CSRD Deadlines & Timeline

After the stop-the-clock delay and the final Omnibus, the CSRD timeline is much simpler. Newly in-scope companies report for FY2027, with first reports in 2028. Below are the confirmed dates, the full history, and a live status board on the parts still moving.

Confirmed dates

FY2027 to 2028

Newly in-scope companies

More than 1,000 employees AND more than EUR 450m turnover. Report for FY2027, first reports published in 2028.

FY2028 to 2029

Non-EU groups

Third-country groups meeting the higher thresholds report for FY2028, with first reports in 2029.

19 Mar 2027

Transposition deadline

Member States must transpose the Omnibus CSRD changes into national law by this date.

Confirmed by the stop-the-clock Directive (EU) 2025/794 and the final Omnibus Directive (EU) 2026/470. See the Council statement

What applies to me, and when

If you are an EU company over both thresholds (more than 1,000 employees and more than EUR 450m turnover), your first report covers FY2027 and is published in 2028. If you are a non-EU group meeting the higher thresholds, it is FY2028, published in 2029. If you already report (Wave 1) and remain above the thresholds, you continue; if you have fallen below, you may get a country-dependent pause.

CSRD reporting timeline by company type after the Omnibus.
Who you areFirst financial yearFirst reportStatus
Wave 1 (former 500+ PIEs) still above thresholdsFY2024 (reported)2025, continuingIn scope, continues
Wave 1 now below thresholdsn/an/aOptional pause FY2025-26; mandatory exit FY2027 (country-dependent)
Newly in-scope (1,000+ emp AND EUR 450m+)FY20272028In scope
Former Wave 2/3 below threshold (incl. listed SMEs)n/an/aOut; use voluntary VSME
Non-EU groups meeting new thresholdsFY20282029In scope

Not sure which row is you, or whether the CSRD applies at all? Try the scope checker for a personalised answer.

The full history

How the timeline moved

From entry into force to the post-Omnibus state, with the source for each step.

  1. 5 Jan 2023Confirmed law

    The CSRD enters into force

    Directive (EU) 2022/2464 becomes law, replacing the NFRD and putting sustainability reporting on a financial footing. The original four-wave rollout begins.

    EUR-Lex

  2. 2025Confirmed law

    Wave 1 reports for FY2024

    The former NFRD population (large public-interest entities with more than 500 employees) published its first CSRD reports in 2025. Those still above the new thresholds keep reporting.

    EUR-Lex

  3. 17 Apr 2025Confirmed law

    Stop-the-clock (Directive (EU) 2025/794)

    Published in the Official Journal on 16 April 2025 and in force from 17 April 2025, the stop-the-clock directive postponed Waves 2 and 3 by two years. It changed timing only, not thresholds.

    Sidley

  4. 18 Mar 2026Confirmed law

    Final Omnibus (Directive (EU) 2026/470)

    Approved by the Council on 24 February 2026, published in the Official Journal on 26 February 2026 and in force from 18 March 2026. It raised thresholds, removed listed SMEs and collapsed the old wave structure.

    Council of the EU

  5. ~17 Sep 2026In flux

    Revised ESRS adoption target

    The Commission committed to adopt the simplified ESRS delegated act within six months of the Omnibus entering into force, around 17 September 2026. In consultation as of June 2026; not yet adopted.

    European Commission

  6. FY2027 -> 2028Confirmed law

    Newly in-scope companies report

    Companies with more than 1,000 employees AND more than EUR 450m turnover report for financial years beginning on or after 1 January 2027, with first reports published in 2028. The revised ESRS apply from FY2027.

    DLA Piper

  7. 19 Mar 2027Confirmed law

    CSRD transposition deadline

    Member States must transpose the Omnibus CSRD changes into national law by 19 March 2027. Until each country legislates, the precise in-scope population and penalties in that jurisdiction stay uncertain.

    Covington

  8. FY2028 -> 2029Confirmed law

    Non-EU groups report

    Third-country groups meeting the higher thresholds (more than EUR 450m EU turnover plus a qualifying EU subsidiary or branch) report for FY2028, with first reports in 2029.

    DLA Piper

Live status board

What is settled, and what is still moving

The timing-related parts of the CSRD that are in flux right now. We mark each one plainly so you are not caught out.

Confirmed lawConfirmed

Wave 1 continues (if still above thresholds)

Companies that already reported for FY2024 and remain above the new thresholds keep reporting each year. The headline "first mandatory reports in 2028" applies to the newly defined in-scope population, not to large companies already in the system.

Coolset

In fluxConfirmed, but country-dependent

Optional Member-State pause for FY2025-FY2026

Wave 1 companies that now fall below the new thresholds may be allowed a transition pause for FY2025 and FY2026, then exit fully from FY2027, but only if their Member State opts to grant it. Whether you can pause depends on your country.

DLA Piper

In fluxTarget ~17 Sep 2026

Revised ESRS adoption

The simplified ESRS were in public consultation from 6 May to 3 June 2026, with adoption targeted around 17 September 2026 and application from FY2027 (voluntary early use for FY2026). Mandatory datapoints are expected to fall by around 60 to 70%. Not yet adopted. See the ESRS standards.

European Commission

In fluxDue 19 Mar 2027

National transposition

Transposition of the original CSRD was slow and uneven, and the new Omnibus thresholds need fresh transposition by 19 March 2027. The practical enforcement picture will keep shifting through 2026 and 2027. Always check the specific Member State.

Covington

Not fully settled yet

The scope thresholds and reporting dates are confirmed law, but the revised ESRS delegated act, national transposition and the optional Wave 1 pause are still settling, and the pause is country-dependent. We will update this page as each piece lands. Commission consultation

Changelog

What we changed, and when

This is a living page. Every material edit is logged here.

  • 8 Jun 2026Reviewed after the revised-ESRS consultation closed (3 Jun 2026). Confirmed the ~17 Sep 2026 adoption target and FY2027 application as still pending.
  • 18 Mar 2026Final Omnibus I Directive (EU) 2026/470 entered into force. Rebuilt the timeline around FY2027 (reports 2028) for the newly in-scope population and the 19 Mar 2027 transposition deadline.
  • 17 Apr 2025Added the stop-the-clock Directive (EU) 2025/794, which postponed Waves 2 and 3 by two years.

This is guidance, not legal advice

This is guidance to help you understand the CSRD timeline, not legal advice. For decisions specific to your business, confirm with the official sources we link or a qualified adviser.

Sources

  1. [1]Council of the EU: sign-off of the Omnibus simplification (24 Feb 2026)retrieved 8 Jun 2026
  2. [2]DLA Piper: CSRD amendments under Omnibus I finalisedretrieved 8 Jun 2026
  3. [3]Coolset: CSRD under the Omnibus, updated scope and timelinesretrieved 8 Jun 2026
  4. [4]Sidley: stop-the-clock directive (EU) 2025/794retrieved 8 Jun 2026
  5. [5]European Commission: consultation on revised ESRS (6 May 2026)retrieved 8 Jun 2026
  6. [6]Covington: Omnibus published in the Official Journal; transposition nextretrieved 8 Jun 2026
  7. [7]Directive (EU) 2022/2464, the CSRD (EUR-Lex)retrieved 8 Jun 2026

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