CSRD Timeline 2025-2028: Who Reports When and What You Need to Know

CSRD reporting began in financial year 2024, with the first sustainability reports due in 2025 from large public-interest entities. The directive then rolls out in four waves through to 2029, progressively bringing large companies, listed SMEs, and non-EU businesses into scope. This guide sets out the exact deadlines, who falls into each wave, and what the EU Omnibus proposal means for your timeline.

CSRD Implementation Timeline at a Glance

The table below summarises all four CSRD reporting waves. If you are unsure which wave applies to your organisation, see the decision tree further down this page.

Wave	Who Is in Scope	Financial Years Covered	First Report Due	Key Details
Wave 1	Large public-interest entities already subject to the NFRD (>500 employees)	FY 2024	2025	Approx. 11,700 companies across the EU. Reports must follow the full European Sustainability Reporting Standards (ESRS).
Wave 2	Other large undertakings meeting at least 2 of 3 criteria: >250 employees, >€50m turnover, >€25m balance sheet total	FY 2025	2026	The largest new cohort — an estimated 35,000+ companies. Includes private companies meeting the size thresholds. First time many mid-market businesses face mandatory sustainability reporting.
Wave 3	Listed SMEs, small and non-complex credit institutions, and captive insurance undertakings	FY 2026	2027	Listed SMEs may opt out until FY 2028 (reporting in 2029). Simplified ESRS standards (LSME ESRS) will apply. Subject to potential delay under the Omnibus proposal — see below.
Wave 4	Non-EU (third-country) companies with >€150m net turnover in the EU and at least one EU subsidiary or branch	FY 2028	2029	Reports prepared by the EU subsidiary or branch on behalf of the third-country parent. A dedicated third-country ESRS is expected.

For a deeper look at how Wave 2 affects mid-sized businesses specifically, read our CSRD guide for medium-sized businesses.

What Changed in 2025-2026?

In February 2025 the European Commission published the Omnibus Simplification Package, a sweeping proposal to reduce regulatory burden across several EU sustainability directives, including the CSRD. The key proposed changes are as follows:

• Wave 2 two-year delay: The Commission proposed postponing the first reporting deadline for Wave 2 companies by two years — from FY 2025 (report in 2026) to FY 2027 (report in 2028). As of early 2026, this delay has not been formally adopted into law, but the European Parliament and Council are actively negotiating it.
• Wave 3 may be removed entirely: Under certain versions of the Omnibus text, listed SMEs could be taken out of mandatory CSRD scope altogether. This remains under discussion.
• Scope thresholds raised: The proposal would increase the size thresholds for “large undertaking” status, potentially excluding a significant number of companies currently assumed to be in Wave 2.
• Simplified value chain reporting: Companies may no longer be required to collect detailed sustainability data from SME suppliers, which would ease the indirect burden on smaller businesses in the supply chain.
• Voluntary reporting encouraged: Companies falling below the revised thresholds would still be able to report voluntarily using simplified standards.

What this means in practice: If your company sits in Wave 2 or Wave 3, you should continue preparing as though the original deadlines stand. Legislative delays are possible but not guaranteed, and companies that wait risk falling behind if the Omnibus amendments are diluted or rejected. Investors and customers will still expect sustainability data regardless of regulatory shifts.

For guidance on how governance structures should evolve alongside reporting obligations, see our article on CSRD governance alignment and reporting.

UK Companies — Does CSRD Apply to You?

Post-Brexit, the CSRD is not directly transposed into UK law. However, UK businesses can still fall within its reach in three ways:

1. Direct scope through EU presence

If your UK-headquartered group has a subsidiary incorporated in an EU member state that meets the relevant size thresholds, that subsidiary must report under the CSRD according to its wave. Alternatively, if you are listed on an EU-regulated market, you are directly in scope.

2. Wave 4 — third-country reporting

UK companies generating more than €150 million in net turnover within the EU will fall into Wave 4 (FY 2028, reporting in 2029), provided they have at least one EU branch or subsidiary above the applicable thresholds.

3. Indirect scope — value chain data requests

Even if your company is not directly captured, EU customers reporting under the CSRD will need sustainability data from their value chain. If you supply goods or services to companies in Waves 1 or 2, expect to receive data requests covering environmental metrics, human rights due diligence, and governance practices. Being unable to respond may put commercial relationships at risk.

UK Sustainability Disclosure Standards (UK SDS)

The UK Government has confirmed it will introduce its own sustainability reporting regime based on the ISSB standards (IFRS S1 and S2). The current expectation is that mandatory UK SDS reporting will begin from 2027 for the largest UK-listed companies and financial institutions, with potential phased extension to large private companies thereafter. While UK SDS differs from the ESRS in structure, there is significant overlap in the underlying data requirements. Companies preparing for CSRD will find much of that work transferable to UK SDS compliance.

How to Determine Your CSRD Reporting Wave

Use the following decision tree to identify which wave — if any — applies to your organisation:

1. Are you an EU public-interest entity with more than 500 employees, already subject to the Non-Financial Reporting Directive (NFRD)?
   Yes → Wave 1. You should already be reporting on FY 2024.
   No → Continue.
2. Are you an EU-incorporated company (or EU subsidiary of a non-EU group) meeting at least two of the following: >250 employees, >€50m turnover, >€25m balance sheet total?
   Yes → Wave 2. Your first reporting year is FY 2025, with the report due in 2026 (subject to potential Omnibus delay).
   No → Continue.
3. Are you a listed SME on an EU-regulated market, a small and non-complex credit institution, or a captive insurance undertaking?
   Yes → Wave 3. First reporting year is FY 2026 (report in 2027), with an opt-out available until FY 2028. Subject to Omnibus changes.
   No → Continue.
4. Are you a non-EU company with more than €150m net turnover generated in the EU, with at least one EU subsidiary or branch?
   Yes → Wave 4. First reporting year is FY 2028, with the report due in 2029.
   No → Continue.
5. None of the above apply.
   You are not currently in direct scope of the CSRD. However, you may face indirect obligations through value chain data requests from EU customers or through forthcoming UK SDS requirements. Voluntary reporting using the ESRS is an option worth considering.

If you are uncertain about your classification, particularly around consolidated vs. individual reporting, consult the full CSRD overview on our dedicated page.

What to Do Now Based on Your Wave

Wave 1 — Already Reporting (FY 2024)

Your first CSRD-aligned report should already be published or in final review. Focus now on:

• Reviewing assurance findings from your limited assurance engagement and addressing any gaps.
• Strengthening data collection processes for your second reporting cycle, especially around Scope 3 emissions and value chain metrics.
• Starting to embed ESRS datapoints into internal management reporting, not just annual disclosure.

Wave 2 — Preparing Now (FY 2025, Report in 2026)

This is the critical preparation window. You should have already completed or be actively working on:

• Double materiality assessment: This is the foundation of your entire CSRD report. If you have not completed this, it should be your immediate priority.
• Gap analysis against the ESRS: Map your current sustainability data collection against the required disclosure requirements and datapoints.
• Selecting reporting software: Manual spreadsheet-based approaches will not scale. Evaluate CSRD reporting software that can handle ESRS taxonomy tagging, data aggregation, and audit trails.
• Governance alignment: Ensure your board and management body have defined roles and responsibilities for sustainability oversight, as required by ESRS 2.
• Engaging your value chain: Begin requesting environmental and social data from key suppliers and customers now — do not wait until the reporting deadline is upon you.

Wave 3 — Listed SMEs (FY 2026, Report in 2027)

Although the Omnibus proposal may delay or remove your obligations, waiting carries risk. Practical steps for now:

• Monitor the legislative progress of the Omnibus Simplification Package closely.
• Conduct a preliminary materiality assessment, even if simplified.
• Begin collecting baseline environmental data (energy consumption, emissions, waste) so you are not starting from scratch if and when reporting becomes mandatory.
• Consider voluntary reporting as a competitive differentiator with investors.

Wave 4 — Non-EU Companies (FY 2028, Report in 2029)

You have more lead time, but the preparation effort is substantial:

• Confirm whether your EU revenue exceeds the €150m threshold and identify which EU subsidiaries or branches will carry the reporting obligation.
• Start aligning group-level sustainability data collection with ESRS requirements, even if your home jurisdiction uses a different framework.
• Use the intervening years to run a pilot CSRD report — the complexity of consolidating cross-border data should not be underestimated.

Whichever wave you fall into, choosing the right ESG reporting software early will significantly reduce the workload and risk of non-compliance.

How Horizon ESG Helps You Meet Your CSRD Deadline

At Horizon ESG, we work with sustainability teams, CFOs, and compliance officers to turn CSRD obligations into a structured, manageable process. Our platform is designed specifically for companies navigating the ESRS for the first time.

• Double materiality assessment tooling that guides you through stakeholder engagement, impact identification, and financial risk scoring.
• ESRS-aligned data collection with built-in disclosure requirement mapping, so you know exactly which datapoints you need and where the gaps are.
• Automated XBRL/iXBRL tagging for digital submission in line with the ESEF regulation.
• Audit-ready outputs with full data provenance and version control, ready for your limited assurance provider.

Whether you are in Wave 1 refining your second report or in Wave 2 preparing your first, we can help you get there. Learn more about our CSRD solution or explore our reporting software.