CSRD Reporting for Fashion Boutiques and Clothing Retailers

Fashion and clothing retail are at the centre of Europe’s sustainability transition. From textile production to end-of-life waste, every stage has environmental and social impacts. For small and medium-sized enterprises (SMEs) — such as independent fashion boutiques, online clothing retailers, or multi-brand stores — the EU’s Corporate Sustainability Reporting Directive (CSRD) introduces new expectations on transparency and accountability.

This guide explains how fashion SMEs can comply with the CSRD or prepare voluntarily under the Voluntary Sustainability Reporting Standard for SMEs (VSME), published by EFRAG in 2024. For more specific guidance, see how textile manufacturers report water and chemical use and supply chain emissions for fashion SMEs.

1. Who Needs to Report Under CSRD

According to Directive (EU) 2022/2464, the CSRD applies to:

For most fashion boutiques and independent clothing retailers, CSRD is not yet mandatory, but adopting the VSME Basic Module now helps prepare for future supply chain requests from large brands or wholesalers.

2. Why It Matters for Fashion SMEs

Larger fashion groups — such as Inditex, H&M, or LVMH — will soon require sustainability data from their suppliers and retail partners. Using the VSME Standard allows smaller retailers to:

• Meet customer and supplier data requests
• Access sustainability-linked finance
• Demonstrate responsible sourcing and ethical practices
• Reduce energy and waste costs

In short, VSME reporting turns compliance into a competitive advantage.

3. Using the VSME Standard: Step-by-Step

The VSME Basic Module is designed for SMEs with limited resources. It focuses on clear and measurable metrics relevant to your operations.

Step 1: Start with Basic Information (Disclosure B1)

Provide details about your business:

• Legal form and NACE code (e.g., G47.71 — Retail sale of clothing in specialised stores)
• Turnover, employees, and locations
• Whether your sustainability report covers only your boutique or the wider group (if you own several shops)

You may also mention sustainability certifications such as:

• Fair Wear Foundation member
• OEKO-TEX Standard 100
• ISO 14001 (if applicable)

Step 2: Describe Your Sustainability Practices (Disclosure B2)

Explain what you’re doing to become more sustainable. Examples for clothing retailers include:

Include any future plans, such as phasing out plastic packaging or adopting digital receipts.

Step 3: Measure Energy and Emissions (Disclosure B3)

Report energy use and greenhouse gas emissions from your boutique or warehouse:

Then calculate Scope 1 and 2 emissions using your utility bills or online calculators. Divide total emissions by turnover for your GHG intensity metric.

Step 4: Waste, Water, and Circular Economy (Disclosures B6–B7)

Fashion SMEs should monitor waste, packaging, and unsold inventory:

• Report total waste generated (kg per year) and percentage recycled
• Disclose if you donate unsold clothing or recycle textile waste
• Track water use (mainly from cleaning or garment care services)

If your store promotes a circular economy model (e.g., resale, vintage, or rental collections), describe this as a positive sustainability contribution.

Step 5: Social Topics (Disclosures B8–B10)

The social section covers workforce and working conditions:

• Number of employees (by gender, contract type)
• Staff turnover
• Health and safety measures (accidents, incidents)
• Equal pay and training hours
• Share of employees covered by collective agreements

Example:

“Our two boutiques in Amsterdam employ 12 staff, 75% women. All receive fair wages above the Dutch legal minimum, and each completes at least 10 hours of sustainability training per year.”

Step 6: Governance (Disclosure B11)

Disclose any convictions or fines for corruption or bribery. If none, simply state:

“The company had no convictions or fines for corruption or bribery in 2024.”

4. Going Beyond: The Comprehensive Module (Optional)

If your boutique supplies fashion brands, banks, or investors, you can add the Comprehensive Module. This includes:

• GHG reduction targets (e.g., -20% energy emissions by 2027)
• Climate risk assessment (e.g., heatwaves affecting summer sales)
• Gender diversity ratios in management
• Human rights policies in your supply chain

These align your disclosure with the European Sustainability Reporting Standards (ESRS) while remaining proportional to SME capacity.

5. Reporting Format and Timing

• Report annually, ideally with your financial statements.
• Use a short PDF or web page titled “Sustainability Report 2025.”
• You may upload it on your website or share it with banks and suppliers.

Sample structure:

1. About our business
2. Sustainability practices
3. Metrics and performance
4. Future targets

6. Quick Wins for Fashion Retailers

7. How to Prepare for CSRD Requests

Fashion SMEs will soon receive sustainability questionnaires from suppliers or lenders. To stay ahead:

• Keep a simple spreadsheet tracking energy, waste, and training hours
• Save invoices and energy bills for evidence
• Review VSME templates for B1–B11 disclosures
• Communicate progress publicly — transparency builds trust

Frequently Asked Questions

Do fashion boutiques need to report under CSRD?

Most small fashion boutiques are not directly required to report under CSRD, which applies to large companies (250+ employees, €40M turnover, or €20M assets). However, many fashion retailers need to provide sustainability data to large buyers, corporate clients, or investors who are CSRD-compliant. The VSME Standard offers a simplified, voluntary framework for fashion boutiques to meet these supply chain requirements efficiently.

Check if CSRD applies to your business →

What are the most important CSRD topics for fashion boutiques?

The key topics for fashion boutiques are: (1) energy use and emissions from stores and operations (VSME B3), (2) waste management including packaging and textile waste (VSME B7), (3) supply chain emissions from purchased goods (Scope 3), and (4) water and chemical use if you manufacture or process textiles (VSME B4, B6). These align with the CSRD’s focus on environmental impacts and are most relevant to fashion operations.

Learn about supply chain emissions →

How do I track energy use across multiple store locations?

Collect energy data from each store separately (using utility bills and meter readings), then aggregate the totals across all locations for your annual report. You can also report intensity metrics (e.g., kWh per m² or per € turnover) to normalize for store size or sales volume. This allows you to identify which stores are most energy-intensive and where efficiency improvements would have the biggest impact.

Can I use existing supplier or inventory data for CSRD reporting?

Yes! You can reuse data from supplier sustainability reports, inventory systems, waste contractor invoices, and any existing environmental management systems. The VSME Standard is designed to work with data you’re already collecting for operational purposes. Just organise your existing data into the VSME Basic Module format (B1–B11) for your sustainability report.

Key Terms

• CSRD – Corporate Sustainability Reporting Directive (EU 2022/2464), requiring large and listed companies to disclose sustainability data.
• VSME – Voluntary Sustainability Reporting Standard for SMEs (EFRAG, 2024).
• Basic Module – Entry-level reporting covering 11 essential disclosures (B1–B11).
• Comprehensive Module – Optional advanced disclosures (C1–C9).
• ESRS – European Sustainability Reporting Standards used by large companies under CSRD.
• SME – Small and medium-sized enterprise.
• Scope 1 and 2 emissions – Direct (fuel use) and indirect (electricity use) greenhouse gas emissions.
• Turnover – Total sales revenue within the reporting year.