When must I report under the CSRD?

Many companies are reading conflicting headlines: one part of the Omnibus on sustainability reporting has been adopted, another part is still only a proposal, and meanwhile, the Commission has issued a quick‑fix that allows some information to be omitted from this year’s reports.

This article explains, in plain language, what has legally changed as of September 2025, what has not, and what that means for you by company size.

1) The “stop‑the‑clock” Omnibus is adopted

In April 2025, the EU adopted a two‑year delay for Wave 2 and Wave 3 CSRD reporters. What do these waves mean? Which wave does your company fall under? Easy:

Wave 1 are large public‑interest entities (500+ employees) which began reporting this year, in 2025, on 2024’s data. The delay does not apply to them, so they remain in scope and on the original timetable.

Waves 2 and 3 benefit from the two‑year delay. Their start line moves out by two years, 2028 and 2029 respectively (reporting on 2027 and 2028’s data). If the simplification passes, these companies may end up out of scope. Until then, they should use the time to build readiness, test data flows, and monitor the Simplification Omnibus developments.

Something to keep in mind if your company falls under Waves 2 or 3 is that if your suppliers/customers fall under Wave 1, they can still request certain information from you.

Therefore, even if you are confident that the EU will end up adopting the exemption, it is advisable to fix any known data gaps and align governance around supply‑chain topics that can be requested by your partners. In that regard, the VSME (the voluntary sustainability standards for SMEs) can be relevant to your business. You can learn all about them in this article.

2) The “simplification” Omnibus is not adopted (yet)

The Commission has proposed to shrink the CSRD scope to large companies with more than 1,000 employees, which would remove roughly 80% of the companies currently in scope. To learn about the other simplification measures proposed, check this article.

Until it is adopted, the current CSRD scope and timing remain in force for Wave 1, that is, for large public-interest companies over 500 employees.

However, given that it is likely that (even if not to the extent proposed) the scope reduction will be eventually adopted, the Commission is aware that companies between 500 and 1000 employees, which are now in Wave 1 but later might be exempted, are caught in a tricky situation: they must go through with their CSRD reporting investments in a moment of great legal uncertainty.

In light of this “grey zone”:

3) The ESRS “quick‑fix” eases Wave 1’s transition towards full compliance

On 11 July 2025, the Commission adopted a Delegated Act that eases what Wave 1 companies must disclose in their first three reporting years:

However, if you omit an entire standard under these phase‑ins but the topic is considered material for your business, you must still provide summarised information.

This quick‑fix was explicitly designed to avoid forcing Wave 1 companies to report fully in 2025–2026 when there’s a realistic prospect that some may later be out of scope if the simplification is adopted.

Practically, that means that if you are Wave 1 you should not stop reporting. The quick‑fix prevents extra build‑out, but it does not remove the obligation to publish your report. In short, you should be aware of the phase-in provisions and use them to reduce your workload. And most of all, keep watching the proposal if you’re around the 1,000 employee mark.

We hope this article helped clarify your reporting obligations. Feel free to reach out with any questions about your sustainability strategy or disclosures!