Knowledge

What is the planning for CSRD and SME?

The implementation of the CSRD (Corporate Sustainability Reporting Directive) is phased, with obligations for companies, including SMEs (small and medium-sized enterprises (SMEs)) being introduced gradually.

Here's an overview of the schedule:

2024 : Large companies already subject to the NFRD (more than 500 employees) must start reporting according to the new CSRD requirements. These reports must be submitted in 2025 for the 2024 financial year.
2025 : Large companies that were not previously covered by the NFRD but are covered by the CSRD (i.e. companies with more than 250 employees, a turnover of more than €40 million, or a balance sheet total of more than €20 million) must start reporting from the 2025 financial year. The first reports are then expected in 2026.
2026 : Listed SMEs, with the exception of micro-enterprises, must start reporting from 2026. This means that they must submit their first sustainability report in 2027 for the 2026 financial year. Listed SMEs have the option to request an additional two-year deferral, meaning that they must comply from 2028 at the latest.
2028 : SMEs that make use of the deferral must start reporting by 2028 at the latest. This applies specifically to listed SMEs that have not yet submitted sustainability reports under the CSRD.

For SMEs that are not listed on a stock exchange, the CSRD obligations do not apply directly. However, these companies may be indirectly affected by CSRD reporting obligations through their value chains. Large companies that report according to CSRD can request information on sustainability impacts from their suppliers, including non-listed SMEs.

In summary, listed SMEs will have to comply with the CSRD reporting obligations from 2026 (or 2028 if postponed). Non-listed SMEs will not be directly obliged for the time being, but will have to take into account possible indirect obligations via their customers or partners.