CSRD Supply Chain Effects: What It Means for Swiss SMEs

The EU Corporate Sustainability Reporting Directive (EU CSRD Directive) does not directly apply to Swiss companies, but its supply chain provisions have far-reaching consequences for Swiss SMEs that trade with EU partners.

CSRD Basics and Updated Timeline

The CSRD requires large EU companies and listed SMEs to report using the European Sustainability Reporting Standards (ESRS). The EU Omnibus I regulation (entered into force 19 March 2026) has significantly changed the phase-in schedule:

• Wave 1 — FY 2024 (reporting in 2025): Large public-interest entities (500+ employees). Already in effect.
• Wave 2 — FY 2027 (was FY 2025): Other large companies meeting size criteria. Delayed by 2 years.
• Wave 3 — FY 2028 (was FY 2026): Listed SMEs. Delayed by 2 years.

Omnibus I also narrowed the scope: the new thresholds require 1,000+ employees AND EUR 450M+ net turnover. Under these rules, data requests to value chain partners with fewer than 1,000 employees are limited to the voluntary EFRAG VSME Standard.

Critically, ESRS still requires reporting on the entire value chain, including suppliers.

Impact on Swiss SMEs

If you supply to EU companies subject to CSRD, expect:

Data Requests

EU clients need value chain data: GHG emissions (Scope 1 and Scope 2), energy consumption, workforce statistics, governance policies. Under Omnibus I, these requests to SME suppliers should be limited to VSME data points.

Supplier Assessments

Companies without sustainability data may be rated poorly in procurement decisions.

Contractual Requirements

Some EU companies embed sustainability reporting into supplier contracts.

How VSME Helps

The VSME standard was designed by EFRAG precisely for SMEs in value chains of reporting companies, and was formally adopted as EC Recommendation 2025/1710 on 30 July 2025:

• Provides data points EU clients need in a standardised format
• Uses a framework endorsed by EFRAG (the same body behind ESRS)
• Covers environment, social, and governance in one document
• Demonstrates proactive commitment to sustainability
• Under Omnibus I, explicitly recognised as the limit of what can be requested from SME value chain partners

Steps to Prepare

1. Identify EU exposure: List clients headquartered in the EU or with significant EU operations.
2. Anticipate requests: Review VSME indicators B3–B12.
3. Collect data: Energy bills, fleet records, HR data, governance documents.
4. Create your declaration: A completed VSME report is a ready-made response to any questionnaire.
5. Update annually: Keep your data current.

Do not wait until your biggest EU client sends a sustainability questionnaire. Start your declaration today with QuickVSME.

Sources

• EU CSRD Directive
• EFRAG VSME Standard