---
title: "VSME Sustainability Report: Structure, Modules, Datapoints (2026)"
description: "What a finished VSME sustainability report contains: the section order, the Basic and Comprehensive modules, and which document each datapoint comes from."
image: https://www.fiegenbaum.solutions/hubfs/pexels-cluster-images/5922679.jpg
---
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###### 9 min read
# VSME and the EU Voluntary Standard (VS): A Guide for SMEs
By: [Johannes Fiegenbaum](https://www.fiegenbaum.solutions/en/blog/author/johannes-fiegenbaum) on 5/26/25, 10:15 AM · Last updated October 12, 2026
[VSME](https://www.fiegenbaum.solutions/en/blog/tag/vsme) [ESG Strategy & Materiality](https://www.fiegenbaum.solutions/en/blog/tag/esg-strategy-materiality)
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.
Since 24 September 2026, the VSME has been EU law as the voluntary standard, commonly called the Voluntary Standard (VS), set out in [Delegated Regulation (EU) 2026/1560](https://eur-lex.europa.eu/eli/reg_del/2026/1560/oj/eng). The structure of a basic and a comprehensive module remains.
**Table of Contents**
1. [What a VSME report is and who asks for one](https://www.fiegenbaum.solutions/en/blog/sustainability-reporting-vsme-standard-smes#what-the-vsme-standard-is)
2. [Basic and Comprehensive modules: what each one asks for](https://www.fiegenbaum.solutions/en/blog/sustainability-reporting-vsme-standard-smes#basic-and-comprehensive-modules)
3. [What a finished VSME report looks like, section by section](https://www.fiegenbaum.solutions/en/blog/sustainability-reporting-vsme-standard-smes#what-a-finished-report-looks-like)
4. [From datapoints to data: what to collect and where it comes from](https://www.fiegenbaum.solutions/en/blog/sustainability-reporting-vsme-standard-smes#from-datapoints-to-data)
5. [What buyers and lenders request, and the assurance question](https://www.fiegenbaum.solutions/en/blog/sustainability-reporting-vsme-standard-smes#what-buyers-and-lenders-request)
6. [FAQs](https://www.fiegenbaum.solutions/en/blog/sustainability-reporting-vsme-standard-smes#faqs)
## 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](https://eur-lex.europa.eu/eli/reg_del/2026/1560/oj/eng) 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](https://www.fiegenbaum.solutions/en/blog/eu-value-chain-cap-five-gaps-voluntary-standard?hsLang=en), 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.
| **Basic module (B1 to B11)** | **Comprehensive module (C1 to C9)** |
| --- | --- |
| Reporting basis and company data | Business model and sustainability strategy |
| Energy consumption and CO₂ emissions | Climate targets and transition plan |
| Water use and waste | Extended social metrics and gender diversity |
| Workforce, working conditions, health and safety | Human rights processes |
| Compliance and anti-corruption | Governance and sector detail |
It is often confused with the standards for companies in mandatory scope:
| **Standard** | **Who it addresses** | **Materiality work** | **Assurance** |
| --- | --- | --- | --- |
| VSME | Undertakings with up to 1,000 employees, listed or not, reporting voluntarily | None required, fixed disclosure list | None required |
| LSME (draft for listed SMEs) | No longer relevant: listed SMEs were taken out of mandatory scope by Directive (EU) 2026/470 | Not applicable | Not applicable |
| ESRS | Large undertakings in mandatory scope | Full double materiality assessment | Assurance regime applies |
Work from the official artefacts, not a summary. EFRAG publishes the [VSME Standard itself](https://www.efrag.org/sites/default/files/sites/webpublishing/SiteAssets/VSME%20Standard.pdf), 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](https://www.fiegenbaum.solutions/en/blog/vsme-report-template-efrag-standard-2026?hsLang=en).
## 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.
| **Report section** | **Disclosures it carries** | **Typical length** |
| --- | --- | --- |
| Company, reporting boundary, list of omissions | B1, B2 | 1 page |
| Energy and greenhouse gas emissions | B3 | 1 to 2 pages |
| Pollution, biodiversity, water, waste | B4 to B7 | 1 to 2 pages |
| Workforce, health and safety, pay and training | B8 to B10 | 2 pages |
| Convictions and fines for corruption | B11 | half a page |
| Strategy, targets, transition plan, climate risk | C1 to C4 | 2 pages |
| Workforce detail, human rights, governance diversity | C5 to C9 | 2 pages |
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](https://www.fiegenbaum.solutions/en/blog/demystifying-esrs-a-comprehensive-guide-to-european-sustainability-reporting-standards-and-csrd-disclosure-requirements?hsLang=en) later, using the method under [materiality assessment for SMEs](https://www.fiegenbaum.solutions/en/blog/materiality-assessment-smes-esg-compliance-growth?hsLang=en). 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.
| **Typical request line** | **VSME coverage** |
| --- | --- |
| Scope 1 and 2 emissions for the last full year | Basic, energy and emissions |
| Product carbon footprint | Not covered; a separate calculation |
| Headcount, turnover, accident rate | Basic, workforce and health and safety |
| Reduction target and transition plan | Comprehensive only |
| Human rights and supplier due diligence | Comprehensive only |
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](https://www.fiegenbaum.solutions/en/blog/vsme-sustainability-reporting-basic-vs-comprehensive-modules?hsLang=en) lays out the decision, and [sustainability consulting](https://www.fiegenbaum.solutions/en/sustainability-consulting?hsLang=en) covers first reports that have to be defensible from day one.
## FAQs
What does VSME stand for?
The voluntary sustainability reporting standard for non-listed micro, small and medium-sized undertakings, adopted by the European Commission as the official Voluntary Standard on 3 July 2026.
Who may use the VSME, and is it mandatory?
Any undertaking with up to 1,000 employees, listed or not, micro companies included. There is no filing obligation; companies report because customers and banks ask for the data.
What is the difference between VSME and LSME?
VSME is the voluntary standard and, since its adoption as the Voluntary Standard, open to undertakings with up to 1,000 employees whether listed or not. LSME was a draft standard for listed SMEs. It lost its purpose when Directive (EU) 2026/470 took listed SMEs out of mandatory reporting.
Where do I download the standard, and is there a report template?
EFRAG publishes the standard as a PDF, a digital template for entering the disclosures and an XBRL taxonomy. All three are free; there is no official layout for the finished document.
What is the difference between the VSME and the Voluntary Standard (VS)?
The Voluntary Standard is the form the VSME has taken since 24 September 2026: the Commission adopted it as [Delegated Regulation (EU) 2026/1560](https://eur-lex.europa.eu/eli/reg_del/2026/1560/oj/eng). It builds on the VSME Recommendation (EU) 2025/1710 and keeps the basic and comprehensive modules; the Recommendation ceased to have legal effect when the regulation entered into force. What is new is its role as the value chain cap: from financial year 2027, customers in CSRD scope may only request the datapoints listed in Annex II from companies with up to 1,000 employees for their own report. More in my article on the [value chain cap](https://www.fiegenbaum.solutions/en/blog/eu-value-chain-cap-five-gaps-voluntary-standard?hsLang=en).
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