# CSRD Now Only Applies to Large Companies – How Growth Companies Answer Customer ESG Requests With AI

> EU's Omnibus reform limits CSRD to firms over 1,000 employees. Growth companies still receive customer ESG data requests. Here's how AI compiles that data quickly.

- Published: 2026-09-20
- Author: Master Mind
- Canonical: https://aimaster.fi/en/artikkelit/csrd-koskee-jatkossa-vain-suuryrityksia-nain-kasvuyritys-vastaa-asiakkaan-esg-ky

The European Commission's Omnibus reform, presented on 26 February 2025, limited the Corporate Sustainability Reporting Directive (CSRD) to companies with more than 1,000 employees in practice (European Commission, 26 Feb 2025). A growth company with 5–80 million euros in revenue is no longer directly obligated to report. Yet the email from a customer's procurement department still asks for emissions data, supplier working conditions, and supply chain risk. The reason is simple: the larger customer needs those figures for its own report.

This isn't an exception — it's a pattern. When a large company reports under CSRD, it asks its value chain for the same data it must collect itself. A growth company sits in that chain as a supplier — not directly regulated, but on the receiving end of the request. The answer is usually assembled by hand: one spreadsheet from HR, another from invoicing, a third from supplier contracts. Every customer asks on a slightly different form, and the work repeats every year.

## What did the Omnibus reform actually change in CSRD?

The European Commission's Omnibus package, presented on 26 February 2025, limits CSRD to companies with more than 1,000 employees. The "stop-the-clock" Directive, agreed in April 2025, postponed reporting for wave two and wave three companies. EFRAG published simplified draft ESRS standards in July 2025, and the Commission formally adopted them on 3 July 2026 (European Commission).

## Why does a growth company still get an ESG request if it's outside CSRD's scope?

Because a large company cannot report on its own value chain without asking suppliers for data. The Commission's delegated act also caps how much information a large company can demand from a small supplier — known as the value chain cap. In July 2025, the Commission also recommended a voluntary VSME reporting standard for small and medium-sized companies, so responses to customer requests follow one consistent format (European Commission, 30 July 2025).

## How does an AI agent compile ESG data in practice?

The first step is mapping where the required information actually lives — at AIMASTER this is the [Master Plan](https://aimaster.fi/tuotteet/master-plan) phase. [Master Layer](https://aimaster.fi/tuotteet/master-layer) is a data foundation layer that connects a company's existing systems (CRM, ERP, documents) securely for AI use. Once HR, procurement, and invoicing data are connected, [Master Mind](https://aimaster.fi/tuotteet/master-mind) is a set of AI agents that operates on top of Master Layer's data and runs business processes independently — in this case, reading the customer's questionnaire, pulling the matching data points, and flagging gaps before the deadline.

- The agent reads the customer's ESG questionnaire and identifies which data points map to VSME or ESRS standard fields.
- The agent retrieves the matching figures from ERP, HR, and procurement data connected through Master Layer.
- The agent flags data points that don't exist in any system, so a person fills them in manually.
- The response is saved as a template for the next questionnaire — the form changes, the data foundation doesn't.

## How much time does a manual ESG questionnaire cost compared to an AI agent?

|  | Manual ESG questionnaire | AI agent-compiled response |
| --- | --- | --- |
| Time per request | 2–5 working days | A few hours for review |
| Error risk | Grows with every manual copy | One data source, one truth |
| Repeatability | Starts from scratch every time | Template improves with each request |

## Should a growth company wait until CSRD applies to it directly?

No. Value chain data requests don't wait for a regulatory timeline. A company that responds quickly and consistently stays in the running for larger customers' procurement processes. A slow or incomplete response drops off the vendor shortlist — not because of regulation, but because a competitor answered first.

The first step isn't buying ESG software — it's mapping where the required data already lives and what's missing. The same principle applies to other fragmented company data — see how [unifying customer data for AI agents](https://aimaster.fi/artikkelit/hajanainen-asiakasdata-tappaa-personoinnin-cdp-ai-agenteille) works in practice. Book a [free Master Mind analysis](https://aimaster.fi/analyysi) to find out where your company's ESG data lives right now.

## Frequently asked questions

### Does CSRD sustainability reporting apply to my company?

Not directly, if your company has fewer than 1,000 employees — the EU's Omnibus reform limited CSRD to the largest companies (European Commission, 26 Feb 2025). You may still receive an ESG data request from a customer that reports under CSRD and needs data from its own value chain.

### What is the VSME standard?

VSME is a voluntary sustainability reporting standard for small and medium-sized companies, recommended by the European Commission in July 2025 (European Commission, 30 Jul 2025). It standardizes the data points a growth company uses to answer larger customers' ESG requests.

### Can an AI agent fill out an ESG questionnaire entirely on its own?

Not entirely. The agent compiles the response from existing data and flags missing points, but a person reviews and approves the response before it's sent. This keeps the error risk under control.

### What does compiling ESG data with AI cost?

The cost depends on how fragmented the data is across systems. The sprint model makes cost predictable: development runs in 3-day cycles, and the first step is mapping where the data already lives and what's missing.