CSRD for SMEs
Most SMEs are not directly in mandatory CSRD scope after the Omnibus changes. But supply chain pressure from large CSRD reporters means most SMEs will need to provide ESG data anyway. Here is what applies to you.
Most SMEs are not directly in mandatory CSRD scope after the Omnibus changes. After the Omnibus package (February 2025), mandatory CSRD scope requires 1,000+ employees AND €450M+ net annual turnover.
Are you in mandatory CSRD scope?
After the Omnibus package (February 2025), mandatory CSRD scope requires 1,000+ employees AND €450M+ net annual turnover. Both criteria must be met.
If you have fewer than 1,000 employees or less than €450M turnover, you are not in mandatory CSRD scope. This is a significant change from the original CSRD which would have caught companies with 250+ employees or €40M turnover.
However: listed SMEs on EU regulated markets may still face disclosure requirements under individual member state rules. And non-mandatory does not mean non-affected.
Why SMEs still need ESG data even outside mandatory scope
Large companies in CSRD scope must report their Scope 3 Category 1 emissions — the emissions embedded in goods and services they purchase from suppliers like you. To calculate this, they need your GHG data.
Expect requests from your largest customers for: total Scope 1 and 2 GHG emissions; energy consumption; basic social metrics (headcount, health and safety); and supplier code of conduct compliance.
Companies that refuse or cannot provide this data risk losing contracts. ESG data provision is increasingly a supply chain qualification criterion.
The VSME — your simplified reporting framework
EFRAG is developing the VSME (Voluntary SME Standard) to provide SMEs with a proportionate way to report the ESG data their customers need.
The VSME has two levels: a Basic level (simplified) and a Comprehensive level (more detailed). The Basic level covers: general company information, GHG emissions (Scope 1 and 2), energy consumption, key social metrics, and governance basics.
The VSME is voluntary — no mandatory filing requirement. But adopting it proactively demonstrates ESG maturity to customers and investors, and prepares you in case thresholds are lowered in future.
Frequently asked questions
Do SMEs need third-party assurance?
Not under VSME — assurance is voluntary. However, some large customers may request externally verified ESG data. Third-party review of SME ESG data is significantly less expensive than full CSRD assurance — typically €5,000–€20,000.
When will the VSME be finalised?
EFRAG published a draft VSME in late 2023. Final delegated act adoption is expected during 2026, following the Omnibus legislative process. Monitor EFRAG announcements.
What is the minimum ESG data set an SME should prepare?
Scope 1 and 2 GHG emissions, total energy consumption, headcount by gender, and a brief statement on anti-corruption policy. This satisfies most large customer data requests and provides a foundation for VSME or full CSRD if thresholds change.