CSRD Timeline

As of: 24 March 2026

CSRD: the new EU framework at a glance

After the European Parliament approved the compromise on the Omnibus I package negotiated in the trilogue on 16 December 2025, the changes to sustainability reporting were also confirmed by the European Council on 24 February 2026
The key new development is the new thresholds for a reporting obligation: > 1,000 employees and > €450 million turnover, which means around 80% of the companies previously covered will no longer be directly obliged to report
The Stop-the-Clock Directive (EU) 2025/794 is already in force and postpones CSRD entry for most companies by two years; companies in the former wave 1 must in principle still report in 2026, but with transitional arrangements

The Corporate Sustainability Reporting Directive (CSRD) is a key milestone in the development of sustainability reporting in Europe. It replaces the previous Non-Financial Reporting Directive (NFRD) and creates a much broader and more binding framework for environmental, social and governance (ESG) information. The aim is to increase the transparency, comparability and reliability of sustainability data and to direct capital specifically into sustainable business models (CSRD, Directive (EU) 2022/2464)

With the growing importance of ESG criteria – both in financing and along the supply chain – the CSRD is becoming a core strategic requirement, especially for mid-sized industrial and technology companies.

This article shows which companies must report from when, how the timeline has changed as a result of the “Stop-the-Clock” Directive 2025/794, and which concrete steps make sense for preparation.

What is the CSRD?

The CSRD is a European Union directive that integrates comprehensive sustainability reporting into existing financial reporting. Among other things, it amends the EU Accounting Directive 2013/34/EU and obliges companies to publish a separate but integrated sustainability section in the management report. This formally raises sustainability topics to the same level as financial performance indicators, and they must be presented with comparable depth, consistency and audit assurance. Companies are obliged to prepare their ESG data according to uniform European standards, making it much more transparent and comparable for capital market participants and stakeholders.

Core elements:

Mandatory assurance: sustainability information must be audited, initially with limited and in future with reasonable assurance.
European Sustainability Reporting Standards (ESRS): the reporting content is specified by the ESRS, which have applied as a delegated regulation since July 2023.
Extended scope: in addition to large public-interest entities (PIEs), other large companies, listed SMEs (with exceptions) and certain non-EU companies are now also covered.
Double materiality: companies must analyse both the impact of their business on the environment and society and the financial impact of sustainability topics on the company.

Who is affected by the CSRD?

According to the current state of the EU legislative process – in particular through the Stop-the-Clock Directive (EU) 2025/794, the Omnibus I package to simplify the CSRD, CSDDD and EU Taxonomy, and the concluded trilogue negotiations – a fundamental realignment of the scope of the CSRD can be expected.

On 16 December 2025, the European Parliament in plenary approved the compromise version of the Omnibus I package negotiated in the trilogue. This concludes the political agreement between the European Parliament, Council and Commission in substance. Formal legal effect was achieved through formal adoption by the Council of the European Union and publication in the Official Journal of the EU.

Against this background, the previous division of the CSRD into so-called “waves” is becoming less relevant. Instead, there is a strong focus on significantly higher quantitative size criteria, which considerably reduces the group of companies obliged to report.

The new thresholds comprise:

Employees: > 1,000
Turnover: > €450 million (net)

Based on the newly agreed thresholds, the scope of the CSRD can be expected to narrow significantly in future; estimates suggest that around 80% of the originally covered companies will drop out. Listed SMEs are to be removed completely from the direct CSRD reporting obligation.

It remains the case that companies already covered by the NFRD with more than 500 employees formally remain in the CSRD regime. However, the Omnibus compromise provides for a transitional arrangement under which companies in the former wave 1 that would no longer be covered under the new thresholds can be exempted from the CSRD obligation for the 2025 and 2026 reporting years, provided the Omnibus package formally comes into force.

CSRD timeline and deadlines (including the “Stop-the-Clock” Directive and the “Quick Fix” Regulation)

In 2025, the original CSRD deadlines were postponed by two years for certain groups of companies by Directive (EU) 2025/794 (“Stop-the-Clock”). This directive is already in force and therefore applicable law.

Important:

Wave 1 (large PIEs with > 500 employees) and
wave 4 (non-EU companies with significant EU activity)
remain unchanged in timing, while all others were each postponed by two years.

1. Large companies & parent companies of large groups (wave 1, 500+ employees, already subject to the NFRD)

Start of application: financial years beginning on or after 1 January 2024.
First report: in 2025 for the 2024 financial year.

Deadline unaffected by the “Stop-the-Clock” Directive.

However: the Quick Fix Regulation applies!

The Quick Fix Regulation (EU) 2025/1416 serves as a substantive relief instrument within the Omnibus I package to reduce the complexity of sustainability reporting (CSRD) in the short term. While other rules postpone the timeline, the Quick Fix extends the so-called “phase-in” reliefs to all companies subject to reporting.

This allows the first-wave pioneers in particular to refrain for now from disclosing particularly difficult data points in the 2025 and 2026 reporting years – such as detailed Scope 3 emissions in the supply chain or complex social disclosures. The aim is to shift the focus from immediate data perfection to building functioning reporting processes and noticeably reduce the administrative burden in the introductory phase

2. Other large companies

First CSRD report: in 2028 for the 2027 financial year.
New first application: financial years beginning on or after 1 January 2027.

It can be assumed that, due to the new thresholds, most of these companies will in future be permanently outside the scope of the CSRD.

3. Listed SMEs, small & non-complex credit institutions

According to the political compromise confirmed in the Omnibus I package, listed SMEs are to be completely exempted from the CSRD obligation in future.

4. Non-EU companies with significant activity in the EU

First application: financial years beginning on or after 1 January 2028.
First report: in 2029 for the 2028 financial year.
Thresholds: parent company generates > €450 million net turnover in the EU and the subsidiary or branch generates turnover > €200 million

The basic logic of including third-country companies is retained, but is more strongly focused on very large economic activities within the EU as part of the Omnibus package.

Who must report in 2025?

For 2025, the current picture is as follows:

Companies that were already subject to reporting under the NFRD and have > 500 employees must publish their first CSRD-compliant report in 2025 for the 2024 financial year. (Cat. 1)
All other players are not obliged to submit a full CSRD report in 2025. (Cat. 2)
The Quick Fix Regulation applies

National implementation in Germany

The CSRD has not yet been transposed into German law, although the transposition deadline for the EU directive ended on 6 July 2024. A draft CSRD implementation act exists in Germany, but the legislative process has not yet been completed in either the Bundestag or the Bundesrat.

Until a national implementation act comes into force, the existing NFRD rules formally continue to apply to German companies, supplemented by application obligations and interpretive guidance under EU law. The lack of national implementation is currently increasing legal uncertainty for affected companies, especially in combination with the ongoing Omnibus reforms.

Impact on companies

Companies that will no longer be directly subject to the CSRD in future should not discontinue ESG data and management processes completely. Capital markets, banks, rating agencies and business partners along the supply chain already demand structured sustainability information today – regardless of formal reporting obligations.
Across countries, the trend towards harmonising global ESG standards is gaining momentum (e.g. International Sustainability Standards Board (ISSB), European Financial Reporting Advisory Group (EFRAG)), which means companies must expect several parallel or converging requirements in the long term.

Recommendations

Early gap analysis and data building: even if the final criteria are not yet fixed, companies should start their reporting and data processes early.
Preparation for assurance/audit obligations: the quality of sustainability data will become a competitive factor.
Dynamic monitoring of regulatory developments: changes in the Omnibus package may alter the group of obliged companies and deadlines again.

Outlook on future developments

With subsequent publication in the Official Journal of the EU, the Omnibus I package is now legally binding. As many companies are no longer legally obliged but still receive requests from banks or customers, voluntary standards are moving into focus:

CSDDD link: the supply chain directive (CSDDD) has also been drastically slimmed down (new limits: > 5,000 employees and > €1.5 billion turnover) and postponed to 2029.

VSME standard: the standard for SMEs not subject to reporting is to be finalised during 2026. It serves as a “protective shield” so that large companies may no longer request more data from their suppliers than this standard provides for

Preparing for the CSRD: implementation steps

Despite planned simplifications under the EU Omnibus package, the CSRD remains a complex, audit-relevant and strategically important undertaking for all companies still affected. Even if many small and medium-sized companies could be relieved in future, all potentially reporting companies need robust data, governance and reporting structures.

The following steps form the 2025 best practice for effective CSRD readiness:

1. Building an understanding of the CSRD requirements

Goal: clarity about scope, obligations and timelines.

Identify relevant ESRS standards (especially ESRS 1 & ESRS 2).
Take into account the impact of the Stop-the-Clock Directive (2025/794).
Monitor potential changes from the Omnibus package (possible raising of thresholds → in future probably only very large companies affected).
Use EFRAG tools: Q&A platform, guidance on ESRS implementation.

2. Stocktake and gap analysis

Goal: clearly identify gaps between the current status and CSRD requirements.

Analyse existing sustainability reports, management systems and KPIs.
Review topics such as climate plans, transition strategies, supply chain information and social topics.
Assess data quality, data availability and internal control mechanisms.
Map existing governance against the compliance, risk and reporting requirements of the ESRS.

3. Further developing a sustainability strategy

Goal: anchor ESG goals clearly and link them to the overall strategy.

Formulate measurable ESG goals (climate pathways, Scope 3 reduction, biodiversity, social risks).
Ensure coherence with the EU Taxonomy, climate targets and supply chain requirements.
Monitor the strategic impact of possible Omnibus adjustments.
Link ESG goals with investment planning, budgeting processes and risk management.

4. Implementing reporting processes and IT systems

Goal: ensure data reliability and audit-ready reports.

Build an integrated ESG data estate (e.g. data warehouse).
Define clear responsibilities and data lineages (data owner, ESG controller).
Introduce an internal control system (ICS) for sustainability data.
Use automation to increase data quality and audit-proofness.
Comply with ESRS requirements for structure, granularity and documentation.

5. Planning external assurance early

Goal: preparation for future audit obligations and greater data integrity.

The CSRD requires limited assurance, later reasonable assurance.
Early alignment with auditors on audit approach, materiality and documentation.
Use pilot assurance for critical KPIs to test maturity and process quality.
Ensure audit-proof process documentation.

6. Communication and transparency

Goal: understandable, consistent and credible ESG communication.

Communicate results understandably to internal and external stakeholders.
Be transparent about data limitations, transition phases and methods.
Develop consistent ESG messages for banks, investors, customers and employees.
Focus on preventing greenwashing (verifiable KPIs, clear boundaries).
Publish the report in the management report in accordance with CSRD requirements.

Telusio’s view

The CSRD remains demanding for affected companies, even though the EU is negotiating significant simplifications and higher thresholds as part of the Omnibus package.

Sustainability managers should therefore keep two things in mind: those who still have to report need reliable data and audit processes, and those who may drop out still remain subject to ESG demands through customers, banks and supply chains.

What matters now is to follow developments closely and, where the CSRD continues to apply, to rely early on auditable, consistent ESG data. This way, companies secure compliance as well as trust and competitiveness.