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VSME Explained: A Simpler Path to Sustainability Reporting

What VSME is based on, how it differs from CSRD and the ESRS, and how difficult it really is

Written by Rahul N·Published 2 September 2026

The Voluntary sustainability reporting Standard for SMEs, VSME, was developed by EFRAG to give smaller, non-listed undertakings a proportionate way to disclose sustainability information, without adopting the full weight of the CSRD and ESRS built for large, mandatory reporters.

What is VSME Based On?

VSME is built on the same underlying sustainability logic as the ESRS, environmental, social, and governance disclosure, but deliberately simplified and scaled down. It draws on the structure and topic areas of the ESRS while removing the double materiality assessment requirement, reducing the number of mandatory data points, and using simpler, more standardised metrics designed to be answerable without a large sustainability team or extensive new data systems.

Who Does It Apply To, and What Is the Timeline?

CSRD applies to large EU companies (meeting size thresholds on turnover, balance sheet, and employee count) and listed SMEs, phased in progressively by company size, with the largest companies reporting first and smaller listed companies following in later phases. VSME, by contrast, applies to any micro, small, or medium sized undertaking that chooses to use it, there is no legal deadline or mandatory phase-in, since it is entirely voluntary. In practice, most VSME adoption is driven by timing pressure from elsewhere: a large customer or lender under CSRD needs sustainability data from its own suppliers, and VSME gives that supplier a standardised way to respond.

CSRD Implementation Timeline

Reporting waveWhoFirst report
Wave 1Large public-interest entities already reporting under the former NFRD (over 500 employees), still meeting the revised thresholdsFY2024, published 2025; some member states may allow a temporary exemption for FY2025–2026
Wave 2 (post-Omnibus)Companies meeting the new, higher thresholds of over 1,000 employees and €450m+ net turnover, that were not already reportingFY2027, published 2028
Wave 3 (listed SMEs)No longer required to report at all — fully exempted under the Omnibus I DirectiveNot applicable
Non-EU parent companiesParent turnover above €450m in the EU, with an EU subsidiary or branch above €200m turnoverFY2028, published 2029

What Happened to CSRD Under the New Omnibus Rule?

In 2025 and 2026, the EU adopted a package of changes known as Omnibus I, aimed at significantly reducing the sustainability reporting burden introduced by the original CSRD. Directive (EU) 2026/470 was published in the Official Journal in late February 2026 and entered into force on 18 March 2026. The key changes are:

For a company that falls out of CSRD’s scope under these revised thresholds, VSME is now the natural landing point, a way to keep providing credible, standardised sustainability information to customers and lenders without the compliance burden of the original CSRD regime.

What is the ESRS?

The ESRS (European Sustainability Reporting Standards) are the detailed disclosure standards that implement the CSRD in practice, they set out exactly what large, in-scope companies must report, and how. VSME is a separate, standalone standard developed by EFRAG alongside the ESRS, built specifically to give smaller, non-listed undertakings a much lighter alternative rather than requiring them to follow the full ESRS.

VSME vs CSRD: What’s the Difference?

CSRDVSME
What it isAn EU directive requiring detailed sustainability reporting, implemented through the ESRSA standalone, voluntary standard for smaller undertakings, developed by EFRAG
Who it applies toLarge companies and listed SMEs, phased in by size and headcountMicro, small, and medium sized undertakings, entirely voluntary, most often used to respond to sustainability data requests from larger customers, banks, or investors
MaterialityRequires a formal double materiality assessment covering impact and financial materialityNo formal double materiality assessment required
ModulesThe ESRS set out 12 detailed standards: 2 cross cutting (general requirements, general disclosures) plus 10 topical standards across environment (climate, pollution, water, biodiversity, resource use), social (own workforce, value chain workers, affected communities, consumers), and governanceTwo modules only: a mandatory Basic Module, and an optional Comprehensive Module for undertakings that want or need to disclose more

In short: CSRD is the binding EU law, implemented in detail through the ESRS, that applies to large and listed companies. VSME is EFRAG’s separate, voluntary standard built specifically for smaller undertakings, structured around just two modules rather than the ESRS’s full set of topical standards.

The Two VSME Modules, in Detail

AreaBasic Module (mandatory)Comprehensive Module (optional)
PurposeA minimum, standardised disclosure answerable from existing recordsExtends the Basic Module for undertakings that want, or are asked, to disclose more
EmissionsScope 1 and Scope 2 greenhouse gas emissions, plus basic energy consumptionAdds Scope 3 (value chain) emissions
PollutionBasic disclosure of pollutant emissions to air, water, and soilMore detailed pollution and environmental performance data
Biodiversity & natureNot requiredDisclosure on sites in or near biodiversity sensitive areas
Water & resource useNot requiredWater consumption and circular economy / resource use indicators
WorkforceHeadcount, contract types, gender split, and health and safety incidentsAdds remuneration, collective bargaining coverage, training, and human rights due diligence indicators
Governance & business conductShort narrative on policies, codes of conduct, and anti-corruption measuresMore detailed governance structures, due diligence processes, and value chain policies
Strategy & targetsNot requiredClimate transition plans, targets, and forward looking strategy disclosures
Typical userMost micro and small undertakings responding to a basic data requestMedium sized undertakings, or any SME facing a more detailed request from a large customer, lender, or investor

How Difficult Is It to Do a VSME?

Considerably less demanding than full ESRS reporting. VSME is structured around a basic module, covering a focused set of environmental, social, and governance data points such as energy consumption, emissions, workforce information, and governance basics, most of which a well organised SME can gather from existing records: utility bills, HR data, and existing policies. An optional additional module covers further detail for organisations that want to disclose more, or that are being asked to by a specific customer or financial institution.

For an MSME with straightforward operations and reasonably organised records, a first VSME report is a realistic undertaking, typically achievable in weeks rather than months, and considerably less resource intensive than a full CSRD-aligned disclosure.

How Does VSME Help Businesses?

VSME gives smaller organisations a credible, standardised way to answer the sustainability data requests that increasingly arrive from customers, lenders, and investors, without having to build a full ESRS reporting function. Because it follows a recognised EU standard, a VSME report carries more weight than an ad hoc questionnaire response, and it creates a foundation that can later be extended toward full ESRS reporting if the business grows into CSRD’s scope, or if a customer requires deeper disclosure.

How ecorune Can Help

We help SMEs and MSMEs scope, collect data for, and prepare their first VSME report, using existing records wherever possible and building a foundation that can grow with the business.

Being asked for a sustainability report by a customer or lender?

We’ll help you respond with a proportionate, credible VSME disclosure.

Book a consultation