CSRD Reporting Deadlines
CSRD has four waves of companies with different reporting deadlines. Wave 1 has filed their first reports. Wave 2 is delayed to 2028 by Omnibus. Wave 4 (non-EU) delayed to 2029. Here are all the dates you need.
CSRD has four waves of companies with different reporting deadlines. Wave 1 — Large PIEs previously under NFRD: First CSRD report covered FY2024, filed in 2025.
The four waves — current deadlines post-Omnibus
Wave 1 — Large PIEs previously under NFRD: First CSRD report covered FY2024, filed in 2025. No delay under Omnibus. These companies have now completed their first reporting cycle.
Wave 2 — Companies with 1,000+ employees AND €450M+ turnover: First report for FY2027, filed in 2028. Originally FY2025/2026, delayed two years by the Omnibus Stop-the-Clock regulation adopted April 2025.
Wave 3 — Listed SMEs: Removed from mandatory scope under Omnibus. Previously scheduled for FY2026. Can opt in voluntarily.
Wave 4 — Non-EU companies with €450M+ EU net turnover: First report for FY2028, filed in 2029. Threshold raised from €150M to €450M under Omnibus.
Non-December fiscal years
The standard deadline is 4 months after the end of the fiscal year. For December fiscal year ends, this means April filing. For March fiscal year ends, this means July filing.
The Omnibus Stop-the-Clock regulation confirmed these filing windows are preserved — the two-year delay shifts the reporting year but not the 4-month filing window.
Companies should check their national regulator's specific filing requirements — some jurisdictions require filing in the national register as well as publication in the annual report.
Planning backwards from your deadline
Wave 2 companies targeting FY2027 reporting now have approximately 18 months before data collection must be complete — and that window is closing. The materiality assessment and gap analysis should be underway or completed in H1 2026.
Key milestones working backwards from a 2028 filing date: April 2028 — filing deadline. October 2027 — assurance engagement underway. April 2027 — full year of data being collected in live systems. October 2026 — data systems implemented and tested. April 2026 — gap analysis and materiality assessment complete.
Companies that have not started their materiality assessment by mid-2026 will struggle to meet the FY2027 data collection requirement. There is no slack left in the Wave 2 timeline.
Frequently asked questions
What is the exact filing deadline for a UK-based EU subsidiary?
UK-based companies are not directly subject to CSRD — the UK has its own sustainability disclosure regime. EU subsidiaries of UK parent companies may be in CSRD scope independently if they meet the thresholds in the member state where they are incorporated.
Can we file late?
No — national regulators can impose fines for late filing. The filing date is a hard deadline, not a target. Build your compliance programme with at least 4–6 weeks of buffer before the filing date.
Does the Omnibus delay mean we can pause CSRD preparation?
No — and companies that paused in 2025 are already behind. The data collection infrastructure needed for FY2027 reporting takes 12–18 months to stand up. As of March 2026, Wave 2 companies should be in implementation, not planning.