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CSRD Deadlines by Country: Who Reports and When

The 2026 Omnibus Directive significantly narrowed who must file a CSRD report. Only companies with more than 1,000 employees and over €450 million in turnover are now legally required to report, which removed mid-sized companies and listed SMEs from the mandate entirely. Small and growing businesses have no filing obligation under these rules, though some choose to report voluntarily and many are asked for sustainability data by their customers.

This page shows who is in scope, when their reports are due, and how that plays out across the countries where most EU supplier pressure originates.

For the full detail of what the reform changed, see what the CSRD Omnibus changed.

Who Reports, and When

The reporting deadlines are set at EU level, so a French company and a Polish company of the same size are on the same EU timetable. How quickly each country writes those dates into national law varies, as the country notes below show. The table shows where things stand after the final Omnibus.

GroupIn scope after the final Omnibus?First report publishedFinancial year
Large public-interest entities already reporting (former Wave 1)Yes, if they have 1,000+ employees and €450m+ turnover2025 (already filed)FY2024 onward
Other large EU companies (former Wave 2)Only if 1,000+ employees and €450m+ turnover2028FY2027
Mid-sized companies, 250 to 1,000 employeesNo longer in scopen/an/a
Listed SMEs (former Wave 3)No longer in scopen/an/a
Large non-EU companies (former Wave 4)Yes, if €450m+ EU turnover and an EU branch or subsidiary generating €200m+2029FY2028

Before the Omnibus, a “large company” met two of three tests: more than 250 employees, €50m+ turnover, or a €25m+ balance sheet. The final Omnibus replaced that with a single, much higher bar of 1,000+ employees and €450m+ turnover, and removed listed SMEs altogether.

A note on the wave numbers. “Wave 1”, “Wave 2” and so on were a useful shorthand while the rollout was staged year by year. After the Omnibus, two of those waves no longer exist as reporting groups. We keep the labels here only because you will still see them in older guidance and in buyer emails.

Large companies already reporting

Europe’s largest banks, insurers and listed groups filed their first CSRD reports in 2025, covering the 2024 financial year. These are the public-interest entities that previously reported under the older Non-Financial Reporting Directive. Many are now in their second cycle. If you supply one of these companies, you are almost certainly already seeing data requests.

One nuance: reporters in this group that now fall below the new 1,000-employee and €450 million bar can use an optional transitional exemption for the 2025 and 2026 financial years, subject to how each Member State implements it.

Other large companies

The next group is large companies that meet the new 1,000-employee and €450 million thresholds. They will publish their first CSRD reports in 2028, covering the 2027 financial year. This is the group that drives the most supplier data requests, because these companies must disclose value-chain information under the ESRS. The delay applies to their own report, not to their data gathering, which is already under way.

Companies now out of scope

Mid-sized companies with 250 to 1,000 employees, and listed SMEs, were within CSRD under the original 2022 directive. The final Omnibus removed both groups, so they have no mandatory report to file. Many will still choose to report voluntarily, because their banks, investors and customers keep asking. The Voluntary Sustainability Reporting Standard for SMEs (VSME) exists for exactly that purpose. See VSME Basic vs Comprehensive Module.

Large non-EU companies

Non-EU parent companies remain in scope where they generate more than €450 million of turnover inside the EU and have an EU branch or subsidiary generating more than €200 million. Their first reports are due in 2029, covering the 2028 financial year. This still captures many large US, UK and Asian groups with significant European operations.

What the EU Changed

CSRD scope and timing changed in two separate steps.

The first was the Stop-the-Clock Directive (EU) 2025/794, in force from April 2025. It did one thing: it delayed reporting deadlines by two years for companies that had not yet started. Nothing about who had to report changed, only when.

The second step was bigger. The final Omnibus Directive was agreed in December 2025, adopted by the Council in February 2026, and entered into force on 18 March 2026. This one changed who reports. It raised the threshold so that only companies with more than 1,000 employees and at least €450 million in turnover fall within CSRD. Mid-sized companies with 250 to 1,000 employees, and listed SMEs, were taken out of scope.

This is not the end of CSRD. The obligation still applies to Europe’s largest companies, and the European Sustainability Reporting Standards (ESRS) behind it have been simplified rather than scrapped. The European Commission adopted a revised, reduced set of ESRS on 3 July 2026; after the Parliament and Council scrutiny period passed without objection, they were published in the Official Journal on 21 September 2026 as Delegated Regulation (EU) 2026/1563. The revised standards apply to financial years starting on or after 1 January 2027, and companies already reporting can choose to use them for FY2026. What changed is the size of the net, not its existence.

Member States must bring their national laws into line with Omnibus I by 19 March 2027. As of late October 2026, that work was uneven: Denmark, Sweden and Poland had bills or first-stage laws in progress, while France, Italy and the Netherlands had reported no Omnibus I legislation yet.

How It Plays Out Country by Country

CSRD is an EU directive, so each Member State writes it into national law. The EU deadlines do not move from one country to another, but transposition has not kept pace everywhere: Germany and the Netherlands had still not passed laws transposing the original CSRD as of October 2026, and Austria only did so in February 2026. What also varies is how quickly large buyers act: how soon they start asking suppliers for data, and how much detail they expect.

France

France transposed CSRD through Ordinance no. 2023-1142 of 6 December 2023, and the Stop-the-Clock delay through Law no. 2025-391 of 30 April 2025, confirming the later reporting dates. But French companies rarely wait for a deadline. The country has reported on sustainability for years, through Grenelle II and the Duty of Vigilance law, and that habit shows in procurement: French buyers often send detailed supplier questionnaires well before their own report is due.

For country-specific guidance, see CSRD Reporting in France: Guide for French SMEs.

Netherlands

The Dutch financial sector took up climate and ESG reporting early, and that culture carries into how Dutch companies buy. Suppliers often receive structured templates aligned to the ESRS before any legal duty applies.

The picture is uneven, though. Many Dutch SMEs have not yet been asked for sustainability data at all. Those embedded in international supply chains, by contrast, face far more frequent and detailed demands, especially for emissions and materials data. It depends less on your size than on who your customers are.

For country-specific guidance, see CSRD Reporting Netherlands: A Guide for SMEs.

Germany

Germany runs CSRD alongside its Supply Chain Act, the LkSG, which already requires large companies to manage human-rights and environmental risks in their supply chains. For German suppliers, that means two streams of questions rather than one.

German buyers typically ask for environmental data such as energy, emissions and waste, as well as workforce and human-rights information, even from small suppliers. Audit expectations are high, so the data you provide may be checked rather than taken at face value.

For country-specific guidance, see CSRD Reporting Germany (Leitfaden für KMU).

Denmark

Denmark transposed CSRD early, through Act no. 480 of 22 May 2024, and in February 2026 used an executive order to exempt companies that fall outside the new Omnibus scope from reporting for FY2025 and FY2026. A bill bringing the Omnibus thresholds into Danish law was introduced in the Folketing in October 2026.

Suppliers to Danish firms may receive detailed questionnaires, sometimes following the ESRS structure rather than a simplified supplier format. Putting your core figures together once, in advance, makes these far easier to handle.

For country-specific guidance, see CSRD Reporting Denmark: Guide for Danish SMEs.

Sweden

Swedish banks factor sustainability risk into lending and investment decisions, which creates market pressure even where no legal duty applies.

Swedish buyers tend to ask for emissions figures backed by a clear method, not rough estimates. If you supply a Swedish company, expect to explain how you reached a number, not just state it. For help choosing an approach, see Estimate Missing Data for CSRD Reporting.

For country-specific guidance, see CSRD Reporting Sweden: Guide for Swedish SMEs.

Poland

Poland feels CSRD mainly through cross-border trade rather than domestic rules. Manufacturing, automotive and electronics, all major Polish export sectors, sit deep inside supply chains led by German and Dutch corporates that are already reporting.

Polish SMEs therefore tend to receive data requests from buyers who are themselves in a reporting cycle. Getting your data into an ESRS-friendly format early protects those export relationships.

For country-specific guidance, see CSRD Reporting Poland: A Guide for Polish SMEs.

We also publish country guides for Austria, Belgium, Ireland, Spain, Italy, Finland, and Portugal.

Why This Still Reaches You

Even if you sit entirely outside CSRD, it can still reach you through the companies that do report. They must disclose what happens across their value chain, and that information has to come from their suppliers. The ESRS asks large companies to disclose, among other things:

  • Value-chain greenhouse gas emissions (Scope 3)
  • Workforce indicators across the supply chain
  • Environmental impacts from the goods and services they buy
  • Risks and dependencies linked to suppliers

This is why supplier questionnaires keep arriving, and why the Omnibus has not stopped them. Narrowing the rules removed mid-sized companies and listed SMEs from reporting, but the large companies still in scope buy from everyone.

How that lands depends on where you sit. An in-scope company is building this disclosure into its own report and its assurance process. An adviser is fielding the same questions on behalf of several clients at once. And a supplier, often a smaller business, picks up a questionnaire that means pulling energy bills from operations, headcount from HR, incident records from health and safety, and supplier spend from finance. Without a plan, that last case becomes a scramble every time a new request arrives.

For suppliers, there is some relief built into the rules. Under the Omnibus, a company in scope of CSRD cannot require a value-chain partner with no more than 1,000 employees to provide more information than the voluntary standard covers. If a buyer’s questionnaire goes well beyond that, you can reasonably point them to the standard, though the cap has legal carve-outs, so some extra requests will lawfully continue. The Commission adopted the VSME-based Voluntary Standard (VS) as a delegated act on 3 July 2026, and it was published in the Official Journal on 21 September 2026 as Delegated Regulation (EU) 2026/1560. Its cap applies to financial years starting on or after 1 January 2027; see what changes when VSME becomes the VS. To go deeper, see How SMEs Can Handle Sustainability Data Requests from Large Clients.

The One Thing Worth Doing This Year

If you are a supplier with no formal reporting duty of your own, the most useful step is a small one: put your core numbers in one place and keep them in the same format each year. A simple annual file covering:

  • Electricity use (kWh or MWh)
  • Fuel use (litres or MWh)
  • Waste volumes by type (hazardous, non-hazardous, recycled)
  • Water withdrawal (m³)
  • Workforce headcount by contract type, gender, and location
  • Any environmental or social initiatives already in place

These are the figures almost every CSRD-reporting buyer will ask for. Kept consistently, they turn each new questionnaire from a research project into a copy-and-paste task. ESG answer banks are built around this idea: reusable answers for small businesses responding to customer and bank ESG requests.

Frequently Asked Questions

Did the Omnibus cancel CSRD?

No. CSRD still applies to Europe’s largest companies, those with more than 1,000 employees and over €450 million in turnover. The Omnibus narrowed the scope and delayed deadlines; it did not remove the reporting duty. Wave 1 companies have already filed. See what the CSRD Omnibus changed for the full detail.

Are listed SMEs still required to report?

No. Under the original 2022 directive, listed SMEs were due to report later this decade. The final Omnibus removed them from mandatory scope altogether. Many still choose to report voluntarily using the VSME standard, because banks, investors and customers continue to ask for the information.

Do CSRD deadlines differ between EU countries?

The legal deadlines are the same across every Member State, and the Omnibus changes apply EU-wide. What differs is how quickly large buyers act. French, German and Dutch companies often request supplier data well ahead of their own reporting deadline.

When will SMEs feel the most pressure from clients?

Many already do. Wave 1 companies are in their reporting cycle now and collecting supply-chain data. Pressure will build as the next group of large companies prepares for first reports in 2028, covering FY2027. The delay buys time for formal reports, not for data requests. See How SMEs Can Handle Sustainability Data Requests from Large Clients.

Sources

Key Terms

  • CSRD: the EU’s corporate sustainability reporting law (Directive (EU) 2022/2464), now applying only to the largest companies after the 2026 Omnibus.
  • Omnibus Directive: Directive (EU) 2026/470, the simplification package that narrowed CSRD scope and delayed deadlines; in force from 18 March 2026.
  • Stop-the-Clock Directive: Directive (EU) 2025/794, in force from April 2025, which delayed CSRD reporting deadlines by two years.
  • ESRS: the European Sustainability Reporting Standards, which set out what companies must disclose under CSRD.
  • VSME: the Voluntary Sustainability Reporting Standard for SMEs, designed to be proportionate for smaller organisations.
  • Scope 3: value-chain emissions, including those from a company’s suppliers and customers.
  • Public-interest entity (PIE): a listed company, bank, or insurer subject to stricter reporting rules; the group that formed Wave 1.

What to Do Next

The Omnibus made CSRD smaller, not gentler on suppliers. Fewer companies file reports, but the ones that do are large, and they still need data from the businesses they buy from. If your customers include a French, Dutch, German, Danish, Swedish, or Polish corporate, the questionnaires are already on their way.

The most effective response is to stop chasing each request separately. Keep one consistent, reusable set of sustainability figures that answers most of them at once. The VSME Basic Module gives small businesses a practical framework for doing exactly that.

Handled this way, CSRD becomes less of an interruption and more of a reason buyers keep choosing you.

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