EU undertaking above the test
More than 1,000 employees and €450m net turnover: report from FY2027, published in 2028.
Art 19a(1), consolidated.EU reporting · the dates
CSRD timeline: every date that decides when you report
The CSRD timeline now turns on one year: from financial year 2027, undertakings that exceed both €450 million of net turnover and 1,000 employees report, under the revised ESRS.
Before that, wave one reported for financial years 2024 to 2026 under the 2023 standards, and non-EU groups follow from financial year 2028.
Every date below is cited to the instrument that sets it, as at 11 October 2026.
The dated register
The CSRD timeline, 2014 to 2031
Each milestone is the date the instrument itself gives, and the source sits under each entry.
Where a document was adopted on one day and published or applied on another, the dates are shown separately, because they are routinely merged.
- 201401
Non-Financial Reporting Directive
Directive 2014/95/EU inserts the two reporting limbs into the Accounting Directive. - 16 December 202202
CSRD published
Directive (EU) 2022/2464 appears in the Official Journal and rewrites Articles 19a and 29a. - 31 July 202303
First ESRS adopted
Delegated Regulation (EU) 2023/2772, published on 22 December 2023. - FY202404
Wave one begins
Wave one applies to financial years starting between 1 January 2024 and 31 December 2026. - 26 February 202505
Omnibus I proposed
The Commission proposes the sustainability omnibus, with SWD(2025) 80. - 14 April 202506
Stop-the-clock
Directive (EU) 2025/794 moves wave two to FY2027 and wave three to FY2028. - 3 December 202507
EFRAG advice submitted
EFRAG’s Sustainability Reporting Board approved the simplified ESRS on 28 November 2025. - 26 February 202608
Omnibus I published
Directive (EU) 2026/470 of 24 February 2026 appears in the Official Journal. - 18 March 202609
Omnibus I in force
The single 1,000-employee and €450 million test is now in the Directive, applying from FY2027. - 3 July 202610
Revised ESRS adopted
The Commission adopts the revised ESRS and the voluntary standard. - 21 September 202611
Published in the Official Journal
Delegated Regulations (EU) 2026/1563 and 2026/1560. - 10 November 202612
- FY202713
New scope and revised ESRS apply
Financial years beginning on or after 1 January 2027; first reports in 2028. - 19 March 202714
Transposition deadline
Member States bring Omnibus I Articles 1–3 into national law. - 1 July 202715
Limited assurance standards due
The Commission must adopt them by this date. - FY202816
Non-EU groups
Article 40a applies; first third-country reports follow in 2029. - 30 April 203117
Which year applies to me?
Four positions, four different first years
The CSRD has no single start date any more; it has a test, and the test has a first year.
Find your position, then read the dates that belong to it.
Read the positions in detail
| Position | First CSRD financial year | Standard | Source |
|---|---|---|---|
| EU undertaking above both thresholds | FY2027 (report 2028) | Revised ESRS | Art 19a(1); DR (EU) 2026/1563 Art 3 |
| Wave-one undertaking that stays above the test | Already reporting since FY2024; revised ESRS from FY2027 | 2023 ESRS to FY2026; revised from FY2027 | Omnibus I recital (31); DR (EU) 2026/1563 Arts 2–3 |
| Wave-one undertaking below the new test | In scope FY2024 to FY2026 only | 2023 ESRS | Omnibus I recital (31) |
| Non-EU group with EU turnover above €450m | FY2028 (report 2029) | ESRS-40a, once adopted | Art 40a; ESRS-40a ED |
| UK supplier with 1,000 employees or fewer | None | Voluntary standard as a ceiling for CSRD requests | Art 19a(3); DR (EU) 2026/1560 |
Wave one is limited to three financial years from 1 January 2024: undertakings in that wave but outside the new test fall outside the CSRD from financial year 2027, as recital (31) of Omnibus I says.
Scope is a separate question from what is reported: once in scope, the materiality assessment decides the content.
Where do you sit?
Wave one, below the new test
In scope for FY2024 to FY2026 only; outside the CSRD from FY2027.
Omnibus I recital (31).Non-EU group with EU turnover
Article 40a from FY2028, first reports in 2029.
€450m EU turnover, two consecutive years.UK supplier
No CSRD duty; the value-chain cap limits what a customer may require.
Art 19a(3).Before Omnibus I
The waves, and why the clock was stopped
The CSRD originally phased in by waves, and wave one reported first.
On 14 April 2025, Directive (EU) 2025/794 postponed the later waves by two years while the Omnibus negotiations ran.
Read what stop-the-clock did
Article 1 of Directive (EU) 2025/794 rewrote the dates for wave two to “financial years starting on or after 1 January 2027” and for wave three to “financial years starting on or after 1 January 2028”.
Its recital (3) says the requirements for undertakings reporting for 2025 and 2026 “should be postponed by two years”.
Omnibus I then replaced the wave structure with a single test from financial year 2027, so the stop-the-clock dates are history rather than live rules.
What changed in scope, line by line, is on the CSRD after Omnibus I.
The old wave systemExplore
Module 02 / 04
Wave two
Moved to FY2027 by stop-the-clock, then replaced by the single test.
Module 03 / 04
Wave three
Moved to FY2028 by stop-the-clock, then removed by Omnibus I.
Omnibus I
Three Omnibus dates, three different meanings
Omnibus I, Directive (EU) 2026/470, narrowed the CSRD to undertakings that exceed both €450 million of net turnover and an average of 1,000 employees.
It has two transposition deadlines, and they must not be swapped.
Read the Omnibus dates and the scope test
The test is cumulative: both thresholds must be exceeded, which is why the wording is “and”, not “or”.
A figure of 1,750 employees circulated before the adopted text and does not appear in it.
Article 5(1) sets 19 March 2027 for Articles 1 to 3 and 26 July 2028 for Article 4, the CSDDD changes covered on the CSDDD guide.
Until a Member State transposes the directive, its national law still carries the earlier text.
Omnibus I datesExplore
Module 01 / 04
26 Feb 2026
Published in the Official Journal (Directive of 24 February 2026).
Module 04 / 04
26 Jul 2028
Transposition of Article 4, the due-diligence limb.
The revised ESRS
Adopted, published, in force, applied
The revised ESRS carry four dates, and only the last one decides what a company reports.
For financial year 2026 there is a three-way choice, and the company must say which it took.
Read the FY2026 choice
Article 2 of Delegated Regulation (EU) 2026/1563 allows, for financial years starting in 2026, the 2023 ESRS as amended by Delegated Regulation (EU) 2025/1416, those standards with eight named reliefs, or the revised ESRS in full.
Article 2(2) requires the undertaking to “clearly state in their sustainability statement which version they apply”.
EFRAG gave the technical advice; the Commission adopted the act, which is why the dates come from the Official Journal and not from EFRAG.
How the revised standards change the assessment is on the double materiality assessment, and the standards themselves on the ESRS page.
Four ESRS datesExplore
2026 to 2029 in detail
The next three years of the CSRD timeline
Most of the dates that still lie ahead sit between late 2026 and 2029.
The consultation dates are as at 11 October 2026 and can move.
- 23 October 202601
Datapoint list feedback closes
EFRAG’s fatal-flaw survey on the 2026 Draft List of Datapoints. - 31 October 202602
- 10 November 202603
- 11 November 202604
- January 202705
ESRS-40a advice due
The Commission consults again before adopting a delegated act. - 1 January 202706
First FY2027 periods start
Single test and revised ESRS apply; UK SRS periods under PS26/19 start too. - 19 March 202707
- 1 July 202708
- 202809
- 26 July 202810
- 202911
First third-country reports
For financial year 2028, under Article 40a.
Non-EU groups
Article 40a: FY2028, and a deadline that has passed twice
A UK parent with large EU operations is reached by Article 40a, on its EU turnover, from financial year 2028.
The standard it would report against, ESRS-40a, is still an exposure draft as at 11 October 2026.
Read the Article 40b deadline chain
Article 40b originally required the third-country standard by 30 June 2024, and Directive (EU) 2024/1306 moved that to 30 June 2026.
That date has also passed without adoption, and nothing in the instrument attaches a consequence to the miss.
EFRAG’s technical advice is due in January 2027, after which the Commission consults before adopting a delegated act.
The draft and its impacts-only design are on ESRS-40a.
Article 40aExplore
Module 01 / 04
EU turnover
More than €450 million in each of the last two consecutive financial years.
Module 02 / 04
EU entity
A subsidiary or branch with more than €200 million net turnover in the preceding year.
Assurance dates
Limited assurance standards by 1 July 2027, and no reasonable-assurance date
Omnibus I moved the deadline for EU limited assurance standards to 1 July 2027.
It also deleted the empowerment to adopt reasonable assurance standards, so no date for reasonable assurance remains.
Read the assurance changes
Recital (5) of Directive (EU) 2026/470 says the requirement to adopt reasonable assurance standards “should be removed”.
What the opinion covers and who may give it are set out under assurance under the CSRD.
Assurance datesExplore
The value-chain cap
When suppliers gain their protection
The value-chain cap protects undertakings with an average of 1,000 employees or fewer from CSRD-purpose data requests beyond the voluntary standard.
Its legal pieces arrive on different dates, as the orbit shows.
Read the cap’s timing
Delegated Regulation (EU) 2026/1560 entered into force on the third day after publication, 24 September 2026, and its Article 3 applies from financial years beginning on or after 1 January 2027.
The cap covers only the datapoints in Annex II to that regulation, and the VSME guide sets out what they are.
Cap datesExplore
For UK groups
What the CSRD timeline means for a UK group
A UK group meets the CSRD only through its EU operations, its EU listing or Article 40a.
The UK’s own timeline is separate, even where the first year is the same.
Read the UK position in more detail
Under the FCA’s PS26/19, listed companies in five categories report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.
That is a disclosure regime with an explanation route, not an unconditional duty, and it uses single (financial) materiality rather than double materiality.
The routes by which the CSRD reaches a UK group are on CSRD reporting for UK groups, and the two regimes are compared on the CSRD and UK SRS side by side.
UK positionsExplore
Module 01 / 04
EU subsidiary
In scope from FY2027 if it exceeds both thresholds on its own or as a group parent.
Module 04 / 04
UK listed
UK SRS on a comply-or-explain basis from periods starting 1 January 2027 — a separate regime.
How many report
The post-Omnibus population, and its caveat
The Commission’s staff working document estimates 6,753 companies remaining in scope after Omnibus I.
That figure covers only companies that stay in scope after the Omnibus changes, and it is not an EU-wide reporting population.
Read the caveat
SWD(2026) 500 says the population “consists exclusively of companies that will remain subject to CSRD reporting following the Omnibus I changes to the scope”.
Wave one and wave two in that document are a cost distinction: wave-one companies have already produced statements, and wave-two companies report for the first time under the revised ESRS.
SWD(2026) 500Explore
Module 04 / 04
About 85%
The Commission’s estimate of companies removed from the original scope.
What goes wrong
Eight CSRD timeline mistakes
“The revised ESRS apply from 10 November 2026.”
That is entry into force; application is from financial years beginning on or after 1 January 2027.
“Wave two reports for 2025.”
Stop-the-clock moved it to FY2027, and Omnibus I then replaced the waves.
Quoting 26 July 2028 for the cap
That is the Article 4 (CSDDD) transposition date; the cap is 19 March 2027.
“CSRD moves to reasonable assurance in 2028.”
The empowerment was deleted; assurance is limited.
“1,000 or €450m”
The test is both thresholds, exceeded together.
Quoting the Article 40b deadline as live
30 June 2026 has passed; ESRS-40a is still a draft.
Treating 6,753 as an EU-wide figure
It counts companies remaining in scope after Omnibus I.
Merging the UK and EU timelines
UK SRS under PS26/19 is a separate comply-or-explain regime.
The thresholds themselves, and a check of where a company sits, are on CSRD thresholds.
Planning
A planning sequence for a FY2027 reporter
This sequence is an illustration of one way to order the work, not a timetable the law sets.
It starts with scope because every later date depends on it.
Read why the order matters
The assessment decides what is reported, and the assurance opinion covers the process that produced it.
The datapoints a statement might draw on are described on ESRS datapoints, and digital tagging on the ESRS XBRL taxonomy.
- 1
Confirm scope
Both thresholds, on the right entity and year.
- 2
Choose the FY2026 version
And state it, if you report for 2026.
- 3
Run the assessment
Under the revised ESRS 1 for FY2027.
- 4
Prepare for assurance
Limited assurance of the statement and the process.
Frequently asked
Questions people ask
When does the CSRD apply after Omnibus I?
For financial years beginning on or after 1 January 2027, the CSRD applies to undertakings that exceed both a net turnover of €450 million and an average of 1,000 employees.
Their first reports under that test cover financial year 2027 and are published in 2028.
What is the CSRD timeline in one sentence?
Wave one reported for financial years 2024 to 2026 under the 2023 ESRS; Omnibus I replaced the waves with a single 1,000-employee and €450 million test from financial year 2027; the revised ESRS apply from the same year; and non-EU groups follow under Article 40a from financial year 2028.
Did stop-the-clock or Omnibus I set the 2027 date?
Both, in turn.
Directive (EU) 2025/794 of 14 April 2025 postponed wave two to financial year 2027 and wave three to 2028.
Omnibus I, Directive (EU) 2026/470, then replaced the waves altogether with the single test from financial year 2027.
When do the revised ESRS enter into force and apply?
Delegated Regulation (EU) 2026/1563 was adopted on 3 July 2026, published in the Official Journal on 21 September 2026 and enters into force on 10 November 2026.
It applies to financial years beginning on or after 1 January 2027.
Entry into force is not application.
Which ESRS apply for financial year 2026?
For a financial year starting in 2026 there are three choices: the 2023 ESRS as amended by Delegated Regulation (EU) 2025/1416; those standards with eight named reliefs; or the revised ESRS in full.
The undertaking must state which version it applied.
When must Member States transpose Omnibus I?
By 19 March 2027 for Articles 1 to 3, which cover the CSRD scope and the value-chain cap.
Article 4, the due-diligence limb, has a later deadline of 26 July 2028.
Do not quote one date for the other.
When do non-EU groups report under the CSRD?
Under Article 40a, from financial year 2028, with first reports in 2029.
It applies where the third-country group generated more than €450 million of net turnover in the EU in each of the last two consecutive financial years and has an EU subsidiary or branch above €200 million.
When are the EU limited assurance standards due?
The Commission must adopt limited assurance standards by 1 July 2027, under Omnibus I. The earlier deadline of 1 October 2026 was moved, and the power to adopt reasonable assurance standards by 1 October 2028 was deleted.
Does CSRD assurance move to reasonable assurance in 2028?
No. Omnibus I removed the requirement to adopt reasonable assurance standards, so there is no legislated move from limited to reasonable assurance.
CSRD assurance is limited assurance.
When does the value-chain cap start?
Omnibus I has been in force since 18 March 2026 and must be transposed by 19 March 2027.
The voluntary standard that sets the cap’s datapoints, Delegated Regulation (EU) 2026/1560, has been in force since 24 September 2026, and its Article 3 applies from financial years beginning on or after 1 January 2027.
How many companies are in scope after Omnibus I?
The Commission’s staff working document SWD(2026) 500 estimates 6,753 companies, of which 1,535 are wave-one companies and 5,218 wave-two companies.
That number covers companies that remain in scope after the Omnibus I changes, not an EU-wide reporting population.
What happens in 2031?
Omnibus I requires a review report by 30 April 2031.
The date is a review, not a change to the rules.
Does the CSRD timeline affect UK SRS reporting?
No. UK SRS runs on its own timeline: under the FCA’s PS26/19, listed companies in five categories report on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.
A UK group may meet both, but neither date moves the other.
What dates are open in late 2026?
As at 11 October 2026: EFRAG’s draft datapoint list takes feedback until 23 October 2026, the ESRS-40a exposure draft until 31 October 2026, and the draft XBRL taxonomy until 11 November 2026; the revised ESRS enter into force on 10 November 2026.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
Checked against 16 sources fromEUR-LexEuropean CommissionEFRAGFinancial Conduct Authority
- EUR-LexDirective (EU) 2022/2464 (the CSRD) — OJ L 322, 16.12.2022
The amending directive that rewrote Articles 19a and 29a of the Accounting Directive.
- EUR-LexDirective 2014/95/EU (the Non-Financial Reporting Directive)
Where the two reporting limbs first appeared, in 2014.
- EUR-LexDirective (EU) 2025/794 (“stop-the-clock”), Art 1 and recital (3)
Of 14 April 2025: wave two moved to FY2027 and wave three to FY2028.
- European CommissionSWD(2025) 80 final, 26 February 2025
The staff working document accompanying the Omnibus I proposal.
- EUR-LexDirective (EU) 2026/470 (Omnibus I) — recitals (4), (5), (31), Arts 1, 2, 5 and 6
Published 26 February 2026, in force 18 March 2026; transposition 19 March 2027 for Articles 1–3.
- EUR-LexDirective 2013/34/EU, consolidated 18 March 2026 — Arts 19a, 29a, 40a
The scope test from FY2027: more than 1,000 employees and €450 million net turnover, both.
- EUR-LexCommission Delegated Regulation (EU) 2023/2772 — the first ESRS
Adopted 31 July 2023, OJ 22 December 2023.
- EUR-LexCommission Delegated Regulation (EU) 2026/1563 — the revised ESRS, Arts 2 and 3
OJ 21 September 2026; in force 10 November 2026; applies to financial years beginning on or after 1 January 2027.
- EUR-LexCommission Delegated Regulation (EU) 2026/1560 — the voluntary standard, Arts 3 and 4
In force 24 September 2026; Article 3 applies from financial years beginning on or after 1 January 2027.
- European CommissionCommission adopts revised sustainability reporting standards, 3 July 2026
The adoption date of the revised ESRS and the voluntary standard.
- EFRAGEFRAG provides its technical advice on draft simplified ESRS, 3 December 2025
EFRAG advises; the Commission adopts.
- EFRAGESRS-40a Exposure Draft, Basis for Conclusions
Third-country reporting from FY2028, first reports in 2029; advice due January 2027.
- EUR-LexDirective (EU) 2024/1306 — the Article 40b deadline moved to 30 June 2026
That date has since passed without the third-country standard being adopted.
- European CommissionSWD(2026) 500 final — the post-Omnibus population
6,753 companies, of which 1,535 in wave one and 5,218 in wave two, remaining in scope after Omnibus I.
- EFRAG2026 Draft List of Datapoints and draft XBRL taxonomy
Feedback to 23 October 2026 and consultation to 11 November 2026 respectively.
- Financial Conduct AuthorityPS26/19 — UK SRS on a comply-or-explain basis
The separate UK timeline for listed companies, periods beginning on or after 1 January 2027.
Continue reading
Read next
The hub
The CSRD explained
Who it covers after Omnibus I, the revised ESRS and assurance.
Assurance
CSRD assurance
Limited assurance only: what the opinion covers and who may give it.
Scope
CSRD thresholds
The 1,000-employee and €450 million test, and an in-scope check.
What changed
The CSRD after Omnibus I
Old and new scope side by side.