VSME Report Example: What a Finished Report Contains, Disclosure by Disclosure

Most people looking up the VSME want to know what goes into the report, not where the standard came from. This page answers that: what the two modules ask for, where those numbers already sit inside a small company, and what a finished report looks like section by section.

What the VSME is and who may use it

The VSME is a voluntary sustainability reporting standard developed by EFRAG for non-listed undertakings: micro, small and medium-sized companies that sit outside the scope of mandatory reporting. There is no filing deadline, no mandatory assurance and no authority to submit it to.

Its purpose is defensive. Large customers and banks ask their suppliers and borrowers for ESG data, and before the VSME every one of them asked differently. The standard gives a small company one answer sheet it can hand to all of them. The European Commission adopted it in July 2026 by delegated act as the official voluntary standard, after an earlier recommendation on voluntary reporting for SMEs, and backs it through its work on digital reporting.

My position: treat the VSME as a data structure first and a document second. A company that builds the collection once can answer a customer questionnaire in an afternoon. A company that writes a report and files it has produced a conforming document with no internal use.

What the VSME asks for: basic module and comprehensive module

The basic module covers eleven disclosures, B1 to B11, and is the entry point. The comprehensive module adds nine further disclosures, C1 to C9, and is only worth the effort when a specific requester asks for something the basic module does not carry, usually transition-plan information or revenue broken down by activity. The module comparison is set out here in detail.

Almost every basic-module datapoint already exists somewhere in the company. The work is collection, not measurement.

Before the first report, collect five things: twelve months of energy and fuel invoices, a payroll export as at the reporting date, the waste contractor statement, the site list with addresses, and any policy documents that already exist. That set covers most of the basic module.

Building the software that collects these disclosures showed me where the basic module breaks in practice, and it is the same three places every time. Unit conversions, because energy arrives as kilowatt hours on one invoice, cubic metres on the next and litres on the fleet card. Contract-type splits, because payroll systems sort part-time, fixed-term and leased staff by their own logic, not by the categories the VSME standard asks for. And waste evidence, because the contractor statement lists container movements while the disclosure wants tonnes by fraction. These are mapping problems, not measurement problems, and they are why a first report takes longer than the datapoint count suggests.

What a finished VSME report looks like: a worked example

The example below is a constructed, typical case rather than a single client: a metal-processing supplier with roughly 120 employees, reporting the basic module because two automotive customers asked for supplier ESG data in the same quarter. The finished document ran to well under twenty pages.

It opened with the basis for preparation: legal form, three sites, employee count, the statement that only the basic module was applied and that the report was not assured. Half a page. The environmental section was the longest part, and almost all of it was table. Electricity and gas came straight from the invoices, diesel from the fleet card statement, Scope 1 and Scope 2 calculated from those figures with published emission factors. Water was one line, because two of the three sites are office and assembly only. Waste ran to a short table by fraction, taken from the disposal contractor statement.

The social section was almost entirely payroll: headcount by contract type and gender, accident figures from the register, training hours, and a sentence on the collective agreement. The governance disclosure was a nil return.

Two lessons from that report. First, the effort sat in the environmental data, and specifically in getting one clean twelve-month energy series across three sites. Everything else was a matter of exporting what already existed. Second, the numbers only became useful once someone looked at them: the energy series showed one site consuming out of proportion to its output, which nobody had noticed because the invoices had never been read side by side. That is the argument for producing the report at all. A structured template shortens the writing, not the collecting.

Who asks for the data, and which datapoints they actually use

Requesters rarely read the whole report. They pull specific disclosure requirements out of it and drop the rest into a file.

The pattern behind this is visible in the reports large companies publish themselves: what a group discloses in its own report is what it later asks its suppliers for. My position on this: report the numbers you would want to steer on anyway, and treat the rest of the basic module as a form to be filled. A short set of metrics with an owner beats a complete report nobody opens.

VSME, CSRD and ESRS: how the voluntary standard fits

Large companies in scope of the CSRD report against the ESRS, a far more demanding set of disclosure requirements. The VSME is the small-company counterpart: same subject matter, a fraction of the datapoints, no double materiality assessment. It is deliberately built so that what an SME reports can be consumed by a customer preparing an ESRS report.

The Omnibus revision narrowed the CSRD to companies above 1,000 employees and above 450 million euros in net turnover, which took most mid-sized companies out of direct scope. It did not remove the questions coming down the supply chain, and it made the VSME the reference for how much a large company may ask of a smaller supplier. How the CSRD side of that exchange works.

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