- 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 Standard, VS (formerly VSME), lets companies with 1,000 employees or fewer 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. From financial years starting on or after 1 January 2027, a client subject to the CSRD can no longer require from a supplier with 1,000 employees or fewer more than the information set out in the VS, and this also covers non-EU suppliers. The supplier can refuse questions that go beyond this value chain cap, and the client must flag them.
The VSME: a voluntary standard for SMEs
To answer these requests proportionately, SMEs can use the VSME, now the Voluntary Standard (VS) set by Delegated Regulation (EU) 2026/1560. It is open to any company outside the CSRD with 1,000 employees or fewer, far lighter than the full CSRD and requires no audit. Companies with 10 employees or fewer can leave out the more complex environmental data (see VS for companies with 10 employees or fewer). 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 | VS (formerly VSME), open to companies with 1,000 employees or fewer, no mandatory audit |
