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CSRD Timeline 2026: Reporting Dates After Omnibus I

October 20, 2026
CSRD Timeline 2026: Reporting Dates After Omnibus I

The CSRD timeline changed substantially in 2026. Companies now in scope are those with more than 1,000 employees and net turnover above €450 million. They apply the revised ESRS from financial years starting on or after January 1, 2027, and publish first reports in 2028. Member States must transpose the changes into national law by March 19, 2027. That is the short version. The detail below tells you which date applies to your company, and what to do in the months before it.

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TL;DR

  • New scope: Directive (EU) 2026/470 limits mandatory CSRD reporting to large undertakings with more than 1,000 employees on average and net turnover above €450 million.
  • First reports: in-scope entities apply the revised ESRS for financial years starting on or after January 1, 2027, so the first reports are published in 2028.
  • Transposition: Member States must write the changes into national law by March 19, 2027, so your local rules decide what happens to companies that fell out of scope.
  • Revised ESRS: the Commission adopted them on July 3, 2026, cutting mandatory data points by more than 60%.
  • Action now: confirm your status in each jurisdiction, then build a quantitative data process before FY2027 begins.

Table of Contents

How the CSRD timeline got here

The original Corporate Sustainability Reporting Directive ((EU) 2022/2464) phased companies in over several waves. Wave 1 covered large public-interest entities with more than 500 employees, reporting on financial year 2024. Wave 2 covered other large undertakings, starting with financial years beginning on or after January 1, 2025. Wave 3 covered listed SMEs, and a later wave covered certain non-EU groups. The Commission's implementation FAQ sets out that original structure.

Then came the Omnibus I package. The first step was the "stop-the-clock" proposal, which the European Parliament's legislative tracker describes as postponing reporting for companies due to report in 2026 and 2027, the so-called wave 2 and 3 companies. The substantive revision followed. The Omnibus I Directive was published in the Official Journal on February 26, 2026 and entered into force in March 2026.

How the CSRD timeline got here — overview diagram

If you read older guides that list "first report in 2026 for FY2025" for wave 2 companies, treat them as out of date. Companies originally expected to publish in 2026 are now expected to report later, with the first reports under the revised regime due in 2028.

The 2026 to 2029 timeline at a glance

DateWhat happensWho it affects
February 26, 2026Omnibus I Directive published in the Official JournalAll CSRD stakeholders
March 2026Directive enters into forceAll CSRD stakeholders
July 3, 2026Commission adopts revised ESRS and a voluntary standard for smaller companiesIn-scope companies, their suppliers
Financial years starting in 2026Option to apply original ESRS or the revised versionCompanies still reporting
March 19, 2027Member State transposition deadlineNational regulators, companies in each Member State
Financial years starting on or after January 1, 2027Revised ESRS apply to in-scope entitiesCompanies above the new thresholds
2028First reports under the revised regime publishedCompanies above the new thresholds

The thresholds, ESRS application date, first-report year and transposition deadline come from the delegated act and directive text. The adoption date for the revised ESRS comes from the Commission's announcement.

Who is in scope now

The mandatory scope is restricted to large undertakings with an average of more than 1,000 employees and a net turnover exceeding €450 million. Compare that with the earlier test of two out of three criteria: 250 or more employees, a €25 million balance sheet or €50 million turnover. For most mid-sized companies the obligation has gone.

Three practical points follow.

  1. Both tests matter. Headcount and turnover are cumulative in the way the research describes them. A company with 1,500 employees and €300 million turnover is not in the new mandatory scope.
  2. Calculate on the right basis. The average employee count and net turnover are measured over the relevant financial years. Check the definitions in the directive text and your national implementation rather than relying on a rounded figure.
  3. Groups need a separate look. A subsidiary may be exempt where a parent reports at group level, and a non-EU group may have its own track. This is where legal counsel earns its fee.

Non-EU groups, including US companies

US readers ask about this most. Non-EU parents with large EU activity are covered by a separate provision of the directive, and the first reports on that track are reported to cover FY2028, with filing in 2029. Because the EU thresholds and group tests are technical, confirm your position against the directive text or with EU counsel before you budget. We do not give a company count here, since estimates vary by source.

What happens to companies that dropped out of scope

This is the most misunderstood part of the 2026 timeline. Companies previously in scope that now fall below 1,000 employees and €450 million are not automatically released. The directive leaves room for Member States to decide, and some may exempt these entities from reporting for the 2025 and 2026 financial years. Until your Member State transposes the directive, check the local status for each jurisdiction where you have a legal entity.

CSRD threshold and Member State exemption decision

BDO's analysis of the post-Omnibus rules makes the same point for original Wave 1 companies: it is not as simple as immediately stopping reporting. Obligations continue for those companies through part of the transition.

A sensible rule: do not dismantle your reporting team until your national law confirms the exemption in writing.

The ESRS choice in financial year 2026

For financial years starting between January 1, 2026 and December 31, 2026, in-scope companies can apply either the original ESRS from Delegated Regulation (EU) 2023/2772 or the newly adopted, simplified version. That elective period is set out in the delegated act. Choosing the revised standards also unlocks some of the relaxations introduced in 2026.

The revised ESRS matter for three reasons:

  • Fewer data points. Mandatory data points fall by more than 60% and total data points by more than 70%.
  • More quantitative content. The simplified standards emphasize quantitative data over narrative, so reporting workflows and system configuration need to produce structured numerical outputs.
  • A value chain cap. The adoption package includes a voluntary standard for smaller companies and a cap on what large reporters can ask of smaller value-chain partners.

If you are a supplier to a large EU group, the last point is good news. Ad hoc questionnaires should give way to a standard set of requests.

What to do between now and FY2027

A company in scope has roughly a year before the first financial year under the revised regime begins. Use it in this order.

  1. Confirm scope in every jurisdiction. Test headcount and turnover at entity and group level. Track your Member State's transposition bill, due by March 19, 2027.
  2. Decide which ESRS version applies to FY2026. If you are still reporting, compare the cost of staying on the original standards with the relief on offer in the revised ones.
  3. Rerun the double materiality assessment. Fewer data points do not remove the need to justify which topics are material.
  4. Map data owners and systems. Quantitative disclosures need controls similar to financial data: owners, definitions, sign-off and an audit trail.
  5. Plan for assurance. Reported information is expected to be reliable and auditable, so involve internal audit early.
  6. Train the team. Revised standards are only useful if preparers, reviewers and assurance providers read them the same way.

Our CSRD requirements checklist for compliance teams and our guide to ESRS compliance steps for FY2027 cover steps 3 to 5 in more depth. For the original wave structure, see our CSRD phase-in timeline.

Our view: plan for the date, not the headline

We train sustainability leads, controllers, internal auditors and assurance practitioners, and we saw the same pattern all year. When the Omnibus was announced, some teams stopped. When the thresholds were confirmed, others assumed they were exempt. Both reactions carry risk.

Our view is that the timeline has moved, but the competence requirement has not. Investors, lenders, customers and group parents still ask for credible, decision-useful data. The Commission itself says the revision aims to reduce administrative burdens while maintaining high-quality disclosures. A smaller standard still needs people who can apply it, test it and defend it.

Three things we would do if we ran your reporting function:

  • Treat the quantitative shift as a data engineering task, not a drafting task.
  • Keep the double materiality assessment alive even if some narrative disclosures shrink.
  • Build assurance-readiness into FY2026 now. Waiting for FY2027 compresses the learning curve into the busiest quarter.

Our programs map to ISSB, ESRS, GRI and ISSA 5000, so the skills carry across frameworks. If your company leaves the CSRD, they still apply to IFRS S1 and S2 reporting, customer questionnaires and supplier data requests.

— Ransford

Build the skills before the first FY2027 report

If your team needs structured preparation, the ESG Training Institute offers a progression from foundation to professional credentials in sustainability reporting:

For shorter, targeted learning, the CPD programmes include Mastering IFRS S1 & S2 Sustainability Reporting at $129 and ESG Reporting for Accountants at $79. The All-Access CPD Pass is $599 per year. Our credentials are assessed against real pass thresholds, not participation. You can see the full catalog on our main site.

FAQ

When is the first CSRD report due under the new rules?

In-scope entities apply the revised ESRS for financial years starting on or after January 1, 2027. The first reports under that regime are published in 2028. Companies outside the new scope should check whether their Member State requires anything earlier.

Do I still have to report for financial year 2025 or 2026?

It depends on your Member State and your size. Companies below the new thresholds are not automatically released, and some Member States may exempt them for the 2025 and 2026 financial years. Verify the status of national transposition for each jurisdiction where you operate.

Which ESRS apply to financial year 2026?

For financial years starting during 2026, in-scope companies can apply the original ESRS from Delegated Regulation (EU) 2023/2772 or the revised version adopted on July 3, 2026. The revised standards unlock additional relaxations. Choose with your assurance provider before the year closes.

What is the Member State transposition deadline?

Member States must transpose the Omnibus I changes into national law by March 19, 2027, as stated in the EY summary of the March 2026 developments. Member States may add national requirements, so local law can be stricter than the directive.

Sources