The Voluntary Sustainability Reporting Standard for non-listed SMEs (VSME) was published by EFRAG to solve one specific problem: the flood of inconsistent questionnaires SMEs receive from customers, lenders, and investors trying to complete their own reports.
Instead of filling in a different template for every counterparty, an SME publishes one VSME report and shares it with everyone. VSME is deliberately proportionate — no double , no XBRL tagging, no mandatory assurance — while still mapping cleanly to datapoints.
This guide covers the two-module structure, what each disclosure actually asks for, the exact datapoints per module, cost benchmarks, and how to produce a first VSME report in weeks rather than months.
The two modules: Basic and Comprehensive
The Basic Module is the minimum. It covers organizational information, environmental data (energy, and 2, water, pollution, , waste), and social data (workforce, health & safety, human rights, community). Most SMEs start here.
The Comprehensive Module adds strategy, business-model resilience, transition plan alignment, additional workforce metrics, (where material), and governance disclosures. It's the format larger customers and banks increasingly request from Tier-1 suppliers.
The two modules are cumulative, not alternative. A Comprehensive report includes everything in Basic plus the additional disclosures — so an SME that starts Basic and later upgrades never has to redo prior work.
Why VSME is the pragmatic choice for SMEs
VSME uses simplified methodology (spend-based emission factors accepted), no assurance requirement, and disclosures scale to size. Adoption cost is a fraction of 's, but the output satisfies most upstream data requests including EBA Pillar 3 , bank ESG questionnaires, and alignment for lender partners.
For SMEs already receiving 3+ different questionnaires per year, publishing a VSME report typically pays back the effort inside one cycle. The alternative — bespoke responses per counterparty — scales the cost linearly with every new customer or lender you win.
Interactive tool
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CSRD & VSME applicability checker
Answer four questions to see which sustainability reporting regime applies to your company and when it kicks in.
Result
In scope
VSME (voluntary standard for SMEs)
Not in scope of CSRD, but VSME is the recommended framework for value-chain requests.
Applicability is our best estimate based on published EU thresholds; consult your auditor for a formal determination.
The Basic Module datapoints in detail
General information (B1): legal form, NACE code, countries of operation, group boundary, and whether the report covers a consolidated or standalone entity. This section takes about an hour if your registrations are current.
Environmental (B3–B8): energy consumption by fuel type (kWh); from combustion, fugitive refrigerants, and process; with both and market-based methods; water withdrawal in areas of water stress; hazardous and non-hazardous waste by disposal route; land use and pollution incidents where material.
Social (B9–B11): headcount split by gender and country, employee turnover, health and safety incident rate (recordable injuries per million hours worked), collective bargaining coverage, and training hours per employee. Most of this is already in payroll or HR systems.
Governance (B12): convictions and fines related to corruption or bribery in the reporting period. Usually a one-line disclosure of 'none' for SMEs with clean records.
The Comprehensive Module: what's added
Strategy and business model (C1–C2): a concise narrative on how sustainability risks and opportunities affect the business model, and any transition plan aligned to 1.5°C.
Additional environmental (C3–C4): where material — the standard accepts spend-based for a first pass — plus reduction targets if publicly committed.
Additional social (C5–C7): human rights due diligence in the supply chain, incidents of discrimination, and community engagement disclosures.
Governance (C8–C9): board composition, gender diversity of management, and revenue derived from controversial sectors (fossil, tobacco, weapons, gambling) — the same list banks screen against under .
A four-step VSME implementation plan
1. Pick the module (Basic first). 2. Assemble one year of energy bills, fuel purchases, waste manifests, and HR headcount data. 3. Run a +2 inventory using the ; use spend-based factors for if you elect the Comprehensive Module. 4. Publish the disclosure — a PDF, a webpage, or an entry in your customer's data portal.
Companies typically complete a first Basic report in 4–8 weeks with software and 3–5 months with spreadsheets and a consultant. The second cycle drops to under two weeks because the data-collection templates are already wired to source systems.
Cost, effort, and payback
Direct software cost for a mid-sized SME (50–250 FTE) sits in the €3–8k/year range for Basic Module reporting. Consultant-led first reports typically land at €10–25k. In both cases, the biggest hidden cost is the internal time to chase down electricity meter data, refrigerant logs, and supplier invoices — which is exactly what a purpose-built tool automates.
Payback shows up in three places: fewer bespoke questionnaires (each takes 20–60 hours of finance/ops time), better lending terms as banks fold into pricing under EBA Pillar 3, and shorter procurement cycles with large customers who screen suppliers on ESG data availability.
FAQ
Frequently asked questions
Is VSME mandatory?
No. VSME is voluntary. But if your customers or banks are CSRD-scoped, they will effectively require you to provide equivalent data — VSME is the proportionate way to do it.
Do I need an auditor for VSME?
No, VSME does not require assurance. Some banks or customers may request it for higher-risk suppliers, but it is not part of the standard.
How does VSME map to CSRD/ESRS?
Every VSME datapoint traces to an ESRS datapoint. Your report can be consumed directly by CSRD-reporting customers with no re-mapping.
Which module should I start with?
Start with Basic. Move to Comprehensive when a large customer or lender specifically asks for it, or when you supply into a Tier-1 CSRD reporter.
Can I use spend-based emission factors for Scope 3 under VSME?
Yes. The Comprehensive Module explicitly accepts spend-based methodology for Scope 3 in the first cycles, upgrading to activity-based or supplier-specific over time.
How often do I have to publish a VSME report?
Annually, aligned with your financial year. There is no formal filing deadline — the standard leaves timing to the reporter, though most publish alongside annual accounts.
Publish a VSME report in weeks, not months
Vuneli generates a compliant VSME Basic or Comprehensive report from your energy bills and HR data — no consultants, no spreadsheets. Share it with every customer and bank in one link.
