- The Omnibus directive (EU) 2026/470 entered into force on 18 March 2026.
- Wave 1 (companies already reporting) continues; Wave 2 (new-scope large companies) reports for FY2027, published in 2028.
- Listed SMEs were removed from the mandatory scope.
- The revised ESRS apply for financial years opening on or after 1 January 2027.
When does the CSRD apply?
The CSRD applies progressively, and the Omnibus package (Directive (EU) 2026/470, in force on 18 March 2026) reshaped the timeline. Whether you are concerned depends on the thresholds (more than 1,000 employees and €450M net turnover).
The reporting waves
| Wave | Who | Timeline |
|---|---|---|
| Wave 1 | Companies already in scope | Continue their reporting |
| Wave 2 | Large companies at the new threshold (>1,000 employees and >€450M) | First financial year 2027, published in 2028 (2-year "stop-the-clock" delay) |
| Wave 3 | Listed SMEs | Removed from the mandatory scope; the voluntary VS (formerly VSME) has been in force since 24 September 2026 |
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The French transposition
In France, the "stop-the-clock" was transposed by law n° 2025-391 of 30 April 2025 (delaying waves 2 and 3). The substantive Omnibus thresholds (1,000/€450M) are being transposed through a further bill and are not yet finalized, so exact French dates should be confirmed against the consolidated text.
How to use the calendar
Even with two years' delay, preparation is a two-year effort: measure in year one, run a test report in year two before the formal audit. Checking your scope early and structuring your CSRD reporting avoids a last-minute rush.
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CSRD timeline — Key Takeaways
| Key point | Explanation |
|---|---|
| Entry into force | Directive (EU) 2026/470, 18 March 2026 |
| Wave 2 | FY2027, published in 2028 |
| Listed SMEs | Removed from the mandatory scope |
| Revised ESRS | Apply from FY2027 |
