5 takeaways from the Dutch implementation proposal of the CSRD (Updated Mar 2026)
Disclaimer: New EUDR developments - December 2025
In November 2025, the European Parliament and Council backed key changes to the EU Deforestation Regulation (EUDR), including a 12‑month enforcement delay and simplified obligations based on company size and supply chain role.
Key changes proposed:
- New enforcement timeline: 30 December 2026 for large/medium operators, 30 June 2027 for small/micro operators
- Simplified DDS: One-time declarations for small and micro primary producers
- Narrowed scope: Most downstream actors and non‑SME traders would no longer need to submit DDSs
- New DDS requirement: Estimated annual quantity of regulated products must be included
These updates are not yet legally binding. A final text will be confirmed through trilogue negotiations and formal publication in the EU’s Official Journal. Until then, the current EUDR regulation and deadlines remain in force.
We continue to monitor developments and will update all guidance as the final law is adopted.
Key takeaways
- The Dutch implementation proposal for the CSRD introduces national-level guidance on how companies in the Netherlands should apply the directive, including audit requirements and penalty frameworks.
- With the Omnibus I Directive raising the scope threshold to 1,000 employees and EUR 450M turnover, many Dutch companies previously in scope are now exempt from mandatory CSRD reporting.
- Coolset's CSRD platform helps Dutch companies assess whether they remain in scope and prepare audit-ready sustainability reports aligned with the latest ESRS.
On January 13th 2025, the Dutch government submitted the CSRD implementation proposal to the House of Representatives (Tweede Kamer). This proposal outlines how the Netherlands plans to transpose the EU Corporate Sustainability Reporting Directive into national law, with specific implications for Dutch companies and their sustainability reporting obligations.
This article summarizes the key points of the Dutch implementation proposal and what they mean for Dutch businesses preparing for CSRD compliance.
Key elements of the Dutch CSRD implementation proposal
Scope and timeline
The Dutch proposal aligns with the EU CSRD timeline for Wave 1 companies (large listed companies already subject to NFRD obligations, reporting on FY2024). For Wave 2 companies (other large companies meeting two of: 250+ employees, €50M+ revenue, €25M+ assets), the proposal reflects the EU Omnibus delay, pushing the reporting start to FY2027.
Assurance requirements
The Dutch proposal designates accountants (registered accountants and accounting consultants under Dutch law) as the competent assurance providers for CSRD sustainability statements. This aligns with the existing Standard 3810N framework for sustainability assurance in the Netherlands.
Integration with annual reporting
The proposal requires CSRD sustainability disclosures to be included in the management report (bestuursverslag), consistent with the EU CSRD directive. This places sustainability disclosures within the annual report alongside financial information.
XBRL tagging requirements
Dutch companies will be required to tag their sustainability statements in XBRL format, enabling machine-readable filing. This requirement aligns with the broader EU approach to structured data in sustainability reporting.
Implications for Dutch companies
Dutch companies planning for CSRD should note the following:
- Wave 1 companies (large NFRD reporters) should already be in compliance for FY2024 reporting
- Wave 2 companies benefit from the EU Omnibus delay but should continue preparation
- Assurance engagements in the Netherlands will follow Standard 3810N until the EU-wide ESSA standard takes effect
- Finance teams should be involved early given the integration with annual reporting requirements
Monitoring developments
The Dutch implementation proposal is subject to parliamentary review and may be amended. Companies should monitor legislative developments through the Tweede Kamer and NBA communications for the latest updates.
For broader context on the EU Omnibus proposal and its impact on CSRD scope and timelines, see our dedicated guide. For guidance on CSRD compliance preparation, see our CSRD overview and audit readiness guide.
Understand the key changes introduced by the Omnibus Proposal and learn how to move forward with confidence under the evolving EU sustainability legislation
on mobile screens
to experience this demo.
↘ Check if your documentation meets PPWR requirements
This free compliance checker scans your packaging documentation and maps it against mandatory PPWR data requirements, giving you a clear view of your compliance status. Get actionable insights on documentation gaps before they become compliance issues.
.webp)
