Key takeaways
- The Law of 2 December 2024 (NUMAC 2024011683), published in the Belgian Official Gazette on 20 December 2024, transposes the CSRD into Belgian law and introduces the sustainability reporting obligation into the Companies and Associations Code.
- Public interest entities with more than 500 employees (wave 1) published their first assured report in 2025 for financial year 2024: their timeline was not changed.
- Large companies (wave 2) and listed SMEs (wave 3) each benefit from a two-year extension after Belgium transposed the Stop-the-Clock directive in December 2025.
- Omnibus I (published in the EU Official Journal on 26 February 2026) raises thresholds to more than 1,000 employees and more than €450 million in turnover: Belgium must transpose it by March 2027.
- Unlisted SMEs fall outside the direct scope of the CSRD, but face an indirect obligation through information requests from their large customers.
The CSRD sustainability report in Belgium became a legal reality with the Law of 2 December 2024, published in the Belgian Official Gazette on 20 December 2024 (NUMAC 2024011683). This text transposes EU Directive 2022/2464 of the European Parliament and of the Council of 14 December 2022 and introduces into the Companies and Associations Code an entirely new obligation: to produce, have assured and publish each year structured information on the company's environmental, social and governance impact.
For directors of Belgian companies, two questions arise immediately: is my company in scope, and by when? This guide sets out the thresholds, the revised timeline and the effects of the Omnibus I package on current obligations.
The CSRD and its transposition into Belgian law
The CSRD replaces and significantly expands the Non-Financial Reporting Directive (NFRD, Directive 2014/95/EU), which only applied to public interest entities with more than 500 employees. The CSRD substantially widens the scope, strengthens content requirements through harmonised European standards, and makes the sustainability report subject to mandatory assurance by a statutory auditor or an approved independent auditor.
The Belgian Law of 2 December 2024 introduces new provisions into the Companies and Associations Code and also amends the rules on the supervision of company auditors to govern sustainability assurance. Contrary to what a first reading might suggest, the sustainability report is not a standalone document: it is integrated into the annual management report, as required by the European directive.
Which Belgian companies are in scope?
The directive introduces a progressive application in three successive waves, based on size thresholds and the nature of the company.
Wave 1 covers public interest entities (PIEs) already subject to the NFRD: banks, insurance companies and listed companies with more than 500 employees. They are subject to the CSRD from financial year 2024 with no transition period, and published their first assured sustainability report in 2025.
Wave 2 targets other large companies and parent companies of large groups. Under the Companies and Associations Code, a company qualifies as large when it meets at least two of the following three criteria: balance sheet total above €25 million, net turnover above €50 million, or an average workforce above 250 employees. These thresholds are assessed over two consecutive financial years.
Wave 3 covers SMEs listed on an EU regulated market, as well as certain small and medium-sized credit institutions and insurance companies. Unlisted SMEs do not fall directly within the scope of the CSRD in its current form.
| Wave 1 | Wave 2 | Wave 3 | |
|---|---|---|---|
| Scope | PIEs with more than 500 employees | Large companies (2 of 3 criteria) | SMEs listed on EU market |
| Size criteria | 500 employees (NFRD) | Balance sheet ≥ €25M / turnover ≥ €50M / ≥ 250 employees | Listed SMEs |
| Reference financial year | 2024 | 2027 (after Stop-the-Clock) | 2028 (after Stop-the-Clock) |
| First report published | 2025 | 2028 | 2029 |
| Assurance required |
The revised timeline after Stop-the-Clock
The dates initially set by the Law of 2 December 2024 were significantly changed by two successive legislative interventions.
First, the European Commission proposed the so-called Stop-the-Clock directive in 2025, suspending for two years the reporting obligations for waves 2 and 3. The European Parliament approved the text on 3 April 2025. Belgium transposed this directive through an amendment to its Law of 2 December 2024, adopted by the Chamber of Representatives on 4 December 2025. Wave 1 is not affected by this postponement: PIEs with more than 500 employees published their first report for financial year 2024.
- 1
Financial year 2024: wave 1 in force
Published in 2025Public interest entities with more than 500 employees (banks, insurers, listed companies) published their first assured sustainability report for financial year 2024. This timeline was not modified by Stop-the-Clock.
- 2
26 February 2026: Omnibus I published
In force mid-March 2026Omnibus I is published in the EU Official Journal. It enters into force twenty days after publication and raises CSRD thresholds to more than 1,000 employees and more than €450 million in turnover. Belgium has twelve months to transpose it.
- 3
Financial year 2027: wave 2 (after postponement)
Published in 2028Following the two-year postponement from Stop-the-Clock, large unlisted companies (2 of 3 criteria) produce their first ESRS sustainability report for financial year 2027, integrated into the management report filed in 2028.
- 4
March 2027: transposition deadline for Omnibus I
Deadline: March 2027Belgium must have adapted its Law of 2 December 2024 to the new Omnibus I thresholds. If transposition occurs before the first wave 2 reference year (2027), the applicable scope will be Omnibus I (1,000 employees and €450 million), not the original thresholds.
- 5
Financial year 2028: wave 3 (after postponement)
Published in 2029SMEs listed on an EU regulated market publish their first sustainability report for financial year 2028, with publication in 2029.
Omnibus I: a fundamental revision of thresholds being transposed
The most significant change to the CSRD framework came with Omnibus I, published in the EU Official Journal on 26 February 2026. This text substantially raises the conditions for the directive's application.
Under Omnibus I, a company is subject to the CSRD only if it simultaneously exceeds both of the following: more than 1,000 employees and net turnover above €450 million. This cumulative double threshold replaces the two-out-of-three mechanism (balance sheet, turnover, headcount) under the Belgian Law of 2 December 2024.
employees
New cumulative Omnibus I threshold (headcount)
in turnover
New cumulative Omnibus I threshold (net turnover)
transposition deadline
Deadline for Belgium to amend the Law of 2 December 2024
The number of Belgian companies directly subject to the CSRD will decrease considerably once Omnibus I is transposed, compared with the scope of the original Law of 2 December 2024. Companies sitting between the old thresholds (250 employees or €50 million in turnover) and the new ones (1,000 employees and €450 million) should closely monitor the progress of Belgian transposition, expected before March 2027.
The Law of 2 December 2024 remains formally in force until it is amended, but the effective thresholds will likely change before the first wave 2 reference year (2027).
Unlisted SMEs: outside direct scope, but not without risk
Unlisted Belgian SMEs are not directly targeted by the CSRD in its current form, nor in the version resulting from Omnibus I. That said, they are not immune to these obligations.
The indirect pressure is real in sectors where large customers are themselves subject to the CSRD (manufacturing, construction, large retail, business services). For an SME supplier, documenting basic ESG data (energy consumption, headcount, responsible purchasing policy) before the first request is considerably easier than doing so under time pressure.
First steps for companies within scope
For companies entering the scope of wave 2, or wishing to anticipate a change in their situation following Omnibus I transposition, structured preparation is essential well before the first reference financial year.
For founders and company directors in Belgium who wish to structure their company optimally before upcoming regulatory deadlines, company formation services in Belgium make it possible to factor in these constraints from the outset.
What to check before your first report
Determine your wave and thresholds
Check whether your company meets at least two of the three current criteria (balance sheet, turnover, headcount) and which financial year will be your first reference year, taking into account the Omnibus I transposition timeline.
Appoint a sustainability officer
Designate a person or team responsible for coordinating data collection, drafting the report and liaising with the assurance auditor.
Audit your existing data
The ESRS require data on emissions (scope 1, 2 and 3), workforce, governance and the value chain. Identifying gaps two to three years before the filing date is far more effective than doing so under pressure.
Coordinate assurance with your auditor
The CSRD makes assurance of the sustainability report mandatory. Inform your statutory auditor or approved independent auditor now: market capacity for these engagements is still limited in Belgium.
Monitor Belgium's transposition of Omnibus I
If your company falls between the old thresholds (250 employees or €50M in turnover) and the new ones (1,000 employees and €450M), your scope depends directly on the date and content of Belgian transposition, expected before March 2027.
Structure your company ahead of upcoming regulatory deadlines
Monsiegesocial helps founders and company directors in Belgium with company formation and registered address services.
Further reading
- Mandatory electronic invoicing in Belgium: another major regulatory obligation with a similarly phased timeline to the CSRD
- The annual management report of a BV/SRL: the document into which the CSRD sustainability report is integrated for companies within scope
- Cross-border company mobility in Belgium: the other major company law reform stemming from EU law, transposed in 2023
- The text of EU Directive 2022/2464 is available on EUR-Lex; the Belgian transposition law of 2 December 2024 (NUMAC 2024011683) is published in the Belgian Official Gazette
