One of the most common questions we get is: “When exactly does CSRD apply to my business?” The honest answer is: it depends entirely on your company's size — the EU phased CSRD in across four separate “waves,” not one single deadline for everyone.
This guide breaks down each wave, what qualifies a company for it, and what to do if you're not sure which one applies to you.
Why CSRD Doesn't Have One Single Deadline
The Corporate Sustainability Reporting Directive was designed to roll out gradually, giving larger, better-resourced companies less time to prepare and smaller companies more runway. That's why you'll see different companies talking about “2025 reporting,” “2026 reporting,” or “2028 reporting” and all be correct — they're just in different waves.
The Four CSRD Waves
Wave 1 — Large Public-Interest Entities (Already Reporting)
Companies already subject to the older Non-Financial Reporting Directive (NFRD) — typically listed companies with more than 500 employees. These businesses began reporting on financial year 2024 data, published during 2025.
Wave 2 — Large Companies Not Previously in Scope
Large companies that meet at least two of these three thresholds: more than 250 employees, more than €50 million in turnover, or more than €25 million on the balance sheet. This wave covers a much larger pool of mid-sized-to-large businesses that weren't previously required to report anything.
Wave 3 — Listed SMEs
Small and medium-sized companies listed on EU-regulated markets, along with small and non-complex credit institutions and captive insurers. Listed SMEs are given the option to delay reporting slightly if they need more preparation time.
Wave 4 — Non-EU Parent Companies
Non-EU companies with significant turnover generated within the EU (above €150 million) and at least one EU subsidiary or branch meeting certain size thresholds. This wave closes the loop so large non-EU groups operating in Europe can't sidestep the directive entirely.
A note on exact dates: the EU has proposed simplifications to CSRD timing (sometimes referred to as the “Omnibus” proposals) that have pushed back reporting dates for later waves since the directive was first adopted. Wave boundaries and thresholds above are the structural framework — always confirm current exact dates against the latest EU Commission guidance before making a compliance decision, since this is an area that has genuinely moved since CSRD was first published.
What If I'm a Small Business Not Directly in Any Wave?
Most European SMBs — the businesses we work with every day — aren't directly captured by any wave. But “not directly in scope” doesn't mean “unaffected.” If any of your customers are large companies already reporting under CSRD, they now need your emissions data as part of their own Scope 3 disclosures. We cover exactly how to handle that in our guide on responding to a supplier carbon data request.
Many SMBs are also choosing to report voluntarily using the ESRS VSME standard — a simplified format built specifically for smaller businesses — because it's becoming the expected answer when a larger customer or lender asks for carbon data.
How “Company Size” Is Actually Measured
EU size thresholds are based on meeting at least two of three criteria:
- Employee count — average number of employees during the financial year
- Turnover — net revenue for the financial year
- Balance sheet total — total assets
These thresholds are also being revisited under the EU's simplification proposals, so the exact figures are worth double-checking against current guidance rather than treating any single number as permanent.
How to Find Out Which Wave You're In
- Check whether you were already subject to NFRD reporting — if yes, you're Wave 1
- Count your average employees, turnover, and balance sheet total against current thresholds
- Check whether you're listed on an EU-regulated market
- If you're a non-EU company, check your EU-generated turnover and EU subsidiary presence
- If none of the above apply, you're likely not directly in scope yet — but check whether your customers are
What to Do Now, Regardless of Your Deadline
Whether your official deadline is next year or several years away, the businesses that struggle most with CSRD are the ones that start from zero the year it's due. Carbon data — energy bills, fuel use, travel, waste — takes time to collect accurately, and having even one year of baseline data makes your first official report dramatically easier.
You can start today with our free carbon footprint calculator— no signup required — and get a feel for what your Scope 1, 2, and 3 numbers actually look like before it's mandatory.