A “Hands-On” Guide To CSRD Obligations For SMEs

Large companies must comply with the CSRD obligations for the first time and prepare an NFS in accordance with CSRD/ESRS. Since they are not yet subject to any sustainability reporting obligations under the NFRD & CSR-RUG, in contrast to the companies subject to reporting obligations in 2024, the companies have at most been able to gain experience in the form of voluntary, partly non-standardized disclosures on sustainability issues. This is shown by a non-representative survey conducted during an ESG webinar: The companies that are required to report for the first time are currently burdened with specific questions and problems, such as system-technical adaptation of the IT infrastructure, identification of supporting software, legal uncertainties, coupled with discussions on the scope of the report. In addition, these companies report numerous operational challenges, such as the hurdles of a first-time preparation of the dual materiality analysis including comprehensible documentation, stakeholder involvement, high administrative costs, interface problems, setting up a sustainability structure, scarcity of resources, lack of added value, unmanageable data management and finding the optimal start time (Dr. Dienst & Partner GmbH & Co. KG, 2024). At the same time, the German economy is complaining in the media about stagnation, increasing bureaucracy and declining productivity (Löhr, 2025). This article provides a “hands-on” guide, especially for small and medium-sized companies that will have to deal with this topic for the first time in the foreseeable future.