How to Report CSRD Data for a Newly Founded Small Business (SME)
Starting a business is hard enough — adding CSRD sustainability reporting can feel overwhelming. But if your company was founded recently, you actually have an advantage: you can build sustainable data practices from day one rather than fixing bad habits later.
This guide walks you through how newly founded small and growing businesses (SMEs) in the EU can set up, collect, and report sustainability data in line with the Corporate Sustainability Reporting Directive (CSRD) and the Voluntary Standard for SMEs (VSME) — without consultants or large systems.
1. Understand Your Reporting Obligation
As a new SME, you’re unlikely to be directly required to report under CSRD right away. The Directive applies to:
- Large companies (250+ employees, €40m turnover, or €20m assets)
- Listed SMEs (reporting starts later, with simplified rules)
- Non-EU companies with large EU activity (€150m+ turnover)
However, even unlisted SMEs often need to provide sustainability data to banks, investors, or corporate customers that do report under CSRD.
That’s where the VSME Standard comes in — a simplified, voluntary framework developed by EFRAG in 2024 to help SMEs report consistently and proportionately.
2. Start With the Core Data You Already Have
New businesses rarely have a full year of data — and that’s fine. For your first sustainability report, collect what’s available and reliable, even if partial. Begin with:
| Area | Example Data | Where to Find It |
|---|---|---|
| Energy use | Electricity and gas invoices | Utility provider or landlord |
| Workforce | Number of employees, hours worked, gender balance | Payroll or HR system |
| Waste | Collection records, recycling estimates | Facility manager or supplier |
| Governance | Code of conduct, anti-corruption policy, risk procedures | Company handbook or director’s notes |
If you don’t have a baseline yet, use estimates based on available records or operational assumptions. CSRD allows reasonable estimation — just document your approach.
3. Choose the Right Framework: VSME Basic Module
The VSME Basic Module is designed exactly for you. It includes 11 disclosures covering environment, social, and governance (ESG) topics most relevant to small businesses:
- Energy and emissions
- Water and waste
- Workforce composition and well-being
- Business conduct and ethics
- Basic governance information
It’s short, achievable, and aligned with CSRD principles, meaning your data will be compatible with larger clients’ reporting needs.
Tip: Start with the Basic Module now — you can expand to the Comprehensive Module later as your business grows.
4. Build Simple Data Collection Habits Early
Instead of waiting until year-end, record sustainability data as part of your normal operations. You can do this in:
- A shared spreadsheet
- A project management tool (e.g., Notion, Airtable)
- Simple sustainability software tailored for SMEs
Set a monthly reminder to:
- Record energy and waste figures
- Update workforce data
- Note any new policies or certifications
This rhythm helps you avoid last-minute stress and ensures your report remains accurate.
5. How to Report With Less Than 12 Months of Data
If your business started mid-year, report the data you have and explain the timeframe. Example wording:
“The company began operations in April 2025. This report covers data for the nine-month period from April to December 2025. Comparative data for prior years is not available.”
CSRD and VSME both allow flexibility for partial-year data, as long as you clearly disclose the period covered.
6. Keep Governance Simple but Visible
Even small businesses must show they manage sustainability responsibly. Include a short section on:
- Who in your company oversees sustainability (often the founder or CFO)
- How decisions are made on environmental or social topics
- Any basic policies or training you’ve introduced
A one-page governance statement shows accountability — and helps future-proof your compliance as you grow.
Frequently Asked Questions
What if I have almost no data yet?
That’s completely acceptable in your first year. You can disclose qualitative information such as policies or intentions (e.g., “energy data will be collected from next quarter onwards”). The key is transparency, not perfection.
Do I need special software for reporting?
Not at the start. A structured spreadsheet is enough. As you grow, consider tools that can connect directly to your invoices, HR data, or meters for automated tracking.
How should I handle estimates?
Mark them clearly and explain the basis (e.g., average monthly consumption x months of operation). Revisit estimates next year once full data is available.
Can I skip topics that don’t apply?
Yes. The VSME Standard allows you to omit non-material disclosures — just include a short note explaining why (“no water-intensive processes; water data not material”).
Key Terms
- CSRD: Corporate Sustainability Reporting Directive (EU 2022/2464)
- VSME: Voluntary Sustainability Reporting Standard for SMEs (EFRAG, 2024)
- ESRS: European Sustainability Reporting Standards
- Materiality: Reporting only what’s relevant to your business or stakeholders
- Limited Assurance: Independent review of reported sustainability data (for larger companies)
Conclusion: Start Simple, Grow Confidently
Starting your sustainability reporting journey early gives you a huge long-term advantage. By using the VSME Basic Module, collecting straightforward data, and keeping clear records, you’ll build a foundation that scales naturally as your business expands.
You don’t need perfection — just clarity, honesty, and a consistent routine. CSRD compliance for SMEs is about progress, not paperwork.