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VSME Standard 2026: Free Report Template with All 143 EFRAG Data Points

By: Johannes Fiegenbaum on 4/2/26 1:50 PM

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Why Do SMEs Suddenly Need to Report Sustainability Data?

Picture this: your largest customer — a listed corporation — sends you a 40-page questionnaire. Topic: sustainability. They need your GHG emissions, water consumption, waste figures. Not out of curiosity, but because the CSRD now requires them to report on their entire value chain — and you are part of it.

Or another scenario: you are renewing a credit line. Your bank asks for a “sustainability profile” for the first time. No legal obligation, but the interest rate depends on it.

Both situations are everyday reality for European SMEs in 2026. And this is exactly why EFRAG developed the VSME standard: a structured format that lets SMEs deliver sustainability data without building a dedicated reporting team.

This page shows you what the VSME contains, which data you actually need, and how to get started pragmatically. You will find the complete template with all data points for reference below.

What Is the VSME Standard — and What Is It Not?

The VSME (Voluntary Sustainability Reporting Standard for non-listed SMEs) was published by the European Commission on 30 July 2025. The name says it all: voluntary and for non-listed SMEs.

In practice, “voluntary” means: no law forces you. But your business partners, banks, and funding bodies effectively do. The VSME is the standard format in which these stakeholders expect your data. If you do not use VSME, you will still answer the same questions — just in a different format each time.

What sets the VSME apart from the full ESRS:

  • Scope: 147 data points instead of 1,100+ in the full ESRS
  • Modular: Start with the Basic Module only (100 data points). The Comprehensive Module (47 more) is optional.
  • Compatible: Your VSME data flows directly into your customers' CSRD reports — no duplicate effort.

Basic or Comprehensive Module — What Do You Actually Need?

The honest answer for most SMEs: the Basic Module is enough to start. It covers everything your customers and banks typically ask for — from energy and emissions to workforce data and anti-corruption.

The Comprehensive Module becomes relevant when you are explicitly asked for strategy disclosures (e.g. for green financing) or when you want to prepare for potential CSRD applicability.

Basic Module

100

data points across 27 disclosures

General company info, energy & emissions, pollution, water, waste, biodiversity, workforce, health & safety, remuneration, anti-corruption

Comprehensive Module

47

additional data points across 13 disclosures

Strategy & business model, GHG reduction targets, climate transition plan, human rights, revenue from controversial activities

What Is Inside the VSME Basic Module?

The Basic Module contains 100 data points. That sounds like a lot — but in practice it is less work than you might expect. A large portion are simple yes/no fields or dropdown selections. The real effort concentrates in three areas:

  1. Energy and emissions (B03): Total energy consumption in MWh, broken down by electricity, self-generation, and fuels. Plus Scope 1, 2, and 3 GHG emissions in tCO₂e. In our experience working with SMEs: if you know your electricity bill and heating costs, you already have 70% of this data.
  2. Waste and water (B06–B07): Water withdrawal, water consumption, waste by type. Your disposal invoices and water meter readings typically cover this.
  3. Workforce (B08–B10): Employee count by contract type, gender, and country. Turnover rate, work-related accidents, remuneration. Most of this data already sits in HR.

The remaining areas — general company information, pollution, biodiversity, governance — are usually short entries with minimal data collection effort for most SMEs.

All data points in detail: Click any section below to see the specific fields required.

General — 29 data points

B01.000 Basis for Preparation 16 data points
Data Point Format
Basis for preparation (Basic Module Only or Basic & Comprehensive Module) select
Basis for reporting (consolidated or individual basis) select
Report contains disclosures from the previous reporting period that remain unchanged Yes / No
List of disclosures for which no changes are reported compared to the previous period reporting multi-select
Link to previous report containing disclosures that remain unchanged text
List of omitted disclosures deemed to be classified or sensitive information multi-select
Undertakings legal form select
Other undertaking's legal form text
NACE sector classification codes multi-select
Assets €
Turnover €
Number of employees number
Employee counting methodology select
Type of number of employees select
Country of primary operations and location of significant assets select
Description of sustainability-related certification(s) or label(s) narrative
B01.100 List of subsidiaries 2 data points
Data Point Format
Name of the subsidiary text
Registered address of the subsidiary text
B01.200 List of sites 5 data points
Data Point Format
Address of site text
Postal code of site text
City of site text
Country of site select
GPS Location of site text
B02.000 Practices, policies and/or future initiatives for transitioning towards a more sustainable economy 3 data points
Data Point Format
Sustainability issues addressed by practice, policy and/or future initiative multi-select
Practice, policy and/or future initiative is publicly available Yes / No
Undertaking has set a target which is related to a policy Yes / No
B02.100 Cooperative specific disclosures 3 data points
Data Point Format
Description of the effective participation of workers, users or other interested parties or ... narrative
Financial investment in the capital or assets of social economy entities €
Description of limits to the distribution of profits connected to the mutualistic nature or ... narrative

Environment — 51 data points

B03.000 Total Energy Consumption 1 data points
Data Point Format
Total energy consumption MWh
B03.100 Breakdown of energy consumption 3 data points
Data Point Format
Energy consumption from electricity MWh
Energy consumption from self-generated electricity MWh
Energy consumption from fuels MWh
B03.200 Estimated Greenhouse Gas Emissions 8 data points
Data Point Format
Gross Scope 1 greenhouse gas emissions tCO₂e
Gross location-based Scope 2 greenhouse gas emissions tCO₂e
Gross market-based Scope 2 greenhouse gas emissions tCO₂e
Total (gross) location-based Scope 1 and Scope 2 GHG emissions tCO₂e
Total (gross) market-based Scope 1 and Scope 2 GHG emissions tCO₂e
Gross Scope 3 greenhouse gas emissions tCO₂e
Total (gross) location-based GHG emissions tCO₂e
Total (gross) market-based GHG emissions tCO₂e
B03.300 Greenhouse Gas Emissions intensity 4 data points
Data Point Format
Location-based Scope 1 and Scope 2 Greenhouse Gas Emissions intensity tCO₂e/€
Market-based Scope 1 and Scope 2 Greenhouse Gas Emissions intensity tCO₂e/€
Total location-based Greenhouse Gas Emissions intensity tCO₂e/€
Total market-based Greenhouse Gas Emissions intensity tCO₂e/€
B04.000 Pollution of air, water and soil: availability of public disclosure 2 data points
Data Point Format
Publicly available disclosure Yes / No
URL or link to the publicly available disclosure text
B04.100 Pollution of air, water and soil: amount of emissions 3 data points
Data Point Format
Amount of emission to air tonnes
Amount of emission to water tonnes
Amount of emission to soil tonnes
B05.000 Sites in biodiversity sensitive areas 3 data points
Data Point Format
Area of site in biodiversity sensitive area hectares
Site located in a biodiversity sensitive area Yes / No
Site located near a biodiversity sensitive area Yes / No
B05.100 Biodiversity - on Land-use 4 data points
Data Point Format
Total sealed area hectares
Total nature oriented area on-site hectares
Total nature oriented area off-site hectares
Total use of land hectares
B06.000 Water Withdrawal 2 data points
Data Point Format
Total amount of water withdrawn from all sites m³
Amount of water withdrawn at sites located in areas of high water-stress m³
B06.100 Water Consumption 2 data points
Data Point Format
Water discharge from undertaking production processes m³
Total water consumption m³
B07.000 Description of circular economy principles 2 data points
Data Point Format
Undertaking applies circular economy principles Yes / No
Description of how circular economy principles are applied narrative
B07.100 Breakdown of waste by type 6 data points
Data Point Format
Waste diverted to recycle or reuse (volume) m³
Waste diverted to recycle or reuse (mass) tonnes
Waste directed to disposal (volume) m³
Waste directed to disposal (mass) tonnes
Total waste recycled, reused and directed to disposal (volume) m³
Total waste recycled, reused and directed to disposal (mass) tonnes
B07.200 Total Hazardous and Non-Hazardous waste 6 data points
Data Point Format
Total Hazardous waste generated (mass) tonnes
Total Non-Hazardous waste generated (mass) tonnes
Total waste generated (mass) tonnes
Total Hazardous waste generated (volume) m³
Total Non-Hazardous waste generated (volume) m³
Total waste generated (volume) m³
B07.300 Breakdown of annual mass-flow of relevant materials used by the undertaking 3 data points
Data Point Format
Name of the material used text
Weight of material used tonnes
Volume of material used m³
B07.400 Total annual mass-flow of materials used by the undertaking 2 data points
Data Point Format
Total weight of material used tonnes
Total volume of material used m³

Social — 18 data points

B08.000 Workforce - General characteristics: type of contract 2 data points
Data Point Format
Number of permanent contact employees number
Number of temporary contract employees number
B08.100 Workforce - General characteristics: gender 4 data points
Data Point Format
Number of male employees number
Number of female employees number
Number of other gender employees number
Number of non-reported gender employees number
B08.200 Workforce - General characteristics: country of employment 1 data points
Data Point Format
Number of employees for country of employment contract number
B08.300 Workforce - General characteristics: turnover rate 1 data points
Data Point Format
Employee turnover rate %
B09.000 Workforce - Health and safety 3 data points
Data Point Format
Number of recordable work related accidents in the reporting period number
Rate of recordable work related accidents in the reporting period number
Number of fatalities as a result of work-related injuries and work-related ill health number
B10.000 Workforce - Remuneration, collective bargaining and training 7 data points
Data Point Format
Employees receive pay equal or above minimum wage determined by national law or collective b... Yes / No
Percentage gap in pay between female and male employees %
Percentage of employees covered by collective bargaining agreements %
Average number of annual training hours per male employee number
Average number of annual training hours per female employee number
Average number of annual training hours per other gender employee number
Average number of annual training hours per non-reported gender employee number

Governance — 2 data points

B11.000 Convictions and fines for corruption and bribery 2 data points
Data Point Format
Total number of convictions for the violation of anti-corruption and anti-bribery laws number
Total amount of fines for the violation of anticorruption and antibribery laws €

When Is the VSME Comprehensive Module Worth It?

The Comprehensive Module adds 47 data points — but it is a different type of work. While the Basic Module mostly asks for numbers, the Comprehensive Module requires strategic narratives: business model description, climate strategy, human rights policies. These are texts that many SMEs have not yet formalised.

A pragmatic approach: use the Comprehensive Module as an internal strategy exercise. The questions EFRAG asks — “How does your business model contribute to sustainability?”, “What climate risks do you see?” — are precisely the questions that board members and investors should be answering anyway. The VSME gives you a structure for that conversation.

General — 7 data points

C01.000 Strategy: Business Model and Sustainability – Related Initiatives 4 data points
Data Point Format
Description of significant groups of products and/or services offered narrative
Description of significant market(s) the undertaking operates in narrative
Description of main business relationships (e.g. key suppliers, customers distribution chann... narrative
Description of key elements of strategy that relates to or affects sustainability issues narrative
C02.000 Description of practices, policies and/or future initiatives for transitioning towards a more sustainable economy 3 data points
Data Point Format
Description of practices, policies and/or future initiatives narrative
Most senior level within its employees that is accountable for policies narrative
Description of the target of practices, policies or future initiatives narrative

Environment — 18 data points

C03.000 Greenhouse Gas Emissions Reduction Baseline and Target Year 2 data points
Data Point Format
Greenhouse gas emission reduction target base year year
Greenhouse gas emission reduction target year year
C03.100 Greenhouse Gas Emission Reduction Targets 8 data points
Data Point Format
Gross Scope 1 greenhouse gas emissions tCO₂e
Gross location-based Scope 2 greenhouse gas emissions tCO₂e
Gross market-based Scope 2 greenhouse gas emissions tCO₂e
Total (gross) location-based Scope 1 and Scope 2 GHG emissions tCO₂e
Total (gross) market-based Scope 1 and Scope 2 GHG emissions tCO₂e
Gross Scope 3 greenhouse gas emissions tCO₂e
Total (gross) location-based GHG emissions tCO₂e
Total (gross) market-based GHG emissions tCO₂e
C03.200 Disclosure of list of main actions the entity seeks to achieve its targets 1 data points
Data Point Format
Disclosure of list of main actions the entity seeks in order to achieve its targets narrative
C03.300 Transition plan for undertakings operating in high climate impact sectors 2 data points
Data Point Format
Description of a transition plan for climate change mitigation, including an explanation of ... narrative
Date of adoption of transition plan for undertaking not having adopted transition plan yet date
C04.000 Climate risks 5 data points
Data Point Format
Description of climate-related hazards and climate-related transition events narrative
Disclosure of how it has assessed the exposure and sensitivity of its assets, activities and... narrative
Time horizons of any climate-related hazards and transition events identified narrative
Disclosure of whether it has undertaken climate change adaptation actions for any climate re... Yes / No
Potential adverse effects of climate risks that may affect its financial performance or busi... narrative

Social — 13 data points

C05.000 Additional (general) workforce characteristics 3 data points
Data Point Format
Female-to-male ratio at management level for the reporting period number
Total number of self-employed workers without personnel that are working exclusively for the... number
Total number of temporary-workers provided by undertakings primarily engaged in employment a... number
C06.000 Additional own workforce information - Human rights policies and processes 4 data points
Data Point Format
Undertaking has a code of conduct or human rights policy for its own workforce Yes / No
Type of content covered by the code of conduct or human rights policy for its own workforce multi-select
Specification other types of content covered by the code of conduct or human rights policy text
Undertaking has a complaint handling mechanism for its own workforce Yes / No
C07.000 Severe negative human rights incidents 6 data points
Data Point Format
Undertaking has confirmed human rights incidents in its own workforce Yes / No
Type of human right related to the confirmed incident multi-select
Specification of other human rights related to the confirmed incident narrative
Description of actions take to address the confirmed incidents narrative
Undertaking aware of any confirmed incidents involving workers in the value chain, affected ... Yes / No
Specification of any confirmed incident involving workers in the value chain, affected commu... narrative

Governance — 9 data points

C08.000 Revenues derived from activities 7 data points
Data Point Format
Revenue derived from controversial weapons (anti-personnel mines, cluster munitions, chemica... €
Revenue derived from cultivation and production of tobacco €
Total revenues derived from fossil (fuel, coal and gas) sector €
Revenue derived from coal €
Revenue derived from oil €
Revenue derived from gas €
Revenue derived from chemical production €
C08.100 Exclusion from EU benchmarks 1 data points
Data Point Format
Undertakings are excluded from any EU reference benchmarks that are aligned with the Paris A... Yes / No
C09.000 Gender diversity ratio in the governance body 1 data points
Data Point Format
Gender diversity ratio in governance body number

All 147 data points — guided, not alone.

VSMEasy walks you through every field with pre-filled suggestions, automatic GHG calculations, and built-in validation.

Try VSMEasy Free →

How Do You Start Your First VSME Report?

1. Assign responsibilities before collecting data

The most common mistake: someone gets “sustainability” dropped on their desk and tries to fill every field alone. That does not work. VSME data comes from at least four departments:

  • Management / Finance: Revenue, assets, legal form, NACE codes (B01)
  • Operations / Facilities: Energy, emissions, waste, water (B03–B07)
  • HR: Headcount, work-related accidents, remuneration (B08–B10)
  • Compliance: Anti-corruption, human rights processes (B11, C06–C07)

A short kick-off meeting with clear ownership — “who delivers what by when?” — saves weeks.

2. Start with data you already have

Many data points already exist — just not in a sustainability report. Electricity bills, heating invoices, waste disposal records, HR master data: that is the core of B03 through B10. Collect what is already available before planning new data collection.

3. Prioritise gaps

It is better to submit a report with a documented gap than no report at all. The VSME explicitly allows this: in B01.000 you list which disclosures you have omitted and why. Typical first-year gaps: Scope 3 emissions and detailed biodiversity data.

4. Use the EFRAG Excel or a dedicated tool

EFRAG provides a free Excel template (version 1.2.0, available in 11 EU languages) with built-in validation. For SMEs that prefer a guided experience, VSMEasy offers automatic calculations and step-by-step workflows.

What Are the Most Common VSME Reporting Mistakes?

  1. Mixing up Scope 2 methods: The VSME asks for both location-based and market-based Scope 2 emissions. Location-based uses your country's grid average factor; market-based uses the factor from your actual energy contract. Both must be reported separately.
  2. Forgetting GHG intensity: B03.300 requires emissions per euro of revenue. Make sure you use the same revenue figure from B01.000.
  3. Mixing waste units: Sections B07.100 and B07.200 accept mass (tonnes) and volume (m³). Pick one and stay consistent — otherwise you will trigger validation errors.
  4. Ignoring Scope 3: Even the Basic Module asks for Scope 3 emissions. If you cannot calculate precisely, provide an estimate and document your methodology. An honest estimate is better than a gap.
  5. Working alone: VSME is a cross-functional topic. Treating it as a solo task leads to incomplete data or abandoned reports.

How Does the VSME Become a Competitive Advantage?

Most SMEs see the VSME as a chore. That is understandable — but it leaves value on the table. Three perspectives worth considering:

Better conversations with banks: Sustainability data is increasingly part of credit risk assessment. A VSME-compliant report shows your bank that you understand and manage your risks — which can directly improve your financing terms.

Stronger supplier positioning: Large companies under CSRD prefer suppliers who can deliver structured ESG data. Proactive VSME reporting makes you the preferred partner — rather than a gap in your customer's value chain report.

Better operational management: The data you collect for the VSME — energy consumption, waste ratios, employee turnover — are also operational management KPIs. Knowing your energy consumption means you can optimise it. Measuring turnover means you can act on it.

Frequently Asked Questions

Is the VSME mandatory?

No. The VSME is voluntary. However, the data it covers is increasingly requested by business partners and banks. A structured VSME report saves significant time compared to answering ad-hoc ESG questionnaires.

How long does the first report take?

Data collection typically takes 2–4 weeks, spread across departments. The actual report filling with a guided tool like VSMEasy takes 2–4 hours. Year two is significantly faster because data sources and processes are already in place.

What is the difference between VSME and ESRS?

The ESRS apply to large listed companies and contain 1,100+ data points. The VSME is the simplified version for SMEs with 147 data points. Both standards are compatible — your VSME data flows directly into your customers' CSRD value chain reports.

Do I need to fill every data point?

No. The VSME allows justified omissions — list them in section B01.000. However, aim for maximum completeness: every gap reduces the report's value for your stakeholders.

Do I need the Comprehensive Module?

Not in the first year for most SMEs. Start with the Basic Module. Add the Comprehensive Module when your bank or largest customer specifically asks for climate strategy or human rights due diligence.

What format does the report need?

No format is mandated. EFRAG provides a free Excel template that can optionally be converted to machine-readable XBRL.

Is the VSME available in my language?

The official EFRAG template is available in 11 EU languages including English, German, French, Spanish, Italian, Dutch, and more.

How are GHG emissions reported?

The Basic Module requires Scope 1 (direct), Scope 2 (purchased energy — both location-based and market-based), and Scope 3 (value chain) in tCO₂e, plus intensity ratios per euro of revenue.

Ready to Start Your VSME Report?

VSMEasy walks you through every data point — with guided workflows and one-click XBRL export. Turn compliance into competitive advantage.

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No credit card required. Basic Module included free.
Johannes Fiegenbaum

Johannes Fiegenbaum

ESG and sustainability consultant based in Hamburg, specialised in VSME reporting and climate risk analysis. Has supported 300+ projects for companies and financial institutions – from mid-sized firms to Commerzbank, UBS and Allianz.

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