The recently adopted 'stop the clock' proposal of the European Commission delays the implementation of CSRD for Wave 2 and Wave 3 companies by two years. Member states will need to adopt this proposal until the end of 2025.
Companies at Wave 1 (companies that need to report for FY24) are not affected by the 'stop the clock' proposal and still need to report for CSRD, if it has been adopted into national law. For companies operating in countries where CSRD has not been adopted, NFRD still applies.
The Corporate Sustainability Reporting Directive (CSRD) outlines a timeline for when different types of organisations must begin reporting. This article will walk through the timeline, stage-by-stage.
The CSRD implementation timeline
January 2025
In 2025, the following companies will have to begin reporting for the 2024 financial year:
Large companies and other companies currently reporting under the NFRD, including.
This includes companies that:
Are a large undertaking, exceeding 2 out of 3 of the following criteria for two successive accounting periods:
A balance sheet total of EUR 20 million, or
A net turnover of EUR 40 million, or
Average number of employees of 500.
Are a public-interest entity, meaning any entity which is:
Trading transferable securities on the regulated market of any Member State, or
A credit institution, or
An insurance undertaking, or
Designated by a Member States as a public interest entity (more info on how the Member States define the scope here).
January 2026
In 2026, the following companies will have to begin reporting for the 2025 financial year:
Large companies and other companies not currently reporting under the NFRD.
January 2027
In 2027, the following companies will have to begin reporting for the 2026 financial year:
SMEs that are listed on a regulated market (except micro undertakings).
June 2027
In June 2027, the EU aims to confirm sector-specific versions of the European Sustainability Reporting Standards (ESRS). Until then, the ESRS are sector-agnostic.
January 2028
In January 2028, the following companies will have to begin reporting for the 2027 financial year:
Large, non-EU entities with branches or subsidiaries in the EU.