Standard

    The VSME Standard

    The VSME standard is the EU's voluntary sustainability reporting framework for non-listed SMEs. Developed by EFRAG and formally recommended by the European Commission on 30 July 2025, it gives companies with fewer than 1,000 employees a structured, proportionate way to report on environmental, social, and governance (ESG) topics, without the full complexity of the CSRD. It is not mandatory. But banks, large customers, and investors are increasingly asking for it. The VSME delegated act, expected in June 2026 (Directive (EU) 2026/470), will give the standard a formal legal basis.


    What Is the VSME Standard?

    VSME stands for Voluntary Sustainability Reporting Standard for non-listed SMEs. It was developed by EFRAG (the European Financial Reporting Advisory Group), published in December 2024, and recommended by the European Commission in July 2025.

    The core idea is simple: large companies under the CSRD must report their sustainability data. As part of that reporting, they also need ESG data from their suppliers and partners. Most of those suppliers are SMEs. Without a common format, SMEs were drowning in one-off questionnaires from banks, customers, and investors, each asking for slightly different information.

    The VSME standard fixes that. It gives SMEs one consistent, credible reporting format that satisfies the most common ESG data requests in one go.

    Three things to know

    It is voluntary. There is no legal obligation to adopt it. It also sets the maximum scope of sustainability information an SME can be required to report under EU law.

    It is aligned with the ESRS, the mandatory CSRD standards, so the data you produce is directly useful to large-company partners.

    It is proportionate, designed for SME resources, not for corporate sustainability teams.

    Who Does the VSME Standard Apply To?

    The VSME framework is designed for non-listed SMEs operating in the EU, specifically companies that fall outside the mandatory scope of the CSRD.

    In practice, that means:

    • Fewer than 1,000 employees
    • Not listed on an EU-regulated stock exchange
    • Typically: net turnover below €450 million
    Already in CSRD scope?

    If your company is listed, or if it meets the large-company thresholds under the CSRD, the VSME is still relevant for your enterprise: as part of your CSRD reporting, you will have to collect ESG information on your stakeholders (suppliers, customers). The VSME is the legal maximum requirement against which your counterparties need to be aligned (typically, small SMEs). In other words, if you are subject to the CSRD, you should require your counterparties to order VSME medals instead of unaudited, hard-to-process VSME reports.

    Why would an SME choose to report voluntarily?

    The pressure is real, even if the obligation is not. Three situations push SMEs towards the VSME standard:

    1. A large customer asks for your ESG data as part of their own CSRD supply-chain disclosure — a growing driver of ESG compliance for SMEs.
    2. A bank or investor requests sustainability information before approving financing.
    3. You want to demonstrate ESG credibility to win contracts, attract talent, or build brand trust.

    The VSME gives you a single, structured answer to all three — and ESG recognition for SMEs is how you make that answer visible to stakeholders.

    What Does the VSME Standard Cover?

    The EFRAG VSME framework is built around two modules: the Basic Module and the Comprehensive Module. You always start with the Basic Module. The Comprehensive Module is your next logical step. You add it when stakeholders need more detail.

    Basic Module (B1–B11)

    The Basic Module is the minimum viable VSME report. It covers 11 disclosure areas:

    CodeTopic
    B1Basis for preparation (company info, reporting scope)
    B2Sustainability practices, policies, and future initiatives
    B3Energy consumption and GHG emissions (Scope 1 & 2)
    B4Pollution (air, water, soil)
    B5Biodiversity (proximity to sensitive areas)
    B6Water withdrawal and consumption
    B7Resource use, circular economy, and waste
    B8Workforce characteristics (gender, contract type)
    B9Health and safety (accidents, fatalities)
    B10Remuneration, collective bargaining, and training
    B11Convictions and fines for corruption or bribery

    Most SMEs will complete the Basic Module in a few weeks, especially if they already track energy bills, HR data, and basic environmental metrics.

    Comprehensive Module (C1–C9)

    The Comprehensive Module adds nine deeper disclosure areas for SMEs whose banks, investors, or corporate clients need more granular information:

    CodeTopic
    C1Business model and sustainability-related initiatives
    C2Detailed sustainability policies, actions, and future plans
    C3GHG reduction targets and climate transition plan
    C4Physical and transition climate risks
    C5Additional workforce characteristics (diversity data)
    C6Human rights policies and due diligence processes
    C7Severe negative human rights incidents
    C8Revenue exposure to high-impact sectors (fossil fuels, etc.)
    C9Gender diversity in governance bodies

    The Comprehensive Module is reported on an "if applicable" basis. You only disclose what is relevant to your business. You don't need to fill in every field.

    VSME Standard vs CSRD. What's the Difference?

    This is the question we hear most. Short answer: they are built for different companies based on their size.

    VSME
    Who it's forNon-listed SMEs, <1,000 employees
    Legal statusVoluntary
    ComplexityLighter, 11 to 20 disclosures
    Materiality assessmentSimplified / lighter approach
    Main purposeRespond to ESG data requests; improve access to finance
    AlignmentDesigned to align with ESRS data needs
    CSRD / ESRS
    Who it's forLarge companies + listed SMEs in CSRD scope
    Legal statusMandatory
    ComplexityHeavy, 1,000+ data points across 12 ESRS
    Materiality assessmentFull double materiality assessment required
    Main purposeMeet statutory CSRD reporting obligations
    AlignmentThe core mandatory standard

    The key point: the VSME produces ESRS-compatible data, which is exactly why large companies and banks accept it. But the process is lighter than the CSRD.

    If you are an SME and not listed, VSME is almost certainly the right framework. If you are in CSRD scope, you need ESRS.

    How to Implement the VSME Standard

    Implementing the VSME standard is more straightforward than most SMEs expect. Here is a practical step-by-step approach.

    Step 1. Confirm VSME is the right fit

    Check that your company is non-listed and has fewer than 1,000 employees. If yes, VSME applies.

    Step 2. Define your purpose and reporting scope

    Ask: Why are we doing this? Is it for a bank, a customer, internal management, or public disclosure? Set your reporting period (typically the calendar year) and decide whether you'll report as a standalone entity or include subsidiaries.

    Step 3. Choose your module

    • Start with the Basic Module if you want the minimum credible report.
    • Add the Comprehensive Module if a bank, investor, or large customer is asking for more depth.

    Once you commit to a module, you must report on all applicable disclosures within it.

    Step 4. Audit your existing data

    You likely have more data than you think. Map what you already have, energy bills, HR records, procurement data, health and safety logs, financial statements, against the VSME disclosure checklist. Identify the gaps.

    Step 5. Collect data and draft the report

    Gather the metrics, write the narrative sections, and structure the report around the module you have chosen. EFRAG's free VSME Digital Template (released May 2025) is a good starting point. It's structured, XBRL-ready, and available on the EFRAG website.

    Step 6. Review and finalise

    Check that all applicable disclosures are complete and internally consistent. Validate figures against source documents. If certain data is genuinely unavailable, VSME allows you to omit it with a clear explanation.

    Get Formally Recognised for Your VSME Compliance

    Completing a VSME report is a real achievement. But a PDF sitting in a folder doesn't signal much to the outside world.

    VSME Medals is the third-party recognition system built specifically on the EFRAG VSME standard. We assess SMEs against the VSME framework and award a formal medal: a credible, independent signal that your sustainability reporting meets the standard.

    The system uses a four-tier medal structure:

    VSME Bronze medal

    Bronze

    Basic Module completed

    VSME Silver medal

    Silver

    Comprehensive Module completed

    VSME Gold medal

    Gold

    SRS Midcaps completed (based on We Are Europe)

    VSME Platinum medal

    Platinum

    Gold plus sectoral comparative analysis and advanced governance

    Each medal comes with a digital badge you can display on your website, in tenders, and in financing applications, turning your VSME report into visible proof of ESG credibility.

    Why does recognition matter?

    Because voluntary reporting without verification is easy.

    An official VSME Medal serves as an immediate, reliable indicator for financial institutions and supply-chain partners, allowing them to verify your sustainability standing without manually analysing a multi-page disclosure.

    Interested in seeing where your business stands?

    Frequently Asked Questions