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| 30) | What should an SME expect to receive in terms of requests for sustainability information as a consequence of the CSRD and ESRS? Paragraphs 132 and 133 of ESRS 1 (General requirements) set out transitional provisions that limit the value chain information that undertakings within the scope of the CSRD have to report and/or collect from actors in their value chain during the first 3 years (98). The extent to which SMEs are asked to provide sustainability information by undertakings as a consequence of the CSRD and ESRS will, during the first 3 years of implementation, be strongly influenced by whether undertakings that fall within the scope of CSRD make use of these transitional provisions regarding value chain reporting. Notwithstanding the transitional provisions referred to above, SMEs should expect undertakings that fall under the scope of CSRD to apply ‘reasonable effort’ to collect from actors in their value chains the information they need in order to comply with ESRS. In accordance with the answer to the previous question, the size and resources, the technical readiness and the proximity of the actor in the value chain are among the criteria that can be used to establish what constitutes ‘reasonable effort’. Therefore, smaller SMEs that have never voluntarily reported sustainability information, that are not connected with severe negative impacts and are not 1st tier suppliers or customers of undertakings that fall within the scope of the CSRD should, at least during the first years of application of the reporting requirements, be less exposed to expectations to have and share sustainability information. Larger SMEs that have previously reported sustainability information (for example because they apply EMAS or other environmental or sustainability certification or reporting schemes) and SMEs that are 1st tier suppliers or customers of undertakings that fall within the scope of the CSRD may be exposed to higher expectations to have and share sustainability information. EFRAG is currently developing two sustainability reporting standards for SMEs: a mandatory one for listed SMEs (LSME ESRS) and a voluntary one for non-listed SMEs (VSME). LSME ESRS will establish the maximum level of sustainability information that ESRS can require an undertaking that falls within the scope of the CSRD to obtain from SMEs in its value chain. VSME will be designed to become a reference point for all actors in the market, to ensure that the reporting effort of CSRD and non-CSRD undertakings is proportionate.

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Source: EUR-Lex (Cellar) · retrieved 2026-09-07 · Text as adopted (Official Journal); later amendments are not incorporated in this text.