- Since the Omnibus, most SMEs are out of the mandatory CSRD scope: the trigger is more than 1,000 employees and €450M net turnover.
- Listed SMEs, once planned to be in scope, were removed by the Omnibus package.
- SMEs remain solicited indirectly: their in-scope clients request ESG data across the value chain.
- The voluntary VSME standard (EFRAG) lets SMEs answer these requests without full CSRD constraints.
Are SMEs concerned by the CSRD?
For most SMEs, the answer is now no. Since the Omnibus, the CSRD applies only above the thresholds of more than 1,000 employees and €450M net turnover — see the CSRD thresholds and who is concerned.
Listed SMEs: removed from the scope
An earlier CSRD wave was meant to cover listed SMEs with a lighter, later regime. The Omnibus package removed listed SMEs from the mandatory scope, further narrowing the perimeter.
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Indirect pressure via the value chain
Large in-scope companies must report on their value chain, so they request ESG data from their SME suppliers. In practice, many SMEs must provide reliable data even without being directly bound.
The VSME: a voluntary standard for SMEs
To answer these requests proportionately, SMEs can use the voluntary VSME standard developed by EFRAG — far lighter than the full CSRD, with no mandatory audit. It is a pragmatic way to structure ESG reporting and stay a preferred supplier.
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CSRD and SMEs — Key Takeaways
| Key point | Explanation |
|---|---|
| Mandatory scope | More than 1,000 employees and €450M net turnover — most SMEs are out |
| Listed SMEs | Removed from the scope by the Omnibus |
| Indirect impact | In-scope clients request ESG data via the value chain |
| Solution | Voluntary VSME standard (EFRAG), no mandatory audit |
