Three overhauls in three years: the dizzying reality of CSRD monitoring
Three overhauls in three years, a deadline that keeps moving, and a text still before the European Parliament. What this changes for those who have to follow the CSRD on a daily basis.
Temps de lecture estimé : X min
This article kicks off the CSRD Summer Workbook I’m publishing every Tuesday this summer. Before diving into the technical standards, I wanted to share what it’s been like to follow this topic daily since day one as an ESG data analyst.
My name is Ahmad Bidawi, and I am an ESG data analyst at Ascend. My job involves, among other things, knowing exactly what the CSRD regulations require, for which companies, and by what date.
In theory, it’s a monitoring role. In practice, for the last three years, it’s been a constant game of catch-up.
A directive that never quite settles in
The CSRD came into force in January 2023. Member states had until July 6, 2024, to transpose it into national law. Most missed this deadline, leading the Commission to launch infringement proceedings against 17 countries in September 2024.
A year later, on February 26, 2025, the Commission proposed the "Stop-the-clock" directive alongside a substantial Omnibus simplification package affecting the CSRD, the Taxonomy, and the CS3D. The Stop-the-clock directive was published on April 16, 2025, delaying implementation by two years for companies not yet subject to the rules and for listed SMEs.
The substantial Omnibus package took another 10 months to stabilize. A provisional agreement between Parliament and the Council was reached on December 9, 2025, followed by Council adoption on February 24, 2026, and entry into force on March 19, 2026. It raised the application thresholds to over 1,000 employees and €450 million in revenue, and pushed back transposition by member states to July 2028.
Three weeks before I wrote this article, on July 3, 2026, the Commission finally adopted the revised and simplified ESRS, with approximately 60% fewer mandatory data points.
This text must still undergo a two-month review by the Council and Parliament, which can be extended once.
As I publish this article, the version of the standards that will apply to the 2027 financial year has not yet been finalized.
What this actually means on a Tuesday morning
Following this file isn't just about reading a text once and applying it. It's about keeping several possible versions of the same requirement up to date in parallel:
- the one currently in force,
- the one proposed by EFRAG,
- the one negotiated by the Council,
- the one that might emerge from parliamentary scrutiny in two to four months.
For a company asking us "what data should I collect this year," the honest answer often starts with "it depends on which version you're using and your application wave."
Five member states had still not transposed the CSRD into their national law by the end of June 2026, despite the December 2025 deadline for the "stop-the-clock" provision.
This means that even the question "which text applies in my country" does not always have a stable answer.
Why I still publish every week
I could wait for everything to stabilize before writing. But the experience of the last three years shows that this stability never quite arrives, and that companies must move forward with the information available.
This summer, I am returning each week to a specific point of the CSRD, trying to clearly state what is settled, what is still under discussion, and what to watch out for, to save you the hours I spent myself untangling it all.