The Corporate Sustainability Reporting Directive (CSRD) is reshaping how companies across Europe disclose their environmental and social impacts. In the Netherlands it now applies to a much smaller group than originally planned: the Omnibus I simplification directive, in force since 18 March 2026, limited mandatory reporting to companies with more than 1,000 employees and net turnover above €450 million.
That change splits Dutch readers into two groups. In-scope companies prepare a sustainability statement under the European Sustainability Reporting Standards (ESRS). Everyone else, which is most Dutch businesses, has no CSRD obligation but increasingly receives sustainability data requests from large customers and banks that do report. This guide covers both paths, including the Voluntary Sustainability Reporting Standard for SMEs (VSME) used to answer those requests.
Is My Business in Scope in the Netherlands?
Since Omnibus I, CSRD obligations apply directly to companies that meet both thresholds:
- More than 1,000 employees, and
- Net turnover above €450 million.
Two groups that were previously headed into scope are now out:
- Listed SMEs: the listed-SME reporting track was removed entirely by Omnibus I.
- Mid-sized companies (250 to 1,000 employees): no longer in scope.
Large public-interest entities that already reported for FY 2024 continue reporting; those now below the new thresholds can use an optional transitional exemption for FY 2025 and FY 2026, subject to Member State implementation. Other in-scope companies report for FY 2027, publishing in 2028. For the full picture of what changed, see CSRD Omnibus Changes.
Most Dutch businesses will not report under CSRD directly. But banks and large clients still expect sustainability data as part of their supply-chain and lending checks. For example, a Dutch logistics firm with 40 employees is not required to file a CSRD report, but if its main customer is a listed multinational in Amsterdam, that customer may still request sustainability data from the firm.
There is now a legal ceiling on those requests: CSRD reporters may not demand more than the VSME data points from value-chain partners with fewer than 1,000 employees, apart from specific carve-outs such as sector-customary information or data required by other EU law.
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 businesses should therefore expect more structured and comparable questionnaires from customers and banks. Preparing early reduces compliance headaches and makes a business more competitive in tenders and financing.
CSRD itself entered Dutch law through an implementation decree amending Book 2 of the Dutch Civil Code (Burgerlijk Wetboek). The later EU changes, the Stop-the-Clock delays and the Omnibus I scope reduction, are set at directive level and are being worked into Dutch law through further amendments.
What is the VSME Standard?
To support smaller companies, the EU created the Voluntary Sustainability Reporting Standard for SMEs (VSME), developed by EFRAG. On 3 July 2026 the European Commission adopted it as a delegated act, the Voluntary Standard (VS), applying from financial years starting 1 January 2027; see what the rename changes. It is designed to:
- Help smaller businesses respond to client and bank requests.
- Provide a Basic Module (the minimum reporting set most requesters expect).
- Offer a Comprehensive Module (an extended set sometimes requested for financing or larger contracts).
The Basic Module covers 11 disclosure 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 and safety.
- Convictions and fines for corruption and bribery.
Much of this information can be drawn from everyday records such as invoices, HR files, or payroll systems. You do not need a sustainability department to get started, and free VSME report tools now generate a finished report at no cost.
Practical Steps for Dutch Businesses Below the Thresholds
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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?
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Start with the basics Collect readily available data:
- Electricity and gas usage from your utility bills.
- Vehicle fuel receipts.
- Number of employees and gender split.
- Training hours and safety incidents.
For most businesses, this data is already sitting in accounts, utility bills, or HR systems.
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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.
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Consider voluntary VSME reporting Adopting the Basic Module gives you a ready-made template for responding to clients and banks, and it matches the cap on what CSRD reporters may ask of you. EFRAG’s free digital template is available in Dutch.
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Communicate your efforts Businesses that show progress on emissions reduction, recycling, or employee well-being gain an edge in tenders and partnerships, beyond simply meeting a request.
Timeline to Keep in Mind
- FY 2024 (published 2025): large public-interest entities in the Netherlands began reporting under CSRD.
- 18 March 2026: Omnibus I entered into force, raising the thresholds and removing listed SMEs from scope.
- FY 2027 (published 2028): remaining in-scope large companies report, against the simplified ESRS adopted on 3 July 2026.
- From 2027: businesses below the thresholds can expect questionnaires and data requests from larger Dutch and EU clients to keep arriving, capped at VSME level for most CSRD purposes.
For EU-wide dates, see CSRD Deadlines by Country.
Why Preparing Early Matters
For Dutch businesses outside CSRD scope, waiting 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.
Frequently Asked Questions
Which Dutch law transposed CSRD?
The Netherlands transposed CSRD through an implementation decree (Implementatiebesluit richtlijn duurzaamheidsrapportage) amending Book 2 of the Dutch Civil Code (Burgerlijk Wetboek). The later EU-level changes, the Stop-the-Clock delays (April 2025) and the Omnibus I scope reduction (March 2026), are being reflected in Dutch law through further amendments.
Who supervises CSRD compliance in the Netherlands?
The AFM (Autoriteit Financiële Markten) supervises listed-company sustainability disclosures as part of regulated-market oversight. Assurance providers are overseen by the NBA (Nederlandse Beroepsorganisatie van Accountants) and registered with the AFM. Non-listed businesses file through the Kamer van Koophandel (Chamber of Commerce) registry.
Do Dutch SMEs have to report under CSRD?
No. Since Omnibus I, only companies with more than 1,000 employees and over €450 million net turnover are CSRD filers, and the listed-SME track has been removed. What an SME may face instead is a customer or bank asking for sustainability data, which the voluntary VSME standard is designed to answer, and which is capped at VSME level for most CSRD purposes.
Can a large customer ask my business for more than VSME data?
Sometimes. The cap on value-chain requests has carve-outs: information customarily exchanged in a sector, data required by other EU law (such as banking or due-diligence rules), and the VSME’s own C3 (greenhouse gas targets) and C4 (climate risk) disclosures sit outside it. Platform assessments such as EcoVadis also continue, though a VSME report can be reused inside them.
Key Terms
- Corporate Sustainability Reporting Directive (CSRD) – The EU law requiring companies with more than 1,000 employees and over €450 million turnover to report on their environmental and social impacts. Smaller businesses are not in scope but may be asked for data by banks or bigger clients.
- Omnibus I – The EU simplification directive (in force 18 March 2026) that raised the CSRD thresholds, removed listed SMEs from scope, and capped value-chain data requests at VSME level.
- Voluntary Sustainability Reporting Standard for SMEs (VSME) – A simplified framework that helps smaller businesses share sustainability information. Voluntary, and adopted as the Voluntary Standard (VS) delegated act on 3 July 2026.
- 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 standard, adding strategy, transition plans, and targets. Banks and large clients may request this level of detail.
- European Sustainability Reporting Standards (ESRS) – The detailed reporting rules that apply to in-scope companies under CSRD. A simplified, revised version was adopted on 3 July 2026 and applies from FY 2027.
- SME (Small and Medium-sized Enterprise) – Under EU accounting rules, a business with up to 250 employees, turnover up to €50 million, or a balance sheet total up to €25 million. Micro-enterprises are smaller still (fewer than 10 employees).
- Scope 1 and Scope 2 emissions – Scope 1 covers greenhouse gas emissions from sources a company directly controls (like fuel used in company vehicles). Scope 2 covers emissions from purchased energy (like electricity or heating). The VSME Basic Module requires only these two; Scope 3 is voluntary in Basic.
- Turnover – The total income a company earns from its normal business activities, usually measured over one year.