EU CSRD Wave 2 — First Sustainability Reports

What this countdown tracks

The first CSRD Wave 2 reporting deadline, due in early 2028 for the financial year 2027, when the second cohort of EU-domiciled large undertakings publishes their first sustainability statements under the European Sustainability Reporting Standards (ESRS). Following the European Commission's Omnibus Simplification Package agreed in 2025, Wave 2 was deferred by two years from the original 2026 reporting cycle to the FY2027 reporting cycle.

About this milestone

The Corporate Sustainability Reporting Directive (Directive (EU) 2022/2464, "CSRD") entered into force in January 2023 and replaces the earlier Non-Financial Reporting Directive. It requires sustainability information to be reported in management reports, in machine-readable digital format (XBRL with the ESRS taxonomy), and to be assured first to a limited-assurance and ultimately to a reasonable-assurance standard. Wave 1 covered Public Interest Entities already in scope of the NFRD with more than 500 employees, reporting for FY2024 in early 2025 under the Set 1 ESRS adopted via Delegated Regulation (EU) 2023/2772.

Wave 2, originally scheduled to apply to other large undertakings (those that exceed two of the three EU thresholds: 250 employees, EUR 50 million net turnover, EUR 25 million balance-sheet total) for FY2025, was deferred to FY2027 by the Omnibus I package agreed by the Council and Parliament in 2025. The Omnibus also rationalised the ESRS Set 1, narrowed the definition of "large undertaking", and recalibrated the value-chain scope. The result is that the first Wave 2 sustainability statements will be published alongside the FY2027 annual reports in spring 2028 — in practice from late February through April 2028, depending on the issuer's reporting calendar.

Key implications

Wave 2 brings tens of thousands of additional EU large undertakings into mandatory ESRS reporting for the first time, requiring double-materiality assessments, value-chain mapping including SMEs, climate transition plans, Scope 1, 2 and material Scope 3 GHG inventories, biodiversity, circular economy, water and marine resources disclosures, workforce metrics, and governance. Reports are filed in iXBRL with the ESRS taxonomy, embedded in the management report and assured by a statutory auditor or independent assurance services provider. The FAQs published by EFRAG and the Commission in late 2025 tightened the value-chain "look-through" expectations and clarified materiality phase-ins.

Past and future phases

• FY2024 (reports published 2025) — Wave 1: NFRD-scope Public Interest Entities >500 employees.
• FY2025 (reports 2026) — originally Wave 2; deferred by Omnibus.
• FY2026 (reports 2027) — originally listed SMEs; deferred and partially descoped.
• FY2027 (reports 2028) — Wave 2: large EU undertakings exceeding two of three thresholds.
• FY2028 (reports 2029) — Listed SMEs reporting under proportionate ESRS LSME.
• FY2029 (reports 2030) — Non-EU parent undertakings with EU activity above thresholds.

How to follow

Primary references are the European Commission's Sustainable Finance pages, the European Financial Reporting Advisory Group (efrag.org) for ESRS standards and Q&As, and the European Securities and Markets Authority (esma.europa.eu) for enforcement convergence. National statutory-audit regulators — France's Haut Conseil du Commissariat aux Comptes, Germany's APAS, Italy's CONSOB and Ireland's IAASA — supervise assurance. Big Four sustainability-reporting trackers (PwC, Deloitte, EY, KPMG), Bloomberg, Reuters, MLex and Responsible Investor publish ongoing analysis. The EU's European Single Access Point (ESAP) launches phased filings collection from mid-2027.

Related countdowns

Wave 2 reporting is part of a wider EU sustainability and disclosure cluster that includes EU CBAM first certificate surrender, the EU AI Act enforcement, the EU AI Act phase 2, and the DMA first review. The 2028 corporate-disclosure cycle also coincides with EU ETS2 launch and the GDPR 10-year review.

FAQ

When is the first Wave 2 CSRD reporting deadline? Early 2028 (between February and April depending on issuer), covering financial year 2027. Where does the obligation apply? Across the European Union, with reports filed alongside FY2027 management reports and made available through national gazettes and the European Single Access Point. Why does Wave 2 matter? It extends mandatory double-materiality sustainability reporting under the European Sustainability Reporting Standards to tens of thousands of additional large EU companies. Who is in scope? EU-domiciled large undertakings exceeding two of the three thresholds (250 employees, EUR 50 million turnover, EUR 25 million balance sheet) as recalibrated by the 2025 Omnibus.