CSRD Deadlines by Country (2025–2028)

The Corporate Sustainability Reporting Directive (CSRD) is rolling out in waves from 2024 to 2028. Whether your organisation is directly reporting or supporting a parent company or client, the implementation dates matter — especially now that national laws and regulator guidance are fully in force across Europe.

Although CSRD is an EU-wide law, each country has introduced practical nuances through transposition, enforcement approaches, and guidance for smaller entities. Suppliers and SMEs increasingly feel these deadlines indirectly, even when they are not legally required to publish a CSRD report.

This guide brings together EU-wide deadlines, company scope, and country-specific differences for France, Netherlands, Germany, Denmark, Sweden, and Poland — the markets where suppliers most often experience pressure from buyers.

1. EU-Wide CSRD Deadlines Table (2025–2028)

CSRD applies in four waves. These deadlines come directly from the Directive.

For a deeper introduction to how these waves affect SMEs, you can also review: CSRD Deadlines for SMEs

2. Which Companies Are in Each Wave?

Wave 1 — 2024 reporting (reports published in 2025)

Large public-interest entities already reporting under NFRD, including major banks and listed groups.

Wave 2 — 2025 reporting (reports published in 2026)

All other large EU companies. This is the wave that drives most supplier data requests, because large companies must now collect value-chain information under the ESRS.

Wave 3 — 2026 reporting (published in 2027)

Listed SMEs (except micro-undertakings) are in scope, but they may opt out until 2028. This is the first time many medium-sized listed companies need to manage structured sustainability reporting.

Wave 4 — 2028 reporting (published in 2029)

Non-EU parent companies operating in the EU with €150m+ EU turnover.

These waves create a cascading effect. Even if you are not directly in scope, your clients, distributors, or lenders likely are — and they must collect sustainability data from their supply chain.

For supplier-side guidance, see: How SMEs Can Handle Sustainability Data Requests from Large Clients

3. Country-Specific Nuances (FR / NL / DE / DK / SE / PL)

CSRD is an EU Directive, meaning every Member State must transpose the rules into national law. The deadlines do not change by country — but the enforcement landscape does.

Below are the practical nuances affecting suppliers and subsidiaries across key European markets.

France (FR)

France already has a long tradition of sustainability reporting through Grenelle II, Duty of Vigilance, and strict social reporting obligations. As a result:

• French regulators expect high data quality early in adoption.
• Many French groups request granular supplier data, especially emissions and workforce metrics.
• Subsidiaries often feed into detailed group reporting systems.

Large French companies tend to move faster than the minimum deadlines, so suppliers receive questionnaires earlier and more frequently.

Netherlands (NL)

Dutch businesses face strong market pressure from investors and banks, especially due to:

• The Dutch financial sector’s early adoption of climate reporting
• A national expectation for transparent value-chain emissions
• Mature digital reporting cultures in Dutch corporates

SMEs supplying Dutch companies often receive highly structured templates earlier than expected.

Useful resource for suppliers in technical sectors: CSRD Reporting for IT and Tech Service Providers

Germany (DE)

Germany’s implementation emphasises:

• Strong audit and assurance expectations
• Close alignment with existing risk-management laws
• High scrutiny for human-rights processes, especially due to the German Supply Chain Act (LkSG)

German buyers commonly request data on both environmental metrics and workforce/human-rights indicators, even from small suppliers.

Denmark (DK)

Denmark has some of the most sustainability-focused businesses in Europe:

• Danish companies often exceed ESRS expectations voluntarily
• Many already report Scope 3 in detail
• Government agencies provide clear guidance to large enterprises transitioning to CSRD

Suppliers to Danish corporates can expect comprehensive questionnaires early in the year, sometimes mirroring the ESRS structure.

Sweden (SE)

Sweden’s regulators and financial sector are early adopters of ESG transparency:

• Listed Swedish companies typically adopt best-practice reporting before required
• Banks integrate sustainability risk deeply into lending decisions
• Stakeholder pressure for credible emissions data is high

Swedish buyers frequently require evidence-based emissions estimates, which may push SMEs to improve data quality sooner.

For emissions-data methods, see: Emission Factor Selection: How to Choose Data Sources

Poland (PL)

Poland has experienced rapid CSRD adoption driven by:

• Integration with multinational supply chains (especially manufacturing, automotive, and electronics)
• Strong reliance on structured sustainability data to maintain export competitiveness
• High demand from German and Dutch clients for aligned reporting formats

Polish SMEs often feel pressure via cross-border procurement rather than domestic regulation.

4. What SMEs Supplying These Companies Need to Know

Even when SMEs are not obligated to report under CSRD, they support the companies that are. ESRS explicitly requires large companies to disclose:

• Value-chain GHG emissions (Scope 3)
• Workforce indicators across the value chain
• Environmental impacts of purchased goods and services
• Expected risks and dependencies linked to suppliers

This is why suppliers receive more questionnaires each year.

SMEs can save significant time by preparing a single, reusable dataset instead of responding to every client separately. A practical solution is to adopt the VSME Basic Module, which aligns with ESRS topics and is widely recognised.

If you are new to VSME, you may find this primer useful: CSRD vs VSME: What’s the Difference and Why It Matters for SMEs

5. “If You’re an SME, Do This One Thing This Year…”

Create a basic annual sustainability file with your core numbers:

• Electricity use (kWh or MWh)
• Fuel use (litres or MWh)
• Waste volumes (hazardous / non-hazardous, recycled)
• Water withdrawal
• Workforce headcount (by contract, gender, location)
• Any environmental or social initiatives you already run

These are the datapoints almost every CSRD-reporting company will ask for.

If you want a structured format, start with the VSME Basic Module or use a simple supplier-ready approach such as: How SMEs Can Handle Sustainability Data Requests from Large Clients

With a clear structure and consistent effort, supporting CSRD clients becomes manageable — and often improves a company’s competitive position in tenders.

Frequently Asked Questions

Do CSRD deadlines differ between EU countries?

The legal deadlines do not change by country. All Member States follow the same four CSRD waves. The differences appear in enforcement, expectations, and how quickly large companies request supplier data. If you want to understand SME timelines, see: CSRD Deadlines for SMEs.

When will SMEs feel the most pressure from clients?

Most SMEs already feel pressure during Wave 2 (2025 reporting). Large companies need supplier data early to complete their ESRS reports. This accelerates data requests across the supply chain. To prepare, see: How SMEs Can Handle Sustainability Data Requests from Large Clients.

Do SMEs need to report under CSRD themselves?

Only listed SMEs (except micro) must report from 2026, with an optional delay to 2028. Non-listed SMEs are not required to report, but many create a VSME Basic Module report to satisfy clients. A comparison is here: CSRD vs VSME Differences.

Key Terms

• CSRD — EU sustainability reporting law applying to large and listed companies.
• ESRS — Standards defining what companies must report.
• VSME — Voluntary standard for non-listed SMEs.
• Scope 3 — Value-chain emissions including suppliers.
• Wave 1–4 — Implementation phases from 2024 to 2028.

Conclusion & Next Steps

CSRD reporting deadlines are fixed across the EU, but the practical impact is shaped by national expectations and sector-level pressure. French, Dutch, German, Danish, Swedish, and Polish companies are among the earliest adopters — which means suppliers working with them feel the tightest timelines.

If your organisation is an SME, the most valuable action this year is simple: create a single, reusable sustainability dataset that aligns with ESRS and VSME.

This keeps client relationships strong, reduces repetitive admin, and positions your business for the growing number of tenders requiring sustainability information.

To continue learning, you may find this helpful: CSRD for Beginners: A Plain-Language Guide for Small Businesses