CSRD Reporting France (Guide pour PME)
Small and growing businesses (SMEs) in France are navigating a new landscape of sustainability disclosure under the Corporate Sustainability Reporting Directive (CSRD). Even if you are not yet required to report formally, your larger clients, banks, or public buyers may soon ask for sustainability information — so it is wise to prepare now. If you need a refresher, start with our plain-language overview CSRD for Beginners. This guide explains the French-specific context, the “Stop-the-Clock” delay, and what you can do today to position your business proactively.
1. French context and key dates
What is CSRD?
The CSRD (Directive (EU) 2022/2464) sets out new EU-wide rules for companies to publish sustainability information covering environmental, social, and governance matters. France has transposed the directive and is preparing for its phased implementation.
France and the “Stop-the-Clock” delay
In 2025, the EU adopted the Omnibus “Stop-the-Clock” package, which delays certain reporting waves under CSRD by two years for companies in later phases. France aligned via national legislation (Law no. 2025-391, often referred to as “DDADUE 2025”), postponing the first reporting obligation for certain large non-listed companies to 2028 (for FY 2027) and for listed SMEs to 2029 (for FY 2028). Transposition of the “Stop-the-Clock” directive into French law is required by 31 December 2025.
What this means for French SMEs
- If you are already in an earlier wave (for example, because you previously reported under NFRD/DPEF rules), you may already be preparing CSRD reports.
- Typical SMEs that sit below the thresholds are not yet obliged to report under CSRD/ESRS, but larger clients will expect data as part of their own value-chain reporting. Keep an eye on the wider timeline in CSRD deadlines for SMEs.
- French law provides some first-year flexibility (for example, allowing certain omissions where disclosure could harm competitive position), helping SMEs ramp up proportionately.
2. What French SMEs should do now (voluntary preparation)
Even before mandatory reporting applies, there are straightforward steps your business can take to get ready.
Step A - Understand your exposure
- Identify whether you supply or depend on larger enterprises that will report under CSRD. They will expect data on workforce, supply chain, resource use, and governance.
- Check whether you meet any thresholds today that might trigger earlier obligations (for example, over 250 employees, €50m turnover, or €25m total assets).
- Review any existing sustainability or RSE documentation you already produce; many French SMEs have voluntary reports that can be aligned with CSRD expectations.
Step B - Start basic data collection
Begin gathering core sustainability information in a simple, proportional way. Useful categories include, as outlined in the CSRD requirements checklist:
- Environmental data: energy consumption, fuel use, water use, waste volumes, and proxy greenhouse gas indicators (such as electricity kWh or litres of fuel).
- Social/workforce data: number of employees, gender breakdown, training hours, and health and safety incidents.
- Governance/business conduct data: ethics policies, anti-corruption training, and supplier codes of conduct.
- Value-chain interactions: information you request from suppliers and data you provide to larger customers.
Step C - Use voluntary reporting frameworks
- Make use of French support programmes such as Bpifrance resources or ADEME training to understand expectations.
- Consider the Voluntary Sustainability Reporting Standard for SMEs (VSME) developed by EFRAG to structure disclosures; compare modules in VSME Basic vs Comprehensive.
- Prepare a simple annual summary for stakeholders (clients, lenders, insurers) showing that you are gathering relevant data and improving over time.
Step D - Communicate to clients and stakeholders
- Let your clients know you are proactively preparing for reporting — it builds trust and can differentiate you in tenders.
- In proposals or contracts, highlight the sustainability data you collect, improvement plans, and readiness to support downstream reporting requests.
- Consider publishing a one-page “Sustainability Snapshot” summarising key metrics and initiatives each year.
Step E - Build internal capability
- Assign responsibility for sustainability data collection (for example, in finance or operations).
- Develop simple workflows to gather utility bills, track workforce training, and map major suppliers, inspired by Value Chain Mapping for CSRD.
- Upskill staff or seek external training. French agencies such as ADEME or regional chambers of commerce frequently host webinars and diagnostics tailored to SMEs.
- Set realistic, incremental targets; improving one or two metrics per year is better than attempting everything at once.
3. Timeline for French businesses (at a glance)
| Phase | Company type | First reporting year | What you should do now |
|---|---|---|---|
| Wave 1 | Large companies already under NFRD/DPEF | Already or 2025 (for FY 2024) | Continue building full CSRD/ESRS reporting processes |
| Wave 2 | Large non-listed companies (over 250 employees or equivalent thresholds) | 2028 (for FY 2027) under the French delay | Formalise data systems, engage stakeholders, and refine double materiality assessments |
| Wave 3 | Listed SMEs | 2029 (for FY 2028) under the French delay | Pilot reporting processes now to avoid a last-minute scramble |
| SMEs in value chains | Smaller firms not yet required by law | Voluntary or when requested by clients | Use the extra time to build disclosure readiness |
Note: The above dates reflect the French transposition of the “Stop-the-Clock” package. Monitor official updates, as timelines may evolve.
4. Practical checklist for French SMEs
✔ Identify your role in the value chain: Are you a supplier to a larger firm subject to CSRD? ✔ Gather existing data: utility bills, workforce headcount, training hours, and waste figures. ✔ Select 3-5 core metrics this year (for example, electricity kWh, employee training hours, anti-corruption policy status). ✔ Document governance: Who is responsible for sustainability, how often you review progress, and how improvements are tracked. ✔ Prepare a one-page summary for clients: explain what data you collect and how you plan to improve performance. ✔ Engage staff: raise awareness of sustainability responsibilities, especially across finance, operations, and HR. ✔ Monitor French support programmes: leverage tools and guidance from Bpifrance, ADEME, and regional agencies. ✔ Review annually: update metrics, refine data collection processes, and communicate progress.
Frequently asked questions
What exactly is the “Stop-the-Clock” delay and how does it affect my business?
The “Stop-the-Clock” directive delays the mandatory first reporting date for companies in the second and third waves of CSRD by approximately two years. For France, this means large non-listed entities report for FY 2027 (filing in 2028), while listed SMEs report for FY 2028 (filing in 2029). Even if you are not in those categories, the delay provides more time to prepare before clients start requesting information.
Does this mean small French SMEs do not need to prepare anything?
No. While many SMEs are not directly required to report yet, they are indirectly affected because large clients, investors, banks, and insurers increasingly request sustainability data. Early preparation delivers practical benefits and protects commercial relationships.
What French resources exist to help me prepare?
Examples include Bpifrance webinars on CSRD readiness, ADEME’s “Pilotage RSE” portal, and regional chambers of commerce that offer diagnostics such as “Diag Adaptation” on climate resilience. These programmes provide templates, training, and diagnostic tools tailored to French SMEs.
Will the reporting standards (ESRS) change and should I wait for them?
EFRAG continues to refine the ESRS and simplified VSME standard, but SMEs do not need to wait. Collecting data now and testing voluntary disclosures will make future compliance easier and signal readiness to partners.
Key terms
- CSRD – Corporate Sustainability Reporting Directive (EU 2022/2464) requiring detailed ESG disclosures by companies.
- VSME – Voluntary Sustainability Reporting Standard for SMEs, offering proportionate disclosure modules.
- ESRS – European Sustainability Reporting Standards that underpin CSRD disclosures for large companies.
- Stop-the-Clock Directive – EU Omnibus package that postpones certain CSRD reporting timelines by two years.
- Double materiality – Requirement to consider both how sustainability matters affect the business and how the business affects people and the environment.
- Value chain – The network of upstream suppliers and downstream customers connected to your business, often the source of CSRD data requests.
Conclusion and next steps
For French SMEs, this moment is an opportunity rather than a compliance crisis. With the Stop-the-Clock delay and clear visibility of future obligations, you have time to set up robust data collection, governance, and communication systems. Focus on a handful of metrics this year, speak regularly with larger clients about your readiness, and tap into French support programmes. With a clear structure and consistent effort, CSRD can become a competitive advantage rather than an obstacle.