How to prepare your first VSME sustainability report
A practical walkthrough for small and mid-sized companies answering customer and bank requests with a VSME-style report: which module, what data, who owns what, and how to avoid over-reporting.
If a bank, an investor or a large customer has sent you a sustainability questionnaire, a VSME-style report is the most efficient way to answer many of them at once. This guide walks through a first report for a small or mid-sized business. It is written for the person who has been handed the task, not for a sustainability specialist.
What the VSME is, in one paragraph
The VSME is a voluntary reporting standard for smaller companies that are not listed. It started as a European Commission Recommendation adopted on 30 July 2025 (Recommendation (EU) 2025/1710), built on EFRAG's work. It has a Basic Module (11 disclosures, B1 to B11) and a Comprehensive Module (9 further disclosures, C1 to C9). The Commission has since adopted a voluntary standard based on the VSME (Delegated Regulation (EU) 2026/1560, published in the Official Journal on 21 September 2026 and in force from 24 September 2026). It keeps the Basic and Comprehensive Modules, but some datapoints and the structure of the text changed, so use the 2026 text, not the 2025 Recommendation, for new templates. It can be used by companies that are not subject to CSRD reporting and have up to 1,000 employees.
Step 1: Decide whether you need it and which module
The VSME is not mandatory for most companies that use it. Use it when customers, banks or investors keep asking you for the same information. Start with the Basic Module. Move to the Comprehensive Module only if a specific requester asks for strategy, targets, transition plans or the extra metrics it covers.
- Collect the last three questionnaires you received.
- Highlight what they all ask for. That overlap is your Basic Module.
- Note anything only one requester asks for. Handle it separately and do not let it grow the whole report.
Step 2: Set the reporting boundary
Decide which legal entities and sites the report covers and which twelve-month period it describes. For most small businesses this is your financial year and the legal entity in your accounts. If you have subsidiaries, state clearly whether the report is individual or consolidated.
Step 3: Assign data owners
Most first reports slip because nobody owns the numbers. Give each data area a named owner and a due date.
| Data area | Typical owner | Typical source |
|---|---|---|
| Energy and fuel | Facilities or finance | Utility bills, fuel cards, meter readings |
| Employees | HR | Payroll and HR system |
| Health and safety | HR or operations | Accident log |
| Policies and governance | Management | Policy documents, board minutes |
| Business model and sites | Management | Company records |
A ready-made worksheet is in our free resources.
Step 4: Collect data for the Basic Module
Gather twelve months of data. Typical items are the number of employees, energy use by source, fuel use, a breakdown of employees by gender, and basic health and safety figures. Keep a note of where every number came from and any estimates you made. A simple "source and method" column next to each figure saves hours when someone asks where a figure came from.
Step 5: Calculate emissions
Convert energy and fuel into greenhouse gas emissions using published emission factors. Record the factor source and year. Scope 1 and 2 are normally enough for a first report. If you need a refresher, read Scope 1, 2 and 3 explained and try the free carbon footprint estimator.
Step 6: Write the narrative sections
Keep the text short and factual: what the business does, its sites, its main products, any certifications, and the policies that exist today. If a policy does not exist, say so. Reporting that you have no formal policy yet is acceptable. Overstating is not.
Step 7: Review, sign off and publish
Ask someone who did not prepare the report to read it against your source data. Then agree who signs it off and where it will be published or shared. Save a dated copy together with your workings.
Step 8: Handle information requests going forward
Under the Omnibus changes, companies that report under the CSRD cannot require value-chain companies with an average of up to 1,000 employees to provide more than the essential datapoints in Annex II of the voluntary standard (Delegated Regulation (EU) 2026/1560), and those companies may decline further requests. This applies to financial years beginning on or after 1 January 2027 and to CSRD reporting only. Confirm how it applies to your customers with your adviser.
Common mistakes
- Reporting everything the Comprehensive Module covers when no one asked.
- Mixing periods, for example energy for a calendar year and staff numbers for a financial year.
- Leaving no record of estimates.
- Producing a polished PDF with no workings behind it.
Find help
i-ESG
Seoul-based ESG data and risk management platform with modules for materiality, reporting, supply chain risk and carbon tracking.
VERSO
Munich-based sustainability software and advisory firm covering ESG data management, double materiality, VSME reports and supply chain due diligence.
Planted
German startup offering an AI-assisted ESG management platform for carbon accounting and CSRD reporting.
Pulsora
ESG management platform for collecting sustainability data and preparing framework reports.
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You can also compare ESG consultants if you want a review before you publish. Read the background in the VSME explained.
Official sources
- Delegated Regulation (EU) 2026/1560: voluntary standard (EUR-Lex)
- EFRAG: sustainability reporting standards
- European Commission: corporate sustainability reporting
This guide is general information, not legal, tax or investment advice. Rules change; check the official sources and talk to an adviser before you rely on it.
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