CSRD Wave 2: FY2027 Preparation Guide
CSRD Wave 2 companies — those with 1,000+ employees AND €450M+ turnover not previously under NFRD — must report for FY2027, with first reports published in 2028. As of March 2026, the preparation window is approximately 18 months. Here is the complete roadmap for Wave 2 compliance.
CSRD Wave 2 companies — those with 1,000+ employees AND €450M+ turnover not previously under NFRD — must report for FY2027, with first reports published in 2028. As of March 2026, Wave 2 companies have approximately 18 months before their FY2027 data collection year begins (January 2027 for December year-ends).
The Wave 2 timeline — where you are now
As of March 2026, Wave 2 companies have approximately 18 months before their FY2027 data collection year begins (January 2027 for December year-ends). The preparation clock is not 18 months — it is already running.
What must be done before January 2027:
Double materiality assessment: Must be complete before data collection begins. You cannot identify which data to collect without knowing which ESRS topics are material. Allow 8–12 weeks for a robust assessment including stakeholder engagement. This means the assessment should start immediately — April/May 2026 at the latest.
Gap analysis: Once materiality is determined, map required ESRS datapoints against current data availability. Identify gaps. Prioritise remediation by: deadline urgency, data lead time, and assurance impact. Allow 4–6 weeks for gap analysis. Start June/July 2026.
Data system implementation: Infrastructure gaps identified in the gap analysis must be closed before FY2027 data collection begins. Scope 3 supplier programmes, contractor H&S reporting systems, and energy sub-metering all take 6–12 months to establish. Start implementation August–October 2026.
Assurance provider engagement: Engage your limited assurance provider by Q3 2026 at the latest — 18 months before filing. The assurance market is already booking 2027/2028 engagements.
The Amended ESRS — what Wave 2 companies report under
Wave 2 companies report under the Amended ESRS — the updated standards published by EFRAG in December 2025 following the Omnibus package. The Amended ESRS reduced mandatory datapoints by approximately 61% compared to the original 2023 ESRS.
Key changes in Amended ESRS relevant to Wave 2: Reduced mandatory ESRS 2 datapoints — fewer required disclosures in governance and strategy sections. Simplified ESRS E1-9 financial effects quantification — less granular quantification required for transition and physical risk financial effects. Reduced ESRS S1 non-employee worker breakdowns — fewer required sub-categories for contractor data. Streamlined ESRS E4 and E3 — some biodiversity and water datapoints moved from mandatory to voluntary.
What did not change: The core structure of all 12 ESRS standards remains intact. Scope 1, 2, and 3 GHG emission disclosure remains mandatory where E1 is material. Double materiality assessment process is unchanged. XBRL tagging and mandatory assurance requirements are unchanged. EU Taxonomy KPIs remain mandatory.
For Wave 2 preparation: Work from the Amended ESRS text — not the original 2023 version. EFRAG published the Amended ESRS on its website (efrag.org). The EFRAG ESRS XBRL Taxonomy will be updated to reflect Amended ESRS datapoints — ensure your XBRL implementation uses the correct taxonomy version for the reporting year.
Learning from Wave 1 — the Wave 2 advantage
Wave 2 companies have a significant advantage over Wave 1 filers — 2 years of Wave 1 peer learning, published ESAP reports for benchmarking, EFRAG Wave 1 review findings, and improved assurance market capacity.
Use Wave 1 reports: Access Wave 1 peer company reports via ESAP (esap.europa.eu) and company websites. Review reports from companies in your sector — what topics did they assess as material? How did they approach Scope 3? What format did they use for the double materiality assessment disclosure? This benchmarking significantly reduces the blank-page problem.
Apply Wave 1 assurance lessons: The most common Wave 1 assurance findings — documentation gaps, non-employee worker data, XBRL errors — are all preventable. Build documentation, contractor data collection, and XBRL implementation into your programme from the start rather than addressing them reactively.
Benefit from supplier readiness: Wave 1 large companies have been engaging their suppliers for Scope 3 data since 2024. By 2026/2027, more tier 1 suppliers have established GHG inventories and can provide primary data to Wave 2 companies. Your Category 1 Scope 3 calculation should benefit from improved supplier data availability compared to Wave 1.
Investor expectations are calibrated: Investors, ESG rating agencies, and assurers now have 1–2 years of CSRD report experience. Their expectations are better calibrated — they know what first-year reports look like and will assess Wave 2 reports in that context rather than comparing to mature voluntary reporters.
Frequently asked questions
We were excluded from CSRD by the Omnibus changes — are we definitely Wave 2?
Check both thresholds: 1,000+ employees AND €450M+ net worldwide turnover. Both must be met simultaneously. If your headcount is 1,200 but turnover is €380M, you are outside Wave 2 scope. If both thresholds are met, you are Wave 2 regardless of whether you were previously in or out of scope under the original CSRD.
Can we start collecting data before completing our materiality assessment?
You can collect data for topics that are almost certainly material — Scope 1, 2, and 3 GHG emissions; energy consumption; headcount and basic HR metrics; H&S incidents. These are material for virtually all large companies. But do not build extensive data infrastructure for topics before confirming materiality — investing in ESRS E4 biodiversity data collection before knowing if biodiversity is material wastes resources.
What is the minimum viable first CSRD report for a Wave 2 company?
A credible first report requires: a documented double materiality assessment; complete ESRS 2 disclosures; complete disclosures for all material topical standards; EU Taxonomy KPIs; XBRL tagging; and limited assurance. Imperfect data with transparent methodology disclosure and improvement commitments is acceptable. Missing mandatory disclosures without justification is not. The Amended ESRS reduces the mandatory datapoint count — use this to focus first-year effort.