Are SMEs required to prepare an ESG report?
Most SMEs are not directly legally required to prepare a sustainability report – the 2026 EU Omnibus Package has further eased these direct obligations. In practice, however, there is growing indirect pressure from large corporate clients subject to the CSRD, banks (MaRisk 2023), and public tenders, all of which increasingly demand ESG disclosures and sustainability reporting.
Direct Reporting Requirements: Which Companies Are Affected?
Since the EU Omnibus Package 2026, only companies with more than 1,000 employees and more than €450 million in net turnover are directly subject to CSRD reporting requirements. The former thresholds (250 employees, €50 million in turnover, €25 million in balance sheet total) no longer apply, so far fewer companies than originally planned fall under direct CSRD compliance. For companies with up to 1,000 employees, the VS standard provides a voluntary reporting framework.
Indirect Pressure on SMEs
Even without direct regulatory obligations, SMEs are indirectly affected through three main channels: CSRD-compliant clients requesting ESG data from their supply chain (Scope 3); banks assessing ESG risks for credit decisions under the 2023 MaRisk guidelines; and public as well as private tenders increasingly incorporating sustainability criteria.
Conclusion: Taking Proactive Action Pays Off
SMEs that voluntarily publish a VS report today are fully prepared for all inquiries, securing supply chain relationships and improving their financing conditions. With ESG Lift, your first ESG report is ready in just 1–3 hours, starting from €890/year.
Are SMEs required to prepare a sustainability report? Direct obligations, indirect pressure from CSRD and banks u2013 the current 2026 legal framework for SMEs regarding ESG reporting.