CSRD Reporting in Belgium: Who Reports and How to Respond

Introduction

Belgium is home to over 1.2 million SMEs. Most of them will feel the indirect impact of the Corporate Sustainability Reporting Directive (CSRD) even though they are not themselves required to report under it.

A smaller number of large Belgian companies file CSRD reports directly. Many more smaller firms will be asked to collect and share sustainability information with clients, banks, and auditors, and can respond using the Voluntary SME (VSME) Standard, a simplified framework designed by EFRAG to make sustainability reporting manageable for smaller firms.

This guide explains what the CSRD means in Belgium, who is in scope after the 2026 Omnibus simplification, and how smaller companies can prepare to answer sustainability requests.

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

1. How CSRD Applies in Belgium

Belgium implements the CSRD through national law amending the Code des sociétés et des associations / Wetboek van vennootschappen en verenigingen (CSA/WVV), with the FSMA acting as supervisor. Because national law implements the EU directive, the scope and timeline changes introduced by the EU’s Omnibus I simplification directive (in force 18 March 2026) flow through into Belgian practice. National audit and language requirements continue to apply alongside the EU timelines.

After Omnibus I, mandatory CSRD reporting is limited to large undertakings with more than 1,000 employees and net turnover above €450 million. The mid-sized and listed-SME tracks that earlier drafts envisaged have been removed.

Timeline for Belgian Companies

Wave 1 companies that already reported under the NFRD continue to report under CSRD. There is no longer a separate listed-SME wave.

2. Belgian Size Thresholds for CSRD Applicability

As in other EU Member States, after Omnibus I the CSRD applies to large companies that meet both of the following criteria:

This is a much higher bar than the earlier draft test (which counted 250 employees, €50 million turnover, or €25 million balance sheet). Companies in the 250–1,000 range, and listed SMEs, are no longer in scope.

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. You are not a CSRD filer in that case; you respond to those requests, often using the VSME standard.

A non-EU parent is brought into scope only where the group has EU turnover above €450 million and an EU subsidiary or branch above €200 million, with first reports expected around 2029 (FY2028).

3. The VSME Standard for Belgian SMEs

The Voluntary SME Standard (VSME), developed by EFRAG, offers a simplified template for small businesses. It is voluntary, sits outside the CSRD and ESRS, and is not a filing. It gives non-listed SMEs a structured way to answer the sustainability questions they receive from clients, banks, and investors.

Key VSME Modules

VSME allows flexibility. Belgian SMEs can answer only on the disclosures relevant to them, and in 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 to Get Started in Belgium

Step 1: Identify whether you’re in scope

Check whether you meet the mandatory thresholds (more than 1,000 employees and turnover above €450 million). Most smaller companies are not in scope, but should still expect client or bank requests for sustainability information.

Step 2: Choose your reporting path

• In scope → Full CSRD report using the ESRS.
• Not in scope → Respond to ESG requests using the voluntary VSME standard. If you are a smaller supplier fielding ESG questionnaires from customers or banks, an ESG answer bank lets you reply consistently without rebuilding your figures each time.

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 in 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 Who Can Verify a CSRD Report.

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 companies above the mandatory thresholds (more than 1,000 employees and turnover above €450 million) must comply directly. Listed SMEs are no longer brought into scope. Other companies can use the VSME Standard voluntarily, typically when a client or bank asks for the data.

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

CSRD in Belgium splits into two practical tasks. Large in-scope companies file under the ESRS, while smaller suppliers focus on responding well to the sustainability data their clients and banks ask for. Either way, the work is a chance to modernise data management, improve transparency, and strengthen relationships.

If you are filing, build the systems and assurance the ESRS require. If you are responding, start with the VSME Standard, build internal data systems, and prepare gradually for assurance where it adds credibility. With proper planning, sustainability reporting becomes a competitive advantage rather than a burden.

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