CSRD has a phased implementation timeline, that gradually expands the scope of companies required to comply with its reporting requirements.
CSRD reporting timeline:
January 1, 2024:
Companies already subject to the Non-Financial Reporting Directive (NFRD):
Large public-interest entities with more than 500 employees (e.g., listed companies, banks, and insurance companies) must start reporting in 2025 on the financial year 2024.
January 1, 2025:
Large companies that are not currently subject to NFRD:
This includes large companies meeting at least two of the following criteria: more than 250 employees, a net turnover of more than €40 million, or total assets of more than €20 million.
These companies must start reporting in 2026 on the financial year 2025.
January 1, 2026:
Listed small and medium-sized enterprises (SMEs), small and non-complex credit institutions, and captive insurance undertakings:
These entities must start reporting in 2027 on the financial year 2026.
However, listed SMEs have the option to opt out of the CSRD reporting requirements until 2028, meaning they can start reporting in 2029 on the financial year 2028 if they choose to take advantage of the opt-out period.
January 1, 2028:
Non-EU companies with substantial activities in the EU:
Non-EU companies with a net turnover of more than €150 million in the EU and at least one subsidiary or branch in the EU must start reporting in 2029 on the financial year 2028.
Summary timeline:
2024: Reporting begins for companies already under NFRD
2025: Reporting begins for large companies not under NFRD
2026: Reporting begins for listed SMEs and certain other entities
2028: Reporting begins for non-EU companies with significant EU operations