CSRD Timeline: When Does It Apply to Your Business?

The Corporate Sustainability Reporting Directive (CSRD) is reshaping how European companies report on environmental, social, and governance (ESG) impacts. Unlike a one-size-fits-all regulation, CSRD rolls out in phases based on company size and listing status. Understanding where your organization falls on this timeline is critical for planning compliance, especially as 2026 approaches with the third and final wave of applicability.

In this guide, we break down the CSRD phased rollout, explain what each deadline means for your business, and help you determine when you need to start reporting.

Overview of CSRD Phased Rollout and Applicability

The CSRD creates a staggered timeline that affects different company categories across 2024, 2025, and 2026. This phased approach gives organizations time to build reporting infrastructure, train teams, and integrate sustainability data into their broader financial reporting processes.

Why a Phased Approach?

The European Commission structured CSRD this way to manage implementation complexity across thousands of companies. Large, publicly-listed firms typically have more established ESG infrastructure, so they report first. Smaller listed companies and those newly in scope come later. This creates a domino effect: suppliers and partners begin preparing months before their official deadline.

Key Applicability Criteria

Company size and listing status determine your CSRD timeline:

• Large Public Interest Entities (PIEs): Companies listed on regulated markets with 500+ employees
• Large Non-Listed Companies: Entities with 250+ employees OR €40 million turnover OR €20 million balance sheet
• Listed SMEs: Companies listed on regulated markets (some exemptions for micro-cap stocks)
• Non-Listed SMEs: Generally out of scope unless owned by a large parent company

The rules are complex, so using a carbon accounting platform like Greenio helps classify your company correctly and track evolving requirements across your jurisdictions.

2024: Large PIEs with 500+ Employees - Already in Effect

The first wave launched on 1 January 2024, affecting Large Public Interest Entities (PIEs). These are the largest, most visible European companies: those listed on regulated markets with at least 500 employees.

Who Is Affected

Large PIEs include major multinational corporations, large financial institutions, and large listed industrial companies. If your organization is listed on a regulated market in any EU member state or EEA country and employs 500+ people, you fall into this first cohort.

First Reporting Deadline

Companies in wave 1 must file their first CSRD report covering the 2024 financial year. Reports are due by 28 March 2025 - meaning sustainability data collection and assurance processes are happening right now, in 2026, as companies finalize their 2024 disclosures.

What They Must Report

These organizations must disclose against the European Sustainability Reporting Standards (ESRS), covering double materiality assessments, governance structures, strategy, targets, and detailed environmental, social, and governance metrics. Third-party assurance (currently limited assurance) is mandatory.

Entities already reporting under the Non-Financial Reporting Directive (NFRD) are transitioning from less prescriptive frameworks into ESRS' detailed, standardized approach.

2025: Other Large Companies - First Reports in 2026

The second wave expands CSRD to companies not yet covered. This includes large unlisted companies and additional listed entities that didn't meet the "PIE" definition.

Applicability Criteria for Wave 2

Any company meeting at least two of these thresholds joins the CSRD on 1 January 2025:

• 250 or more employees
• Net turnover of €40 million or more
• Balance sheet total of €20 million or more

This wave captures many privately-held mid-market companies, holding companies, and smaller listed firms that weren't PIEs in 2024.

First Reporting Timeline

Wave 2 companies report against the 2025 financial year, with first disclosures due by 28 March 2026. If your organization falls here, you're now in active implementation mode - data systems should be in place, materiality assessments underway, and assurance providers engaged.

Scope Across Europe

This wave affects thousands of large unlisted companies across every EU and EEA country. France, Germany, Spain, Italy, Poland, and the Netherlands see particularly significant numbers of newly-in-scope organizations.

For country-specific guidance, review carbon accounting requirements in Germany and sustainability reporting rules in France to understand local nuances.

2026: Listed SMEs with Opt-Out Until 2028

The third and final wave includes listed SMEs - companies listed on regulated markets that don't meet the large company definition. This is the smallest of the three groups but still represents hundreds of entities across Europe.

Who Qualifies as a Listed SME

Listed SMEs are equity-listed companies that fall below the 250-employee threshold AND don't meet at least two of the size thresholds (€40 million turnover, €20 million balance sheet). They must be listed on a regulated market in an EU or EEA member state.

Key Feature: Two-Year Opt-Out

Unlike waves 1 and 2, listed SMEs can opt out of CSRD requirements until 31 December 2027. A company can choose to report from 2026 onwards or defer for two years, reporting from 2028 onwards (covering the 2028 financial year, with reports due in 2029).

This opt-out is a critical distinction. It gives smaller listed companies time to assess feasibility and cost-benefit before committing to ESRS reporting.

First Reporting Deadline (If Not Opting Out)

Listed SMEs choosing to report from 2026 onwards file their first disclosure covering the 2026 financial year by 28 March 2027.

Those using the opt-out can delay until 2028 financial year reporting (due 28 March 2029).

CSRD Applicability Timeline Table

Year	Company Category	Size Criteria	First Report Due
2024	Large PIEs	Listed, 500+ employees	28 March 2025
2025	Other large companies	250+ employees OR €40m turnover OR €20m balance sheet	28 March 2026
2026	Listed SMEs	Listed, below 250 employees, below size thresholds	28 March 2027*

*Listed SMEs can opt out until 31 December 2027. If opting out, first report due 28 March 2029.

Country-Specific CSRD Implementation Guides

CSRD applies uniformly across all EU and EEA countries, but implementation details, stakeholder expectations, and enforcement priorities vary. Each country has unique characteristics:

• Germany: Strong focus on governance and supply chain due diligence, overlapping with German Supply Chain Due Diligence Act requirements
• France: CSRD layered atop France's existing Loi Agile and double materiality frameworks; integrated with banking sector oversight
• Spain, Italy, Netherlands, Belgium, Sweden, Denmark: Each with distinct stakeholder ecosystems and sectoral emphasis

Review carbon accounting requirements in Germany and sustainability reporting rules in France for detailed country guidance.

For a comprehensive framework overview, see What is CSRD and how does it work?.

Preparing Your Organization for CSRD

Regardless of your wave, preparation should start now. Key steps include:

1. Confirm your applicability - Determine which wave you fall into based on current size and listing status
2. Conduct a double materiality assessment - Identify financially material and impact material ESG topics specific to your sector and business model
3. Implement data systems - Integrate sustainability KPI tracking into operational systems
4. Engage assurance providers - Arrange third-party assurance (limited or reasonable) well before reporting deadlines
5. Train teams - Ensure finance, ESG, operations, and legal teams understand ESRS requirements
6. Map to ESRS standards - Understand which of the 12 ESRS standards apply to your sector and material topics

Platforms like Greenio streamline these processes by automating data collection, materiality mapping, ESRS alignment, and assurance workflows across multiple jurisdictions.

FAQ: CSRD Timeline and Applicability

When does CSRD apply to my company?

CSRD applies based on your company size, listing status, and the year. Large PIEs (listed, 500+ employees) were first in scope on 1 January 2024. Large unlisted companies and smaller listed firms became in scope on 1 January 2025. Listed SMEs become subject on 1 January 2026, though they can opt out until 31 December 2027. Non-listed SMEs below the large company thresholds generally remain out of scope unless they're owned by a CSRD-obligated parent.

What is the CSRD deadline for SMEs?

Listed SMEs must report their first ESRS disclosure by 28 March 2027 if they choose to comply from 2026 onwards. Alternatively, they can opt out until 31 December 2027 and delay reporting until 28 March 2029 (for the 2028 financial year). Non-listed SMEs are not currently in scope of CSRD.

Can SMEs opt out of CSRD?

Only listed SMEs can opt out, and only until 31 December 2027. Non-listed SMEs and large companies in waves 1 and 2 cannot opt out - CSRD compliance is mandatory. Note that "opt-out" means deferring for two years, not permanently exempting from CSRD; the requirement will eventually apply.

Is CSRD the same as the previous NFRD?

No. CSRD replaces the Non-Financial Reporting Directive (NFRD) with stronger requirements. CSRD mandates double materiality assessments, standardized ESRS reporting (not company-chosen frameworks), mandatory third-party assurance, and digital filing. It also covers significantly more organizations than the NFRD. Companies already reporting under NFRD must transition to ESRS when their wave becomes effective.

What happens if my company doesn't comply with CSRD?

Non-compliance can result in regulatory enforcement actions, fines, reputational damage, investor pressure, and potential delisting or trading restrictions. National authorities in each EU member state enforce CSRD through their financial regulators and corporate governance oversight bodies. Compliance is not optional for in-scope companies.

Conclusion: Act Now on CSRD Timeline

The CSRD phased rollout is well underway. If your company falls into wave 1 or 2, your first report is either due soon or already in final preparation stages. If you're a listed SME, 2026 marks your decision point: commit to reporting or use the opt-out window before it closes.

Whichever cohort you're in, the time to start is now. Building robust ESG data systems, conducting rigorous materiality assessments, and securing assurance takes months of planning. The earlier you begin, the smoother your transition to CSRD compliance.

Use the CSRD timeline table above to pinpoint your deadline, consult country-specific guides for your jurisdiction's nuances, and leverage technology platforms to automate data collection and reporting workflows. CSRD compliance is complex, but it's manageable with proper preparation.