CSRD: industrial SMEs in the pipeline

The EU's Corporate Sustainability Reporting Directive (CSRD) sets this timeline:

• January 2025: companies already under NFRD (~12,000 in EU)
• January 2026: large non-listed companies (>250 employees, >€50M revenue, >€25M assets)
• January 2027: listed SMEs (~150 in Spain, but may affect supplier SMEs)
• January 2029: non-listed SMEs (voluntary until 2029)

Why it affects SMEs

While most industrial SMEs aren't required until 2029, their large customers already are. Consequence: they request sustainability data from suppliers.

What they request

A typical SME industrial supplier receives forms with:

• Scope 1 emissions: direct fuels (gas, diesel, natural gas)
• Scope 2 emissions: electricity consumed
• Scope 3 emissions: supply chain (transport, waste, etc.)
• Gender equality policy: women in management, pay gap
• Human rights: anti-modern-slavery policy, child labor in suppliers
• Waste: tons generated, percentage recycled

What to do now (proactively)

• Calculate Scope 1+2 emissions (free MITECO calculators)
• Documented equality policy (required for >50 employees since 2022)
• Supplier ethical code (Chamber of Commerce templates)
• Climate action plan (IDAE offers free consultations)

Cost of inaction

SMEs not responding to ESG forms from large companies:

• Contract loss: 47% of large companies already exclude suppliers without ESG data
• Procurement penalty: lower margins negotiated
• Reputational risk: ending up on sector blacklists

CSRD is here. The question isn't whether it'll affect SMEs, but how prepared they'll be when their turn comes.

Share