CSRD Deadlines by Country: Updated for 2026 Omnibus Changes

Wave 1 (large listed companies) already filed first reports in 2025 for FY 2024. Wave 2 (other large EU companies) now reports for FY 2027, published 2028 — delayed two years by the Omnibus Stop-the-Clock Regulation (EU) 2025/780. Wave 3 (listed SMEs) reports for FY 2028, published 2029. Non-listed small and growing businesses (SMEs) are not directly in scope but face buyer questionnaires now regardless of the delays.

The deadlines are identical across EU Member States — what varies is enforcement pace, buyer behaviour, and national support. This guide covers the practical differences across France, the Netherlands, Germany, Denmark, Sweden, and Poland — the markets where suppliers most often receive CSRD data requests.

For a broader SME-focused overview, see CSRD Deadlines for SMEs.

What Changed: The 2025 Omnibus Stop-the-Clock

In early 2025, the European Commission published the Omnibus Simplification Package, which proposed significant changes to CSRD scope and timelines. The Stop-the-Clock Regulation (EU) 2025/780 entered into force on 17 April 2025 and formally delayed reporting for Wave 2 and Wave 3 companies by two years.

This was not a cancellation of CSRD — it was a practical adjustment to give companies and Member States more time to implement the rules correctly. The direction of travel remains unchanged.

1. EU-Wide CSRD Deadlines Table (Updated 2026)

Previous timelines (before Omnibus): Wave 2 was FY 2025 (published 2026); Wave 3 was FY 2026 (published 2027). Both have been pushed back by two years under Regulation (EU) 2025/780.

2. What Each Wave Means in Practice

Wave 1 — Reports due 2025 (already underway)

Large public-interest entities — major banks, listed companies, and insurance groups that already reported under NFRD — submitted their first CSRD-aligned reports in 2025 for FY 2024. Many are now in their second cycle. Suppliers to Wave 1 companies are already receiving detailed data requests.

Wave 2 — Reports due 2028 (delayed from 2026)

All other large EU companies now report for FY 2027, with first reports published in 2028. This is the wave that generates the most supplier data requests, because these companies must disclose value-chain information under ESRS. The two-year delay does not stop data collection — it is already under way.

Wave 3 — Reports due 2029 (delayed from 2027)

Listed SMEs (except micro-undertakings) must now report for FY 2028. They may still voluntarily opt out further, depending on national implementation. Many listed SMEs are using the extra time to build internal systems and run trial reports using the VSME Basic vs Comprehensive Module as a starting framework.

Wave 4 — Reports due 2029 (unchanged)

Non-EU parent companies with €150m or more in EU net turnover and at least one EU subsidiary or branch are still required to report for FY 2028, published in 2029. This includes large US, UK, and Asian multinationals with significant European operations.

3. Country-Specific Nuances

CSRD is an EU Directive, meaning Member States must transpose the rules into national law. The reporting deadlines do not change by country — but enforcement expectations, national support programmes, and the pace at which large buyers request supplier data vary considerably.

France (FR)

France transposed the Omnibus Stop-the-Clock delay via Law no. 2025-391 (DDADUE 2025), formally postponing Wave 2 reporting to FY 2027 (published 2028) and listed SMEs to FY 2028 (published 2029).

Despite the delay, French large companies tend to move fast. France has a long tradition of sustainability reporting through Grenelle II and the Duty of Vigilance law, and regulators expect high data quality from suppliers early. French buyers frequently issue detailed questionnaires to suppliers well ahead of their own reporting deadlines.

For a full France-specific guide, see CSRD Reporting France.

Netherlands (NL)

The Dutch financial sector adopted climate and ESG reporting early, and that culture flows through to buyer behaviour. SMEs supplying Dutch companies often receive highly structured supplier templates aligned to ESRS — even before they are legally required to respond.

Dutch buyers commonly request value-chain emissions (Scope 3) data and workforce indicators as part of procurement processes. The extra time created by the Omnibus delay has generally been used by Dutch corporates to improve their data collection infrastructure, not to slow down.

Germany (DE)

Germany’s CSRD implementation sits alongside the German Supply Chain Act (LkSG), which already requires large companies to manage human rights and environmental risks in their supply chains. This creates a dual layer of data requests for German suppliers.

German buyers typically require both environmental data (energy, emissions, waste) and workforce and human-rights indicators, even from small suppliers. German audit expectations are also high — limited assurance for Wave 2 reports is expected to be taken seriously from the outset.

Denmark (DK)

Denmark has some of the most sustainability-engaged businesses in Europe. Many Danish corporates already report Scope 3 in detail and have adopted best-practice ESG reporting ahead of regulatory requirements.

Suppliers to Danish companies can expect comprehensive questionnaires early in the reporting year, often mirroring the full ESRS structure rather than simplified supplier formats. The delayed deadlines have been used by Danish buyers to strengthen their value-chain data systems.

Sweden (SE)

Swedish regulators and financial institutions are early adopters of ESG transparency. Banks integrate sustainability risk deeply into lending and investment decisions, creating strong market pressure even where legal obligations do not yet apply. For country-specific guidance, see CSRD Reporting Sweden: Guide for Swedish SMEs.

Swedish buyers frequently request evidence-based emissions estimates with clear methodology — not just rough figures. SMEs supplying Swedish firms should expect to explain how they calculated their numbers, not just report them. For guidance on selecting the right calculation approach, see Estimate Missing Data for CSRD Reporting.

Poland (PL)

Poland feels CSRD pressure primarily through cross-border procurement rather than domestic regulation. Manufacturing, automotive, and electronics sectors — all major Polish export industries — are deeply embedded in supply chains led by German and Dutch corporates now in their CSRD reporting cycles.

Polish SMEs often receive data requests from buyers who are themselves Wave 1 or Wave 2 reporters. Aligning early with ESRS-compatible data formats protects export relationships and positions businesses competitively.

4. What SMEs in the Supply Chain Need to Know

Even when your business is not required to report under CSRD, you are likely supporting companies that are. ESRS explicitly requires large companies to disclose:

• Value-chain GHG emissions (Scope 3)
• Workforce indicators across the supply chain
• Environmental impacts from purchased goods and services
• Risks and dependencies linked to suppliers

This is why supplier data requests have increased significantly since 2025. The Omnibus delay does not reduce these requests — Wave 1 and Wave 2 companies are actively collecting supplier data right now.

The most practical response is to prepare a single, reusable sustainability dataset covering energy use, workforce headcount, waste volumes, and basic governance information. This avoids completing dozens of different questionnaires each year.

To understand how to handle these requests, see How SMEs Can Handle Sustainability Data Requests from Large Clients.

5. One Thing to Do This Year

If your business is not yet required to report formally, the single most valuable action is to create a basic annual sustainability file with your core numbers:

• Electricity use (kWh or MWh)
• Fuel use (litres or MWh)
• Waste volumes (by type: hazardous, non-hazardous, recycled)
• Water withdrawal (m³)
• Workforce headcount (by contract type, gender, and location)
• Any environmental or social initiatives already in place

These are the data points that almost every CSRD-reporting buyer will ask for. Keeping them in a single, consistent format year-on-year reduces admin and makes supplier questionnaires straightforward to answer.

Frequently Asked Questions

Did the Omnibus regulation cancel CSRD?

No. The Omnibus Stop-the-Clock regulation delayed Wave 2 and Wave 3 reporting timelines by two years — it did not cancel CSRD or remove the requirement to report. Wave 1 companies have already filed reports. Wave 2 and Wave 3 companies are using the extra time to improve their systems, and supplier data requests continue. See CSRD Deadlines for SMEs for a detailed breakdown of how timelines apply to smaller businesses.

Do CSRD deadlines differ between EU countries?

The legal deadlines are the same across all EU Member States. The Omnibus delay applies equally across the EU. What differs is enforcement expectation, the pace of supplier data requests, and the quality of national support programmes. French, German, and Dutch buyers typically move faster than the minimum deadlines require.

When will SMEs feel the most pressure from clients?

Most SMEs are already feeling pressure from Wave 1 and early Wave 2 reporters who are actively collecting supply-chain data. This pressure will increase as more Wave 2 companies finalise their ESRS reporting scope in 2026 and 2027. The Omnibus delay buys time for formal reporting — not for avoiding data requests. See How SMEs Can Handle Sustainability Data Requests from Large Clients.

Do non-listed SMEs need to report under CSRD at all?

Non-listed SMEs are not required to report under CSRD. Listed SMEs (except micro-undertakings) were originally scheduled for Wave 3 in 2027, but this has been delayed to 2029 under the Omnibus. Many non-listed SMEs choose to produce a voluntary VSME report to satisfy client, bank, and investor requests without going through full ESRS compliance.

Key Terms

• CSRD — EU sustainability reporting law applying to large and listed companies (Directive 2022/2464/EU).
• Omnibus Simplification Package — European Commission proposal (2025) that included the Stop-the-Clock regulation delaying Wave 2 and Wave 3 by two years.
• Stop-the-Clock Regulation — Regulation (EU) 2025/780, in force from April 2025, formally delaying CSRD timelines.
• ESRS — European Sustainability Reporting Standards defining what companies must disclose under CSRD.
• VSME — Voluntary Sustainability Reporting Standard for SMEs, aligned with ESRS but proportionate for smaller organisations.
• Scope 3 — Value-chain emissions including those from suppliers and customers.
• Wave 1–4 — Implementation phases under CSRD, running from FY 2024 to FY 2028.

Conclusion and Next Steps

The Omnibus Stop-the-Clock delay has given Wave 2 and Wave 3 companies more time — but it has not paused the practical impact on suppliers. If your business is in a supply chain led by a French, Dutch, German, Danish, Swedish, or Polish corporate, data requests are already arriving.

The most effective response is a consistent, reusable sustainability dataset that satisfies multiple clients without duplicating effort. The VSME Basic Module provides a practical framework for doing exactly that.

With a clear structure and consistent effort, CSRD can become a competitive advantage rather than an obstacle.