Policy Briefing — CSRD second-wave large-company filings lock for FY 2025 reports
From financial years starting 1 January 2025, all remaining large EU undertakings must publish CSRD-aligned sustainability statements, making March 2026 the deadline window to finalise FY 2025 double materiality, ESRS metrics, and limited assurance packs before annual reports are filed.
Executive briefing: Directive (EU) 2022/2464 (CSRD) Article 5(2)(b) requires large EU undertakings not previously in scope to report under the European Sustainability Reporting Standards (ESRS) for financial years starting on or after 1 January 2025. Most calendar-year filers deliver FY 2025 management reports by March 2026, forcing controllers to validate double materiality conclusions, value-chain data, and assurance evidence under compressed timelines.
Mandatory deliverables
- ESRS disclosures. Articles 19a and 29a of Directive 2013/34/EU, as amended, require narrative and quantitative disclosures across ESRS environmental, social, and governance topics.
- Limited assurance. Article 26 obliges statutory auditors or assurance providers to issue limited assurance opinions over the sustainability statement, demanding documented controls and evidence trails.
- Digital tagging. Article 29d mandates XBRL tagging aligned to the ESRS taxonomy within the European Single Electronic Format (ESEF).
Program actions
- Data sourcing. Reconcile climate, workforce, and supply-chain metrics with finance systems, ensuring traceability to source registries and vendor attestations.
- Materiality governance. Document board reviews of double materiality determinations, including reassessments triggered by 2025 risk updates.
- Assurance readiness. Align internal audit, sustainability, and finance walkthroughs to satisfy ISA 3000 (Revised) evidence expectations before external assurance commences.
Enablement moves
- Deploy ESRS tagging pilots in staging environments to validate taxonomy coverage, extension use, and automated validation checks.
- Integrate supply-chain questionnaires and contract clauses that capture required value-chain metrics for ESRS S2 and E1 disclosures.