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By Leïla KAMARA*
The original CSRD (2022/2464) placed SMEs at a structural competitive disadvantage compared to non-EU companies on sustainability disclosure timelines. Under that framework, EU-based SMEs were required to report by 2029 (based on 2028 financial year), while non-EU companies faced no equivalent obligations until 2030. The revised CSRD (2026/470) substantially addresses this asymmetry.
SMEs are no longer at a relative disadvantage: non-EU corporations meeting the revised eligibility threshold—1,000 employees and EUR 450m net income—are now treated almost equally with large EU corporations, subject to one additional year of lead time (2028 for EU corporations versus 2029 for non-EU corporations). (CSSF Omnibus Package, May 2026)...
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