Sustainability Reporting Made Easy: A Guide to the VSME Standard for SMEs

A VSME report is what a small or medium-sized company hands over when a large customer or a bank asks for sustainability data. This page covers what such a report contains, section by section, which module supplies each section, and where the underlying numbers come from.

What a VSME report is and who asks for one

VSME is short for the voluntary sustainability reporting standard for non-listed micro, small and medium-sized undertakings. EFRAG published the final version in December 2024, and the European Commission adopted it as the official Voluntary Standard by Delegated Regulation (EU) 2026/1560 of 3 July 2026. It is open to undertakings with up to 1,000 employees, so the group that may use it is wider than the label SME suggests.

Voluntary has a narrow meaning: no authority issues a penalty for not filing. It does not mean nobody asks. The requests come from large companies that need supplier data for their own reporting, and from banks that need it for a credit file. The same standard sets the value chain cap, the limit on what such a customer may demand from a smaller supplier, which applies from financial year 2027.

A metal parts supplier with about 90 employees in southern Germany received four ESG questionnaires in twelve months, from three customers and its house bank. No two asked the same questions, and one VSME dataset answered all four.

Basic and Comprehensive modules: what each one asks for

The Basic module (B1 to B11) is the foundation and carries most of the datapoints. Basic on its own is a complete report, not a partial one, but whichever module you choose has to be completed in full: picking single disclosures out of Comprehensive is not a VSME report.

It is often confused with the standards for companies in mandatory scope:

Work from the official artefacts, not a summary. EFRAG publishes the VSME Standard itself, a question and answer platform, a digital template for entering the disclosures, and an XBRL taxonomy for machine-readable filing. A field-by-field walkthrough of that template sits in the VSME report template with all EFRAG datapoints.

What a finished VSME report looks like, section by section

The standard lists disclosures; it does not prescribe a document. Every first report I have worked on ended in roughly the same order, because that is the order a reader follows without a guide. The lengths below are what my own drafts run to, not a rule from the standard.

As a rough estimate, a Basic-only report runs to around 10 pages including the tables. Two things go at the front rather than the back: the reporting boundary, meaning which legal entities and sites the figures cover, and the disclosures you omitted with the reason. Reviewers look for both first. A worked version of this order sits in the VSME report example, disclosure by disclosure.

From datapoints to data: what to collect and where it comes from

Double materiality is not required here; the standard works from a fixed list instead. Run a materiality view only if a customer asks for one or you intend to move to full ESRS later, using the method under materiality assessment for SMEs. The shortcut costs later: without it you have no documented reason why a topic is absent, so the first customer asking why there is no biodiversity figure gets an improvised answer.

Almost every Basic datapoint already exists somewhere in the company. The work is locating it, not measuring it. Pull these before writing anything:

• twelve months of electricity, gas and heating invoices, per site and per meter
• fuel card statements and the vehicle list
• water and waste invoices plus disposal contractor reports
• payroll export for headcount, gender split and turnover, and the accident register
• purchasing records for fuels and refrigerants that no central invoice covers

From building a VSME reporting tool, three fields stall people every time. Splitting electricity between sites that share a meter, where the only honest answer is a documented allocation key. Scope 2, where the standard requires the location-based figure and a market-based one is optional, so label which number is which. And part-year data from a site acquired or closed mid-year, which belongs in the report with the period noted rather than scaled up to a full year.

What buyers and lenders request, and the assurance question

Requests are narrower than the standard. Across the extracted sustainability reports behind my benchmark work, what large companies publish themselves, and therefore what they are able to ask a supplier for, clusters on energy, Scope 1 and 2 emissions, headcount and gender split. The full disclosure set almost never arrives. A questionnaire maps onto the VSME roughly like this.

A VSME report needs no external assurance; that regime covers companies in mandatory scope, not voluntary filers. Buyers and banks do occasionally ask for a limited review anyway, and that request is decided months earlier, by whether every figure traces back to a named document with a person and a date.

My position: a report shaped purely to satisfy a questionnaire gets filed and forgotten. The same invoices also produce an energy cost baseline. Collect once, use twice, or the exercise stays a cost. Where the module choice is still open, the comparison of the two modules lays out the decision, and sustainability consulting covers first reports that have to be defensible from day one.

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