The Corporate Sustainability Reporting Directive (CSRD) introduces new sustainability reporting requirements across the European Union. Understanding the first-time reporting timeline is crucial for companies preparing to comply. Here’s a breakdown of the key dates and timelines:
CSRD First-Time Reporting Timeline
CSRD First-Time Reporting Timeline
| Company Type |
Financial Year (FY) for First Reporting |
First CSRD Report Due |
| Large Public-Interest Entities (NFRD) |
FY 2024 |
Early 2025 |
| Large Companies Not Previously Under NFRD |
FY 2025 |
Early 2026 |
| Listed SMEs, Small Credit Institutions, and Captive Insurance Undertakings |
FY 2026 |
Early 2027 |
| Non-EU Companies with Significant EU Operations |
FY 2028 |
Early 2029 |
Key Notes:
- Phased Approach: The timeline reflects a phased implementation based on company size and regulatory status.
- Flexibility for SMEs: Listed SMEs and certain small institutions have a longer timeframe to comply, recognizing their potentially limited resources.
- Non-EU Companies: Companies outside the EU but with substantial EU business activities are included, ensuring comprehensive coverage of the directive.
* NFRD: Non-Financial Reporting Directive, the previous framework replaced by CSRD.
** Non-EU Companies must comply if they generate more than €150 million in net turnover within the EU and have at least one EU subsidiary or branch.
Detailed Explanation of the Timeline
- FY 2024: Large public-interest companies (e.g., those covered by the NFRD) will need to start collecting data for their first CSRD-compliant report, which will be published in early 2025.
- FY 2025: Other large companies (with over 250 employees, €40 million turnover, or €20 million in assets) must begin compliance, with their first report due in early 2026.
- FY 2026: Listed SMEs, small credit institutions, and captive insurance companies will begin reporting under the CSRD framework. The first report is expected in early 2027. A simplified standard may apply to these entities.
- FY 2028: Non-EU companies meeting the criteria must start compliance, with the first report due in early 2029.
Key Actions for First-Time Reporters
- Conduct a Gap Analysis: Compare current reporting practices against CSRD requirements to identify areas needing improvement.
- Implement Double Materiality Assessment: Evaluate both financial and impact materiality in your reporting process.
- Align with ESRS Standards: Familiarize yourself with the European Sustainability Reporting Standards (ESRS) to ensure compliance.
- Prepare for Assurance Requirements: Establish internal processes to meet the limited assurance requirements, which will eventually move to reasonable assurance.
This timeline provides a structured approach for companies to prepare for the new reporting obligations, helping ensure a smooth transition to CSRD compliance.
