W
Wave Reporting (CSRD Phased Implementation)
Definition
Wave reporting refers to the phased implementation schedule of the EU CSRD (Directive (EU) 2022/2464), under which different categories of companies are required to begin CSRD sustainability reporting at different times. Following the Stop-the-Clock Directive (Directive (EU) 2025/794, in force April 17, 2025) and Omnibus I: Wave 1 (large public interest entities >500 employees): 2024 FY reporting (reports published 2025) — unchanged. Wave 2 (large EU companies not qualifying as PIEs): delayed from 2025 FY to 2027 FY at earliest. Wave 3 (listed SMEs): removed from mandatory CSRD scope under Omnibus I’s proposed revised thresholds (>1,000 employees / €450M turnover).
Source
CSRD (EU) 2022/2464; Stop-the-Clock Directive (EU) 2025/794; Omnibus I provisional agreement (December 2025).
Practical Explanation (Compliance Context)
Wave 1 reporters are in active reporting mode; their 2024 FY statements are due in 2025. Wave 2 companies have a two-year reprieve but should use the time to build ESG data infrastructure, conduct double materiality assessments, and prepare systems for 2027 FY reporting. Under Omnibus I’s proposed revised scope (>1,000 employees), many originally Wave 2 and Wave 3 companies may fall entirely out of mandatory scope. Final scope confirmation awaits formal Omnibus I adoption.