Corporate Sustainability Reporting Directive: Schedule Confirmed, Reporting Obligation Extends to Listed SMEs

On 21 June 2022, the Council of the European Union and the European Parliament reached a provisional agreement on the content of the Corporate Sustainability Reporting Directive (the CSRD) and the schedule for its entry into force. According to the agreement, the reporting obligation would apply to all listed companies, except the smallest micro-enterprises, and non-EU companies that operate in the European internal market and have a revenue that exceeds certain limits. This approach deviates from the proposal published in the spring, according to which the listed SMEs would be exempt from the reporting obligation. 

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The CSRD will enter into force in four phases:

The reporting obligations applied to SMEs will be more limited, and SMEs that do not fall under the scope of application of the Directive can also voluntarily observe them as of 2026.