What is the impact of the CSRD on SMEs?

SMEs will both directly and indirectly be affected by the CSRD. The CSRD distinguishes between SMEs with and without a public listing.

For SMEs, a set of European Sustainability Reporting Standards (the Listed-SME ‘LSME’ Standard & the Voluntary-SME ‘VSME’ Standard, see the questions under 'More information') are being developed. This entails a lighter regime that suits the smaller size of the undertaking.

Direct impact

Listed SMEs are obliged to report their sustainability performance over the fiscal year starting on or after the 1st of January 2026.

Indirect impact

Non-listed SMEs fall outside the scope of the CSRD. They do not have to publish a sustainability report. The large undertakings reporting under the CSRD must however also report on different indicators in their value chain. For example, SMEs that are producers for an undertaking subject to reporting obligations could be asked by that undertaking to share sustainability information regarding CO2-emissions or could be held to adhere to certain to sustainability requirements via contractual obligations. The CSRD states that the ESRS should not specify disclosures that would require undertakings to obtain information from small and medium-sized undertakings in their value chain that exceeds the information to be disclosed in accordance with the sustainability reporting standards for small and medium-sized undertakings (LSME). This LSME-standard is not final yet, once this is the case, SME’s can use this standard to get an idea of the questions that could be asked.

SMEs can also use the CSRD to proactively show what they are doing in terms of sustainability, and with this they can support and unburden customers by showing what they are doing in terms of sustainability, and what information they have available.

See the EFRAG website for the current status of the SME standards and for more information the implementation guidance on the value chain.

More information:

Where refers to a listing, it means that the securities of the undertaking are traded on the regulated market within the European Union.
See also question 'What is the LSME reporting standard and the impact on SMEs?'
See also question 'What is the VSME reporting standard and the impact on non-listed SMEs?'

Questions CSRD & ESRS

Do you have questions about the CSRD, ESRS or are you missing a question in this list? Send us an e-mail and we will contact you as soon as possible. For technical questions, EFRAG has set up an ESRS Q&A platform (latest release of technical explanations: December 2024). Here you can submit a question, and also find answers to previously asked questions.

Questions regarding individual facts or circumstances will not be answered through these channels. For such questions, we recommend that you contact an advisor such as your company accountant.

Disclaimer

The SER and the DASB have put this questions and answers document together based on publicly available information at the time of publication. Although these questions have been answered with the utmost care, users of this document cannot be given any guarantees relating to the accuracy, topicality and completeness of the information displayed. The SER, the DASB and other parties related to this document cannot be held liable for the consequences of the use of the information from this document. This document does not represent the view of (EFRAG) or the European Commission, nor the SER or DASB.

It is not permitted to copy or distribute the included information or individual elements (including images) without explicit permission, if this may cause confusion about the origin of the material.

Sustainability