European Commission publishes the SME Relief Package. Action 14 mandates EFRAG to develop a simple, standardized voluntary reporting standard for non-listed SMEs.
VSME: Voluntary Sustainability Reporting Standard for SMEs
The VSME gives non-listed companies outside mandatory CSRD scope a modular framework for disclosing sustainability data to customers, banks, and financial institutions.
Next deadline:
No fixed date: the VSME standard is available for adoption now. Data requests from CSRD-reporting customers and financial institutions are active across supply chains. Companies that want to respond with a consistent, capped dataset should have their VSME reporting framework in place before those requests arrive.
The value-chain cap is already in force under the Omnibus I Directive: CSRD-reporting companies may not request sustainability information from companies with fewer than 1,000 employees beyond what the VSME standard covers. The VSME Delegated Act, published in draft on 6 May 2026, formalises the cap as a binding regulation. Final adoption is expected in Q3 2026.
Companies with a complete VSME dataset in place before that date will have a documented, standardized basis for limiting incoming requests from the moment the Delegated Act takes effect.
VSME Timeline
What VSME requires
Under the Omnibus I Directive, companies with fewer than 1,000 employees and under €450 million in net turnover fall outside mandatory CSRD scope and may report voluntarily using VSME.
The framework has two modules. The Basic Module covers 11 disclosure areas including GHG emissions (Scope 1 and 2), energy use, water, workforce conditions, and anti-corruption.
The Comprehensive Module adds 9 further disclosure areas covering climate targets, biodiversity, and human rights due diligence in the value chain.
No Double Materiality Assessment is required. Disclosures apply on an "if applicable" basis, and there is no external audit obligation.
Common VSME implementation challenges
Inconsistent, overlapping data requests from the supply chain
Companies not subject to CSRD receive separate questionnaires from multiple customers, each formatted differently and covering overlapping but inconsistent data sets. Each request generates a separate response, producing disclosures that vary across the same reporting period.
No established sustainability data infrastructure
GHG emissions, workforce metrics, and governance indicators typically sit in separate systems or spreadsheets with no shared collection process. A repeatable reporting workflow requires defined ownership across business functions and a single data layer to draw from.
No materiality process means scope remains a judgment call
VSME replaced the mandatory Double Materiality Assessment with an "if applicable" principle: disclosures are reported only when relevant to the company's circumstances. Underestimating scope produces incomplete disclosures that customers and banks will challenge; overestimating scope creates unnecessary reporting burden.
Each stakeholder requests sustainability data in a different format
A structured VSME dataset resolves format inconsistency only if the underlying data is collected centrally, not assembled per request. Data collected into individual documents per stakeholder produces the same duplication problem regardless of which standard is in use.
VSME reporting built on one shared data layer
The osapiens HUB covers all 20 VSME disclosures through the Reporting Cockpit. GHG data collected for VSME directly feeds corporate carbon and product carbon calculations on the same platform.
Cover all 20 VSME disclosures with pre-mapped templates
The osapiens HUB Reporting Cockpit provides pre-built templates for all 20 VSME disclosures across both modules, with the "if applicable" logic built in. Completed disclosures export in PDF and XBRL-ready format for customers and financial institutions.
Feed VSME emissions data directly into carbon reporting
GHG emissions data collected for VSME Basic Module disclosures feeds directly into the osapiens HUB for Corporate Carbon Management without a second collection run. Product-level emissions tracked through the osapiens HUB for Product Carbon Management draw from the same data layer.
Share one consistent disclosure record with every stakeholder
A completed VSME disclosure in the Reporting Cockpit produces a version-controlled record with a full data trail covering source, collection period, and approver. The same record is shared directly with customers, banks, and procurement platforms, replacing per-request data assembly.
ADDITIONAL VSME RESOURCES
Frequently Asked Questions (FAQ)
No. The Omnibus I Directive sets the mandatory CSRD exemption threshold at fewer than 1,000 employees and under €450 million in net turnover, but any company may adopt VSME regardless of size. Non-listed companies including SMEs, international subsidiaries, and mid-sized businesses use it as a structured response framework for sustainability data requests from customers, banks, and procurement partners.
No. The VSME is voluntary and there are no penalties for non-adoption. The practical driver is external demand: CSRD-reporting companies collect sustainability data from their supply chains, and banks and insurers require it for lending and underwriting decisions.
The value-chain cap is already in force under the Omnibus I Directive: CSRD-reporting companies may not request sustainability information from companies with fewer than 1,000 employees beyond what the VSME standard covers. The VSME Delegated Act, published in draft on 6 May 2026, formalises this as a binding regulation with final adoption expected in Q3 2026. Companies reporting under VSME have a documented dataset that defines the upper limit of what customers and banks may legitimately request.
GHG emissions are a core requirement of the VSME Basic Module, covering Scope 1 and Scope 2 at minimum. Companies using the osapiens HUB for VSME feed the same emissions data directly into the osapiens HUB for Corporate Carbon Management and the osapiens HUB for Product Carbon Management. Data collected once for a VSME Basic Module disclosure populates both corporate and product carbon footprint calculations without a separate collection run.
One HUB. Every sustainability signal.