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

The VSME is the voluntary sustainability reporting standard for small and medium-sized enterprises outside CSRD scope. It exists to give an SME one answer when a customer or a bank sends a sustainability questionnaire. This page covers what the standard is, what its two modules ask for, and where the official documents live.

What the VSME standard is

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; the European Commission adopted it as the official Voluntary Standard by delegated act on 3 July 2026. It is a reporting standard in the same family as the ESRS, but stripped down to what a company without a sustainability department can actually produce.

More on this point: VSME Report Example: What a Finished Report Contains, Disclosure by Disclosure.

Voluntary has a narrow meaning here: no authority issues a penalty for not filing. It does not mean nobody asks. The same standard defines the value chain cap, the limit on what a CSRD-mandated customer may demand from a smaller supplier.

It is for non-listed companies below the CSRD thresholds, which after the Omnibus revision start at more than 1,000 employees and 450 million euros in turnover. Micro companies are explicitly included.

A metal parts supplier with about 90 employees in southern Germany received four different 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 standard is modular. The Basic module (B1 to B11) is the foundation and carries most of the datapoints. The Comprehensive module (C1 to C9) adds further datapoints for companies whose lenders push past the basics: strategy, climate transition plan, human rights, gender diversity. Together that is the 147 datapoints usually quoted for the EFRAG standard. Reporting Basic only is a complete report, not a partial one.

Work from the official artefacts, not a summary. EFRAG publishes the VSME Standard itself, a Q&A platform, a digital template for filling in the disclosures, and an XBRL taxonomy for machine-readable filing. The digital template is what most SMEs searching for a VSME report template are after; a field-by-field walkthrough sits in the VSME report template with all EFRAG datapoints.

My position: the module choice is usually made backwards. Companies pick Comprehensive because it sounds thorough, then stall on a transition plan they have no budget for. Pick Basic, finish it, and let the first request that goes beyond it decide whether Comprehensive is worth a year.

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

Double materiality is not required for a VSME report; the standard works from a fixed list of disclosures instead. Run a materiality view only if a customer asks for one or you intend to move to full ESRS later, using the method set out under materiality assessment for SMEs.

Almost every Basic datapoint already exists somewhere in the company. The work is locating it, not measuring it.

The same supplier assembled its first Basic dataset from eleven existing documents, and spent its real effort on splitting electricity between two sites that shared a meter. Definitions for a handful of key ESG metrics take longer to settle than the numbers do. From the second reporting year onwards prior-year comparatives belong in the report, so document how each figure was derived.

What buyers and lenders actually request

Value chain requests are narrower than the standard. Across the 1,401 extracted CSRD and ESRS reports behind my benchmark work, the recurring supplier ask is emissions and workforce data, rarely the full disclosure set. A questionnaire maps onto the VSME roughly like this.

From building a VSME reporting tool, the fields that stall people are the same three: splitting energy by source and site, choosing between the location-based and market-based Scope 2 method, and pinning down which headcount definition applies. None is hard; all three are decisions nobody has been asked to make before.

My position: a report shaped purely to satisfy a questionnaire gets filed and forgotten. The same eleven documents that produce a VSME report also produce an energy cost baseline and a supplier comparison. Collect once, use twice, or the exercise stays a cost.

Quality checks and assurance for a voluntary report

A VSME report needs no external assurance. The CSRD assurance regime applies to companies in CSRD scope, not to voluntary filers. Buyers and banks occasionally ask for a limited review anyway, and a report built on documented sources survives that request without a project.

Before publishing, check that:

• every figure traces back to a named document, with person and date recorded
• the reporting boundary matches the legal entity in the accounts
• omitted disclosures are marked as omitted, with a reason, rather than left blank
• one person outside the preparing team has read it end to end

That traceability is what makes the second and third customer answer cheap. Where the choice between the modules 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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