Wave 2 companies — large EU companies meeting two of three criteria (250+ employees, €40M+ turnover, €20M+ assets) — must file their first CSRD report covering financial year 2025 in 2026. If this applies to your company, use this checklist to track readiness.
Phase 1: Governance and Scope (Complete by Q2 2025)
Confirm CSRD Scope
- Confirm the company meets Wave 2 criteria (250+ employees, €40M+ turnover, €20M+ assets — two of three)
- Confirm Wave 2 applies (financial year 2025, report published in 2026)
- Identify whether a parent company consolidates this entity — if so, determine whether the subsidiary is included in the parent's consolidated report
- Identify whether non-EU group companies are affected (Wave 4 from FY 2028)
Governance Setup
- Assign CSRD ownership — identify who is responsible for sustainability reporting (CFO, CSO, ESG lead, or equivalent)
- Brief the board — ensure at least one board-level body has oversight of sustainability reporting
- Brief management — ESRS 2 requires disclosure of management's role in sustainability
- Identify sustainability committee or equivalent governance body
- Create a project plan with timelines for the first report
Phase 2: Double Materiality Assessment (Complete by Q3 2025)
- Document your business model, activities, and value chain (prerequisite for materiality assessment)
- Compile the full ESRS topic list (all 10 topical standards + sector-specific topics)
- Conduct stakeholder mapping — identify affected stakeholders and information users
- Conduct or commission stakeholder engagement for DMA input
- Complete impact assessment for each topic: severity, scale, irremediability, likelihood
- Complete financial materiality assessment for each topic
- Apply materiality thresholds — determine which topics are material
- Document the full DMA process and conclusions
- Get senior management sign-off on materiality conclusions
- Identify which ESRS topical standards apply based on material topics
Phase 3: Data Collection Systems (Implement by Q3 2025)
Environmental Data (if E1 material — almost always)
- Energy consumption tracking implemented by site: electricity, gas, fuel (monthly)
- Renewable energy percentage tracked: on-site generation + PPAs/GOs
- Scope 1 emissions calculation: fleet fuel, generator fuel, refrigerants (annual F-gas inventory)
- Scope 2 emissions: location-based and market-based calculation approach confirmed
- Scope 3 priority categories identified and data collection initiated:
- Category 1 (purchased goods/services): spend data by category
- Category 6 (business travel): flight and accommodation data from expense systems
- Category 7 (employee commuting): methodology and data collection approach
Workforce Data (if S1 material — almost always)
- Headcount tracking by gender, employment type, geography (monthly HR data)
- Training hours per employee tracking
- Gender pay gap calculation capability confirmed
- CEO pay ratio calculation capability confirmed
- Total recordable incident rate (TRIR) tracking
- Collective bargaining coverage percentage
Business Conduct Data (if G1 material — frequently)
- Anti-bribery and anti-corruption policy documented and current
- Legal proceedings tracking (material court cases, regulatory actions)
- Payment practices data (average payment terms, late payment rates)
Phase 4: Policy and Target Development (Q3-Q4 2025)
- Environmental policy reviewed or created
- Climate transition plan drafted (for ESRS E1)
- GHG reduction targets set with base year, target year, percentage reduction
- Energy targets set (renewable energy percentage target)
- Workforce development and diversity targets set
- Supply chain sustainability policy documented
Phase 5: First Report Preparation (Q4 2025 to Q2 2026)
ESRS 2 (All Companies — Mandatory)
- Governance section: board and management sustainability oversight documented
- Strategy section: business model, material topics, how they affect strategy
- IRO management section: policies and actions for each material topic
- Metrics section: quantitative metrics for each material topic
Topical Standards (Apply to Material Topics Only)
- ESRS E1: GHG emissions (Scope 1, 2, 3), energy consumption, transition plan
- ESRS S1: Workforce headcount, pay, H&S, training, diversity metrics
- ESRS G1: Anti-corruption policies, legal proceedings, payment practices
- [Other material topics as applicable — E2-E5, S2-S4]
Phase 6: Assurance and Publication (Q1-Q2 2026)
- Assurance provider engaged — limited assurance required
- Data evidence package prepared for assurance review
- Underlying documentation assembled: utility bills, HR system exports, cloud carbon reports, incident records
- Assurance fieldwork completed
- Assurance report obtained
- ESEF taxonomy tagging completed for quantitative disclosures
- Report integrated into management report
- Published and filed with competent authority
Ongoing Obligations After First Report
- Annual reporting cycle established (same process each year)
- Materiality assessment reviewed annually (or when business model changes significantly)
- Data collection systems maintained and improved
- Assurance provider relationship maintained
- Regulatory guidance monitored (EFRAG issues guidance notes; member states may add requirements)