What is the general CSRD deadline?
The CSRD applies to a wide range of companies within the European Union. The implementation of the Corporate Sustainability Reporting Directive (CSRD) introduces its deadlines in various phases.
The CSRD deadline outlined below guides you through the EU’s gradual approach to integrating different sectors and company sizes under the legislation. Based on different characteristics, your company can determine which category it falls into.
Publicly listed companies (2024)
The first group required to report will be publicly listed companies. They must report on the fiscal year 2024 and publish the report in 2025. Companies in this group have the following characteristics:
Company characteristics:
- More than 500 employees
- Already complied with NFRD
- Publicly listed
- Established in the EU
This category thus includes publicly listed companies within the EU that employ more than 500 workers. These companies have been required to report their non-financial information since 2014. This is why these companies must report first. With the introduction of the CSRD, the requirements of the NFRD (Non-Financial Reporting Directive) are expanded and detailed further.
Large non-publicly listed companies (2025)
The second group that will need to comply with the legislation are large non-publicly listed companies. They must prepare the report for the fiscal year 2025 in the year 2026. Companies within this group have the following characteristics:
Company characteristics:
- Not publicly listed
- Balance sheet total of more than 25 million
- More than 50 million in net revenue
- More than 250 employees
- Established in the EU
Large enterprises that are not publicly traded but meet certain criteria are now also required to report their sustainability information. The requirement is to meet two of the three guidelines for two years: a balance sheet total of 20 million, net revenue of 40 million, and more than 250 employees.
Publicly listed SMEs (2026)
The third group is the publicly listed SMEs. For the fiscal year 2026, with reports published in 2027, publicly listed SMEs within the EU are expected to comply with the legislation.
Company characteristics:
- Publicly listed
- Established in the EU
- Not in the above categories
This group does not fall within the previously mentioned criteria but still has a significant impact. Due to their listing, this group is also mandated by the European Commission to report. This is partly to provide insights on sustainability information for investors.
Deadlines for non-eu companies (2028)
The last group consists of companies not established within the European Union. They must start from January 1, 2028, and report in 2029. These companies must also comply with CSRD, as they are considered significantly important players in the European market. They also make a substantial contribution to achieving the European Green Deal.
Company characteristics:
- Not established within the EU
- Revenue of 150 million in the EU
- At least one subsidiary or branch in the EU
The extension of CSRD obligations also applies to companies outside the EU. This concerns companies generating significant revenue in the EU and having at least one subsidiary or branch within the EU.
Exception to CSRD deadline
The CSRD offers various transition provisions and exceptions. This helps organizations gradually transition to full compliance with the new reporting requirements. Below is an overview of the main provisions and exceptions.
Value chain transition period
There is an additional three-year transition period for reporting on complex components such as information from the value chains for CSRD. This is particularly relevant for obtaining information from medium and small businesses.
This approach acknowledges the challenges companies face, including possible limited financial and personnel resources. Thus, collecting comprehensive sustainability data from the entire value chain can pose a significant burden.
This extended period provides companies additional time to strengthen partnerships with suppliers and partners. Or alternatively, to implement data collection systems and prepare for full compliance without unnecessary pressure on operations.
Transitional period for comparative information
Another exemption is the transitional period for comparative information. This exemption means that companies are not immediately required to report comparative information in the first year of preparing their sustainability declaration according to the ESRS.
This exception is intended to give companies time to adjust to the new requirements. They do not have to focus initially on providing comparative information.
Exemption from specific reporting requirements
Besides the exceptions to the CSRD deadlines, there are also some exceptions to the reporting requirements. This includes specific ESG information that may be challenging for some companies to collect. These exceptions can change your personal CSRD timeline, as you can initially focus on collecting other relevant data.
Below is an overview of some important, phased reporting requirements. These are found in Annex C of the ESRS 1 of the CSRD legislation. It is advisable to consult this before absolute certainty for exclusion can be determined.
Exemptions for companies with fewer than 750 employees
Companies with fewer than 750 employees have exemptions under the European Sustainability Reporting Standards (ESRS). This exemption applies for the first years (depending on the specific exemption) after the start of reporting.
They can postpone reporting on scope 3 emissions and total greenhouse gas emissions (ESRS E1). They can also delay detailed reporting on the financial effects of environmental risks and opportunities regarding climate change (ESRS E1), pollution (ESRS E2), water and marine resources (ESRS E3), and the circular economy (ESRS E5). Additionally, they can postpone the entire report on biodiversity and ecosystems (ESRS E4).
For social and worker aspects, such as working conditions, health, and safety in the workplace, the standards ESRS S1, S2, S3, and S4 provide more lenient conditions for both qualitative and quantitative information. This gives these companies more time to adjust their reporting processes.
Other exemptions for the CSRD deadline
Other enterprises, without specific limitations based on the number of employees, also have some more lenient transition rules. However, these transition provisions are somewhat less lenient than those for companies with fewer than 750 employees. The transition requirements apply to:
There are some exemptions for ESRS 2 SBM-3. The material impacts, risks, and opportunities, and their interaction with strategy and business model. Enterprises can omit the intended financial effects for the first year of their sustainability declaration. For the first three years, if quantitative reporting is not practically feasible, they may provide only qualitative information.
For specific environmental and social themes, the ESRS offer more lenient rules for reporting financial effects of certain risks and opportunities. These exemptions allow companies to provide primarily qualitative information in the initial years of reporting under the CSRD if quantitative data is not feasible.
Development of CSRD deadlines
The implementation of the CSRD brings significant changes to the reporting obligations of organizations in Europe. This also applies to organizations from third countries active in the European market.
It’s important to recognize that the CSRD is part of a broader framework of sustainability legislation and standards within the EU. This includes the EU Taxonomy and the Corporate Sustainability Due Diligence Directive (CSDDD), as well as sector-specific standards. This complexity highlights the importance of ongoing vigilance and adaptation to new requirements and standards.
Recent developments, such as the agreement between the council and the European Parliament on February 14, 2024, illustrate how quickly changes can occur. It was decided to postpone the reporting obligations for certain sectors and enterprises from third countries by two years.
These developments underline the necessity for organizations to actively follow the publications and updates of the European Union. It is crucial for your organization to not only prepare for the current requirements but also to remain flexible and plan ahead for future adjustments.
