If you run a company in the Netherlands, sustainability reporting is no longer one question but three. Is your company covered by the EU reporting rules? Which Dutch rules already apply to you today? And what will your customers and banks ask for, whatever the law says?
This guide answers all three, with links to the official sources.
Who must report under CSRD, and when
The EU Corporate Sustainability Reporting Directive (CSRD) is the headline rule, but its arrival in Dutch law has been slow. The implementation bill was submitted to parliament in January 2025 and has not been finalised. The European Commission has opened infringement proceedings against the Netherlands over the delay. The SER explains the Dutch implementation route and its current status.
The scope also changed. The EU omnibus directive, in force since 18 March 2026, raised the reporting threshold to companies with more than 1,000 employees and over 450 million euros in annual turnover. That removes most Dutch companies from the legal duty to report. RVO explains the omnibus changes in plain terms.
Two practical conclusions. If your company meets the new thresholds, keep preparing a report that follows the European Sustainability Reporting Standards (ESRS): the duty is coming even if the Dutch law is late. If your company fell out of scope, the data requests do not stop. Large customers, banks, and investors that still report will keep asking Dutch suppliers for emissions figures, policies, and targets so they can complete their own value-chain reporting.
The rule most companies miss: mobility reporting (WPM)
While CSRD gets the attention, a Dutch rule already applies today. Employers with 100 or more employees must report the kilometres their people travel for commuting and business trips each year, split by transport mode and fuel type. Reports go through the RVO portal for work-related mobility (WPM).
The report covering 2025 travel is due by 30 June 2026. From 1 January 2026 the threshold rises to 250 employees, so 2025 is the last reporting year for employers with between 100 and 250 employees. If that is you, this deadline still applies.
The energy-saving obligation
Business locations that use at least 50,000 kWh of electricity or 25,000 cubic metres of natural gas per year must implement every energy-saving measure that pays for itself within five years, and report the measures they have taken under the four-yearly information duty. RVO describes the obligation and who it covers.
This is not a disclosure rule in the CSRD sense, but the same underlying data (energy use per site, measures taken, savings achieved) shows up in customer questionnaires and emissions calculations, so it pays to keep it organised once.
What Dutch companies should prepare
- Check your CSRD position under the amended thresholds: over 1,000 employees and over 450 million euros turnover means prepare; under them means prepare for customer requests instead.
- If you employ 100 people or more, collect this year's commuting and business-travel data now rather than reconstructing it in June.
- Keep an energy register per site: consumption, measures taken, and payback estimates.
- Build one defensible emissions baseline (Scope 1 and 2, and the Scope 3 categories your customers ask about). Every rule and every questionnaire draws on the same numbers.
Common mistakes
The most expensive mistake is waiting for the Dutch CSRD law before doing anything. Customers, banks, and group parents ask for sustainability data on their own schedule, and an answer built in a rush looks like one. The second mistake is treating WPM as an HR chore: it is emissions data, and companies that connect it to their carbon footprint answer both obligations with one dataset. The third is missing the threshold changes and either over-preparing for a duty that no longer applies or under-preparing for one that still does.
How Keslio can help
We help Dutch companies work out which rules apply, build the emissions baseline behind them, and turn it into reporting customers and regulators accept. Start with a free emissions estimate or see our reporting and communications support.
Sources and further reading