CSRD Reporting in Denmark: Who Reports and How to Respond

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 public-interest entities (more than 500 employees) reported for FY 2024 in 2025. Following the Omnibus I simplification directive of 18 March 2026, mandatory CSRD scope now covers companies with more than 1,000 employees and net turnover above €450 million. Those companies report for FY 2027 (first reports published in 2028). The earlier listed-SME reporting track has been removed.

This guide is for anyone dealing with CSRD in Denmark. If you run an in-scope company, it sets out who must report, when, and against which standards. If you are a supplier or adviser to Danish corporates, it explains how the Voluntary Sustainability Reporting Standard for SMEs (VSME) offers a simpler, proportionate way to respond to the ESG data requests that flow down the value chain.

Smaller suppliers feel the effect of CSRD even when they are not filers, because they receive ESG data requests from their large customers. 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. 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

2. Danish Size Thresholds for CSRD Applicability

Since the Omnibus I simplification directive in force from 18 March 2026, a company in Denmark falls within mandatory CSRD scope only if it meets both of the following thresholds:

The earlier test based on 250 employees no longer brings a company into CSRD scope. Mid-sized companies (250 to 1,000 employees) are not in scope, and the listed-SME reporting track has been removed.

Companies above these thresholds are directly required to report under CSRD. Many smaller suppliers to large corporations are not CSRD filers, but they still receive ESG data requests through their customers’ value chains and can respond using the VSME standard.

3. The Voluntary SME (VSME) Standard in Denmark

The VSME Standard, published by EFRAG in 2024, is a voluntary standard that helps non-listed SMEs share sustainability information in a simpler way when responding to data requests from larger companies, banks, and investors. It is not part of CSRD or the ESRS, and using it is not a regulatory filing.

VSME Reporting Modules

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. The Supplier Path: Responding to Danish CSRD Data Requests

In-scope companies follow the mandatory route set out in Section 4: report against the full ESRS, file digitally with the Erhvervsstyrelsen, and obtain limited assurance. The steps below are for the larger group of suppliers and smaller businesses that are not filers but still need to answer ESG data requests from their Danish customers.

Step 1: Determine if you’re in scope

Check your size against the Danish thresholds above. If you meet both, you report under full CSRD. If you don’t, you are not a filer, but you can still respond to customer requests voluntarily using VSME.

Step 2: Select your reporting framework

There are two reporting paths in Denmark:

• Full CSRD and the ESRS, for large companies within scope, or
• VSME, for suppliers and smaller businesses responding to data requests.

If you are answering customer or bank ESG requests rather than filing, an ESG answer bank keeps your VSME-aligned answers in one place so you can reuse them across questionnaires instead of starting from scratch each time.

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 Who Can Verify a CSRD Report.

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 companies above the scope thresholds (more than 1,000 employees and net turnover above €450m) must report; listed status alone no longer triggers CSRD, and listed SMEs were removed from scope. 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

CSRD in Denmark now splits cleanly into two groups. In-scope companies with more than 1,000 employees and net turnover above €450 million report against the full ESRS, file with the Erhvervsstyrelsen, and obtain limited assurance. Everyone else, including suppliers and smaller businesses, sits outside mandatory scope but still meets ESG data requests flowing down the value chain.

For that second group, the VSME Standard offers a proportionate way to respond. Starting with it helps build data management habits, answer client requests consistently, and turn reporting into a way to strengthen trust with customers, banks, and investors.

To plan your reporting year and milestones, see the Annual CSRD Reporting Calendar.