CSRD Reporting Denmark: Guide for Danish SMEs
Denmark transposed the Corporate Sustainability Reporting Directive (CSRD) into national law through amendments to the Årsregnskabsloven (Danish Financial Statements Act), supervised by the Danish Business Authority (Erhvervsstyrelsen). Large listed companies reported for FY 2024 in 2025. Wave 2 companies now report for FY 2027 (published 2028) under the Omnibus Stop-the-Clock delays; listed SMEs report for FY 2028 (published 2029).
Small and growing businesses (SMEs) supplying Danish corporates feel the pressure earlier than the legal deadlines suggest. Danish buyers are well-known in the EU for comprehensive supplier questionnaires — often mirroring the full ESRS structure rather than simplified supplier formats — so preparing a VSME-aligned data set pays off quickly.
This guide explains how CSRD applies in Denmark, who must report and when, and how the Voluntary Sustainability Reporting Standard for SMEs (VSME) offers a simpler, proportionate way to respond to client data requests. For company-size thresholds, see Is My Company Too Small for CSRD?.
1. How CSRD Applies in Denmark
The CSRD has been incorporated into Danish law through amendments to the Årsregnskabsloven (Danish Financial Statements Act), managed by the Danish Business Authority (Erhvervsstyrelsen).
Denmark follows the EU-wide implementation schedule, meaning the first wave of companies report for FY2024 (in 2025).
CSRD Timeline for Danish Companies
| Company Type | First CSRD Report | Reporting Year | Assurance Required |
|---|---|---|---|
| Large listed companies | 2025 | FY2024 | Limited assurance |
| Large non-listed companies | 2028 (delayed under Omnibus) | FY2027 | Limited assurance |
| Listed SMEs | 2029 (optional deferral to 2030) | FY2028 | Limited assurance |
| Non-listed SMEs (VSME) | Voluntary | Any year | Optional |
2. Danish Size Thresholds for CSRD Applicability
In Denmark, a company qualifies as “large” if it exceeds two of the following three thresholds for two consecutive years:
| Criterion | Danish Threshold |
|---|---|
| Net turnover | > DKK 313 million (≈ €42 million) |
| Balance sheet total | > DKK 156 million (≈ €21 million) |
| Average employees | > 250 |
Companies above these thresholds will be directly required to report under CSRD. However, many small and growing business suppliers to large corporations will still need to provide sustainability data as part of value chain reporting.
3. The Voluntary SME (VSME) Standard in Denmark
The VSME Standard, published by EFRAG in 2024, is designed to help SMEs report sustainability information in a simpler way that aligns with CSRD.
VSME Reporting Modules
| Module | Focus Area | Example Indicators |
|---|---|---|
| Basic Module (B1–B11) | Core environmental, social, and governance disclosures | Energy and GHG (B3), water (B6), waste (B7), workforce (B8–B10), governance (B11) |
| Comprehensive Module (C1–C9) | Advanced disclosures for firms with ESG-focused clients or lenders | Climate targets (C3), climate risks (C4), value chain (C7), human rights (C6) |
Small and growing businesses can select relevant modules and gradually expand over time. Reports may be produced in Danish or English, depending on audience needs.
4. Where and How to Report in Denmark
For companies under mandatory CSRD:
- Reports must be filed digitally with the Erhvervsstyrelsen alongside annual financial statements.
- Reports must comply with ESRS (European Sustainability Reporting Standards).
- Data must be presented in XHTML format with a limited assurance statement from an accredited auditor.
For VSME (voluntary) reporters:
- Reports are not filed with authorities, but can be shared with banks, clients, or investors directly.
- It’s good practice to publish them on your website and maintain a copy for seven years, in line with Danish accounting law.
5. Steps for Danish Small and Growing Businesses to Get Started
Step 1: Determine if you’re in scope
Check your size against the Danish thresholds above. If you don’t meet them, you can still start voluntarily using VSME.
Step 2: Select your reporting framework
Decide whether you’ll use:
- Full CSRD (for large or listed companies), or
- VSME (for SMEs and suppliers starting out).
Step 3: Gather key data
Start with what’s easiest to access:
- Energy use and invoices
- Waste and recycling data
- Employee headcount and gender ratios
- Training and policy information
For help embedding data collection into daily routines, see How to Integrate CSRD Data Collection into Existing Workflows.
Step 4: Assign internal responsibility
Nominate one person — often from finance or operations — to coordinate sustainability data each quarter.
Step 5: Plan for external review
While assurance is optional for SMEs, a review by your revisor (auditor) improves quality and readiness for future CSRD adoption. For audit preparation, read How to Prepare for Your First CSRD Audit or Review.
6. Danish Support and Resources
Danish small and growing businesses can access support through:
- Erhvervsstyrelsen (Danish Business Authority) – Official CSRD and ESG implementation guidance.
- Dansk Industri (DI) – Templates and training for corporate sustainability.
- SMVdanmark – SME-focused sustainability toolkits and events.
- Finanstilsynet (FSA) – Guidance for financial institutions under CSRD.
- Revisorforeningen (FSR) – Technical support for assurance and ESRS interpretation.
Many industry associations also offer sector-specific CSRD workshops for small and growing businesses in manufacturing, retail, and professional services.
7. Example: Simplified Danish Small Business Disclosure
Virksomhed: NordWind ApS Regnskabsår: 2025 Antal medarbejdere: 37 Energiforbrug: 92.000 kWh elektricitet (100 % grøn energi) Affald: 2,5 ton, hvoraf 1,8 ton genanvendt Uddannelse: 10 timer pr. medarbejder Ligestilling: 45 % kvinder i medarbejderstaben Governance: Etikkode og klimamål godkendt af bestyrelsen i 2025
This sample aligns with the VSME format and can be published as part of a small and growing business’s annual report or website disclosure.
Frequently Asked Questions
Is CSRD mandatory for all Danish SMEs?
No. Only large or listed companies must report. However, SMEs will likely receive data requests from clients or banks.
Can SMEs publish reports in English?
Yes, both Danish and English reports are accepted for voluntary reporting.
Do SMEs need an auditor for VSME reports?
No, but limited assurance is recommended for credibility and future readiness.
How long should sustainability data be stored?
At least seven years, according to Danish accounting retention requirements.
Key Terms
- CSRD – Corporate Sustainability Reporting Directive, EU regulation for ESG disclosure.
- VSME – Voluntary SME standard for simplified sustainability reporting.
- ESRS – European Sustainability Reporting Standards guiding disclosure content.
- Limited assurance – Moderate-level audit verifying data accuracy.
- Revisor – Certified Danish auditor responsible for financial and sustainability assurance.
Conclusion
For Danish small and growing businesses, CSRD represents a shift toward structured sustainability — but it doesn’t have to be complex. Starting with the VSME Standard helps build data management habits, prepare for future client requests, and demonstrate environmental and social responsibility.
By aligning early, small and growing businesses can turn reporting into a competitive advantage and strengthen trust with partners and investors.
To plan your reporting year and milestones, see the Annual CSRD Reporting Calendar.
