CSRD Reporting Belgium: Guide for Belgian SMEs

Introduction

Belgium is home to over 1.2 million SMEs, most of which will soon feel the impact of the Corporate Sustainability Reporting Directive (CSRD) — even if they’re not directly required to report.

From 2025 onward, thousands of Belgian companies will need to collect and share sustainability information with clients, banks, and auditors. Others will adopt the Voluntary SME (VSME) Standard, a simplified reporting framework designed by EFRAG to make sustainability reporting manageable for smaller firms.

This guide explains what the CSRD means for Belgian SMEs, the key reporting thresholds, and how to prepare for the first disclosure cycle.

For clarity on company size criteria, see Is My Company Too Small for CSRD? Size Questions Answered.

1. How CSRD Applies in Belgium

The CSRD was transposed into Belgian law in 2024 through an update to the Code des sociétés et des associations / Wetboek van vennootschappen en verenigingen (CSA/WVV). It aligns with EU-wide timelines but also includes national audit and language requirements for sustainability reports.

Timeline for Belgian Companies

Belgian companies already subject to non-financial reporting under the NFRD must now transition to full CSRD standards.

2. Belgian Size Thresholds for CSRD Applicability

As in other EU Member States, the CSRD applies to large companies that meet two of the following three criteria for two consecutive years:

If your company is below these limits but supplies to large clients, you may still be asked for sustainability data as part of their value chain reporting.

Belgian authorities estimate that around 2,000 companies will report directly under CSRD, while tens of thousands will provide data indirectly.

3. The VSME Standard for Belgian SMEs

The Voluntary SME Standard (VSME), developed by EFRAG and adopted by the EU in 2024, offers a simplified template for small businesses. It covers essential topics without requiring full ESRS reporting.

Key VSME Modules

VSME allows flexibility — Belgian SMEs can report only on the modules relevant to them, and in either Dutch, French, or English, depending on their audience.

4. Where and How to Submit CSRD Reports in Belgium

For companies under mandatory CSRD:

• Reports must be submitted to the National Bank of Belgium (NBB) in digital XHTML format, alongside annual financial filings.
• Assurance reports must be included, performed by accredited statutory auditors (commissaires / bedrijfsrevisoren).
• Data must align with the ESRS standards issued by EFRAG and adopted by the EU Commission.

For voluntary VSME reporters:

• Reports can be shared directly with banks, investors, or clients.
• There is no formal submission requirement, but maintaining digital copies and audit trails is recommended.

5. Practical Steps for Belgian SMEs Getting Started

Step 1: Identify whether you’re in scope

Check size thresholds and listing status. Even if not directly covered, expect client or bank requests for sustainability information.

Step 2: Choose your reporting path

• In-scope → Full CSRD report using ESRS.
• Out-of-scope SME → Voluntary reporting using the VSME standard.

Step 3: Collect baseline data

Focus on energy, workforce, and waste first. These are easy to measure and form the foundation for broader reporting.

Step 4: Set up internal ownership

Assign one person — often finance, HR, or operations — to manage sustainability data coordination.

Step 5: Plan for assurance

Although voluntary for most SMEs, limited assurance builds credibility. Belgian SMEs can work with their existing statutory auditor or a certified ESG specialist.

For early preparation, see How to Prepare for Your First CSRD Audit or Review.

6. Local Support and Resources in Belgium

Belgian SMEs can access several resources for CSRD and sustainability support:

• Febelfin – Guidance on sustainable finance and green loans.
• VBO/FEB – Employer federation offering CSRD readiness tools.
• VOKA / UWE / BECI – Regional chambers of commerce offering training.
• Sustainability federations (such as The Shift) – Support on ESG metrics and strategy.
• Institute of Registered Auditors (IBR/IRE) – Information on assurance standards and audit readiness.

Frequently Asked Questions

Is CSRD reporting mandatory for all Belgian SMEs?

No. Only large or listed SMEs must comply directly. Other SMEs can adopt the VSME Standard voluntarily or when required by clients.

Can we submit our sustainability report in English?

Yes. Reports can be published in English, Dutch, or French — but check your shareholders’ or auditor’s preferred language.

Do SMEs need an auditor for VSME reports?

No, but voluntary assurance is encouraged for credibility, especially when providing data to banks or large clients.

What if our data is incomplete?

You can use estimates or averages if you clearly disclose your methods. See How to Estimate Missing Data for CSRD Reporting.

Key Terms

• CSRD – Corporate Sustainability Reporting Directive (EU 2022/2464).
• VSME – Voluntary SME sustainability reporting standard.
• ESRS – European Sustainability Reporting Standards defining disclosure content.
• Limited assurance – Moderate external verification of sustainability data.
• Commissaire / Bedrijfsrevisor – Accredited Belgian statutory auditor.

Conclusion

For Belgian SMEs, CSRD is not just a compliance requirement — it’s a chance to modernise data management, improve transparency, and strengthen client relationships.

Start with the VSME Standard, build internal data systems, and prepare gradually for future assurance requirements. With proper planning, sustainability reporting can become a competitive advantage — not a burden.

To map your reporting schedule and milestones, see the Annual CSRD Reporting Calendar.