Corporate Sustainability Reporting Directive

(CSRD)

Directive (EU) 2022/2464 as regards corporate sustainability reporting (CSRD)

Requiring certain companies to report on the impact of corporate activities on the environment and society.

Entry into force

5 January 2023

 ESG – Approval of CSRD (8 December 2022)

2023

30 June 2023

Sustainability reporting standards

EU Commission to adopt delegated acts to provide for sustainability reporting standards. The sustainability reporting standards must specify the information that undertakings are to report in accordance with Articles 19a and 29a of Directive 2013/34/EU, known as the Accounting Directive, and, where relevant, must specify the structure to be used to present that information.

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Update 22 December 2023: Commission Delegated Regulation (EU) 2023/2772 supplementing Directive 2013/34/EU as regards sustainability reporting standards was published in the Official Journal of the EU. The Commission Delegated Regulation includes the first set of sector-agnostic European Sustainability Reporting Standards (ESRS).

In force

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Update 8 May 2024: Directive (EU) 2024/1306 amending Directive 2013/34/EU as regards the time limits for the adoption of sustainability reporting standards for certain sectors and for certain third-country undertakings was published in the Official Journal of the EU. The Directive postpones the adoption of sector-specific ESRS and sustainability reporting standards to 30 June 2026.

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Update 11 July 2025: EU Commission adopted a proposal for a Delegated Regulation amending Commission Delegated Regulation (EU) 2023/2772 as regards the postponement of the date of application of the disclosure requirements for certain undertakings. 

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Update 31 July 2025: EFRAG published the revised and simplified ESRS Exposure Drafts as part of the Omnibus I revision report.

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Update 3 July 2026: EU Commission adopted a proposal for a Delegated Regulation amending Commission Delegated Regulation (EU) 2023/2772 as regards the simplification of certain sustainability reporting standards. Not in force until it is published in the Official Journal of the EU.


CSRD update: “quick fix” offers breathing space for Wave 1 companies (15 July 2025) 

EFRAG publishes amended ESRS Exposure Drafts (5 August 2025)

Revised European Sustainability Reporting Standards: EU Commission adopts Delegated Act (3 July 2026)

Amendments to Audit Regulation apply

1 January 2024

Amendments to Regulation (EU) 537/2014 on specific requirements regarding statutory audit of public-interest entities (known as the Audit Regulation) to apply for financial years starting on or after 1 January 2024.

2024

30 June 2024

Sustainability reporting standards for small and medium-sized undertakings

EU Commission to adopt delegated acts to provide for sustainability reporting standards that are proportionate and relevant to the capacities and characteristics of small and medium-sized undertakings (SMEs) and to the scale and complexity of their activities. These sustainability reporting standards must specify for SMEs the information that is to be reported in accordance with Article 19a(6) of Directive (EU) 2013/34/EU, known as the Accounting Directive.
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Update 30 July 2025: EU Commission adopted a recommendation on voluntary sustainability reporting for SMEs. The recommendation is an intermediary solution until the delegated act on a voluntary standard is formally adopted. 

Update 3 July 2026: EU Commission adopted a proposal for a Delegated Regulation supplementing the Accounting Directive by establishing sustainability reporting standards for voluntary use by undertakings protected by the value chain cap. Not in force until it is published in the Official Journal of the EU.

Implementation of CSRD

6 July 2024

Member States to bring into force the laws, regulations and administrative provisions necessary to comply with Article 1 (Amendments to the Accounting Directive), Article 2 (Amendments to the Transparency Directive) and Article 3 (Amendments to the Audit Directive) of the Directive.

Luxembourg implementation 29 March 2024: bill of law 8370 implementing the CSRD was submitted to the Luxembourg Parliament. The bill of law is pending with the Luxembourg legislature.

Latest developments in Luxembourg’s CSRD implementation process: the final stretch? (6 November 2024) 

Implementation of CSRD into Luxembourg law: expanded sustainability reporting obligations for Luxembourg and foreign undertakings (15 May 2024)

Implementation of Stop-the-Clock Directive

31 December 2025

Member States to bring into force the laws, regulations and administrative provisions necessary to comply with Directive (EU) 2025/794 as regards the dates from which Member States are to apply certain corporate sustainability reporting and due diligence requirements, known as the Stop-the-Clock Directive.

“Stop-the-Clock”: points to consider for Luxembourg reporting entities and groups (10 April 2025)

Entry into force of Omnibus I Simplification Directive

18 March 2026

Directive (EU) 2026/470 as regards certain corporate sustainability reporting requirements and certain corporate sustainability due diligence requirements, known as the Omnibus I Simplification Directive, entersed into force. The Omnibus I Simplification Directive significantly narrowed the scope of application of the CSRD.

Omnibus I is final: clarity for businesses on sustainability obligations (2 March 2026)

30 June 2026

Sustainability reporting standards for third-country undertakings

EU Commission to adopt a delegated act to provide for sustainability reporting standards for third-country undertakings that specify the information to be included in the sustainability reports referred to in Article 40a of Directive (EU) 2013/34/EU, known as the Accounting Directive.

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Update 8 May 2024: Directive (EU) 2024/1306 amending Directive 2013/34/EU as regards the time limits for the adoption of sustainability reporting standards for certain sectors and for certain third-country undertakings was published in the Official Journal of the EU. The Directive postpones the adoption of sector-specific European Sustainability Reporting Standards (ESRS) and sustainability reporting standards by two years to 30 June 2026.

2027

19 March 2027

Reporting for financial years starting between 1 January 2024 and 31 December 2026

Member States to apply the measures necessary to comply with Article 1 (Amendments to the Accounting Directive) with the exception of point (14) (Reporting concerning third-country undertakings) and Article 2 (Amendments to the Transparency Directive) to:

  • Large undertakings
  • Parent undertakings of large groups (consolidated)

with the following thresholds:

  • Balance sheet total > EUR 25m, or
  • Net turnover > EUR 50m, and
  • More than 500 employees (mandatory).

Omnibus I is final: clarity for businesses on sustainability obligations (2 March 2026)

Member States may exempt large undertakings which do not exceed a net turnover of EUR 450m or an average number of 1,000 employees (consolidated) from CSRD reporting between 1 January 2025 and 31 December 2026.

1 July 2027

Assurance standards for sustainability reporting (Article 26a of Audit Directive)

EU Commission to adopt delegated acts in accordance with Directive 2006/43/EC, known as the Audit Directive, in order to provide for limited assurance standards setting out the procedures that the auditor(s) and the audit firm(s)  must perform in order to draw their conclusions on the assurance of sustainability reporting, including engagement planning, risk consideration and response to risks, and type of conclusions to be included in the assurance report on sustainability reporting, or, where relevant, in the audit report.

Omnibus I is final: clarity for businesses on sustainability obligations (2 March 2026)

Entry into application

1 January 2028

Chapter 9a (Reporting concerning third-country undertakings) of Directive (EU) 2013/34/EU, known as the Accounting Directive, starts applying.

Omnibus I is final: clarity for businesses on sustainability obligations (2 March 2026)

2028

As from 2028

CSRD reporting for financial years starting on or after 1 January 2027

Member States to apply the measures necessary to comply with Article 1 (Amendments to the Accounting Directive), with the exception of point (14) (Reporting concerning third-country undertakings) and Article 2 (Amendments to the Transparency Directive) to:

  • Large undertakings 
  • Parent undertakings of large groups (consolidated) 

with the following thresholds: 

  • Net turnover > EUR 450m, and 
  • More than 1000 employees 

Directive (EU) 2025/794, known as the Stop-the-Clock Directive, postponed the application of the CSRD for what were previously referred to as Wave 2 companies by two years to 2027.

“Stop-the-Clock”: points to consider for Luxembourg reporting entities and groups (10 April 2025)

Directive (EU) 2026/470, known as the Omnibus I Simplification Directive, significantly narrowed the scope of application.

Omnibus I is final: clarity for businesses on sustainability obligations (2 March 2026)

31 December 2028

Milestone

Review and reporting

EU Commission to review and report on the level of concentration of the sustainability assurance market. That review must take into account the national regimes applicable to independent assurance services providers and assess whether and to what extent those national regimes contribute to opening up the assurance market.

31 December 2028

Milestone

Review and reporting

EU Commission to assess possible legal measures to ensure sufficient diversification of the sustainability assurance market and appropriate sustainability reporting quality. EU Commission to review the measures provided for in Article 34 of Directive 2013/34/EU, known as the Accounting Directive, and assess the need to extend them to other large undertakings. EU Commission to report, accompanied by legislative proposals if necessary, to the EU Parliament and the Council of the EU.

2029

As from 2029

CSRD reporting for non-EU companies for financial years starting on or after 1 January 2028

Member States to apply the measures necessary to comply with Article 1 (Amendments to the Accounting Directive), point (14) (Reporting concerning third-country undertakings) to: 

  • Third-country companies

with the following thresholds (both apply):

  • consolidated turnover > EUR 450m in the EU 
  • EU subsidiary/EU branch with turnover of > EUR 200m. 

Directive (EU) 2026/470, known as the Omnibus I Simplification Directive, significantly narrowed the scope of application.

Omnibus I is final: clarity for businesses on sustainability obligations (2 March 2026)

30 April 2029

Milestone

Review and reporting

EU Commission to submit a report, accompanied by legislative proposals if necessary, to the EU Parliament and the Council of the EU on the implementation of the CSRD, including, inter alia:

  • an assessment of the achievement of the goals of the CSRD, including the convergence of reporting practices between Member States;
  • an assessment of the number of small and medium-sized undertakings voluntarily using the sustainability reporting standards referred to in Article 29ca of Directive 2013/34/EU, known as the Accounting Directive;
  • an assessment of the implementation of the reporting requirements on subsidiaries and branches of third-country undertakings introduced by the CSRD, including an assessment of the number of third-country undertakings which have a subsidiary undertaking or a branch reporting in accordance with Article 40a of the Accounting Directive, and an assessment of the enforcement mechanism and the thresholds set out in that Article;
  • an assessment of whether and how to ensure that the sustainability reports published by undertakings falling under the scope of the CSRD are accessible for those with disabilities.

EU Commission to submit a report every three years thereafter.

2031

30 April 2031

Milestone

Review and reporting

EU Commission to submit a report, accompanied by legislative proposals if necessary, to the EU Parliament and the Council of the EU on the implementation of the CSRD, including, inter alia:

  • an assessment of whether and how the scope of the provisions amended by the CSRD should be extended, in particular in relation to large undertakings with a net turnover not exceeding EUR 450m and an average number of employees not exceeding 1,000 during the financial year, as well as to third-county undertakings operating directly on the EU internal market without a subsidiary or a branch on the territory of the EU.

EU Commission to submit a report every three years thereafter.