CSRD – the challenge for reporting
If you’re running or advising a medium-sized business based in the UK or EU, you may be asking:
- Are we affected by CSRD?
- When do we need to start preparing?
- What if we’re not directly reporting, but our clients are?
As of 2026, the Corporate Sustainability Reporting Directive (CSRD) is reshaping how sustainability data flows through the entire European business ecosystem. Even with shifting deadlines and ongoing exemptions, medium-sized businesses are already feeling the impact.
This article is for business owners, CFOs, operations leads, and sustainability managers who want clear answers and next steps without getting lost in regulatory language.
Who needs to report under CSRD and when?
Here’s a simple breakdown:
- Large companies in the EU or listed on EU-regulated markets began reporting in 2025.
- Listed medium-sized companies (SMEs) were originally required to start reporting in 2027 (based on FY2026), though recent EU proposals may exempt many entirely or push obligations to 2029.
- Non-listed medium-sized companies are not directly in scope, but many are indirectly affected by their roles in the supply chains of larger reporting entities.
Bottom line: Even if you’re not mandated to publish a CSRD report yet, your customers or investors might already be asking you for sustainability data.
And if you’re UK-based? You’re not subject to CSRD directly, but if you have EU subsidiaries, clients, or investment relationships, expect similar expectations and requests.
Why Medium-Sized Businesses can’t wait
You may not have to publish a report in 2026, but that doesn’t mean you’re off the hook.
CSRD requires large companies to report ESG data across their entire value chain and that includes you.
If your business provides products or services to CSRD-regulated companies, they will need data from you to meet their obligations.
Already in 2025:
- Over 60% of mid-size EU suppliers were asked to provide ESG metrics aligned with CSRD.
- Sustainability questionnaires are now being baked into procurement and vendor onboarding processes.
So whether you’re in manufacturing, logistics, B2B services, or tech, if you’re in the value chain, you’re in the frame.
What you should be doing in 2026
The biggest risk for medium-sized businesses is waiting too long to prepare. Here’s how to start:
- Assess your status
- Are you listed in the EU?
- Do you operate in EU countries or serve EU-headquartered clients?
- Are you receiving ESG data requests?
- Evaluate your current data
- Do you know your Scope 1 and 2 emissions? Any supplier data for Scope 3?
- Are you tracking employee data like diversity, turnover, and training?
- Do you have policies in place on topics like governance, anti-bribery, or sustainability?
- Talk to key stakeholders
- What are your top customers or investors asking for?
- Are banks or lenders requesting ESG disclosures?
- Outline a simple CSRD roadmap
- Begin with a materiality assessment.
- Identify your key data gaps.
- Assign responsibility internally, even if it’s just one person coordinating efforts.
This isn’t just about regulation – It’s Strategy
Many companies start CSRD preparation because they feel they have to. But the businesses that benefit the most see it as an opportunity:
- Stronger customer relationships: Show key clients that you’re reliable and future-ready.
- Competitive advantage: Meet ESG expectations ahead of competitors.
- Operational clarity: Build a clearer view of your business’s risks and impacts.
- Future-proofing: Position your company to respond to future UK or EU regulatory shifts.
By investing early — even with simple steps you reduce risk, avoid late-stage panic, and gain control over your sustainability narrative.
Where to start today
If you’ve read this far, you’re likely looking for practical guidance. We recommend starting with:
- A 60-minute materiality workshop to define what matters most for your business.
- A data gap check – what you already track, what you’ll need, and what can wait.
- A client-focused strategy – identifying who will be asking you for data and when.
The rules may still evolve, but the direction of travel is clear. Whether you’re in scope today or not until 2028, your customers and partners will expect CSRD-aligned data soon.
Final Takeaway
Sustainability reporting isn’t just for the big players anymore. If you’re a medium-sized company in Europe or the UK, now is the time to take small, smart steps.
Don’t wait for a formal obligation to start preparing. Start with what you can control — clarity, data, and planning.
Horizon ESG helps medium-sized businesses build tailored, low-friction sustainability reporting strategies aligned with CSRD and other frameworks. Get in touch for a free CSRD readiness check, no fluff, just clear next steps.
Book a free CSRD readiness check
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