Standards and reporting
VSME reporting
VSME reporting helps smaller businesses organise sustainability information, but a report prepared today must distinguish the 2025 recommendation from the 2026 Voluntary Standard.
What does VSME reporting mean now?
The search term VSME now needs a version label because the 2026 Voluntary Standard is in force and the earlier recommendation no longer produces legal effects Recital 5 and Article 4.
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2025 origin
The original recommendation introduced a voluntary standard for smaller undertakings Recommendation 2025/1710.
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2026 act
Delegated Regulation 2026/1560 establishes the current Voluntary Standard Article 2.
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Clear claim
Write the instrument, module and reporting period beside any statement about the report's basis.
Read the detailed guidance and evidence
A supplier questionnaire, an Excel workbook and a published standard can carry similar names while referring to different versions.
The Commission's July announcement records adoption, while the Official Journal text establishes the present legal status Adoption announcement Published regulation.
Use the wider sustainability reporting standards guide to distinguish this voluntary route from other reporting frameworks.
Use the sustainability report template to organise the selected reporting basis, narrative and supporting evidence.
Which dates and documents matter?
The regulation entered into force on 24 September 2026, while Article 3's value-chain cap applies to financial years beginning on or after 1 January 2027 Article 4.
| Document or event | How to use it | Avoid this mistake |
|---|---|---|
| 2025 recommendation | Historical starting point for VSME | Calling it the current operative instrument |
| 3 July 2026 adoption | Explains the Commission's decision | Treating an announcement as the final legal text |
| 21 September 2026 publication | Identifies the Official Journal instrument | Leaving the act described as awaiting publication |
| 24 September 2026 commencement | Establishes the regulation is in force | Borrowing the revised ESRS commencement date |
| FYs beginning from 1 January 2027 | Article 3 application timing | Treating commencement and application as identical |
Read the detailed guidance and evidence
Keep the report's preparation date separate from the financial year it describes.
The transmitted memorandum explains the policy background but the published regulation governs the final wording Commission memorandum.
Who is the Voluntary Standard for?
Annex I intends the voluntary standard for undertakings that do not exceed an average of 1,000 employees during the preceding financial year Annex I paragraphs 2–4.
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Reporting choice
Using this standard is voluntary rather than a new reporting obligation Annex I paragraph 4.
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Counterparties
Its objectives include helping respond to customers, banks and investors Annex I paragraph 1.
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Separate duties
Assess other applicable reporting requirements separately before selecting a voluntary framework.
Read the detailed guidance and evidence
Voluntary reporting can organise a reusable evidence base without turning every customer questionnaire into a separate reporting system.
A voluntary report does not automatically replace a statutory report or establish that another framework's requirements have been met.
Ask a sustainability reporting consultant to specify the reporting basis and deliverables rather than promise general compliance.
Should you choose Basic or Comprehensive?
Basic is the prerequisite for Comprehensive, and the report must identify its selected module option Annex I paragraphs 6–7 and 27.
| Choice | Reader task | Control before making a claim |
|---|---|---|
| Basic only | Prepare the B1–B11 foundation | Review each field and its applicability |
| Basic plus Comprehensive | Add information relevant to the intended recipients | Review the selected module's complete requirements |
| Extra recipient questions | Distinguish supplementary information from the module claim | Label additional content and its purpose |
| A partly filled workbook | Identify unfinished evidence collection | Do not describe technical completion as conformity |
Read the detailed guidance and evidence
Paragraph 25 permits additional Comprehensive disclosures, while paragraph 27 says a selected module must be complied with in its entirety subject to applicability Annex I paragraphs 25 and 27.
For a report claiming the Basic-plus-Comprehensive option, check the full selected module rather than presenting a convenient subset as complete.
Does every datapoint need an answer?
The standard distinguishes essential, conditional, voluntary and sector-consideration information, with additional relief identified for undertakings with ten employees or fewer Annex I paragraph 8.
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Essential
Review the requirements of the selected module before stating its basis.
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Conditional
An if-applicable disclosure depends on the circumstances specified in that disclosure Annex I paragraph 15.
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Additional
Voluntary fields and sector information have a different status from essential fields Annex I paragraphs 8 and 12–13.
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Smallest firms
Square brackets identify datapoints voluntary for undertakings with ten employees or fewer Annex I paragraph 8.
Read the detailed guidance and evidence
Create an applicability column in the working register so that missing evidence is not mistaken for an inapplicable disclosure.
The standard assumes an omitted if-applicable disclosure is not applicable, but an internal explanation helps reviewers distinguish that decision from an accidental blank Annex I paragraph 15.
This register is editorial preparation advice rather than an additional reporting requirement.
What should the evidence register contain?
Use a register that connects the reporting boundary and period to source records, calculations and review decisions, supporting the standard's verifiable-information principle Annex I paragraph 11.
| Evidence area | Useful source record | Review question |
|---|---|---|
| Entity and boundary | Entity list and subsidiary decisions | Does the report state individual or consolidated preparation? |
| Energy | Invoices, meter records and unit conversions | Can another reviewer reproduce the total in MWh? |
| Emissions | Activity data, factor references and calculations | Are Scope 1 and location-based Scope 2 identifiable? |
| Workforce | Controlled HR totals and relevant breakdowns | Do the period and counting approach match the report? |
| Policies and incidents | Approved policies and controlled records | Is the answer supported rather than inferred? |
| Applicability and omissions | Decision log with reviewer | Is a blank explained by the right provision? |
Read the detailed guidance and evidence
Retain the calculation trail alongside the report rather than relying on an exported total alone.
Check the sustainability software guide for questions to ask about data ownership, exports and version history.
How should energy and emissions be treated?
B3 addresses energy in MWh and estimated gross Scope 1 and location-based Scope 2 emissions, with these datapoints voluntary for undertakings with ten employees or fewer Annex I paragraphs 32–33.
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Energy units
Keep invoice units and conversions visible before reporting MWh.
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Scope 2
The specified B3 measure is location-based purchased-energy emissions Annex I paragraph 33.
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Scope 3
Sector-relevant Scope 3 information is a separate consideration rather than a universal Basic requirement Annex I paragraphs 49–52.
Read the detailed guidance and evidence
The Scope 2 guide explains why a location-based result should not be silently replaced by a market-based figure.
If Scope 3 is reported, identify the relevant categories and retain the assessment supporting their selection Annex I paragraph 51.
A workbook validation tick cannot establish that invoices, organisational boundaries or selected factors were correct.
Is the value-chain cap the whole standard?
No: Article 3 limits the cap to Annex II's listed datapoints, with different coverage for the two employee bands Article 3 and Annex II.
| Illustrative area | Ten employees or fewer | More than ten employees |
|---|---|---|
| Module and reporting basis | Listed | Listed |
| Total energy and gross emissions | Not listed for this band | Listed |
| Total water withdrawal | Not listed for this band | Listed |
| Employee contract and gender information | Listed | Listed |
| Specified accident and remuneration information | Listed | Listed |
| Scope 3 quantification | Not listed | Not listed |
Read the detailed guidance and evidence
The cap is a limit on relevant information demands, not a universal instruction that every supplier must publish all listed information.
Keep the requested field's exact reference and the applicable employee band beside any cap assessment.
Can an EU customer still ask for more?
The cap does not prevent voluntary sharing or apply to every information request, and its practical operation needs the reporting purpose and national implementation checked Value-chain provisions and Article 5 Commission explanation.
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Purpose
Separate CSRD reporting information from due diligence, financing and other requests.
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Recipient
Identify the requesting undertaking and the relevant jurisdiction before relying on a legal protection.
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Exact field
Compare the requested datapoint with Annex II rather than the whole voluntary report Article 3.
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Extra information
Requests beyond the cap require separate treatment rather than an assumption that no further questions are allowed Value-chain provisions.
Read the detailed guidance and evidence
The Commission explains that over-cap information may still be requested, with the protected undertaking informed which information exceeds the cap and of its right to decline Question 3.
The directive's relevant transposition deadline is 19 March 2027, so do not describe that protection as automatically enforceable against every EU customer today Article 5.
The cap itself does not oblige a value-chain undertaking to provide sustainability information Article 2 value-chain provisions.
Is the official Excel template up to date?
EFRAG currently lists v1.3.0 from 11 June 2026 and says materials aligned to the July 2026 Voluntary Standard are scheduled for Q4 2026 Current release notice.
| Resource | Verified state on 26 October 2026 | Practical use |
|---|---|---|
| Digital Template v1.3.0 | Listed as published 11 June 2026 | Check its content against the chosen reporting text |
| Updated VS materials | EFRAG says publication scheduled for Q4 2026 | Recheck the owner page before starting or migrating |
| Excel compatibility | Developed and tested in Excel 365 | Test calculations if using another application |
| XBRL converter | Converts the workbook into a digital report | Review output and validation messages |
| Release history | Owner documents features and fixes | Retain the exact version used |
Read the detailed guidance and evidence
The June announcement belongs to the earlier VSME tools and should not be presented as evidence that the later standard has already been incorporated June release announcement.
The web converter's terms restrict it to personal and non-commercial use and prohibit automated HTTP use Converter terms.
What should be reviewed before sharing?
Check the report's basis, comparatives, omissions and evidence before treating a technically valid export as a finished report Annex I paragraphs 11, 14, 22 and 27.
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Basis
Name the text, selected module and individual or consolidated boundary Annex I paragraph 27.
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Comparatives
Previous-year figures apply from the second reporting year except metrics reported for the first time Annex I paragraph 14.
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Omissions
Qualifying omissions need the stated safeguards, identification and reporting-date reassessment Annex I paragraph 22.
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Sharing
Public publication is a choice rather than a universal requirement of this standard Annex I paragraph 20.
Read the detailed guidance and evidence
Undertakings applying the standard are not obliged to seek assurance for the information they report Recital 5.
A customer may have separate needs, so agree the recipient, format and intended use before finalising the evidence pack.
How might a small supplier organise the work?
A fictional 35-person component supplier can organise a customer request into a reusable evidence pack without claiming that this example determines its legal duties.
| Fictional task | Working decision | Evidence retained |
|---|---|---|
| Customer sends questionnaire | Ask what reporting purpose it serves | Request and recipient explanation |
| Supplier chooses report basis | Record standard version and module | Approved reporting brief |
| Operations prepares energy data | Reconcile invoices and units | Activity register and calculations |
| HR prepares workforce figures | Use a consistent reporting period | Controlled aggregate records |
| Reviewer identifies extra requests | Separate Annex II assessment from voluntary sharing | Question-by-question decision log |
| Supplier shares report | Retain version and recipient record | Report, evidence index and change log |
Read the detailed guidance and evidence
The aim is a repeatable process that preserves the link between the answer sent and the evidence reviewed.
When comparing carbon accounting software, test whether the same evidence can be exported and reviewed outside the platform.
What makes the next reporting cycle easier?
A clear reporting period, evidence index and change log support consistent updates, while Annex I requires period consistency and conditional annual updates Annex I paragraph 18.
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Owners
Keep a named owner and reviewer for each evidence area.
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Changes
Record altered boundaries, methods and newly reported metrics.
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Version
Retain the standard, template and export versions used.
Read the detailed guidance and evidence
If specific datapoints have not changed, the standard permits indicating that fact and referring to the prior report's information Annex I paragraph 18.
Make next-cycle preparation a controlled update rather than a search for the previous year's spreadsheet.
How do you prepare the first report?
Use this editorial nine-step workflow to organise preparation and review without treating it as a statutory timetable.
- 101
Log the request
Identify the recipient, requested information and stated purpose. - 202
Choose the reporting text
Record the current instrument and distinguish any older template. - 303
Define the boundary
Document the entity, subsidiaries and reporting period. - 404
Select the module
Review the chosen module's requirements and the intended claim. - 505
Map applicability
Distinguish essential, conditional, voluntary and sector information. - 606
Collect the records
Assign finance, operations and workforce evidence owners. - 707
Reconcile the data
Retain activity records, conversions and explanations for differences. - 808
Review and share
Check basis, omissions, confidentiality and recipient needs. - 909
Retain the handover
Keep the report, evidence index, decisions and change log together.
Frequently asked
Questions people ask
Is VSME reporting mandatory?
The 2026 Voluntary Standard does not itself impose a reporting obligation, although separate reporting or information duties need their own assessment.
Can Comprehensive be used without Basic?
No, applying Basic is a prerequisite for Comprehensive and the report must identify its selected option.
Is Scope 3 always required?
No, the standard treats Scope 3 as information to consider according to the undertaking and its sector rather than a universal Basic requirement.
Does the value-chain cap include the full standard?
No, Article 3 limits the cap to Annex II's listed datapoints and distinguishes employee bands.
Must a report be public and assured?
Public publication is optional and applying this standard does not oblige assurance.
Is the official Excel file already aligned to the 2026 standard?
EFRAG currently lists the June 2026 v1.3.0 template and says updated Voluntary Standard materials are scheduled for Q4 2026, so check the owner page and version before use.
Sources
Primary sources
Primary provisions and official owner guidance checked on 26 October 2026; historical and draft resources are labelled in the guide.
- European Commission / EUR-LexDelegated Regulation (EU) 2026/1560: Articles and Annexes I–II
- European Commission / EUR-LexRecommendation (EU) 2025/1710: historical VSME recommendation
- European Parliament and Council / EUR-LexDirective (EU) 2026/470: value-chain provisions and transposition
- EFRAGVSME Digital Template and XBRL Taxonomy: current release notice
- EFRAGDigital Template to XBRL Converter and use terms
- EFRAGDigital Template to XBRL Converter release history
- EFRAGJune 2026 digital-template and converter update
- European Commission3 July 2026 adoption announcement: historical status
- European Commission6 May 2026 explanation of the value-chain cap: draft-era guidance
- European Commission / Council registerC(2026) 5011 final: transmitted explanatory memorandum
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