CSRD : What Swiss SMEs Need to Know
The CSRD is a European directive. But its effects cross borders — and reach directly or indirectly into the order books of Swiss SMEs. Even if SMEs are not yet subject to the CSRD themselves, there is a strong chance that their stakeholders — starting with their clients — are.
Here is how to get ahead of it so you don’t lose contracts — and how tools like the VSME standard can help structure your approach, starting today. As the Canton of Geneva notes in its practical guide on non-financial reporting: “Doing nothing has a cost.”
Here is how to get ahead of it so you don’t lose contracts — and how tools like the VSME standard can help structure your approach, starting today. As the Canton of Geneva notes in its practical guide on non-financial reporting: “Doing nothing has a cost.”
Text published 21 April 2026
In 2026, one acronym is cropping up with increasing frequency in commercial exchanges between Swiss SMEs and their European clients and suppliers: CSRD. The Corporate Sustainability Reporting Directive is a European directive that requires large companies to publish detailed reports on their environmental, social and governance (ESG) performance. Yet even if Swiss SMEs are not directly caught by its provisions, they are — and will increasingly — feel its practical effects in their day-to-day commercial relationships.
At SpringWorks, we are already seeing this play out with our clients: Swiss SMEs suddenly receiving ESG questionnaires from their European partners, or losing tenders because they cannot provide sustainability data. This is not a distant trend — it is today’s reality. Practical tools exist to help prepare effectively, at an SME’s scale, without drowning in complexity.
The CSRD is not simply an evolution of traditional CSR reporting. It represents a fundamental shift in how companies account for their impact on the world.
- A broader-reaching European directive. The CSRD replaces the former NFRD and has applied since 2024 to large European companies with more than 500 employees, progressively extending to those with more than 250 employees or over EUR 40 million in turnover.
- Standardised and audited requirements. CSRD disclosures are governed by 12 ESRS (European Sustainability Reporting Standards) — 10 thematic (environment, social, governance) and 2 cross-cutting — and must be verified by an independent auditor. These standards cover 82 mandatory reporting topics.
- Double materiality: a founding concept. Companies in scope must assess not only the impact of ESG issues on their financial performance ("financial materiality", or outside-in), but also the impact of their own activities on the environment and society ("impact materiality", or inside-out). A powerful tool for steering a company's sustainability strategy.
- The value chain under the spotlight. This is where SMEs come in: large companies subject to the CSRD must report on the emissions and practices across their entire value chain — including suppliers, subcontractors and service providers.
- A phased timeline. Large companies (>500 employees): report from 2025 (FY 2024). Mid-sized listed companies: from 2026. Listed SMEs and non-EU companies active in Europe: progressively through to 2029.
Who is in scope? A summary table
| Company | CSRD? | Timeline (post-Omnibus 2025) | Impact on your SME |
|---|---|---|---|
| Large listed EU company (Wave 1, >500 employees) |
Yes | Report from 2025 (FY 2024) |
ESG data already being requested |
| Large unlisted EU company (Wave 2, >1,000 empl. AND >EUR 450m TO) |
Yes | From 2028 (FY 2027) |
Suppliers included — VSME-level data requested |
| Non-EU company (Wave 4, >EUR 450m TO in EU) |
Yes | From 2029 (FY 2028) |
Subsidiaries and value chain within scope |
| Swiss SME, non-listed (<1,000 employees) |
Not directly | VSME voluntary — start now | EU partners in scope: you fall within their reporting perimeter |
In early 2025, the EU launched a major simplification of the CSRD. The number of companies directly in scope was reduced by 85%. Entry thresholds were raised (>1,000 employees AND >EUR 450m turnover), and application timelines were pushed back for large unlisted (Wave 2) and non-EU (Wave 4) companies. For SMEs, this simplification does not change the underlying dynamic: the trickle-down effect through the value chain remains very real.
Switzerland is not an EU member state, and unlisted SMEs with fewer than 250 employees are not directly subject to the CSRD. However, companies working with European clients, partners or suppliers that are subject to the directive fall within their reporting perimeter. The CSRD also applies to non-European companies generating more than EUR 150 million in turnover in the EU, or with a subsidiary there exceeding certain thresholds.
In practice, here is what is happening:
- CSR questionnaires landing in your inbox. European clients — subject to the CSRD or with an established CSR approach — are sending increasingly detailed forms to assess your carbon footprint, social practices and governance. Failing to respond risks being delisted.
- Tenders integrating ESG criteria. 42% of SMEs with a formalised CSR strategy have won a contract on the strength of that commitment (Geneva Chamber of Commerce, 2025). This trend will only intensify with the CSRD.
- Pressure moving up the chain. A European multinational subject to the CSRD will naturally favour subcontractors capable of providing reliable ESG data. As the Canton of Geneva's guide highlights, anticipating these requests is a direct competitive advantage: "CSR-ready" SMEs will become tomorrow's preferred partners.
- Tightening access to finance. Banks are increasingly factoring ESG criteria into their lending decisions. An SME without sustainability data may be offered less favourable terms.
A founding concept of the CSRD, double materiality is also a powerful strategic tool for any SME wishing to structure its CSR approach rigorously — even without any legal obligation to do so.
Traditional CSR approaches focused on financial materiality: an issue was considered relevant only if it had an impact on the company's economic performance. The CSRD goes further by adding impact materiality: the obligation to account for the impact of your activities on the environment and society, even where that impact has no direct financial effect.
In concrete terms, a double materiality analysis allows you to:
- Identify ESG issues that represent a risk or opportunity for your company (e.g. climate risks affecting your operations, opportunities linked to the circular economy).
- Assess the impact of your activities on those same issues (e.g. your carbon footprint, your responsible procurement practices, your working conditions).
- Prioritise the most relevant actions and monitoring indicators for your sector and business model.
The Canton of Geneva's guide notes that climate change (ESRS E1) is considered by the CSRD to be a material issue for every company without exception.
In response to the complexity of the CSRD, EFRAG (the European Financial Reporting Advisory Group) developed in December 2024 a standard specifically designed for non-listed SMEs: the VSME (Voluntary Sustainability Reporting Standard for non-listed SMEs).
The VSME is voluntary, but it represents the most direct response to the data requests your European partners subject to the CSRD will be sending your way. Its objectives are threefold:
- Respond to ESG data requests from major corporate clients and suppliers.
- Facilitate access to bank financing and investors.
- Improve internal management of sustainability issues to strengthen competitiveness and resilience.
Two progressive modules, scaled to your SME's size:
| VSME Module | For whom? | Key content |
|---|---|---|
| Basic Module (B1–B11) |
All SMEs — mandatory starting point | Energy, GHG (scope 1 & 2), water, waste, social metrics, governance |
| Comprehensive Module (C1–C9) |
SMEs with financial partners or major corporate clients | Strategy, GHG reduction targets, climate risks, diversity |
The Basic Module covers the essentials: energy consumption, greenhouse gas emissions (scope 1 & 2), water, biodiversity, waste management, workforce characteristics, health and safety, remuneration and governance. This is the minimum your commercial partners will expect.
The Comprehensive Module goes further: business model and strategy, quantified GHG reduction targets, identified climate risks, human rights in the value chain, gender diversity at management level. It meets the requirements of the most demanding investors and major clients.
What the VSME asks of you in practice — a few examples:
- Energy consumption in MWh, broken down between renewable and non-renewable sources
- Scope 1 GHG emissions (direct sources) and scope 2 (purchased energy) in tCO₂eq
- Carbon intensity (GHG / turnover)
- Waste management practices (total generated, including hazardous, and proportion recycled)
- Gender pay gap (mandatory from 150 employees)
- Any CSR certifications obtained (B Corp, ISO 14001, EcoEntreprise…)
If you already use a framework such as ISO 26000 or GRI, or if you have carried out a carbon footprint assessment, you already hold a significant portion of the data needed for VSME reporting. It is often a matter of completing and structuring what already exists.
Faced with these challenges, the Canton of Geneva has taken the initiative. The Department of Economy and Employment (DEE) published in 2024 a comprehensive practical guide on non-financial reporting, specifically aimed at local SMEs. The guide notably highlights that:
- Sustainability is no longer optional, but a necessity — one that also brings concrete advantages: stronger competitiveness, better risk management, increased attractiveness as an employer and business partner, and improved access to finance.
- Cantonal resources exist to support SMEs: the OCEI (Office for Economic Development and Innovation) sustainability network, grant programmes (SIG Éco21, Mon Entreprise Durable by Coptain…), and complementary guides on specific topics such as decarbonisation.
- Concrete local examples inspire action: Romande Energie and Swissquote already publish standalone sustainability reports; Nespresso, Ricola and Eldora are cited as references in non-financial reporting.
The Geneva guide also provides a comparative framework across the main CSR standards (ISO 26000, GRI, B Corp, CSRD/ESRS), helping SMEs assess where they currently stand and identify pathways towards VSME or CSRD-compatible reporting.
You do not need to be a large company to get ready. Here is a pragmatic, step-by-step approach designed for the resources of Swiss SMEs.
Step 1: Assess your real exposure
The first question is simple: among your clients, partners and suppliers, how many are subject to the CSRD? If you work with European companies of more than 250 employees, the answer is probably "several". A quick audit of your commercial portfolio is enough to assess the urgency.
Step 2: Conduct a CSR diagnosis / double materiality analysis
Before collecting data, identify which ESG issues are material for your business — those on which your company has a significant impact and/or which represent a risk or opportunity for your performance. This work is the foundation of any credible reporting, whether based on the VSME, ISO 26000 or the CSRD.
Step 3: Collect and structure your ESG data
Scope 1 and 2 carbon emissions (from your energy and fuel bills), energy consumption, waste management, HR indicators (gender pay equity, training, workplace accidents)… The data your clients will request is specific and quantified. Putting a simple but reliable collection system in place is a priority. Numerous free tools exist for SMEs to calculate GHG emissions (SME Climate Hub, Business Carbon Calculator, etc.).
Step 4: Choose your level of VSME ambition
Based on your SME's size, your sector and your partners' expectations, opt for either the Basic or the Comprehensive Module. If you have already conducted a carbon footprint assessment, hold an ISO 26000 certification or are working towards B Corp, you have a solid foundation to build on — it is often a matter of completing and structuring what already exists.
Step 5: Formalise, communicate — and shift the narrative
A simplified sustainability report, a dedicated section on your website, a mention in your commercial proposals… The visibility of your CSR commitment becomes a genuine commercial differentiator. But beware of two symmetrical pitfalls:
- Greenwashing: communicating on commitments that lack substance. Informed clients, professional buyers and AI tools that fact-check corporate claims are not easily fooled. The consequences — legal, reputational and commercial — are real.
- Greenhushing: staying silent about your commitments for fear of being perceived negatively or accused of greenwashing. This is the opposite mistake: your stakeholders expect transparency and evidence.
Standard structure for a sustainability report (source: Canton of Geneva guide):
→ Introduction & management message
→ Methodology & scope
→ Materiality analysis
→ ESG results & KPIs
→ Case studies & initiatives
→ Future objectives → Conclusion
The CSRD is not a punishment handed down to large companies. It is a clear signal to the entire economy: sustainability is no longer optional — it is now a condition of access to the market. As the Canton of Geneva's guide puts it: "doing nothing has a cost."
For Swiss SMEs, the stakes are clear: those who act now — leveraging tools like the VSME, structuring their non-financial reporting and activating available support — will be tomorrow's preferred partners. Those who wait risk being excluded from increasingly demanding value chains.
The good news? You do not need to be a large company to prepare well. With the right method, the right support and the right tools, every SME can turn the CSRD into a lasting competitive advantage.
The right approach? Transparency grounded in evidence, considering your CSR approach not as a response to a regulatory constraint, but as a strategic advantage. Operational resilience, cost reduction, access to new markets, talent attraction — these are the tangible outcomes your sustainability commitment produces. That is the language your clients, partners and lenders want to hear.
At SpringWorks, we support Swiss SMEs in turning regulatory challenges into performance drivers. Our approach is structured in three stages:
- CSR diagnosis & double materiality analysis. We assess your current CSR maturity, identify the material issues for your business and evaluate your degree of exposure to CSRD requirements through your commercial partners. Concrete, jargon-free analysis.
- Strategy, VSME & action plan. We co-build with you a CSR roadmap aligned with your business challenges and your clients' requirements — including choosing the right VSME module, defining key indicators and structuring a measurable action plan.
- Reporting & certification support. We guide you towards the most appropriate labels and certifications (B Corp, EcoEntreprise, ISO 14001…) and help you structure your first sustainability report — VSME-compatible and aligned with your European partners' expectations.
And because cost is often a barrier, we also help you identify and activate the available cantonal and federal grant programmes — in some cases covering up to 50% of costs (Viva-Vaud, SIG Éco21, Mon Entreprise Durable in Geneva, Reffnet…).