CSRD applies in waves. Wave 1 (large listed EU companies and large PIEs) reported first on FY2024 data in 2025. Wave 2 (other large EU companies) was originally scheduled for FY2025 reports in 2026 but has been deferred to FY2027 under the 2025 Omnibus I proposal. Listed SMEs (Wave 3) and non-EU parents with EU presence follow in later years. Timelines are currently under revision — check the latest EFRAG updates.
What is double materiality?
Double materiality is the ESRS principle that companies must assess both (i) impact materiality — how the company affects people and the environment, and (ii) financial materiality — how sustainability matters affect the company's financial performance. A topic is material if it is material under either perspective.
How many ESRS datapoints are there?
The full set of ESRS (ESRS 1, ESRS 2, and the ten topical standards E1–E5, S1–S4, G1) contains roughly 1,100 datapoints. The proportion that is mandatory, phased-in, or voluntary depends on the result of the double materiality assessment and the 2025 Omnibus simplification amendments.
What is the Omnibus I proposal?
The Omnibus I simplification package proposed by the European Commission in 2025 reduces the scope and number of datapoints, delays reporting timelines by two years for Waves 2 and 3, and revises value-chain reporting requirements. Several provisions are still under legislative review and subject to change.
In what format do ESRS disclosures have to be filed?
ESRS disclosures must be published as part of the management report, in Inline XBRL (iXBRL) format tagged against the ESRS XBRL taxonomy. Formist produces an XBRL-JSON datapoint file that can be used to validate the tagged report before filing.
Do non-EU companies need to comply?
Non-EU groups with significant EU presence (more than EUR 450 million net turnover in the EU for two consecutive years, plus an EU subsidiary or branch meeting thresholds) fall under CSRD for FY2028 reports (as revised by Omnibus). Many also report voluntarily to meet investor and customer expectations.