CSRD Deadlines for SMEs

Many small and growing businesses (SMEs) are hearing about the Corporate Sustainability Reporting Directive (CSRD). Most small and growing businesses (SMEs) won’t have to file a CSRD report — but your bank or a large customer may ask for the same data. This timeline shows when those requests are likely to start, so you can prepare early and avoid last-minute pressure.

1. CSRD Timeline for Large Companies

The CSRD is being phased in gradually, starting with large listed and public-interest companies:

• 2024 reporting (published in 2025): Largest listed companies (first mandatory reports published 2025).
• 2025 reporting (published in 2026): Other large companies meeting size thresholds (reports published 2026).
• 2026 reporting (published in 2027): Listed SMEs and certain small financial institutions (reports published 2027); listed SMEs may opt for a two-year deferral.

By 2026–2027, many large companies will be legally required to collect supply chain information — and that’s where SMEs come in.

2. What This Means for SMEs

Most small and growing businesses (SMEs) are not directly required to report under the CSRD. However:

• Banks and large clients will start asking suppliers for data from 2025 onwards, so they can meet their own deadlines.
• Listed SMEs (a minority of SMEs) will be required to report from 2026, though they can opt to delay by two years.
• Voluntary adoption of the Voluntary Sustainability Reporting Standard for SMEs (VSME) is encouraged, so you can provide clear and consistent information when asked.

For example, a local manufacturer might be asked to provide: 12 months of electricity invoices, a count of employees by contract type (permanent/temporary), and basic waste volumes — all data you probably already hold.

3. Key Deadlines at a Glance

• 2024 → Large listed companies start reporting.
• 2025 → Other large companies begin reporting. Expect first wave of data requests to SMEs.
• 2026 → Listed SMEs in scope (with an optional two-year delay). Broader supply chain pressure builds.
• 2027 → Non-listed small and growing businesses (SMEs) may increasingly be asked by banks or customers for VSME-aligned data.

4. How SMEs Can Prepare

You don’t need to produce a full CSRD report. Instead, small and growing businesses (SMEs) should:

1. Check your records today — collect the last 12 months of electricity, gas and fuel invoices.
2. Note workforce numbers — current headcount and hires/leavers over the last year.
3. Talk to your bank or clients — ask whether they will require a VSME Basic Module or a simple spreadsheet.
4. Use VSME Basic Module as a guide — it lists the minimum fields typically requested (energy, waste, workforce, governance). See our CSRD requirements checklist for details.
5. Start simple — two years of consistent, simple data is better than perfect figures for one year.

Key Terms

• Corporate Sustainability Reporting Directive (CSRD) — An EU law that requires large companies — and eventually some medium-sized ones — to report on their environmental and social impacts. Smaller suppliers are not directly in scope but may be asked for CSRD-style data by banks or bigger clients.
• Voluntary Sustainability Reporting Standard for SMEs (VSME) — A simplified framework designed to help SMEs share sustainability information. It is voluntary but can help SMEs respond to client or bank requests.
• Basic Module — The minimum set of sustainability disclosures under the VSME. It covers essential topics such as energy use, greenhouse gas emissions, waste, workforce data, and basic governance issues.
• Comprehensive Module — An extended version of the VSME reporting standard. It includes additional details on strategy, transition plans, and targets. Banks or large clients may request this level of detail.
• European Sustainability Reporting Standards (ESRS) — The detailed reporting rules that apply to large companies under CSRD. The VSME is a simplified, proportionate version for smaller businesses.
• SME (Small and Medium-sized Enterprise) — A business with fewer than 250 employees, a turnover under €50 million, or a balance sheet total under €25 million. Micro-enterprises are even smaller (fewer than 10 employees).
• Scope 1 and Scope 2 emissions — Scope 1 refers to greenhouse gas emissions from sources a company directly controls (like fuel used in company vehicles). Scope 2 refers to emissions from purchased energy (like electricity or heating). SMEs may only need to report these two.
• Turnover — The total income a company earns from its normal business activities, usually measured over one year.

Not sure if CSRD deadlines apply to your company? Use our readiness assessment to understand your timeline and requirements:

This tool will help you determine whether you’re directly in scope or need to prepare for supply chain data requests.