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One of the most persistent CSRD myths is that there is a single, stable reporting timeline that companies can plan against with confidence.
There isn’t.
While the Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS) are firmly embedded in EU law, how and when different companies enter the reporting regime has been deliberately re-sequenced to reflect implementation reality.
First, the Foundations: What Will Not Change
Before looking at dates, it is critical to understand what does not change, regardless of delays, simplifications, or political adjustments.
Once CSRD applies to a company:
- sustainability reporting is mandatory, not voluntary,
- ESRS are the required reporting standards,
- disclosures must sit in the management report,
- sustainability information is subject to statutory assurance,
- and double materiality assessment is always required.
No EU initiative currently under discussion alters these fundamentals.
The ESRS Baseline: Which Standards Apply, and When
All CSRD reporting today is based on ESRS Set 1, which includes:
- two cross-cutting standards (general requirements and disclosures),
- environmental standards (E-topics),
- social standards (S-topics),
- governance and business conduct standards.
Sector-specific ESRS will be introduced later, after the initial reporting cycles stabilise. Their future adoption may affect disclosure depth, but does not delay CSRD applicability.
Companies should plan on:
- reporting under cross-cutting ESRS from day one, and
- expanding topical disclosures as materiality and standards mature.
Wave 1: What Is Already Locked In
Companies Previously Subject to NFRD
The first CSRD reporting wave is complete in legal terms and already operational.
In scope
- Large EU-listed companies
- Large banks
- Large insurance undertakings
- More than 500 employees
Timeline
- Financial year 2024: First CSRD-aligned reporting period
- 2025: First sustainability statements published under ESRS
There are:
- no deferrals,
- no simplifications,
- no opt-outs.
These companies are already being reviewed by auditors against ESRS expectations.
Why the Original CSRD Timeline Was Re-Sequenced
The original CSRD rollout assumed:
- immediate data availability,
- mature value-chain transparency,
- and audit-ready sustainability controls.
That assumption proved unrealistic for first-time reporters.
Regulators responded by re-sequencing entry, not weakening obligations:
- first-time reporting burden was reduced,
- datapoints were prioritised,
- timelines were adjusted to reflect operational readiness.
This is execution calibration — not regulatory retreat.
Other Large EU Companies: In Scope, but Phased
Who This Applies To
EU companies meeting at least two of the following:
- more than 250 employees,
- more than €40 million net turnover,
- more than €20 million total assets,
and not previously covered by NFRD.
Timeline Reality
These companies:
- are legally subject to CSRD,
- must use ESRS,
- are affected by phasing-in and simplification measures.
What may vary:
- first reporting year,
- disclosure depth in early cycles,
- sequencing of ESRS datapoints.
What does not vary:
- obligation to report,
- requirement for double materiality,
- inclusion in the management report,
- preparation for assurance.
Delays adjust when you report, not whether you report.
Listed SMEs: Deferred Entry, Not Exemption
Listed SMEs were always part of the CSRD design — with proportionality.
Key points
- Listed SMEs remain in scope by law
- Simplified ESRS apply
- Temporary opt-outs exist, under defined conditions
This creates a longer runway, not a free pass. Listed SMEs that delay preparation until the final reporting year face the highest execution risk.
Non-EU Companies: The Longest Timeline — and the Greatest Risk
CSRD also applies to non-EU companies that:
- generate more than €150 million annual turnover in the EU, and
- have a significant EU branch or qualifying subsidiary.
Expected Timeline
- Financial year 2028: First reporting period
- 2029: First sustainability statement published
- Reporting at group level, using dedicated non-EU standards
This long runway often creates false confidence. In practice, non-EU groups face:
- fragmented data landscapes,
- misalignment with EU materiality logic,
- underdeveloped value-chain controls.
Late preparation compresses remediation into a narrow window.
Timeline vs Reporting Mechanics: Where CSRD Actually Lands
CSRD sustainability disclosures:
- must be included in the management report,
- follow the same publication cycle as financial reporting,
- fall within the statutory audit perimeter.
This means CSRD timelines must be planned backwards from financial close and audit schedules, not from sustainability team roadmaps.
Assurance Timelines: The Hidden Constraint
Once CSRD reporting begins:
- limited assurance applies initially,
- reasonable assurance is expected in later phases.
Assurance readiness affects timelines more than regulation does:
- controls must exist before reporting,
- evidence must exist before controls,
- and governance must exist before evidence.
Most delays come from assurance readiness, not legal ambiguity.
CSRD Timeline Snapshot (30-Second View)
- Already reporting: NFRD companies (FY 2024 → publish 2025)
- In scope, phased: Other large EU companies
- Deferred, not exempt: Listed SMEs
- Long runway: Non-EU companies (FY 2028 → publish 2029)
- Always required: ESRS, double materiality, management report inclusion, assurance
If your planning does not reflect this structure, it is incomplete.
CSRD Timelines Are About Sequencing, Not Avoidance
The EU has not diluted CSRD ambition. It has acknowledged implementation reality.
The regulatory direction is fixed:
- broader coverage,
- deeper assurance,
- stronger value-chain transparency.
Only the sequencing is adaptive.
Companies that use this time to build structured, audit-ready systems will absorb future changes with minimal friction. Companies that wait for “final dates” will not.