Your VSME report, built from the data you already have

The ask

Large companies and financial institutions carry sustainability reporting duties of their own, and they discharge part of them by asking their suppliers and borrowers for data. If you are an SME, that is how ESG reporting reaches you: not as a law aimed at you, but as a questionnaire from a bank or a large customer that you cannot commercially ignore.

The EU’s answer to that trickle-down is VSME, the voluntary sustainability reporting standard for non-listed SMEs, developed by EFRAG and published in December 2024. In July 2025 the European Commission formally recommended it, asking large companies and financial institutions to limit what they request from SME partners to what VSME contains. The 2026 Omnibus changes went further: companies in scope of EU sustainability reporting may no longer demand more than VSME-level information from value-chain partners with fewer than 1,000 employees. One properly built VSME report is therefore designed to answer most of these requests at once.

Who this applies to

Non-listed SMEs and mid-market companies that are not themselves in scope of EU sustainability reporting law. After the 2026 Omnibus changes, mandatory reporting only reaches large undertakings with more than 1,000 employees and over EUR 450 million turnover. If that is not you, nobody can oblige you to publish a sustainability report; but your bank, your insurer and your largest customers can keep asking, and they do.

This deliverable fits you if those requests are landing and you want one document, in the EU’s own format, that answers them. It is precise about its own limits: VSME is the ceiling of what such counterparts should ask of you, which is exactly what makes it worth having.

What you need to have ready

This list doubles as our intake. Several VSME disclosures only apply in specific circumstances, so for many companies the final report is shorter than the standard suggests. Whatever is missing becomes the gap list.

• Electricity and gas bills for the reporting year, plus fuel purchases for vehicles and heating
• A site list: your locations and what happens at each
• HR roster data: headcount by contract type, gender and country, plus leavers during the year
• Payroll data points: coverage of collective bargaining, pay relative to minimum wage, and data for the gender pay gap
• Your accident log: recordable work-related incidents for the year
• Training hours per employee, if tracked
• Waste records and water bills, where relevant to your operations
• Any existing policies, certificates or prior sustainability statements

What Humboldt delivers

The Basic module of VSME, disclosures B1 through B11, filled in and delivered in EFRAG’s official digital template so a bank or corporate customer can take it in directly. Energy use is compiled in MWh from your bills, Scope 1 and 2 greenhouse gas emissions are calculated per the GHG Protocol, workforce and governance datapoints come from your own records, and every number carries an evidence trail back to its source document.

Missing data does not stop the report. Where your records leave a defensible route to a number, emissions derived from spend, fuel from mileage, we estimate it and mark it clearly as an estimate with the method used; VSME itself accepts estimated figures as long as they are labelled as such. And where the report reveals a missing basic, a code of conduct, an environmental policy, we include a ready-to-adapt template so you can close the gap by tailoring it.

A datapoint that cannot be evidenced or defensibly estimated goes on the gap list with a note on what to start collecting so next year’s report is complete. A senior ESG expert checks and signs the whole report and signs off before it reaches you.