CSRD Deadlines by Country: Who Reports, and When

A sustainability questionnaire lands in your inbox from one of your biggest customers. It asks for your energy use, your emissions, perhaps your headcount broken down by gender, and it sets a deadline. If you run a small business in Europe, this is how the Corporate Sustainability Reporting Directive (CSRD) usually reaches you: not as a law you must obey, but as a request from a customer you cannot afford to lose.

The reassuring part first. Almost no small and growing business (SME) has to file a CSRD report, and the 2026 Omnibus made the rules narrower still. But the questionnaires keep coming, because CSRD reaches most small businesses through their customers rather than through the law.

Here is what changed. The EU rewrote the rules twice. First it delayed the reporting deadlines. Then, in the final Omnibus Directive that took effect in March 2026, it sharply narrowed who must report at all. It lifted the bar to companies with more than 1,000 employees and over €450 million in turnover, and dropped listed SMEs from the rules entirely.

So the group of companies filing CSRD reports just became much smaller. But those companies are large, and they buy from thousands of suppliers. When they report, they must account for their supply chain, which is why the questionnaire still arrives in your inbox. This guide explains who reports, when, and how that plays out across France, the Netherlands, Germany, Denmark, Sweden, and Poland.

For a broader SME-focused overview, see CSRD Deadlines for SMEs.

Who Is Being Asked Right Now

CSRD reporting may sit with Europe’s largest companies, but the data requests have already spread well beyond them. If you supply a large business, you may recognise some of these situations.

A small food producer selling to a supermarket chain receives a supplier questionnaire asking for energy use, packaging weight, and emissions per product line. A textile workshop supplying a European clothing brand is asked to confirm working-hour limits and fire-safety standards at its factory. An engineering firm that machines parts for a German carmaker is sent a portal login and a deadline to upload its Scope 1 and Scope 2 figures.

None of these businesses is required to file a CSRD report. All of them are being asked for CSRD data, because their customers are reporting, or soon will be. And many are facing it for the first time, without the in-house expertise that larger firms take for granted.

The pattern is consistent. The request rarely arrives as a new law. It arrives as an email from a customer you want to keep.

What the EU Changed, in Two Steps

CSRD scope and timing changed in two separate steps, and it is easy to confuse them.

The first step 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 are being simplified rather than scrapped. What changed is the size of the net.

Who Reports, and When

The reporting deadlines are the same in every EU Member State. A French company and a Polish company of the same size report in the same year. The table below shows where things stand after the final Omnibus.

Before the Omnibus, a “large company” met two of three tests: more than 250 employees, €40m+ turnover, or a €20m+ 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.

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 at least one qualifying EU branch or subsidiary. 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.

How It Plays Out Country by Country

CSRD is an EU directive, so each Member State writes it into national law. The deadlines do not move from one country to another. What does vary is how quickly large buyers act: how soon they start asking suppliers for data, and how much detail they expect.

France

France transposed the Stop-the-Clock delay through Law no. 2025-391, 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 a full France-specific guide, see CSRD Reporting France.

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.

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.

Denmark

Danish companies are among the most sustainability-engaged in Europe. Many already report their value-chain emissions in detail and adopted strong ESG practices ahead of any requirement.

Suppliers to Danish firms can expect thorough questionnaires early in the year, often following the full ESRS structure rather than a simplified supplier format. Putting your core figures together once, in advance, makes these far easier to handle.

Sweden

Swedish regulators and banks were early movers on ESG transparency. Banks weigh sustainability risk heavily in lending and investment decisions, which creates market pressure even where no legal duty applies. For country-specific guidance, see CSRD Reporting Sweden: Guide for Swedish SMEs.

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.

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.

Why This Still Reaches Your Business

You can be entirely outside CSRD and still feel it every week. The companies that do report 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 have multiplied since 2025, and why the Omnibus has not slowed them down. Narrowing the rules removed mid-sized companies and listed SMEs from reporting, but the large companies still in scope buy from everyone.

In a small business, one of these questionnaires usually lands on a single person’s desk. Answering it well means pulling energy bills from operations, headcount from HR, incident records from health and safety, and supplier spend from finance. Without a plan, that becomes a scramble every time a new request arrives.

There is some relief built into the rules. Under the Omnibus, a company in scope of CSRD cannot ask a supplier with fewer than 1,000 employees for more information than the VSME standard covers. If a buyer’s questionnaire goes well beyond that, you can reasonably point them to the standard. To go deeper, see How SMEs Can Handle Sustainability Data Requests from Large Clients.

The One Thing Worth Doing This Year

If your business has no formal reporting duty, 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.

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 CSRD Deadlines for SMEs for how the timelines apply to smaller businesses.

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.

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: the 2025–2026 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.