CSRD Reporting in Finland: Who Reports and How to Respond

The EU’s Corporate Sustainability Reporting Directive (CSRD) is now part of Finnish law, and it reaches companies in two very different ways. A small number of large Finnish corporates must publish audited sustainability reports. A far larger number of businesses will never file under CSRD themselves, but will be asked for sustainability data by the large companies and lenders that do.

Finland implements CSRD through amendments to its accounting law (Kirjanpitolaki), and the largest Finnish reporters, including Kesko, Neste, Nokia, Kone, and UPM-Kymmene, are already disclosing under it. This guide covers both sides. The next section sets out who actually has to report. From there, one path is for companies that are in scope, and another is for suppliers being asked for ESG data. For a general overview of the size thresholds that decide whether a business must report, see Is My Company Too Small for CSRD?.

Who reports under CSRD in Finland

Finland is an EU member state, so the CSRD Directive (2022/2464/EU) applies fully. Because Finnish law implements the EU directive through the accounting law (Kirjanpitolaki), the 2026 Omnibus changes to scope and timing flow straight through to Finnish companies.

Two EU measures shaped the current schedule. The “Stop-the-Clock” Directive (EU 2025/794, April 2025) postponed later reporting deadlines, and the Omnibus I simplification directive (in force 18 March 2026) narrowed who is in scope (what the Omnibus changed). Here is where the schedule stands:

Wave 1 reporters, large Finnish public-interest entities (PIEs) with more than 500 employees, are already in scope, having reported for FY 2024. Under Omnibus I, mandatory CSRD scope is now limited to companies with more than 1,000 employees and net turnover above €450 million. Both conditions must be met. Those Wave 2 companies report for FY 2027, published in 2028. The previously planned wave for listed SMEs has been removed, so listed SMEs are no longer brought into scope.

Companies below the 1,000-employee and €450 million threshold, which is the great majority of Finnish businesses, are not CSRD filers. The voluntary VSME Standard instead gives them a proportionate way to disclose the sustainability data that large clients and lenders increasingly request. For a full breakdown of EU-wide deadlines, see CSRD Deadlines by Country: Who Reports When.

If your company is in scope

If your company crosses the threshold, you report under the full CSRD regime. In practice that means:

• ESRS disclosures. You report against the European Sustainability Reporting Standards as part of your annual management report. Post-Omnibus, the ESRS 2 general disclosures apply to every reporter, with the topical standards (climate, biodiversity, water, workforce, governance, and so on) applied where your double materiality assessment shows them to be material.
• Double materiality. You assess each sustainability topic from two angles: its impact on people and the environment, and its financial effect on your business. This assessment determines which topical disclosures you must make.
• Limited assurance. An accredited auditor provides limited assurance over the disclosures. In Finland this is carried out by an authorised auditor (tilintarkastaja). For when assurance is required and what it covers, see CSRD Audit Requirements.
• Digital filing. Reports are filed digitally in XHTML format, with the sustainability information tagged so it is machine-readable.

Finnish reporters are supervised by the Finnish Financial Supervisory Authority (Finanssivalvonta, FIN-FSA), with company filings handled by the Finnish Patent and Registration Office (PRH). The largest Finnish reporters, including Kesko, Neste, Nokia, Kone, and UPM-Kymmene, already publish under this regime; companies crossing the threshold for the first time face the same requirements on the Wave 2 timeline, reporting for FY 2027.

If you’re a supplier asked for ESG data

Most Finnish businesses sit below the threshold and will never file under CSRD. They still feel its effects, because large Finnish companies reporting under CSRD must disclose data across their full value chains. That means they collect sustainability information from their suppliers.

If you supply a large Finnish corporate or a major Nordic buyer, 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. To understand exactly what large clients ask for, see CSRD Supplier Requirements: What Small Businesses Should Expect.

There is also a legal ceiling on these requests. Since Omnibus I, an in-scope customer cannot demand more sustainability data for CSRD purposes from a supplier with fewer than 1,000 employees than the VSME Standard covers. One well-prepared VSME report can therefore answer most of the questionnaires you receive; see how one VSME report answers every ESG request.

If most of your effort goes into answering the same ESG questions over and over for different customers and banks, an ESG answer bank stores those answers once so you can reuse them for each new request rather than starting from scratch every time.

The VSME Standard: your practical route

The Voluntary Sustainability Reporting Standard for non-listed SMEs (VSME), published by EFRAG in 2024, is designed 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:

Most suppliers 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, such as energy invoices, waste logs, and HR records. For a detailed explanation of what the Basic Module requires, see The VSME Basic Module Explained.

Which Finnish sectors face the earliest pressure

Some sectors encounter supply chain data requests before others. Businesses 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, so 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 takes effect.

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.

How to respond: a practical process

Many Finnish businesses already hold some of the relevant data; the challenge is making it structured and reportable.

Step 1: Confirm the voluntary route applies. Check that your company is below the post-Omnibus CSRD threshold of more than 1,000 employees and net turnover above €450 million. If you are below it, the voluntary 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 businesses can begin with data already 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 VSME topic will be equally relevant. A technology consultancy has different priorities from a paper manufacturer. Map which topics (energy, workforce, waste, governance) matter most to your operations and clients.

Step 4: Assign responsibility internally. Nominate one person to coordinate sustainability data collection. In smaller businesses this is often someone in finance or operations. Regular quarterly data checks beat an annual scramble.

Step 5: Produce a simple disclosure. A short, clearly structured VSME Basic report, even one or two pages, is enough to answer 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 and builds readiness should you ever cross the mandatory threshold.

Example: a simplified VSME 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.

Finnish Support and Resources

Finnish businesses 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 businesses.
• 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.

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). Large Finnish companies meeting the post-Omnibus threshold (more than 1,000 employees and net turnover above €450 million) report for FY 2027 (published 2028). The earlier planned wave for listed SMEs has been removed, so listed SMEs are not brought into scope. Companies below the threshold are not required to report but can use the voluntary VSME Standard at any time.

Which language must Finnish CSRD reports be filed in?

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 businesses 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 existing Finnish sustainability data make reporting easier?

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 Sustainability Reporting Standard for non-listed SMEs. A simplified framework from EFRAG for non-listed SMEs reporting voluntarily or in response to client requests.
• ESRS — European Sustainability Reporting Standards. The disclosure standards under CSRD: 12 in total, made up of two cross-cutting standards and ten topical standards across environment, social, and governance. Post-Omnibus, only ESRS 2 is mandatory for all reporters, with topical standards applied where material.
• 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 I — The EU’s 2026 simplification directive (in force 18 March 2026) that narrowed mandatory CSRD scope to companies with more than 1,000 employees and net turnover above €450 million, and removed the planned wave for listed SMEs.

Conclusion and Next Steps

CSRD reaches Finnish businesses on two tracks. A small group of large corporates report under the full ESRS regime with limited assurance; everyone else is far more likely to meet CSRD through the supplier questionnaires those corporates send down their value chains.

If you are in scope, the work centres on double materiality, ESRS disclosures, and assurance on the Wave 2 timeline. If you are a supplier, the VSME Basic Module is the practical answer: eleven straightforward disclosures that address the data clients and lenders most commonly request, and which most businesses can produce from information they already hold.

Use the Annual CSRD Reporting Calendar to plan your data collection milestones. Free VSME report tools now generate a finished Basic Module report at no cost, which is usually enough to answer a first customer or bank request. Whichever path applies to you, the readiness assessment below helps you see where to focus first.