Policy Briefing — Listed SMEs finalise CSRD controls before FY 2026 reporting
Listed SMEs that do not opt for the temporary deferral must collect CSRD data for financial years starting 1 January 2026, making November the last checkpoint to secure ESRS processes, opt-out decisions, and proportional assurance plans.
Executive briefing: CSRD Article 5(2)(c) requires listed small and medium-sized enterprises (excluding micro-enterprises) to report in accordance with ESRS for financial years starting on or after 1 January 2026, with an optional deferral until 2028. Firms proceeding without the opt-out must lock proportionality decisions, supply-chain questionnaires, and limited assurance scope by November 2026 to meet FY 2026 close.
Mandatory deliverables
- ESRS for SMEs. Prepare to apply the forthcoming proportionate ESRS set, covering sustainability policies, metrics, and targets tailored to SME scale.
- Deferral governance. Boards choosing the Article 5 opt-out must publish an explanation and reassess annually; those proceeding must document rationale for proportional disclosures.
- Assurance scope. Align limited assurance arrangements, ensuring auditors understand SME simplifications and data boundaries.
Program actions
- Data collection. Build lightweight data models for greenhouse gas emissions, workforce metrics, and supply-chain impacts suited to SME resources.
- Stakeholder communication. Coordinate investor and lender briefings explaining the chosen path (opt-out or early compliance) and associated disclosure granularity.
- Control design. Implement pragmatic evidence retention, segregation of duties, and review checkpoints that satisfy limited assurance without over-engineering.
Enablement moves
- Leverage industry associations and chambers of commerce for shared templates and benchmarking on SME ESRS adoption.
- Integrate CSRD data with existing local GAAP and tax reporting systems to reduce manual reconciliation.