CSRD (Corporate Sustainability Reporting Directive)

The EU Corporate Sustainability Reporting Directive (CSRD) (Directive (EU) 2022/2464) requires large companies to disclose standardised sustainability information in their annual management reports, prepared in accordance with the European Sustainability Reporting Standards (ESRS). The CSRD replaced the Non-Financial Reporting Directive (NFRD). Wave 1 (large public interest entities >500 employees) applied from the 2024 financial year, with reports published in 2025. The Stop-the-Clock Directive (Directive (EU) 2025/794, in force April 17, 2025) postponed Wave 2 and Wave 3 by two years. The Omnibus I provisional agreement (December 2025) proposes reducing scope to companies with >1,000 employees and net turnover >€450M, cutting the number of affected companies by approximately 80%.

CSRD (Directive (EU) 2022/2464), OJ L, 16 December 2022; Stop-the-Clock Directive (EU) 2025/794; Omnibus I provisional agreement (COM(2025) 811/812, December 2025).

Wave 1 companies must report on 2024 FY sustainability performance. Wave 2 companies (originally 2025 FY) are now delayed to 2027 FY. Wave 3 (listed SMEs) has been removed from scope under Omnibus I. US and non-EU companies with significant EU operations remain potentially in scope; the ESRS for non-EU third-country undertakings has been de-prioritised. Compliance teams should monitor Omnibus I’s formal adoption and revised ESRS expected Q2 2026.