CSRD wave 2: a practical checklist for FY2025 reporters
If your large EU company is in CSRD wave 2, you are reporting on FY2025 data in early 2026. Here is what to lock down now — without waiting for the consultants.
Confirm you are actually in scope
- Wave 2 captures large EU companies meeting two of three thresholds: >250 employees, >€50m turnover, >€25m balance sheet total.
- Recent EU 'Omnibus' simplification proposals may shift thresholds and timelines — check with your auditor and legal team before assuming.
- Even if you slip below threshold, you will still receive customer questionnaires from in-scope customers.
Run a proper double materiality assessment
ESRS 1 and ESRS 2 require both impact materiality (where you affect people and planet) and financial materiality (where ESG topics affect your enterprise value). Document the process — workshops, stakeholder lists, scoring rubric. The auditor will ask to see it.
Lock your organisational and operational boundaries
Decide which legal entities, joint ventures and leased assets are in your reporting boundary. Use the GHG Protocol equity-share or operational-control approach consistently across Scope 1, 2 and 3.
Get Scope 1 and 2 baselined first
- Scope 1 and 2 are usually 80% of effort, 20% of emissions. Get them right and reusable: utility bills, fuel cards, fleet fuel logs, refrigerant top-ups.
- Use both location-based and market-based methods for Scope 2 if you have any green tariffs or PPAs.
Pick the 3-5 Scope 3 categories that actually matter
Do not try to cover all 15 categories in year one. Use a screening (spend-based or industry average) to identify the top categories, then commit to improving primary data over time.
Build the audit trail as you go
Limited assurance under ISAE 3000 needs traceable rows. Capture source documents, calculation methodology and reviewer sign-off at intake — not three months after.
Subscribe for ESG reporting tips
One short email a month: framework updates, deadlines and templates for ESG reporters.
By subscribing you agree to receive occasional emails from 1esg.app. Unsubscribe anytime.