CSRD Reporting Netherlands: A Guide for SMEs

The Corporate Sustainability Reporting Directive (CSRD) is reshaping how companies across Europe disclose their environmental and social impacts. In the Netherlands, many small and medium-sized enterprises (SMEs) are only now realising how CSRD may affect them — even if they are not directly in scope.

This guide explains what Dutch SMEs need to know about CSRD, the upcoming Voluntary Sustainability Reporting Standard for SMEs (VSME), and practical steps to prepare.

Is My Business in Scope in the Netherlands?

In the Netherlands, CSRD obligations apply directly to:

• Large companies that meet two out of three thresholds:

  • More than 250 employees
  • Over €40 million turnover
  • Over €20 million in total assets

• Listed SMEs (from 2026 onwards), though they will have simplified reporting options.

Most Dutch SMEs won’t have to report under CSRD directly. But banks and large clients will increasingly expect CSRD-style data as part of their supply chain checks.

For example:

• A Dutch logistics firm with 40 employees might not be legally required to file a CSRD report.
• But if its main customer is a listed multinational in Amsterdam, that customer will likely request sustainability data from the firm.

The Dutch Context

The Netherlands already has a strong tradition of sustainability regulation. Businesses face national requirements such as the Energie-audit EED, rules on waste management, and the CO₂ performance ladder in some sectors.

CSRD builds on this by standardising data requests across the EU. Dutch SMEs should therefore expect more structured and comparable questionnaires from customers and banks. Preparing early reduces compliance headaches and makes your business more competitive in tenders, financing, and partnerships.

What is the VSME Standard?

To support smaller companies, the EU has created the Voluntary Sustainability Reporting Standard for SMEs (VSME). It is designed to:

• Help SMEs respond to client and bank requests.
• Provide a Basic Module (minimum reporting set most SMEs are expected to provide).
• Offer a Comprehensive Module (extended set sometimes requested for financing or larger contracts).

The Basic Module covers 11 areas, including:

• Energy and greenhouse gas emissions (based on utility bills and fuel use).
• Waste and resource use.
• Water consumption.
• Workforce data — pay, training, and health & safety.
• Anti-bribery and corruption disclosures.

Much of this information can be drawn from everyday records — invoices, HR files, or payroll systems. You don’t need a sustainability department to get started.

Practical Steps for Dutch SMEs

1. Check your exposure

   • Are your main customers large companies subject to CSRD?
   • Do you rely on bank loans or investors who may ask for sustainability data?

2. Start with the basics Collect readily available data:

   • Electricity and gas usage from your Energiebelasting utility bills.
   • Vehicle fuel receipts.
   • Number of employees and gender split.
   • Training hours or safety incidents.

   For most SMEs, this data is already sitting in your accounts, utility bills, or HR systems.

3. Use existing Dutch frameworks

   • If you already report under the Energie-audit EED, much of that data overlaps with VSME B3 (energy and emissions).
   • If you are part of the CO₂ performance ladder, you are already tracking emissions in a structured way.

4. Consider voluntary VSME reporting Even if not mandatory, adopting the Basic Module gives you a ready-made template for responding to clients and banks.

5. Communicate your efforts Reporting is not just about compliance. Dutch SMEs that show progress on emissions reduction, recycling, or employee well-being gain a competitive edge in tenders and partnerships.

Timeline to Keep in Mind

• 2024: Large listed companies in the Netherlands begin reporting under CSRD.
• 2026: Listed SMEs must report.
• From 2027: Non-listed SMEs will likely see more questionnaires and data requests from larger Dutch and EU clients.

Why Preparing Early Matters

For Dutch SMEs, waiting until 2027 may seem tempting. But those who prepare now will find it easier to respond to requests from customers and banks, win contracts, and build trust. Using the VSME Basic Module is a practical first step that requires only a modest investment of time.

Key Terms

• Corporate Sustainability Reporting Directive (CSRD) — An EU law that requires large companies — and eventually some medium-sized ones — to report on their environmental and social impacts. Smaller suppliers are not directly in scope but may be asked for CSRD-style data by banks or bigger clients.
• Voluntary Sustainability Reporting Standard for SMEs (VSME) — A simplified framework designed to help SMEs share sustainability information. It is voluntary but can help SMEs respond to client or bank requests.
• Basic Module — The minimum set of sustainability disclosures under the VSME. It covers essential topics such as energy use, greenhouse gas emissions, waste, workforce data, and basic governance issues.
• Comprehensive Module — An extended version of the VSME reporting standard. It includes additional details on strategy, transition plans, and targets. Banks or large clients may request this level of detail.
• European Sustainability Reporting Standards (ESRS) — The detailed reporting rules that apply to large companies under CSRD. The VSME is a simplified, proportionate version for smaller businesses.
• SME (Small and Medium-sized Enterprise) — A business with fewer than 250 employees, a turnover under €50 million, or a balance sheet total under €25 million. Micro-enterprises are even smaller (fewer than 10 employees).
• Scope 1 and Scope 2 emissions — Scope 1 refers to greenhouse gas emissions from sources a company directly controls (like fuel used in company vehicles). Scope 2 refers to emissions from purchased energy (like electricity or heating). SMEs may only need to report these two.
• Turnover — The total income a company earns from its normal business activities, usually measured over one year.