When will the sustainability report become mandatory?

The obligation to draft and publish a sustainability report enters into force in different stages. PIEs with more than 500 employees are the first group that are required to report. These undertakings already have a reporting obligation under the Non-Financial Reporting Directive (NFRD) regarding certain sustainability topics, which has been expanded under the CSRD. They will be required to provide a sustainability report on fiscal years beginning on or after 1 January 2024. This means that the first sustainability reports will be made public in early 2025.

Large undertakings and large PIEs follow a year later with a report on the fiscal year that starts on or after 1 January 2025. Undertakings that are part of a group can make use of a reporting exemption under certain conditions.

The reporting obligation for medium- and small-sized listed entities starts for fiscal years starting on or after 1 January 2026, followed by non-EU undertakings with a reporting obligation for fiscal years on or after 1 January 2028. Please find below an overview of the dates of entry into force of the reporting obligation:

Financial years starting on or from
Who?
1 January 2024
Undertakings which currently have to publish a non- financial disclosure in their management report based on the EU Non-Financial Reporting Directive. These are large public interest entities PIEs (banks, insurance companies, listed firms) with more than 500 employees.
1 January 2025
Large undertakings (private limited companies, public limited companies, general partnerships and limited partnerships) with a EU legal form.
1 January 2026
Medium and small listed firms.
1 January 2028
Non-EU undertakings (without EU legal forms; for example originating from the United States or Japan), whereby the reporting requirement applies to the branch/major subsidiary of which the parent is outside the EU, see question 'Which undertakings from outside the EU are obliged to draft a sustainability report?'.
   

For more information, see article 5 of the CSRD and the explanation in the above questions of chapter 3.

More information:


Questions CSRD & ESRS

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