on the timeline?

No: Directive (EU) 2026/470 deleted the Commission's power to adopt reasonable-assurance standards, and Article 34(1)(aa) of Directive 2013/34/EU, as replaced, requires limited assurance only. The former date of 1 October 2028 was a Commission deadline, never a company one; see limited assurance of CSRD reporting.

Does a financial year starting on 1 April 2027 fall under the new scope?

Yes, for a company above both thresholds: it is the first financial year starting on or after 1 January 2027, so it is that company's first CSRD year, with publication at the latest by 31 March 2029. Both dates are calculated from Article 5(2) of the CSRD and Article 30 of Directive 2013/34/EU.