Which companies must comply with the CSRD?
- Wave 1 – Listed companies have been subject to CSRD since the reporting year 2024
- Wave 2 – Large companies that are not public interest entities (PIEs), have more than 1,000 employees and turnover above €450 million, will be CSRD-compliant in calendar year 2028 (financial year 2027).
- There is also a CSRD obligation for non-European companies with more than €450 million turnover in the EU and whose subsidiaries and branches in the EU generate more than €200 million turnover.
- Wave 3 – Smaller SMEs report voluntarily from 2026 under the VSME guidelines (Voluntary Small and Medium Enterprises).
Which companies must comply with the CSDDD?
The Corporate Sustainability Due Diligence Directive (CSDDD), which requires organisations to take appropriate measures to monitor their value chain for human rights and environmental risks, has been postponed by one year. Companies will be subject to CSDDD from 26 July 2029 if they have more than 5,000 employees and a turnover of €1.5 billion.
The scope of the value chain to be mapped has also been reduced. Companies may now focus on parts of their activity chain where actual and potential negative impacts are most likely. A company may prioritise assessing negative impacts involving direct business partners. Efforts should be based on reasonably available information. This reduces the need to pass on information requests to smaller partners. In addition, reporting sector-specific information is now voluntary rather than mandatory.
Dutch legislation on CSRD and CSDDD
The directive enters into force twenty days after publication in the Official Journal of the European Commission. Member States will then implement the directive into their national laws. We expect the Netherlands to adopt the European Commission’s decisions without changes.
Legislation is a means, not an end
Complying with sustainability directives is not the only reason to work towards a future-proof business and a sustainable strategy for your company. CSRD and CSDDD have helped create a common standard and a new norm for transparency and responsible business. They provide useful tools to help organisations gain insight into (chain) risks and opportunities.
Ensure you can effectively respond to questions about your sustainability performance from key stakeholders, such as market players, direct stakeholders, or commercial partners. Transparency and clear communication on sustainability give you the chance to stand out from competitors.
“There has been a lot of discussion recently about the reporting burden under CSRD. The downside is that this puts sustainability in a negative light. While reporting and sustainability, although related, are absolutely not synonyms. Reporting is a discipline; sustainability is something you simply need to do because the world is on the wrong track: action is needed!”
Tjeerd Krumpelman, Partner | Impact House
Want to know the best next steps for your organisation?
A double materiality analysis (DMA) helps your organisation focus on which sustainability information to manage and report. Read how Boekestijn, transport and freight services, approached this.
Start with the (simplified) European Sustainability Reporting Standards (ESRS) or the voluntary reporting standard for SMEs (VSME) to make your sustainability ambitions and results visible within your organisation.
Would you like to discuss these insights further? Our specialists are happy to help.
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