The CSRD second wave no longer reports in 2026. Directive (EU) 2025/794 postponed the former second- and third-wave start dates by two years, and Directive (EU) 2026/470 then narrowed the EU-level scope and removed the listed-SME wave. Under the amended timetable, the current second-wave start is financial year 2027, normally producing reports in 2028.
Scope is not determined by the date alone. The 2026 Omnibus I Directive uses a threshold of net turnover exceeding EUR 450 million and an average of more than 1,000 employees for EU undertakings and groups, with separate third-country rules. Because CSRD obligations operate through national law and Directive (EU) 2026/470 has a transposition deadline of 19 March 2027, organisations must check the law in each relevant Member State before relying on an exemption or transition.
Quick answer
| Question | Position at 8 August 2026 |
|---|---|
| Is the old FY 2025 second-wave start current? | No. The stop-the-clock Directive moved it to FY 2027. |
| Who is in the amended EU-level scope? | In general, EU undertakings and parent undertakings exceeding both EUR 450 million net turnover and 1,000 average employees, subject to the detailed rules and national implementation. |
| Are listed SMEs a future mandatory wave? | No. Directive (EU) 2026/470 deleted that wave from the EU framework. |
| Do first-wave companies keep reporting? | Those meeting the narrowed thresholds continue after FY 2026. Member States may exempt first-wave undertakings below the new thresholds for FY 2025–2026 before they leave EU-level scope from FY 2027. Check national implementation. |
| Which standards apply? | Delegated Regulation (EU) 2023/2772, as amended by Delegated Regulation (EU) 2025/1416, remains the binding baseline until later amendments enter into force. The Commission adopted revised acts on 3 July 2026, but its official page stated they were awaiting scrutiny and publication. |
| Where can implementation support start? | A scoped regulatory compliance review can confirm group scope, national law, timetable, data owners, and assurance readiness. |
The corrected CSRD timetable
| Cohort | Reporting period | Typical publication | Current position |
|---|---|---|---|
| Phase 1 entry | FY 2024 | 2025 | The former NFRD cohort began reporting under CSRD |
| Phase 1 transition | FY 2025–FY 2026 | 2026–2027 | First-wave undertakings, subject to national implementation and optional relief for those below the new thresholds |
| Phase 2 and continuing narrowed scope | FY 2027 onward | 2028 onward | Undertakings and groups meeting the amended thresholds, including continuing first-wave reporters that remain in scope |
| Former listed-SME wave | Removed | Not applicable | Directive (EU) 2026/470 deleted the mandatory listed-SME phase |
| Third-country group reporting | FY 2028 | 2029 | Separate group-level conditions apply, subject to transposition |
Calendar-year assumptions do not work for every group. Confirm the undertaking's financial year, consolidation level, legal form, listing status, Member State law, and any subsidiary exemption.
Scope under the amended EU framework
EU undertakings and groups
Directive (EU) 2026/470 limits Articles 19a and 29a reporting to an undertaking—or a parent undertaking at consolidated level—that exceeds both:
- EUR 450 million net turnover; and
- an average of 1,000 employees during the financial year.
The Directive also permits Member States to exempt first-wave undertakings below either threshold for financial years beginning from 1 January 2025 through 31 December 2026. Whether and how that relief applies must be checked in national law.
Third-country undertakings
The amended Article 40a route uses distinct conditions. At EU level, Directive (EU) 2026/470 raises:
- the third-country undertaking's EU net-turnover threshold to more than EUR 450 million in each of the last two consecutive financial years; and
- the relevant EU subsidiary or, where applicable, branch turnover threshold to more than EUR 200 million in the preceding financial year.
These are not interchangeable with the EU-undertaking thresholds. Group structure and the exact subsidiary/branch route matter.
Value-chain protection
The Omnibus I Directive introduces a value-chain cap for undertakings with no more than 1,000 employees. The detailed right to decline information beyond the voluntary standard and the reporting undertaking's corresponding limits should be implemented in national law. Procurement teams should therefore avoid sending unlimited ESG questionnaires and should record why requested data is necessary.
What CSRD reporting still requires
For an undertaking that is in scope, sustainability information belongs in the management report and is prepared under the applicable ESRS. The core workstreams remain:
- governance and responsibility for sustainability information;
- the business model, strategy, and sustainability-related risks and opportunities;
- impacts on people and the environment;
- policies, actions, metrics, and targets;
- double materiality;
- value-chain information within the amended limits;
- internal controls and evidence; and
- sustainability assurance.
The legal test and the applicable ESRS text should drive the disclosure index. Do not begin with a generic ESG questionnaire and assume it covers the reporting requirements.
Double materiality
Double materiality asks whether a sustainability matter is material from either or both perspectives:
- impact materiality: the undertaking's actual or potential positive or negative impacts on people or the environment; and
- financial materiality: sustainability-related risks or opportunities that affect, or could affect, the undertaking's financial position, performance, cash flows, access to finance, or cost of capital.
A defensible assessment records:
- the reporting boundary and value chain;
- the topic universe and evidence sources;
- affected stakeholders and engagement;
- thresholds and scoring rules;
- management judgements and contrary evidence;
- the final material topics and disclosure consequences; and
- approval, review, and change triggers.
Materiality is not a licence to omit ESRS 2 general disclosures or to use unexplained thresholds. Apply the text of the binding ESRS in force for the reporting period.
ESRS status in August 2026
Commission Delegated Regulation (EU) 2023/2772 established the first ESRS set. Delegated Regulation (EU) 2025/1416 added “quick-fix” phase-ins for wave-one undertakings for financial years beginning on or after 1 January 2025. That amended baseline contains:
- cross-cutting ESRS 1 and ESRS 2;
- environmental standards E1–E5;
- social standards S1–S4; and
- governance standard G1.
On 3 July 2026, the Commission adopted revised ESRS and a voluntary standard for smaller undertakings. The Commission's official implementation page stated that the acts were not yet in force pending scrutiny and publication. Teams should not quietly replace the binding reporting baseline with a draft; record which legal version applies when the report is prepared.
Assurance
CSRD sustainability information is subject to limited assurance under the applicable national implementation. Directive (EU) 2026/470 moved the Commission deadline for EU limited-assurance standards to 1 July 2027 and removed the former mandate to adopt reasonable-assurance standards.
Prepare for assurance by maintaining:
- a controlled disclosure index;
- named data and control owners;
- documented calculation methods and estimates;
- reconciliations to finance and operational systems;
- evidence of materiality decisions;
- review and approval logs; and
- a record of limitations, corrections, and subsequent events.
Do not describe reasonable assurance from 2028 as an automatic next stage; that former timetable has been removed.
A practical preparation plan
1. Confirm scope and national law
Map every legal entity and group, the two amended thresholds, financial years, listing status, third-country presence, and Member State implementation. Obtain advice on uncertain group structures and transitional relief.
2. Set governance
Assign an accountable executive, reporting lead, finance owner, sustainability subject-matter owners, legal reviewer, internal-control owner, and audit liaison.
3. Perform double materiality
Use documented evidence and stakeholder input. Preserve the reasoning for included and excluded topics.
4. Build the disclosure and data map
For each applicable datapoint, record definition, source system, owner, calculation, frequency, control, evidence, and limitation.
5. Test controls and draft early
Run a dry close, reconcile data, test evidence retrieval, and ask the assurance provider to identify readiness gaps without allowing assurance independence to become blurred.
6. Monitor the framework
Track national transposition of Directive (EU) 2026/470, the legal status of the July 2026 ESRS acts, Commission assurance standards, and group changes. Date every scope memo.
Frequently asked questions
Does exceeding 1,000 employees alone create CSRD scope?
Not under the amended EU-level Article 19a/29a threshold: the undertaking or group must also exceed EUR 450 million net turnover. Detailed definitions, aggregation, exemptions, and national implementation still matter.
Should a company below the new scope stop all ESG work?
Not automatically. It may have reporting duties under other law, contractual information requests, financing requirements, or voluntary reporting objectives. The value-chain cap should be considered when customers request CSRD information.
Are the July 2026 revised ESRS already binding?
The Commission adopted them on 3 July 2026, but its official page stated that they would apply only after the scrutiny period and entry into force. Check the Official Journal and the reporting-period rules before use.
Can a separate sustainability report replace the management-report statement?
For mandatory CSRD reporting, sustainability information is included in the management report as required by the Accounting Directive framework. A separate publication may supplement but does not itself satisfy that placement rule.
Sources and review
This guide was substantively reviewed on 8 August 2026. Because CSRD is implemented through Member State law, verify the current national rules for the relevant undertaking.
- Directive (EU) 2025/794 — stop-the-clock Directive
- Directive (EU) 2026/470 — Omnibus I amendments
- Consolidated Accounting Directive 2013/34/EU as at 18 March 2026
- Delegated Regulation (EU) 2023/2772 — European Sustainability Reporting Standards
- Delegated Regulation (EU) 2025/1416 — ESRS quick-fix phase-ins
- European Commission — corporate sustainability reporting
- European Commission — CSRD delegated and implementing acts
For a documented scope memo, data-and-control map, and assurance-readiness plan, see Vision Compliance's regulatory compliance service.
Robert Lozo, mag. iur., is a Partner at Vision Compliance specializing in EU regulatory compliance. He advises organizations on GDPR, NIS2, AI Act, and financial regulation, delivering audit-ready documentation and compliance roadmaps across regulated industries.