The 4 Waves: Who's In (Under Law as of January 2026)
CSRD Calendar 2026-2030 (Publication Year, Calendar-Year Entities)
What to Do with This Calendar (Operational Mode, No Smoke)
4 Key Factors When Choosing a CSRD Solution
5 Benefits of Having a Robust CSRD Solution
Why Dcycle is the Best CSRD Solution
Frequently Asked Questions (FAQs)
The CSRD calendar 2026 to 2030 is not just a compliance timeline—it's a roadmap that defines which companies must report sustainability data, when they need to deliver, and what systems they must build to survive audit scrutiny and regulatory evolution.
This calendar matters because missing your wave means scrambling to build data infrastructure under time pressure, facing audit failures, or discovering gaps in your supply chain reporting when it's too late to fix them cleanly.
The confusion starts with how CSRD frames obligations: the directive sets requirements by financial year, but companies publish reports the following year, typically alongside management reports and annual accounts. This creates a dual-year dynamic—the year of the financial exercise and the year of publication—that trips up even seasoned compliance teams.
Then comes the legal postponement ("stop the clock") adopted in April 2025, which shifts waves 2 and 3 back by two years. This changes everything that happens between 2026 and 2028 and fundamentally alters implementation priorities for thousands of companies.
On top of that, wave definitions rely on accounting thresholds (turnover, assets, employees), consolidation rules, and multi-year consecutiveness tests—not gut feeling. A company with 280 employees might assume it's "large" and panic about 2028 deadlines, only to discover it doesn't meet two of three size criteria and isn't obliged at all.
This guide unpacks the real CSRD calendar 2026-2030, explains who reports when under current law (as of January 2026), and provides operational guidance for building data systems, evidence trails, and control frameworks that won't collapse under assurance pressure.
We're not consultants or auditors. We're a solution for companies that need to collect all their ESG data and distribute it to any use case—NFRD, CSRD, SBTi, EU Taxonomy, ISOs, or whatever else comes next. Our platform centralizes, automates, and delivers traceability so sustainability becomes a strategic lever, not an administrative burden.
Let's break down the calendar, the waves, the practical triggers, and what you need to do now to stay competitive between 2026 and 2030.
Wave 1 includes companies already reporting under NFRD, which in practice means:
Wave 1 companies are already publishing CSRD-compliant reports. Their first CSRD financial year was 2024, with reports published in 2025.
Key 2026 context: The ESRS "quick fix" provides flexibility so wave 1 companies don't have to add new data burdens in 2025 and 2026 compared to 2024, and extends certain transitional reliefs.
Wave 2 covers large companies and large group parent companies that don't fall into wave 1.
The original calendar set the first financial year as 2025, but the "stop the clock" postponement moves this to financial year 2027.
Translation: If your financial year aligns with the calendar year, wave 2's first obligation is for financial year 2027, with publication in 2028.
To qualify as a "large company" under the Accounting Directive, you must exceed at least 2 of 3 thresholds on the closing date, for two consecutive financial years:
Critical trap: Having 260 employees doesn't automatically make you large if you don't hit the other two thresholds. You need 2 of 3, sustained over two years.
Wave 3 includes:
The original calendar set the first financial year as 2026, but the "stop the clock" moves this to financial year 2028.
Translation: If your financial year is calendar-based, wave 3's first obligation is for financial year 2028, with publication in 2029.
Useful note: CSRD itself allowed listed SMEs to opt out of reporting for financial years starting before 1 January 2028. With the "stop the clock", their first obligation now falls in financial year 2028 anyway, so this opt-out becomes moot in most cases.
What is a "listed SME" for CSRD?
It's not just "a small company with shares". It's a company with securities admitted to trading on an EU regulated market and that qualifies as micro, small, or medium-sized under the Accounting Directive. Micro-enterprises are excluded from the listed SME wave.
Wave 4 applies to groups or companies from third countries that:
Wave 4 applies to financial years starting from 1 January 2028, meaning first publication in 2029 (assuming calendar year closing).
Below, we discuss "publication in 202X" assuming a 31 December closing date. If your financial year closes in March, for example, shift the publication year accordingly.
Wave 1 reports (those already obliged).
Key 2026 context: The ESRS "quick fix" provides flexibility for wave 1 companies not to add new data burdens in 2025 and 2026 versus 2024, and extends transitional reliefs.
Operational priority: Consolidate data systems and evidence with an audit mindset, but leverage transitional reliefs for 2025-2026 to close supply chain gaps without breaking internal controls.
Wave 1 continues reporting.
Waves 2 and 3 do not yet enter due to the legal postponement.
Operational priority: If you're wave 2, 2026-2027 is your window to complete double materiality, build data architecture (entities, controls, traceability), and select which ESRS criteria actually apply to you.
Wave 1 continues.
Wave 2 starts for the first time (large companies "rest"), as their obligation shifts to financial years starting from 1/1/2027.
Operational priority: Wave 2 companies must have data systems, controls, and evidence ready for assurance by 2028. This means 2027 is the build year, not a "wait and see" year.
This is the big jump:
Operational priority: If you're wave 3 or 4, don't wait until 2028 to design processes. The burden typically comes from governance, data quality, and supplier dependencies.
Waves 1, 2, 3, and 4 all report in "normal" regime (second year for waves 3 and 4, third year for wave 2).
Operational priority: Industrialization—SLAs for data, quality dashboards, and systematic reduction of uncertainty in high-weight Scope 3 categories.
Many subsidiaries can be exempt if they're included in the consolidated report of the group (EU or non-EU, if equivalence exists), and CSRD creates a relevant transitional regime until January 2030 for certain subgroups with non-EU parent companies.
Translation: If you're a subsidiary, check group consolidation and exemption rules before assuming you report individually.
During the first 3 years of application for a company, if it doesn't have all necessary value chain information, it must explain efforts, reasons, and a plan to complete the data.
This matters hugely for planning 2026-2029 without promising the impossible on Scope 3, procurement, logistics, or product use.
Translation: You won't get penalized for incomplete supplier data in year 1, but you must document the gap and the roadmap to close it.
For reports from third countries published by an EU subsidiary or branch, the directive requires publication (with assurance opinion) within 12 months from the closing date, as articulated by each Member State.
Translation: Non-EU groups in wave 4 need to plan consolidation and assurance through the EU entity well in advance—this effort scales fast.
To ensure compliance beyond CSRD and align with future European directives, companies should also familiarize themselves with emerging sustainable finance frameworks that connect disclosure obligations with investment and funding criteria. These frameworks are rapidly shaping how sustainability performance translates into access to capital and market trust.
CNMV and ICAC have reiterated that Spanish transposition has been delayed and have published criteria to maintain comparability, explicitly signaling the effect of "stop the clock" and the simplification context, including national guidance such as EINF for sustainability reporting in Spain.
Watch out: Potential additional changes 2026-2030 (not current law, but could alter "who"):
In late 2025, there was political agreement on an Omnibus simplification package that, if converted into final text, could reduce scope and change expectations (e.g., focusing CSRD on companies with more than 1,000 employees, eliminating sectoral rules, and transitioning to reasonable assurance).
As of January 2026, this is a point to monitor, not a consolidated obligation for the calendar.
Consolidate your data and evidence system with an audit mindset, but leverage transitional reliefs for 2025-2026 to close value chain gaps without breaking internal controls.
2026-2027 is your build window for double materiality, data architecture (entities, controls, traceability), and ESRS criteria selection that actually applies.
Don't wait until 2028 to design processes. The burden typically comes from governance, data quality, and supplier dependencies.
Review soon if you meet the €150M EU threshold and the subsidiary/branch condition, because the consolidation and assurance effort through the EU entity scales dramatically.
One of the most obvious benefits is resource optimization.
By having a platform that automates the collection, structuring, and distribution of ESG data, we directly reduce time and effort dedicated to manual tasks.
Additionally, we eliminate dependencies on external consultancies or isolated tools, which decreases recurring costs and allows us to allocate those resources to higher-value areas.
Bottom line: When we centralize ESG information in a single solution, we improve operational efficiency and reduce unnecessary expenses.
Each company has a different level of maturity in its ESG strategy. That's why a solid alternative must offer flexibility to adapt to different development phases and organization sizes.
Having a scalable tool allows us to start with the essentials (for example, measuring Carbon Footprint or consolidating social data) and then expand to other frameworks or certifications as business needs evolve.
This way, we ensure the investment remains useful long-term.
In our case, we work with this logic: a living solution, capable of growing with the company and covering any ESG use case it needs to address.
Time is a strategic resource.
That's why one of the biggest advantages of switching to a more advanced solution is the ability to generate ESG reports automatically and in just minutes.
By having all data centralized and traceable, we can generate reports for NFRD, CSRD, SBTi, Taxonomy, or ISOs without duplicating efforts or depending on spreadsheets.
This not only accelerates team work but also increases the reliability and consistency of information presented to auditors, regulators, or investors.
The result: less administrative burden, more agility, and more control over data.
Today, no company operates with a single system. That's why it's fundamental that the ESG tool integrates easily with existing ERPs, CRMs, or internal platforms.
A good alternative must guarantee total interoperability, allowing data to flow without interruptions between different business areas.
This avoids duplications, improves traceability, and facilitates the connection between sustainability, finance, and operations.
Additionally, by working with a cloud infrastructure, implementation is fast, secure, and without the need for complex technical developments.
This way, we ensure that sustainability is managed with the same logic as other key business processes.
Another aspect to consider is clarity in pricing structure. Many ESG platforms work with closed models or unpredictable fees, making it difficult to estimate the real long-term cost of use.
Opting for an alternative with flexible and transparent pricing models allows adjusting the service to the size and needs of each company.
This helps maintain clearer economic control, without hidden costs or billing surprises.
The first step is being very clear about which regulatory frameworks you need to cover and which indicators are truly relevant for your organization.
Not all companies have the same obligations or the same objectives.
You must analyze whether you need to comply with NFRD, CSRD, SBTi, EU Taxonomy, ISOs, or any other standard, and ensure the new solution can easily adapt to each one without requiring additional developments or implementations.
It's also important to define critical ESG KPIs: energy, emissions, resource consumption, diversity, supply chain, or governance.
The clearer this definition, the easier it will be to find a tool that centralizes and translates that data into useful and actionable information.
The success of an ESG solution depends as much on technology as on the people who use it. That's why you must identify which areas will participate in ESG management and how many users will be involved.
It's not just the sustainability team: finance, operations, HR, or procurement also generate relevant information.
An adequate platform must allow collaboration between departments, assign roles, and maintain complete data traceability without duplicating tasks.
Additionally, the more intuitive the tool, the faster its adoption will be and the less time will be lost in training or technical support.
Corporate sustainability must be managed with the same agility as any other business process.
Today, relevant data for ESG management already exists within the company.
It's spread across billing systems, financial tools, CRMs, or ERPs. That's why choosing the platform must guarantee smooth integration with those systems, avoiding manual processes or unnecessary data loads.
A good alternative must be able to extract information directly from original sources, consolidate it automatically, and distribute it to different use cases. This way, we keep data updated and coherent without depending on intermediaries.
Additionally, a connected architecture allows information to flow with agility, eliminating data silos and improving the accuracy of ESG reports.
Beyond the initial price, you must analyze the total cost of ownership (TCO). This includes not only the license or subscription but also implementation time, integrations, training, and maintenance.
A solution that seems economical can become costly if it requires complex configurations or external services to function.
That's why it's worth investing in a cloud platform, modular and ready to use, that allows scaling without hidden costs or technical dependencies.
The key is investing in a tool that not only complies with regulations but also generates efficiency and return in daily operations.
When ESG data is managed correctly, the time and resource savings are tangible.
When choosing between different CSRD solutions, what really makes the difference isn't just functionality, but the ability to offer an integral, flexible solution oriented to the real value of ESG data.
In our case, we're not auditors or consultants, we're a solution designed for companies that want to measure, manage, and communicate their ESG impact simply and efficiently.
Our goal is that each organization can collect all its ESG information and distribute it automatically to different use cases, without complications or manual processes.
We centralize environmental, social, and governance data from any source—ERP, CRM, spreadsheets, or internal systems—and convert them into standardized, traceable metrics ready for official reports.
This way, companies can generate documentation compatible with NFRD, CSRD, SBTi, EU Taxonomy, ISOs, or any other standard, in minutes.
Additionally, our platform is designed to automate and simplify ESG management to the maximum. Everything works in the cloud, without complex installations or the need for technical developments.
In a few clicks, teams can visualize their performance, identify areas for improvement, and prepare reports ready for audits or regulatory reviews.
We firmly believe that sustainability must be a strategic lever for competitiveness, not an administrative process.
That's why our mission is clear: convert ESG data into smarter, more efficient, and more profitable business decisions.
With Dcycle, companies can control their information, reduce costs, automate processes, and guarantee total traceability of their ESG indicators.
In a market where measuring well is the difference between moving forward or falling behind, our proposal is simple: make sustainability work as a real growth engine.
When seeking CSRD solutions, the first thing you must be clear about is what you need to solve and what you expect to obtain from the change.
It's not about finding a similar tool, but identifying a solution that adapts to your company's reality and improves how you manage your ESG data.
You should prioritize three key aspects: automation, traceability, and adaptability. A good platform must collect data automatically, maintain complete traceability of each record, and allow adapting to different regulatory frameworks without complex configurations.
It's also worth ensuring the solution is easy to implement, scalable, and compatible with your internal systems.
This will avoid cost overruns and allow you to start working quickly, maintaining data reliability from day one.
The main advantages are flexibility and functional coverage.
While some tools focus on a sector or specific data type, today there are more complete solutions that cover all ESG aspects: environmental, social, and governance.
These alternatives allow centralizing all information in the same environment, automating reports, reducing manual processes, and facilitating the generation of documentation compatible with NFRD, CSRD, SBTi, EU Taxonomy, or ISOs.
Additionally, many current platforms offer greater transparency in pricing and implementation times, which facilitates planning and project control from the start.
Bottom line: The change isn't just technological, but also strategic—we move from measuring by obligation to managing by value.
To compare different ESG tools objectively, the most advisable is to define measurable criteria before starting.
This allows us to evaluate each solution based on our real needs, without being swayed by marketing or functionalities that don't add value to our business.
We can do it by evaluating four variables:
By comparing with these parameters, the decision becomes more rational and aligned with business objectives.
The important thing isn't having "more data," but that data is useful, reliable, and easy to convert into action.
Before carrying out a migration, it's fundamental to organize and audit existing data. This implies reviewing what information we have, in what format, and what part of it remains relevant or should be updated.
The second step is to define who will be responsible for each type of data within the new platform: emissions, energy consumption, suppliers, governance, etc.
This way, the transition will be faster and without information losses.
We also recommend planning integrations with internal systems (like ERP or CRM) and establishing a progressive adoption calendar. This way, we ensure teams adapt naturally, maintaining day-to-day operability without interruptions.
In our case, we help companies migrate and structure their ESG data without complications, ensuring all information is traced and ready to use from day one.
Because we're not auditors or consultants, we're a solution for companies that seek to automate, centralize, and leverage their ESG data with an integral vision.
Our goal is that each company can manage its non-financial information efficiently, without depending on manual processes or multiple disconnected tools.
We collect all ESG data—environmental, social, and governance—and distribute them automatically in different use cases: NFRD, SBTi, CSRD, Taxonomy, ISOs, or any other regulatory framework. All from a single platform, in the cloud, ready to use, and without installation.
Additionally, we facilitate team collaboration, information sharing, and report generation in minutes.
Traceability is guaranteed and data reliability is total.
Our mission is clear: convert sustainability into a strategic lever for the company. We don't want ESG management to be a burden, but a tool that provides clarity, efficiency, and competitiveness.
If something defines our proposal, it's this: we make measuring, managing, and communicating ESG impact simpler, faster, and more profitable.
The first checkpoint is defining which frameworks or regulations you need to comply with. Not all platforms offer the same coverage or update level against the regulations being implemented in Europe.
You must ensure the tool can adapt to main reference frameworks like NFRD, CSRD, SBTi objectives, EU Taxonomy, or ISO certifications, guaranteeing a solid compliance approach that lets the company meet regulations without duplicating efforts.
Each company may be subject to different requirements, so having a solution capable of distributing ESG data to different formats and reports is fundamental to avoid duplicating efforts.
Additionally, choosing a flexible platform allows you to anticipate regulatory changes, avoiding having to replace the system or resort to external consultancies every time a new legal requirement or reporting standard appears.
ESG management doesn't depend on one person. It involves different areas and teams: finance, operations, procurement, HR, or sustainability.
That's why it's critical to analyze how many users will work with the tool and what level of access or control each one needs.
A good ESG solution must allow defining roles, permissions, and workflows, ensuring that each user can collaborate without compromising data integrity. When information flows in an orderly way, errors are reduced and efficiency increases.
It's also important that the platform is intuitive and accessible for all profiles. We can't depend on a technical department for every update.
The key is that any team member can access, interpret, and update ESG information without friction.
In practice, the success of ESG management depends on how much we can automate repetitive processes.
If we keep depending on spreadsheets or manual updates, the risk of error increases and information loses value over time.
That's why we should look for solutions that automate data collection from original sources and transform them into coherent and traceable metrics. This includes energy, operational, logistical, or financial data, among others.
A solid platform must offer data history, automatic validations, and complete traceability, so that any figure is backed by its origin and context.
That traceability not only provides reliability but also facilitates audits, verifications, or regulatory reviews without additional effort.
The fourth key factor is technological integrations.
In most companies, relevant information for ESG reports already exists within systems like ERP, CRM, billing tools, or internal databases.
A good alternative must be able to connect directly with those sources, avoiding duplications or manual information loads.
The more fluid the connection between systems, the faster and more accurate the generation of ESG reports will be.
Additionally, integration not only improves operational efficiency but also allows maintaining a single work environment, where data is automatically updated and remains aligned with business reality.
Carbon footprint calculation analyzes all emissions generated throughout a product’s life cycle, including raw material extraction, production, transportation, usage, and disposal.
The most recognized methodologies are:
Digital tools like Dcycle simplify the process, providing accurate and actionable insights.
Some strategies require initial investment, but long-term benefits outweigh costs.
Investing in carbon reduction is not just an environmental action, it’s a smart business strategy.