VSME Reporting: Basic vs Comprehensive Module Explained

VSME stands for the voluntary sustainability reporting standard for non-listed micro, small and medium-sized undertakings. It has two modules, a basic one and a comprehensive one, and for most companies the entire first reporting project comes down to picking the right one. That choice is rarely about company size. It is about who asked for the report, what the requester does with it, and which data already exists inside the company.

What the VSME is and which companies use it

The VSME is EFRAG's voluntary reporting standard for small and medium-sized enterprises that are not listed on a regulated market, from micro entities upward. Nothing in it is compulsory. No company is legally required to publish a VSME report, and no authority sanctions one that does not. In July 2026 the European Commission adopted it as the official voluntary standard by delegated act, which gives it a standing that no market-driven questionnaire template has.

The companies that end up using it are almost never doing so out of enthusiasm for reporting. A metal parts supplier with 120 employees receives an ESG questionnaire from a customer that reports under CSRD itself, or a bank asks for emissions figures when a credit line comes up for renewal. The questionnaire arrives with fifty fields in a customer-specific layout. The VSME report answers it once, in a form the next customer accepts as well.

How the VSME relates to CSRD, ESRS and the omnibus changes

The full ESRS apply to companies inside the CSRD scope. After the omnibus revision that scope is far smaller than originally planned: reporting is limited to companies above 1,000 employees and 450 million euro net turnover, for financial years starting in 2027.

That did not remove the data requests, it moved them. Large reporters still need value chain data and still ask suppliers for it. What changed is that the same package caps how much they may ask. An in-scope company may not demand more sustainability information from an SME supplier than the voluntary standard contains, and that cap applies from financial year 2027 onwards. For a supplier this turns the VSME into a defensive document: it answers the request and draws a line around it.

Basic vs comprehensive: the two modules side by side

The basic module runs from B1 to B11 and is designed to be answerable from records a company already keeps. The comprehensive module adds C1 to C9 on top: strategy, targets, climate risk and a set of workforce and governance disclosures that mostly do not exist as data yet and have to be produced.

The basic module is enough when the report exists to answer customer questionnaires, when nobody has asked for reduction targets in writing, and when this is the first reporting year. Go comprehensive when a bank has tied loan conditions to targets, when a tender asks for a transition plan, or when the company expects to grow into CSRD scope. A report template helps with either one.

What the report is actually used for: customers, banks, tenders

Most of my clients are mid-market companies in trade and industry, and the requester determines the module far more reliably than any decision matrix.

Customer questionnaires are satisfied by the basic module in nearly every case. What procurement wants is comparable energy, emissions and workforce figures, and the value chain cap gives the supplier an argument for stopping there. Banks are different: sustainability-linked conditions need a target and a trajectory, which is C3, so a company negotiating a margin step will not get through on the basic module. Public tenders vary the most, and their scoring criteria are published, so read those before deciding anything.

My position on this: the voluntariness is a formality. A supplier inside the value chain of a reporting corporation, or a company whose credit line is up for renewal, has no real choice. Voluntary means no state penalty, not no pressure.

Producing the first report: sequence, data sources, effort

The order of work that has held up in practice: fix the reporting period and the module first, then collect the basic module data before writing anything, then close the gaps that surface. Companies that draft first and collect afterwards rewrite the report twice.

The data sources needed for the basic module are short enough to list:

• Electricity, gas and district heating invoices for the full reporting year
• Fuel card statements and the vehicle list
• HRIS headcount by contract type, plus payroll for pay and collective bargaining coverage
• Accident log and training records
• Waste disposal invoices by waste stream

One lesson from the first VSME report I delivered with an SME: the report itself was the least valuable output. What mattered were the analyses it made possible afterwards, electricity cost structure, physical climate risk at the main site, and a make-or-buy decision on energy that had been argued about for years without numbers. Treat the VSME as an entry point into your own data, not as the endpoint of a compliance exercise. If a customer request is already on your desk, get in touch.

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