Skip to content

Resources · Regulation

VSME explained: today the Voluntary Standard

The VSME became the Voluntary Standard — Delegated Regulation (EU) 2026/1560, applicable since Sep 24, 2026. Voluntary in content, but with a binding cap on what large customers may ask of you.

The Voluntary Standard at a glance

What?

The "sustainability reporting standard for voluntary use" — that is the official name. It succeeds the VSME and is set out in Delegated Regulation (EU) 2026/1560.

Since when?

Published in the Official Journal on Sep 21, 2026, applicable since Sep 24, 2026. The earlier (EU) 2025/1710 on the VSME has had no legal effect since.

For whom?

Undertakings with an average of up to 1,000 employees that are not subject to mandatory reporting. That includes self-employed businesses and listed micro undertakings.

Structure?

Basic module B1–B11 and comprehensive module C1–C9. The comprehensive module builds on the basic one; it does not replace it.

The real leverage

Article 3 is binding: a CSRD-reporting customer may request at most the Annex II datapoints from you if you have up to 1,000 employees — for financial years from 2027.

What you need to know about the Voluntary Standard

From VSME to the Voluntary Standard

EFRAG developed the Voluntary Sustainability Reporting Standard for non-listed SMEs — VSME — in 2024. The Commission recommended it for voluntary use in 2025 ((EU) 2025/1710). Delegated Regulation (EU) 2026/1560 turned it into EU law, applicable since Sep 24, 2026. The official name is now the "sustainability reporting standard for voluntary use", the Voluntary Standard or VS for short. The VSME recommendation has had no legal effect since. The standard remains voluntary: no company has to apply it.

Who can apply the Voluntary Standard?

The standard addresses undertakings with an average of up to 1,000 employees that are not subject to mandatory reporting. The frequently repeated description "non-listed SMEs" applied to the 2024 VSME, not to the Voluntary Standard.

  • Undertakings with an average of up to 1,000 employees
  • including self-employed businesses and listed micro undertakings
  • For undertakings with up to 10 employees, individual datapoints are voluntary
  • For contrast: from financial year 2027, only companies above 1,000 employees and above EUR 450m turnover report under the CSRD

The cap on data requests

This is the most important and most overlooked part. The standard itself is voluntary — Article 3 of Regulation (EU) 2026/1560 is not. A CSRD-reporting company may request at most the Annex II datapoints of the standard from undertakings in its value chain that have an average of up to 1,000 employees. This applies to financial years starting on or after 1 January 2027. You do not have to answer questionnaires that go beyond it. For smaller companies, that makes the standard less an obligation than an argument.

Structure: basic and comprehensive module

The standard has two modules. The basic module B1–B11 is a prerequisite for the comprehensive module C1–C9 — applying the comprehensive module also satisfies the basic one.

  • Basic module B1–B11: general company information, energy and greenhouse gas emissions, pollution, biodiversity, water, waste and workforce metrics
  • Comprehensive module C1–C9: strategy, GHG targets and transition, climate risks, extended workforce data, human-rights policies and incidents, revenues from certain activities, and gender diversity in the governance body
  • For micro undertakings the basic module is the intended route

No materiality assessment

A widespread misunderstanding: the Voluntary Standard contains no materiality assessment — neither a simplified one in the basic module nor a deeper one in the comprehensive module. You report the datapoints of the module you choose. A double materiality assessment in the ESRS sense is not part of the standard. That is one of the main reasons the effort sits well below CSRD reporting.

What it gives your company

The standard answers a practical problem: differently worded ESG questionnaires from customers, banks and investors.

  • One structured answer to many requests instead of starting over each time
  • An argument against large customers who ask for more than Article 3 allows
  • Data structures that stay reusable if a reporting duty arrives later
  • Defensible figures for credit discussions and funding applications

Frequently asked questions about the Voluntary Standard

No. Applying it is voluntary, even though the standard has sat in a delegated regulation since Sep 24, 2026. Only Article 3 of the regulation is binding — and it limits what others may ask of you rather than imposing anything on you.

It became the Voluntary Standard. The legal basis was the Commission's (EU) 2025/1710; today it is Delegated Regulation (EU) 2026/1560. The recommendation has had no legal effect since Sep 24, 2026. The name VSME is still in common use, and it refers to the Voluntary Standard.

Undertakings with an average of up to 1,000 employees that are not subject to mandatory reporting — including self-employed businesses and listed micro undertakings. "Non-listed SMEs" was the target group of the 2024 VSME and is out of date.

No, and in fact none at all. The Voluntary Standard contains no materiality assessment, not even in the comprehensive module. You report the datapoints of your module. That is a fundamental difference from ESRS reporting.

At most the Annex II datapoints of the Voluntary Standard, if you have an average of up to 1,000 employees. That is set out in Article 3 of Regulation (EU) 2026/1560 and applies to financial years starting on or after 1 January 2027. You do not have to answer questionnaires that go beyond it.

The basic module B1–B11 covers the disclosures that Annex II — and therefore supply chain requests — may require, which is enough for most smaller companies. The comprehensive module C1–C9 pays off if you want to communicate targets, climate risks and governance actively, for example to investors.

Indirectly, yes. The datapoints connect to the ESRS in substance, so structures and processes stay reusable. It is not a full substitute: the scope is smaller and no materiality assessment is included. After Omnibus I ((EU) 2026/470), the number of companies subject to mandatory reporting has fallen sharply anyway.

Related resources

CSRD – the EU reporting obligation

Who is affected, from when and how to prepare.

EU Omnibus package

Why far fewer companies are subject to mandatory reporting today.

ESRS – the reporting standards

Structure, topical standards and datapoints of the ESRS.

GHG accounting

The emissions data the basic module requires.

VS reporting with NetCero

How NetCero guides you through reporting under the Voluntary Standard.

Glossary

ESG terms from A to Z

Legal sources

Delegated Regulation (EU) 2026/1560 — VS-Standard

Recommendation (EU) 2025/1710 — VSME

Directive (EU) 2026/470 — Omnibus I

Book a demo

Capture ESG data in a structured way – without a reporting duty

In a free demo we'll show you how NetCero guides you through the Voluntary Standard and turns your ESG data into a form banks, investors and large customers accept.

Book a demo