CSRD Reporting in Finland: Guide for Finnish SMEs
Finland has one of the strongest sustainability cultures in Europe. Many small and growing businesses (SMEs) already measure energy consumption, track waste, and publish environmental policies — not because regulators demand it, but because it aligns with Finnish values and customer expectations. That head start matters enormously as the EU’s Corporate Sustainability Reporting Directive (CSRD) takes effect.
Whether your business is directly in scope or responding to data requests from larger clients, this guide explains what CSRD means for Finnish SMEs, when the deadlines apply, and how to prepare. For a general overview of the size thresholds that determine whether your business must report, see Is My Company Too Small for CSRD?.
1. How CSRD Applies in Finland
Finland is an EU member state, which means the CSRD Directive (2022/2464/EU) applies fully. Finland transposed the directive into national law in 2024, bringing Finnish companies within scope according to the EU-wide schedule.
Mandatory reporters must prepare sustainability disclosures as part of their annual management reports, following the European Sustainability Reporting Standards (ESRS) — a set of topic-based standards covering climate, biodiversity, water, workforce, and governance. Reports must be filed digitally in XHTML format and undergo limited assurance from an accredited auditor.
Finnish businesses are supervised by the Finnish Financial Supervisory Authority (Finanssivalvonta, FIN-FSA) and the Finnish Patent and Registration Office (PRH), which oversees company filings. The Ministry of Economic Affairs and Employment (TEM) coordinates national CSRD implementation guidance.
2. CSRD Timeline and Deadlines for Finnish Businesses
The EU’s 2026 Omnibus package introduced a “Stop-the-Clock” measure, delaying Wave 2 and Wave 3 deadlines by two years. Here is where the schedule currently stands:
| Company Type | First Report Published | Reporting Year | Assurance |
|---|---|---|---|
| Large PIEs (>500 employees) — Wave 1 | 2025 | FY 2024 | Limited assurance |
| Other large companies — Wave 2 | 2028 (delayed from 2026) | FY 2027 | Limited assurance |
| Listed SMEs — Wave 3 | 2029 (delayed from 2027) | FY 2028 | Limited assurance |
| Non-listed SMEs (voluntary VSME) | Any year | Voluntary | Optional |
Wave 1 reporters — large Finnish public-interest entities (PIEs) with more than 500 employees — are already in scope, having reported for FY 2024. Large companies below the PIE threshold now report for FY 2027, published in 2028. Listed SMEs follow a year later, with an optional two-year deferral also available in some circumstances.
Non-listed SMEs are not required to report under CSRD. However, the voluntary VSME Standard gives them a practical, proportionate path to disclose sustainability data — which is increasingly requested by large clients and lenders. For a full breakdown of EU-wide deadlines, see CSRD Deadlines by Country: Who Reports When.
3. What This Means for Finnish SMEs Not Directly in Scope
Even if your business sits below the mandatory thresholds, you will feel the impact of CSRD sooner than the legal deadlines suggest. Large Finnish companies already reporting under CSRD — including Kesko, Neste, Nokia, Kone, and UPM-Kymmene — are required to disclose data across their full value chains. That means they are collecting sustainability information from their suppliers.
If you supply a large Finnish corporate or a major Nordic buyer, you should expect questionnaires asking about your:
- Energy consumption and greenhouse gas emissions (Scope 1 and 2)
- Waste generation and recycling rates
- Workforce data: headcount, diversity, training hours, turnover
- Environmental and social policies
- Business conduct and anti-corruption practices
These requests arrive through procurement portals, supplier assessments, or sustainability questionnaires. Finnish businesses in forestry and paper supply chains, manufacturing, cleantech, and technology services are among the first to receive them. To understand exactly what large clients ask for, see CSRD Supplier Requirements: What Small Businesses Should Expect.
4. The Voluntary VSME Standard: The Practical Route for Finnish SMEs
The Voluntary SME Sustainability Reporting Standard (VSME), published by EFRAG in 2024, is designed precisely for non-listed SMEs that want to respond to client data requests or begin sustainability reporting without the full complexity of ESRS.
The VSME has two modules:
| Module | Scope | Best for |
|---|---|---|
| Basic Module (B1–B11) | 11 core disclosures: energy, GHG, water, waste, workforce, governance | Most Finnish SMEs receiving supplier questionnaires |
| Comprehensive Module (C1–C9) | 9 advanced disclosures: climate targets, climate risks, value chain, human rights | SMEs with ESG-focused lenders or enterprise clients |
Most Finnish SMEs starting out will find the VSME Basic Module sufficient. It covers the data points most commonly requested by large clients and aligns naturally with data many Finnish businesses already hold — energy invoices, waste logs, HR records. For a detailed explanation of what the Basic Module requires, see The VSME Basic Module Explained.
5. Which Finnish Sectors Face Earliest Pressure
Some sectors will encounter supply chain data requests before others. Finnish SMEs in these areas should prioritise VSME preparation:
Technology and software. Finnish tech and SaaS companies supplying enterprise clients in the Nordics or wider EU face early ESG questionnaires. Clients such as major banks, telecoms, and public-sector organisations are already integrating CSRD into procurement.
Forestry, paper, and bio-based materials. Finland’s forest industry is deeply integrated into large corporate value chains. Companies like UPM, Stora Enso, and Metsä Group are Wave 1 reporters — their suppliers need to be ready with basic environmental and social data.
Manufacturing and industrial suppliers. Finnish manufacturers supplying European industrial buyers, automotive companies, or construction groups will face sustainability data requests as Wave 2 reporting kicks in.
Cleantech and renewable energy. Finnish cleantech firms often position sustainability as a core selling point. Formalising that data in a VSME report strengthens financing applications and enterprise sales.
Professional services. Accounting, legal, and consulting firms supplying large Nordic corporates will increasingly need to provide workforce diversity, travel emissions, and governance policy data.
6. How Finnish SMEs Can Prepare: Practical Steps
Finnish businesses are better placed than most to start. Many already have some relevant data; the challenge is making it structured and reportable.
Step 1: Confirm whether you are in scope
Check whether your company meets the large-company thresholds: more than 250 employees, or more than €40 million in turnover, or more than €20 million on the balance sheet (meeting two of three criteria for two consecutive years). If you do, mandatory CSRD reporting applies. If not, the VSME Standard is your starting point. Use CSRD vs VSME: Which One Applies to My Business? to work through the decision.
Step 2: Gather what you already have
Most Finnish SMEs can begin with data already available in existing systems:
- Energy invoices from your electricity and heat supplier (Fortum, Helen, etc.)
- Waste records from your waste management provider (Lassila & Tikanoja, Remeo, etc.)
- HR data: employee headcount, gender split, training hours, turnover rates
- Procurement records for identifying key suppliers
Step 3: Identify your material topics
Not every ESRS or VSME topic will be equally relevant to your business. A technology consultancy has different sustainability priorities from a paper manufacturer. Start by mapping which topics — energy, workforce, waste, governance — are most significant to your operations and clients.
Step 4: Assign responsibility internally
Nominate one person to coordinate sustainability data collection. In smaller Finnish businesses this is often someone in finance or operations. Regular quarterly data checks are more effective than an annual scramble.
Step 5: Produce a simple disclosure
A short, clearly structured VSME Basic report — even one or two pages — is enough to respond to most supplier questionnaires. It can be shared with clients, published on your website, or submitted to lenders. For help building the process, see How to Integrate CSRD Data Collection into Existing Workflows.
Step 6: Consider optional limited assurance
Voluntary assurance by a Finnish auditor (tilintarkastaja) adds credibility to your report and builds readiness for future mandatory requirements. For guidance on the assurance process, see How to Prepare for Your First CSRD Audit or Review.
7. Finnish Support and Resources
Finnish SMEs can access national guidance from:
- PRH (Finnish Patent and Registration Office) — Official filing guidance for annual reports and sustainability disclosures.
- Finanssivalvonta (FIN-FSA) — Supervision of financial and sustainability reporting for regulated entities.
- TEM (Ministry of Economic Affairs and Employment) — National CSRD implementation guidance and SME support resources.
- Business Finland — Sustainability-linked innovation funding and export promotion for Finnish SMEs.
- Suomen Yrittäjät (Finnish Entrepreneurs) — SME association with CSRD workshops and guidance toolkits.
- EK (Confederation of Finnish Industries) — CSRD guidance for Finnish exporters and industrial businesses.
- Tilintarkastajat (Finnish auditors) — Provide VSME reporting support and optional limited assurance.
Many Finnish industry associations — including those covering technology, manufacturing, and forestry — also run sector-specific sustainability workshops for smaller businesses.
8. Example: Simplified Finnish SME Disclosure
Company: NordTech Oy Financial year: 2025 Employees: 28 Energy consumption: 61,000 kWh electricity (100% renewable via Fortum wind contract) Waste: 1.8 tonnes total; 1.4 tonnes recycled (78%) Training: 12 hours per employee per year Workforce: 46% women; zero involuntary turnover in 2025 Governance: Anti-corruption policy and environmental targets approved by board in January 2025
This example follows the VSME Basic structure and can be shared with clients, published on a company website, or attached to a tender application.
Frequently Asked Questions
When does CSRD take effect for Finnish businesses?
Finnish large PIEs with more than 500 employees reported for FY 2024 (published in 2025). Other large Finnish companies report for FY 2027 (published 2028) following the Omnibus delay. Listed Finnish SMEs report for FY 2028 (published 2029). Non-listed SMEs are not required to report but can use the voluntary VSME Standard at any time.
Do Finnish SMEs need to report in Finnish or English?
Mandatory CSRD reporters must file with the PRH in Finnish or Swedish (both are official national languages). Voluntary VSME reports can be produced in Finnish, Swedish, or English — whichever is most useful for your client or investor audience. Many Finnish SMEs publish bilingual summaries for international partners.
Will my Finnish clients ask for sustainability data even if I’m not in scope?
Very likely, yes. Large Finnish companies reporting under CSRD are required to disclose sustainability data across their value chains, which includes their suppliers. If you supply Kesko, Neste, Nokia, Kone, UPM, or similar organisations, expect ESG questionnaires as part of their supplier due diligence process. The VSME Basic Module covers the most commonly requested data points.
Does Finland’s strong sustainability culture make CSRD easier to implement?
It genuinely helps. Many Finnish businesses already track energy consumption, use renewable electricity contracts, report recycling data to waste providers, and maintain HR records with training hours. This existing data can often be mapped directly to VSME disclosures. The main work is structuring it into a reportable format and filling any gaps — rather than starting from scratch.
Key Terms
- CSRD — Corporate Sustainability Reporting Directive (EU 2022/2464). The EU regulation requiring large companies to disclose sustainability information annually.
- VSME — Voluntary SME Sustainability Reporting Standard. A simplified framework from EFRAG for non-listed SMEs reporting voluntarily or in response to client requests.
- ESRS — European Sustainability Reporting Standards. The mandatory disclosure standards under CSRD, covering 12 topic areas across environment, social, and governance.
- EFRAG — European Financial Reporting Advisory Group. The EU body that developed and maintains the ESRS and VSME standards.
- PIE — Public Interest Entity. Companies listed on EU regulated markets, banks, and insurers. Wave 1 CSRD reporters.
- Limited assurance — A moderate level of external verification of sustainability disclosures, required for mandatory CSRD reporters.
- PRH — Finnish Patent and Registration Office (Patentti- ja rekisterihallitus). Oversees company registration and filing in Finland.
- Tilintarkastaja — A Finnish certified auditor, authorised to provide limited assurance on sustainability reports.
- Omnibus — The EU’s 2026 regulatory package that delayed CSRD deadlines for Wave 2 and Wave 3 companies.
Conclusion and Next Steps
Finland’s sustainability culture is a genuine competitive asset as CSRD takes effect. Small and growing businesses that already track energy use, manage waste responsibly, and value workforce transparency are in a strong position to convert existing data into structured disclosures without major new effort.
The most practical first step is the VSME Basic Module — eleven straightforward disclosures that address the data clients and lenders most commonly request. Most Finnish SMEs can produce a compliant VSME Basic report using information they already hold.
Starting early means you’re ready when the first supplier questionnaire arrives — not scrambling to respond. Use the Annual CSRD Reporting Calendar to plan your data collection milestones, and take the readiness assessment below to see where to focus your effort first.
Assess Your CSRD Readiness
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