A plan, not a countdown
Eight moves, each tied to an article.
The plan starts with the scope answer and the national option, because those decide everything else. It puts the value chain cap and the omission register before the assurance conversation, because they change what the auditor can test. It keeps the due diligence plan separate, because its dates are a year later.
| When | Move | What it involves | Provision | Evidence to keep |
|---|---|---|---|---|
| Now | Settle the scope, year by year | Write the entity, the financial year start, the turnover, the average headcount and the public-interest status into one memo. Record the source of each figure and the year-by-year answer. Do not collapse the transition into one date. | Article 5(2) of the CSRD as amended; Article 19a(1) and 29a(1) | A scope memo with a row per financial year. |
| Within 30 days | Check the national option | Ask the national authority or read the transposing measure. The 2025-2026 exemption and the financial holding option depend on it. Record the answer, the date and the text you read. | Article 3; Article 2(5)(d) | The national measure, dated, with the option recorded. |
| Within 45 days | Rewrite the value chain request | Mark every item that exceeds the voluntary standards, add the right to decline, and remove any contract clause that demands more. Ask each supplier for a self-declaration of average headcount. | Article 19a(3) and 29a(3) as amended; Article 29ca | A request template and a file of self-declarations. |
| Within 60 days | Open the omission register | Record each withheld item, the ground, the alternative disclosure considered and the reassessment date. The commercial-prejudice route has four conditions; the other routes have two. | Article 19a(3), fourth subparagraph, as amended | An omission register approved by the board. |
| Within 75 days | Agree the assurance scope | Agree in writing that the limited assurance opinion covers the ESRS, the process, the mark-up and the Article 8 disclosures. Show how a protected supplier right to decline was respected. | Article 34(1)(aa) and 34(2a) as amended | An engagement letter and a scope note. |
| By 19 March 2027 | Put the transposition date on the board calendar | The date is for the Member State. The company action is to be ready for the financial year that starts on or after 1 January 2027. Record the national measure and the first reporting year separately. | Article 5(1) | A board minute with both dates. |
| First reporting year | File and assure the statement | Prepare the statement, the Taxonomy disclosures and the mark-up in the electronic format once the tagging rules exist. Keep the value chain explanation for the first three years. | Article 19a; Article 29d; Article 34 | The published statement and the assurance report. |
| 26 July 2028 | Separate the due diligence plan | The CSDDD changes are transposed later and apply from 26 July 2029. Test the CSDDD threshold separately and do not put its dates on the reporting statement plan. | Article 4; Article 37 of Directive (EU) 2024/1760 as amended | A second plan with its own owner and dates. |
What the kit adds
The free plan is the sequence. The USD 799 kit carries the same moves in a working register with an owner, a due date and an evidence pointer on every duty, plus the board pack and the CSV and XLSX versions. See the kit.
Not legal advice; does not certify. The plan records the dates in the directive; the national transposition measure controls the route.