Small international groups should not begin with a generic ESG report. Start by separating three questions: whether a legal reporting duty applies, what information a lender or customer is asking for, and what the group can support with records. Those are different jobs, even when they arrive in the same email.
First: establish whether there is a legal filing duty
EU sustainability reporting rules target companies above specified thresholds and listed companies. The European Commission says the first CSRD companies applied the new rules for financial year 2024, with reports published in 2025. For other cohorts, the timetable changed. Directive (EU) 2025/794, in force since 16 April 2025, postponed by two years the reporting requirements for companies that had been due to start for financial years beginning in 2025 or 2026. A group should therefore check its legal entity, listing status, employee and financial data against the law as transposed in each relevant Member State. A group structure chart is not a scope analysis.
Second: treat customer and bank questionnaires as commercial requests
A group outside a statutory reporting obligation may still be asked for climate, workforce, governance or supplier data by a customer, bank or insurer. That does not turn the questionnaire into a filing obligation. It does mean the answer needs ownership, source records and a clear approval route. Record who asked, the entity and period covered, the stated framework, the requested assurance level, and the deadline. Do not answer for the whole group when the request concerns one supplier or subsidiary.
What is in force, and what is still pending
In force: Directive (EU) 2025/794 changed the application dates for the affected CSRD cohorts. Adopted but not yet applicable at the time of writing: on 3 July 2026 the Commission adopted revised ESRS and a voluntary reporting standard for smaller companies, then sent the measures to the European Parliament and Council for scrutiny. The Commission says the measures apply after the scrutiny period ends, which may be two months and can be extended by two more. Treat the revised standards as a pending implementation item until the legal process is complete; do not describe them as current mandatory rules.
Use a proportionate evidence pack
For many smaller groups, a practical first pack is more useful than a glossy report: legal-entity list; ownership and operating-country map; energy and travel records that actually exist; payroll and workforce-policy records; supplier-code and sanctions controls; incident and complaints log; and the calculation notes behind every number shared externally. State boundaries and gaps. If a figure covers only one country, label it that way. If data is estimated, say who estimated it and why.
Choose the response level before collecting data
- Legal-reporting work: obtain a jurisdiction-specific scope assessment and timetable.
- Counterparty response: answer only the request, with documented boundaries and approvals.
- Voluntary baseline: build a repeatable dataset where customers or finance providers regularly ask for information.
The Commission's voluntary SME reporting recommendation was designed to make it easier for SMEs to answer sustainability-information requests from large companies and financial institutions. It is a reference point, not proof that every SME must publish a report. Keep voluntary reporting separate from legal advice on CSRD scope.
A 30-day operating plan
Week one: map entities, countries, requests and data owners. Week two: collect only records that can be traced to a source. Week three: review material claims with finance, HR, operations and legal owners. Week four: approve a controlled response template and set a refresh date. Stop when a claim cannot be substantiated. A short, accurate response is safer than a broad statement with no audit trail.
FAQ
Does every EU-linked small group need a CSRD report in 2026?
No. Scope depends on the applicable legal rules, the entity or group facts and national implementation. The 2025 Directive postponed application dates for certain later cohorts; verify the position for each relevant entity.
Can a customer require ESG information even if we are outside CSRD?
A customer can make an information request as part of its commercial relationship. The request is not itself a statutory filing duty. Respond with a defined scope and evidence.
Are the revised 2026 ESRS already mandatory?
Not on the Commission's 3 July 2026 description. The measures were sent to Parliament and Council for scrutiny and apply after that process ends.
Official sources
- EUR-Lex — Directive (EU) 2025/794, in force, 16 April 2025
- European Commission — corporate sustainability reporting overview, updated 3 July 2026
- European Commission — revised ESRS and voluntary standard, 3 July 2026
- European Commission — voluntary sustainability reporting recommendation for SMEs
Checked 2 August 2026. This guide distinguishes rules in force from measures under scrutiny. It is not a jurisdiction-specific legal opinion.
