2027 is not a year of one big deadline. It is a year in which several changes land in different places, and the pattern only shows up when you put them side by side.
The short version: the obligation to report narrows, while the obligation to prove things widens. Fewer companies file sustainability reports. More companies have to produce defensible numbers, because their customers, their tender authorities and their advertising regulators now ask for them.
Here is the calendar.
1 January 2027: CSRD's revised scope takes effect
The Omnibus package narrowed CSRD to companies above 1,000 employees and €450 million turnover. That revised scope applies to financial years beginning on or after 1 January 2027.
Two consequences. Many mid-sized companies that spent 2024 and 2025 preparing are now out of scope, including some first-wave companies that had already reported. And companies remaining in scope still need value chain data, which they get by asking suppliers.
The net effect for a mid-sized business: your own reporting obligation may have vanished, while the questions from your large customers intensify. That is the gap VSME fills.
1 January 2027: ProRail moves to CO2-Prestatieladder 4.0
ProRail applies Handbook 4.0 to new tenders published from 1 January 2027, following Rijkswaterstaat, which has awarded on 4.0 since 1 July 2026.
Version 4.0 replaces five levels with three tiers at higher ambition, emphasising structural CO2 reduction including within the supply chain. ProRail applies preliminary fictitious reductions to bid prices from 2027: 4% at tier 1, 7% at tier 2, 10% at tier 3.
Version 3.1 cannot be used after 14 January 2027. Certification takes months, so a contractor holding a 3.1 certificate in late 2026 has a scheduling problem rather than a paperwork problem.
1 February 2027: CBAM certificate sales begin
The CBAM definitive regime started on 1 January 2026. Certificates go on sale from 1 February 2027, covering emissions embedded in 2026 imports. The first annual CBAM report for 2026 imports, with certificate surrender, is due 30 September 2027.
The timing trap: certificates are bought in 2027 but priced against what you imported in 2026. Importers of steel, aluminium, cement and fertiliser who treat this as a 2027 problem are collecting 2026 data retrospectively, which is harder and produces worse numbers.
Importers may report verified actual values or Commission default values. Where reliable country-specific data is unavailable, defaults are based on the average emission intensity of the ten highest-emitting exporters, adjusted regionally. In practice, actual supplier data is generally more favourable than defaults, which is the argument for collecting it.
April 2027: NHS supplier requirements tighten
From April 2027, NHS suppliers must publicly report targets and emissions and publish a Carbon Reduction Plan addressing global emissions across Scope 1, 2 and 3, aligned to the NHS net zero target.
This moves beyond PPN 006, which covers UK emissions and a defined Scope 3 subset. The expansion to global scope and full Scope 3 brings purchased goods and services into play, usually the largest category and the one never previously calculated. Details in our NHS Evergreen guide.
Through 2027: EmpCo enforcement
The claims rules took effect on 27 September 2026 with no transition period. 2027 is the first full year of enforcement.
Generic environmental claims and offset-based neutrality claims are prohibited. Forward-looking targets require a costed implementation plan and independent verification. The exposure here is not size-dependent, so companies out of CSRD scope are fully in scope for this. See what the rules prohibit.
Already in force, still landing: BPM 2.0
The revised Dutch determination method took effect on 1 July 2026, aligning to EN 15804+A2 and expanding impact categories from 11 to 19, alongside a 15% tighter MPG requirement for offices and a first-time requirement for utility buildings.
Through 2027 this works through the permit pipeline, project by project. Manufacturers whose EPDs are still on the +A1 basis are progressively designed out. See why scores changed.
The pattern
Read the calendar together and one direction emerges.
Reporting obligations narrowed. Proof obligations did not. CSRD covers fewer companies. Meanwhile procurement frameworks, customer questionnaires and advertising rules all now require defensible numbers, and none of them care how large you are.
Product-level data is becoming the unit of exchange. CBAM needs embedded emissions per import. BPM 2.0 needs product EPDs. Claims need product footprints. Corporate-level reporting does not answer any of these.
Scope 3 is where the work moved. NHS Evergreen, the CO2-Prestatieladder's supply chain emphasis, CBAM, and value chain requests under VSME all point at the same category, and it is the one most organisations have never calculated.
Lead times are the binding constraint. Certification takes months. Supplier data collection takes longer. EPD production takes time. Every deadline in this list is really a deadline minus that lead time.
What to do about it
Work out which of these actually apply to you, which is usually fewer than the list suggests. Then work backwards from the earliest one that does.
For most companies the practical starting point is the same regardless of which deadline bites: a corporate footprint with a boundary that holds steady, Scope 3 on the categories that matter, and product-level data where products are what your customers ask about.
Keeping that on a consistent platform rather than rebuilding annually is what makes the second and third year cheap.
Tell us which of these apply to you.
Sources: European Commission Omnibus I package, CO2-Prestatieladder, Regulation (EU) 2023/956 as amended, NHS England Evergreen supplier assessment, Directive (EU) 2024/825, Nationale Milieudatabase.
