CSRD Deadlines 2025–2028: Which Phase Applies to Your Company

The Corporate Sustainability Reporting Directive is not a single deadline. It is a phased rollout that brings different types of companies into scope over four years — and the requirements expand at each stage. If you are a board member, CEO, or sustainability leader at an EU company, the first question is not "what do I need to report?" but "when does my obligation begin?"

Getting this wrong has consequences. Late or non-compliant CSRD filings expose the company to regulatory sanctions, qualified audit opinions, and investor concern. Getting it right early creates a structural advantage: you build the data infrastructure once and refine it over subsequent periods, rather than scrambling under deadline pressure.

The Four Phases

Phase 1 — FY2024 (reports due in 2025)

Who: Companies already subject to the Non-Financial Reporting Directive (NFRD) — large EU public-interest entities with 500+ employees.

What changed: These companies transitioned from NFRD to ESRS. If you were reporting under NFRD, the framework shift is substantial: ESRS requires structured data, double materiality assessment, and disclosure across up to 10 topical standards — compared to the narrative-focused NFRD approach.

Status: If you are in Phase 1, your first ESRS-compliant report was due in 2025. You should now be in your second reporting cycle, refining data quality and closing first-year gaps.

Phase 2 — FY2025 (reports due in 2026)

Who: All large EU companies meeting two of three criteria:

250+ employees
€50M+ net turnover
€25M+ total assets

This is the broadest expansion. Phase 2 brings thousands of companies into scope that have never been required to produce structured sustainability disclosures. Many are mid-market industrial companies, family-owned enterprises, and national-champion businesses that treated ESG as voluntary until now.

Key challenge: These companies typically have limited sustainability infrastructure — no dedicated reporting tools, no established data collection processes for GHG emissions, and no experience with double materiality assessments. The gap between "awareness" and "compliance-ready" is significant.

If you are in Phase 2, your FY2025 data reporting period has already started. Your ESRS-compliant report is due in 2026 alongside your annual financial statements.

Phase 3 — FY2026 (reports due in 2027)

Who: Listed SMEs (small and medium-sized enterprises listed on EU-regulated markets), and small and non-complex credit institutions.

Simplified standards: Listed SMEs can use LSME-ESRS (voluntary simplified standards) instead of the full ESRS set. This reduces the reporting burden, but still requires structured data and a materiality-driven approach.

Opt-out option: Listed SMEs may opt out for up to two additional years (until FY2028), after which compliance becomes mandatory.

Phase 4 — FY2028 (reports due in 2029)

Who: Non-EU companies with significant EU operations — specifically, those with net turnover exceeding €150M in the EU and at least one EU subsidiary or branch meeting size thresholds.

Import: This extends CSRD to major non-European multinationals. US, UK, Swiss, Japanese, and other headquartered companies with substantial EU revenue will need to produce consolidated sustainability reports under ESRS.

What "Compliance" Actually Means

Meeting a CSRD deadline is not simply publishing a sustainability section in your annual report. It requires:

1. Double Materiality Assessment A formal, documented process evaluating impact materiality (your effects on people and environment) and financial materiality (how sustainability issues affect your business). This determines which of the 10 ESRS topical standards — E1 through E5 (environment), S1 through S4 (social), G1 (governance) — are material to your company and therefore require disclosure.

2. ESRS Data Collection Quantitative and qualitative data across every material standard. This is not narrative reporting. ESRS defines specific datapoints: GHG emissions by scope, energy consumption by source, workforce metrics by gender and contract type, water withdrawal by source, waste by disposal method. Each datapoint must be traceable and audit-ready.

3. GHG Accounting (Scopes 1, 2, and 3) Climate-related disclosures under ESRS E1 require a full GHG inventory following the GHG Protocol Corporate Standard. This includes all three scopes, with Scope 3 requiring screening of all 15 value chain categories. For most companies, Scope 3 is the most resource-intensive part of the process.

4. External Assurance CSRD mandates limited assurance from an independent auditor under ISAE 3000 (or equivalent national standards). This means your data must withstand third-party verification — complete audit trails, documented methodologies, and evidence-backed figures.

5. Digital Filing CSRD reports must be filed in iXBRL/ESEF format for companies subject to EU electronic reporting requirements. This is a structured digital format — not a PDF upload.

The Cost of Waiting

A common pattern among Phase 2 companies is deferring preparation until the reporting year has started, then discovering that:

Scope 3 supplier data collection takes 3–6 months to yield adequate responses
Double materiality assessments require stakeholder engagement that cannot be compressed into weeks
The data infrastructure needed for ESRS-compliant reporting does not exist and cannot be built retroactively
Auditors need access to systems, methodologies, and evidence trails before the engagement — not after the report is drafted

The companies that handle CSRD compliance efficiently typically start preparation 6–12 months before the reporting period begins. For Phase 2 companies reporting on FY2025, that window is already closed — the question now is how to accelerate.

What to Do Right Now

If you are in Phase 2 (FY2025, due 2026):

You are in the reporting period now. Prioritise getting your GHG accounting infrastructure operational — Scopes 1, 2, and a spend-based Scope 3 baseline
Conduct (or finalise) your double materiality assessment to define which ESRS standards apply. Use our free DMA tool to generate a preliminary materiality matrix.
Engage your external auditor on expectations for limited assurance
Set up a structured data collection system with full audit trails — manual processes will not survive assurance

If you are in Phase 3 (FY2026, due 2027):

You have the advantage of time but not as much as it feels. Start your double materiality assessment this year. Assess your readiness for free.
Evaluate whether you will use LSME-ESRS or full ESRS standards
Begin Scope 1 and 2 data collection immediately as a dry run

If you are in Phase 4 (FY2028, due 2029):

Identify which EU subsidiaries or branches trigger the threshold
Map your existing sustainability reporting (GRI, TCFD, ISSB, SEC Climate Rule) to ESRS requirements — significant overlap exists but gaps are real
Begin socialising the requirement with your board, since ESRS reporting will require governance-level disclosures on sustainability oversight

A Note on Multi-Framework Reporting

CSRD does not exist in isolation. Most companies subject to ESRS also report to CDP (investor-requested), follow GRI (stakeholder reporting), align with ISSB IFRS S1/S2 (financial market standards), and assess EU Taxonomy alignment (regulatory classification). Some face additional jurisdictional requirements: SEC Climate Rule (US), California SB 253 (US), SEBI BRSR (India).

The strategic implication is clear: your reporting infrastructure should not be framework-specific. A platform that natively supports multiple frameworks using shared underlying data eliminates the duplication, inconsistency, and reconciliation effort that comes from managing each framework in a separate tool or spreadsheet.

Note: The 2026 Omnibus Directive raised the CSRD employee threshold from 250 to 1,000. Check our breakdown of the revised scope to confirm whether your company's obligations have changed.

Emistra supports 11 frameworks natively — ESRS, GRI, TCFD, ISSB, CDP, EU Taxonomy, SASB, SEC Climate Rule, California SB 253, SEBI BRSR, and GHG Protocol — across 23 report templates with iXBRL/ESEF export, full audit trails, and a dedicated auditor portal for ISAE 3000 limited assurance. Get started →