Does your company fall under the CSRD? The short answer
For most SMEs, the answer has been no since the 2026 simplification: the CSRD (the corporate sustainability reporting directive) is directly aimed at large and listed enterprises. Following the revision, the thresholds are set such that smaller companies generally do not have to prepare a full sustainability report themselves under that directive.
Yet that is not the whole story. Even if you are not yourself subject to reporting obligations, you may encounter it because a large customer, your bank or your insurer is subject to the CSRD and needs data from their own value chain — including from you. This happens via a questionnaire, not through your own legal obligation. The difference between those two is precisely what this article is about.
Which enterprises are directly subject to the CSRD
The directive distinguishes a number of categories of enterprises that must report themselves: listed enterprises and large non-listed enterprises that exceed certain thresholds for turnover, balance sheet total and number of employees. Those thresholds are set out in the directive itself and have been adjusted with the 2026 simplification, as a result of which some of the previously designated enterprises now fall outside it.
Whether an enterprise is precisely above or below those thresholds is a factual question that differs per enterprise and is ultimately answered on the basis of the official text, not on the basis of a rule of thumb. If you are uncertain about your own figures, consulting a lawyer or accountant is the recommended course of action; we cannot make that assessment for you here.
Why you as an SME will still encounter it
An enterprise that is itself subject to the CSRD must also report on its value chain — meaning suppliers, contractors and other parties it does business with. To obtain that information, such an enterprise sends questionnaires to its SME suppliers. That is why an installation company, a cleaning company or a transport operator with fewer than a thousand employees suddenly receives an ESG questionnaire from its largest customer, without ever falling under the directive itself.
Since March 2026, a limit has been set to that practice: the so-called value chain obligation. A reporting enterprise may not demand more sustainability information from a supplier with a thousand employees or fewer than is set out in the voluntary EU standard for non-listed SMEs, the VSME. Anything beyond that, you as a supplier may refuse. That is precisely what esgia's cap check does for you: assessing per question whether it falls within that limit, and if not, how you communicate that properly back to your customer.
How to determine whether you are yourself subject to reporting obligations
Because the thresholds have been changed after 2026 and not every enterprise has the same structure — think of a holding company with multiple subsidiaries, or an enterprise that has just crossed or fallen below a threshold — a self-assessment is needed. The official text of the directive on EUR-Lex is the starting point; a lawyer or accountant can place that text alongside your annual figures. We cannot make a statement about your specific situation here, but in a few questions can show what that typically amounts to for your type of business.
What to do if you do receive a questionnaire, but are not yourself subject to reporting obligations
Most SMEs that encounter the CSRD do so not as reporters, but as suppliers answering questions. For that situation, the distinction between "do I need to know this" and "may my customer ask me this" is the most important. Under the topics that have been worked through per situation you will find background on concepts such as scope 1, 2 and 3 and the VSME standard, so you can read a questionnaire without first having to take a course on it.
It is important to understand that this is not a matter of certification or audit: no recognized body exists for these SME sustainability reports, and an answer to a questionnaire is not a mark of conformity. It is a factual exchange of data that you usually already have in-house, such as your energy bill or payroll records. On the page that explains where the information comes from is how that translation process works.
Are you unsure whether your company itself falls under the CSRD, or particularly if you are receiving questionnaires as a supplier? Take the free quick-scan or read through the topics — both are available without an account and will give you clarity within half an hour about where you stand exactly. For questions not covered here, see an overview with other frequently asked questions ready.