What does this mean in practical terms for the companies concerned?
The most visible changes relate to reporting thresholds and timelines. In practical terms, the CSRD now applies to EU-based companies with more than 1,000 employees and over €450 million in revenue.
For Wave 1 companies those already in scope today, with some exceptions the timeline remains unchanged. For Wave 2 companies all other organisations exceeding 1,000 employees and €450 million in revenue, again with some exceptions the first report will be due in 2028, covering the 2027 financial year.
Companies based outside the EU fall within the scope of the CSRD if they have a European subsidiary generating at least €200 million in EU revenue, and consolidated EU revenue of at least €450 million. For these companies, the first report will be due in 2029, covering the 2028 financial year.
And what about the content of the ESRS? What happens to the 1,200 indicators?
EFRAG has recently proposed a simplified set of ESRS standards, which is expected to be formally validated by mid-2026. In concrete terms, the number of indicators would be reduced from 1,144 to around 450.
Additional simplifications have also been proposed, including a streamlined report structure with a stronger focus on the General Disclosure Requirements. Without going into technical detail, the key takeaway is that the reporting burden under CSRD will be significantly reduced.
Does that mean the CSRD has been stripped of its substance?
Europe has listened to companies’ concerns. The regulation has been simplified, but its core principles remain intact.
What matters most is the usefulness of the regulation. Personally, I am convinced of its value. We need to make CSRD a regulation that delivers real benefits for businesses. If simplification helps achieve that, then it is a positive step.
At Sweep, we support our clients not just to “do reporting,” but to produce reporting that is genuinely useful.
If I am a sustainability leader in a company subject to CSRD, what should I be doing in the coming weeks and months?
My advice is to start as early as possible. The year 2026 should be used as a preparation year. Begin structuring the project now: identify the teams involved, define your needs, determine which data is required and how it will be collected.
This remains a company-wide project that requires real internal coordination and organisation.
Above all, approach this exercise as a way to strengthen your competitiveness. CSRD will help you identify opportunities and mitigate risks through the IRO framework Impacts, Risks, and Opportunities and improve your resilience to risks, including climate-related risks.
In reality, it will help consolidate long-term success in a low-carbon economy. This regulation can truly be a source of value creation for companies.
