CSRD Compliance & Reporting: A Complete Guide for EU and Non-EU Companies

CSRD reporting comes in multiple waves and affects the following organizations.

Wave 1 – FY 2024 reporting (published in 2025)

Large EU companies meeting the updated size criteria under the phased CSRD implementation.

From Jan. 1, 2024, to Dec. 31, 2026, large public-interest entities with more than 500 employees initially were subject to CSRD reporting unless exempt under national law.

For financial years beginning in 2025 or 2026, Member States may exempt companies that will fall outside the revised Omnibus scope from 2027 (i.e., below €450 million turnover and 1,000 employees), so companies must closely monitor national implementation.

Wave 2 — FY 2027 reporting (published in 2028)

EU undertakings or parent undertakings that, as of their balance sheet date, exceed €450 million in net annual turnover and an average of 1,000 employees during the financial year will be subject to reporting requirements for financial

years beginning Jan.1, 2027 (reporting in 2028). The revised scope threshold is assessed based on a single financial year.

The same thresholds and timeline apply to non-EU issuers on an EU regulated market.

Wave 3 – FY 2028 reporting (published in 2029) – removed from scope after the latest Omnibus ruling, March 4, 2026. No longer applies.

Listed SMEs on regulated markets, certain small and non-complex credit institutions and captive insurance entities – Originally due to report FY 2026.

Wave 4 — FY 2028 reporting (published in 2029):

Non-EU parent companies with significant operations or listed subsidiaries within the EU. Omnibus thresholds (>1000 employees and > €450m turnover etc.) CSRD or a branch > €200m turnover in the EU + parent exceeds €450m globally.

Non-EU parent companies with significant operations in the EU (that meet CSRD scope requirements through subsidiaries or branches) must publish their first CSRD/ESRS reports in respect of FY 2028, with reports due in 2029. This timeline remains unchanged under Stop-the-Clock.

It is required for companies to conduct a double materiality assessment to include only those factors or measurements that are important or relevant to them, such as:

• Environmental factors including Scope 3 emissions, demands on resources and biodiversity impacts.
• Social factors including human rights, health and safety metrics, and employee diversity.
• Governance issues incorporating corporate policies, board oversight and stakeholder management.

CSRD also connects to several related frameworks companies may be reporting against in parallel, including GRI, IFRS S1 and S2, and the PCAF Standard for financial institutions.

Sphera delivers a comprehensive and modular ESRS-aligned offering — enabling organizations to move from initial readiness assessment to full, audit-ready disclosure with confidence.

Our integrated approach combines over 30 years of expertise in corporate and product sustainability with deep regulatory insight and sector-specific advisory capability. We support organizations at every stage of their CSRD journey, including:

• Double materiality assessments aligned with ESRS requirements
• Data gap and readiness assessments to evaluate existing data architecture against ESRS disclosure requirements
• EU Taxonomy alignment and reporting
• ESRS E1 Climate implementation, including greenhouse gas (GHG) accounting and transition planning
• Topical standards support, including circular economy strategy, biodiversity impact assessments and social governance disclosures
• Climate risk assessment and scenario modeling to assess sustainability-related exposure
• Data functional architecture design, enabling a centralized, audit-ready single source of truth
• Advisory and critical review services to strengthen governance and disclosure quality
• Report content development and structured disclosure support.

Our technology-enabled approach, including SpheraCloud for Corporate Sustainability, allows organizations to integrate sustainability data across business units and value chains — improving transparency, traceability, and long-term reporting resilience.