CSRD in the Netherlands: Timeline & Requirements

Where does Dutch CSRD transposition stand?

The Dutch government chose to implement the CSRD through two instruments. An implementing bill (Wet tot implementatie richtlijn duurzaamheidsrapportering) covers assurance rules and CSRD applicability to listed companies and other public interest entities. A governmental decree (Implementatiebesluit richtlijn duurzaamheidsrapportering) covers disclosure requirements, the assurance statement, audit committee obligations, and implementation timelines. As of March 2026, neither instrument had been finalised.

Parliament received the implementing bill on 13 January 2025, roughly six months after the EU transposition deadline. The Council of State (Raad van State) had already issued its advisory opinion on 28 August 2024, giving the bill a clean pass. But progress stalled in the Tweede Kamer. Members of the Senate exercised their right to submit written questions on the draft implementing decree in February 2025, and the answers fed into a second consultation round that dragged through the spring.

Then the political situation collapsed entirely. In early June 2025, Wilders exited the coalition and the Dutch government fell. Climate and sustainability policy became uncertain again, and CSRD transposition was not a priority for the caretaker government.

At EU level, the Netherlands pushed for the Stop-the-Clock Directive to also cover Wave 1 companies. The rationale was pragmatic: national law hadn’t been transposed, so requiring Wave 1 companies to report under a directive that didn’t yet exist in Dutch statute created a paradox. The European Commission declined.

Where this leaves firms in practice is messy. Wave 1 companies (large PIEs with 500+ employees) were expected to include CSRD-compliant sustainability reports in their FY2024 annual reports, and most large listed Dutch companies did exactly that, following the AFM’s December 2024 guidance. But no enforceable Dutch legal basis existed at the time those reports were published. The implementing bill must still pass both chambers of parliament before CSRD reporting obligations become enforceable under Dutch law.

One area of clarity: the draft implementing decree confirmed that the Netherlands will not gold-plate CSRD requirements. No additional national requirements beyond the EU minimum. Dutch cooperatives fall outside scope unless they qualify as banks or insurance companies, and pension funds are included only if they meet the large-company size criteria. DNB, public development banks, and credit unions are explicitly exempted.

A specific provision worth noting for audit firms with cross-border clients: if a subsidiary’s data are included in the consolidated management report or sustainability report of its parent company, that subsidiary can be exempt from individual reporting. The parent company must disclose which subsidiaries are included in the consolidation and which are exempt. Alternatively, a company can prepare what the decree calls “artificial consolidation”: a combined sustainability report for all EU subsidiaries in scope, without it being a formal group report. If one subsidiary in the group prepares this combined report (typically the one with the largest EEA turnover in the preceding five years), all included subsidiaries are exempt from their own standalone reporting.

The revised CSRD timeline after Stop-the-Clock

The Stop-the-Clock Directive entered into force on 17 April 2025 after an overwhelming European Parliament vote on 3 April (531 in favour, 69 against). It postpones by two years the CSRD reporting requirements for companies that hadn’t yet started reporting. EU member states were required to transpose it by 31 December 2025.

Below is the revised timeline for Dutch companies, incorporating both the Stop-the-Clock Directive and the Omnibus I provisional agreement of December 2025.

Wave 1 (large PIEs, 500+ employees under the original CSRD): Required to report for FY2024, with first reports due in 2025. Stop-the-Clock did not change this. However, the Omnibus I provisional agreement introduces a member state option: companies that fall out of the revised scope (those with 501 to 1,000 employees, or those not meeting the €450 million turnover threshold) can be exempted from reporting for FY2025 and FY2026. Those that remain in scope must continue reporting.

Wave 2 (other large companies, including non-listed large entities): Originally FY2025, now postponed to FY2027 (first reports due in 2028). This is by far the largest affected group in the Netherlands. For SRA member firms with mid-market audit clients, Wave 2 is the wave that matters, and it just moved two years out.

Wave 3 (listed SMEs, small and non-complex credit institutions, captive insurers): Originally FY2026, now postponed to FY2028 (first reports in 2029). Under the Omnibus I agreement, listed SMEs are removed from scope entirely, which means this wave effectively disappears for most entities that would have been captured.

Wave 4 (non-EU companies with substantial EU activity): Unchanged. FY2028 reporting, first reports in 2029. Under the revised scope, the non-EU parent must generate €450 million in EU net turnover, with the EU subsidiary or branch exceeding €200 million net turnover.

For mid-market Dutch firms, the headline is this: many companies that expected to start CSRD reporting for FY2025 now have until FY2027, and a significant number will fall out of scope entirely once the Omnibus I thresholds are formally adopted.

How significant? The European Commission estimates roughly 80% of companies originally in scope will no longer be required to report. To put that in Dutch market terms: a manufacturer with 400 employees and €80 million turnover was firmly within the original two-out-of-three test. Under the revised thresholds, it doesn’t come close. Audit teams that spent 2024 running ESRS gap analyses for these clients should flag the scope change in their next planning meeting.

But there’s a wrinkle. Many of those companies sit in the value chains of larger entities that remain in scope. Even if they’re not required to report under CSRD, they may receive information requests from customers, lenders, and investors who need their sustainability data for their own reporting. The Omnibus I “protected undertaking” concept limits the scope of those requests, but it doesn’t eliminate them entirely. Companies that fall out of mandatory scope may still find themselves spending time on sustainability data collection, just less of it, and with the legal right to refuse anything beyond the voluntary standard.

What the Omnibus I agreement changes for scope

On 9 December 2025, the Council Presidency and European Parliament negotiators reached a provisional agreement that rewrites the CSRD’s scope criteria. The original directive used a two-out-of-three test: more than 250 employees, €50 million net turnover, or €25 million balance sheet total. Omnibus I replaces this with a dual cumulative test: both 1,000+ employees and €450 million+ net turnover.

Both thresholds must be met. Not either. Both.

This is a structural reduction, not a temporary delay. Listed SMEs are removed from scope entirely. Financial holding companies (those not involved in day-to-day management of subsidiaries) are excluded. And the subsidiary exemption has been broadened: large listed subsidiaries can now opt out of standalone reporting if they’re included in their parent’s consolidated CSRD report. Previously, large listed subsidiaries couldn’t use this exemption.

For Dutch audit firms that serve mid-market clients, the practical effect is substantial. Consider a Dutch manufacturing group with 800 employees and €300 million turnover. Under the original CSRD, firmly in scope. Under the revised thresholds, out. All the double materiality assessment work, ESRS gap analysis, and data collection that company invested in during 2024 and 2025 may no longer be required for mandatory reporting.

The value chain also changes. Omnibus I introduces the concept of a “protected undertaking”: any company with 1,000 or fewer employees that sits in the value chain of a CSRD-reporting entity can refuse information requests that go beyond voluntary reporting standards. Reporting companies cannot contractually override this right, and any contractual provisions that attempt to do so are not binding. For mid-market Dutch suppliers to large multinationals, this caps the trickle-down reporting pressure that many businesses feared.

On the reporting standards themselves, EFRAG was tasked with drafting simplified ESRS by October 2025. Revised exposure drafts were published on 31 July 2025, with final technical advice submitted in December 2025. The simplified standards reduce mandatory data points by approximately 70% compared to the original ESRS Set 1. Adoption by the European Commission is expected in time for FY2027 reporting.

Two more structural changes matter for engagement planning. First, the Omnibus I agreement removes the future obligation to obtain reasonable assurance on sustainability reports. Limited assurance is now the permanent standard, which changes how you scope and price engagements. Second, sector-specific ESRS have been abolished entirely, replaced by non-binding sector-specific guidelines that the Commission may (or may not) issue.

The Omnibus I agreement also includes a review clause. By 26 July 2031, the Commission must assess whether the CSRD’s scope should be expanded again, weighing the need for sustainability data to mobilise private investment against the impact of reporting on EU competitiveness. In other words, the current scope reduction may not be permanent. But for planning purposes over the next five years, the 1,000-employee and €450 million thresholds are the operative numbers.

What the AFM expects from Wave 1 reporters

The Autoriteit Financiële Markten published guidance in December 2024 strongly encouraging Wave 1 companies to publish CSRD-compliant sustainability reports for FY2024, despite the absence of Dutch transposing legislation.

Don’t wait for national law. That was the AFM’s position.

Eumedion reinforced this message in its October 2024 Focus Letter. As the Dutch investor association representing institutional investors, Eumedion called on Wave 1 companies to submit their CSRD sustainability reports to an advisory shareholder vote. Eumedion’s argument was that sustainability information had reached a status comparable to financial information and should receive equivalent board accountability. Most large listed companies followed both recommendations.

For auditors engaged on Wave 1 files, the implementing bill contains a transitional provision addressing the appointment gap. When a company was required to prepare a sustainability report for FY2024 and the annual general meeting had been convened before the implementation act entered into force, the statutory auditor of the financial statements is deemed to have been appointed as the auditor of the sustainability report. This legal fiction solves a real problem: companies publishing assured sustainability reports without having formally appointed an assurance provider under a law that didn’t yet exist.

This temporary arrangement was extended by one additional year. For FY2025, the supervisory board can grant the assurance engagement if the general meeting hasn’t done so. Standard appointment procedures resume from FY2026: general meeting appoints, supervisory board as fallback.

In practice, most Wave 1 companies appointed their existing statutory auditor for sustainability assurance, which made sense operationally. The statutory auditor already understands the business, has access to the financial data that overlaps with ESRS disclosures (particularly ESRS E1 climate and ESRS S1 own workforce), and has an existing relationship with the audit committee. Appointing a separate sustainability auditor introduces coordination overhead that few companies wanted to absorb in the first reporting year.

Assurance requirements under the Dutch implementation

Limited assurance from year one. That’s the baseline in the Dutch implementing bill, consistent with the CSRD requirement. The sustainability report forms part of the management report (bestuursverslag), and the auditor issues a separate assurance opinion on sustainability reporting alongside the statutory audit opinion on the financial statements.

Who can provide this assurance? Under the implementing decree, only registered accountants (RA or AA with appropriate registration). The decree does not exercise the member state option to allow independent assurance services providers (IASPs) other than statutory auditors. Several other EU member states are considering opening the market to non-auditor providers, but the Netherlands has deferred the decision.

For audit firms, the fee structure matters. The amended EU Audit Regulation (Article 4(2), subparagraph 2) exempts sustainability report assurance fees from the statutory audit fee cap. This exemption applies to all financial years beginning on or after 1 January 2024, regardless of whether the CSRD has been transposed into national law. But consulting fees related to CSRD implementation support are not covered. Those remain subject to independence requirements and the fee cap. Your engagement letter should separate these components explicitly.

A question that smaller firms should consider: if sustainability assurance is reserved for statutory auditors and the training pipeline is limited, will there be enough capacity in the market? With Wave 2 reporting now delayed to FY2027, Dutch audit firms have additional time to build sustainability assurance competence. But waiting until 2027 to start is waiting too long. Clients in the CSRD/ESRS compliance checker scope will expect their auditor to be ready.

The assurance standard itself is still evolving. The IAASB finalised ISSA 5000 (International Standard on Sustainability Assurance) in 2024, but the EU has not yet formally adopted it. Dutch practitioners currently lack a definitive EU assurance standard to anchor their engagement methodology. In the interim, the NBA (Koninklijke Nederlandse Beroepsorganisatie van Accountants) and audit firm methodologies based on ISAE 3000 (Revised) will fill the gap. Once the EU adopts an assurance standard, Dutch firms will need to align.

For engagement planning, one practical implication deserves attention: CSRD assurance covers the entire sustainability report within the management report, not individual ESRS data points in isolation. The auditor forms a conclusion on the sustainability report as a whole. If the client’s double materiality assessment is flawed (for example, omitting a material topic), the assurance conclusion is affected even if every disclosed data point is accurate. Auditors should evaluate the DMA process at planning stage, not as an afterthought during fieldwork.

Worked example: assessing CSRD applicability for a Dutch holding company

Client scenario: Van der Berg Holding N.V. is a Dutch holding company listed on Euronext Amsterdam. It consolidates four operating subsidiaries across the Netherlands and Belgium. For FY2025, the group reported €380 million net turnover, €210 million balance sheet total, and an average of 870 employees.

Step 1: Determine the original CSRD wave

Van der Berg Holding N.V. is listed and qualifies as a large public interest entity. Under the original CSRD, Wave 1 applies if the entity had more than 500 employees. With 870, it qualifies.

Step 2: Apply the Stop-the-Clock Directive

Stop-the-Clock does not postpone Wave 1 reporting. Van der Berg Holding was required to report for FY2024 and continues to face a reporting obligation for FY2025 under the current CSRD text. No relief from this instrument.

Step 3: Apply the Omnibus I scope revision

Under the provisional agreement, CSRD scope requires both 1,000+ employees and €450 million+ net turnover. Van der Berg Holding has 870 employees and €380 million turnover. It misses both thresholds. Under the revised CSRD, this entity falls out of scope.

Step 4: Assess the transitional position

Until Omnibus I is formally adopted and transposed into Dutch law, Van der Berg Holding remains technically subject to the current CSRD scope. If the Netherlands exercises its member state option, the company would be exempt for FY2025 and FY2026. Recommend that the client continue preparing for CSRD reporting until legal certainty exists, while flagging the likely scope exit in the planning memo.

Step 5: Evaluate subsidiary implications

Van der Berg Holding has four subsidiaries. Even if the holding company exits scope, each subsidiary’s CSRD obligations depend on whether it independently meets the revised thresholds. Subsidiaries included in a parent’s consolidated CSRD report are generally exempt from standalone reporting, but if the parent stops reporting, that exemption disappears.

Conclusion: Van der Berg Holding N.V. is currently in scope as a Wave 1 company but will fall out once the Omnibus I thresholds are formally adopted. Document both the current legal position and the expected future position.

Practical checklist for Dutch CSRD engagements

1. Confirm the entity’s CSRD wave classification using the original scope criteria (listed PIE with 500+ employees = Wave 1; other large company = Wave 2; listed SME = Wave 3). Record the classification and the specific size criteria in the planning memorandum.
2. Apply the revised Omnibus I thresholds: both 1,000+ employees on average during the financial year and €450 million+ net annual turnover. If the entity meets only one or neither, document the expected scope exit and set a monitoring trigger for when the directive is formally adopted.
3. Check Dutch CSRD transposition status. As of March 2026, neither the implementing bill nor the implementing decree had been finalised. Track progress through the Eerste Kamer and the Staatsblad for publication of the final text.
4. For Wave 1 clients reporting on FY2024 or FY2025, confirm sustainability auditor appointment under the transitional provision. If the statutory auditor has been deemed appointed by operation of law, document this in both the engagement letter and planning file.
5. Assess whether the client is a “protected undertaking” in any value chain context (1,000 or fewer employees, in the value chain of a CSRD-reporting company). Advise on the right to refuse information requests exceeding voluntary standards.
6. Review the client’s double materiality assessment against the simplified ESRS. With a 70% reduction in mandatory data points, an initial DMA performed under the original ESRS Set 1 may cover topics that are no longer required. Determine whether the material topics need narrowing, and document the rationale in the engagement file.

Common mistakes on Dutch CSRD engagements

• Assuming that the Stop-the-Clock Directive postpones all CSRD reporting. It does not. Wave 1 companies (large PIEs with 500+ employees) received no delay under the directive. The AFM’s December 2024 guidance made clear that these companies should report for FY2024 regardless of whether national law had been transposed.
• Treating the Omnibus I scope revision as final before it enters into force. The provisional agreement of 9 December 2025 still requires formal Council adoption, which had not occurred as of March 2026. Until the revised directive is published in the Official Journal and transposed into Dutch law, the current CSRD scope remains the legal baseline. Planning on the assumption that the revised thresholds are already binding creates audit risk.

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Frequently asked questions

Further reading and source references

• CSRD (Directive 2022/2464): the Corporate Sustainability Reporting Directive, as amended by the Stop-the-Clock Directive and Omnibus I.
• AFM guidance (December 2024): strongly encouraging Wave 1 companies to publish CSRD-compliant reports for FY2024.
• Stop-the-Clock Directive (Directive (EU) 2025/794): postponing Waves 2 and 3 by two years.
• Omnibus I (Directive (EU) 2026/470, published 26 February 2026): revised CSRD scope thresholds, removal of reasonable assurance, and simplified ESRS.