What VSME is
VSME stands for Voluntary Sustainability Reporting Standard for non-listed SMEs. It was developed and published by EFRAG, the European Financial Reporting Advisory Group, the same body that develops the mandatory European Sustainability Reporting Standards (ESRS) used under the Corporate Sustainability Reporting Directive (CSRD). EFRAG released VSME on 17 December 2024, as a standalone, voluntary standard aimed specifically at companies that are not themselves in scope of mandatory sustainability reporting law.
On 30 July 2025, the European Commission formally endorsed VSME through Commission Recommendation (EU) 2025/1710, recommending that large companies and financial institutions limit what sustainability data they request from SME business partners to what VSME contains. That endorsement is what turns VSME from “one more voluntary framework” into a de facto ceiling on what an SME can reasonably be asked for.
Who publishes and governs it
EFRAG owns and maintains the standard, and it is also responsible for the official VSME digital reporting template and its underlying XBRL taxonomy, so that a completed VSME report can be transmitted in a structured, machine-readable format rather than only as a document. This matters in practice: a bank or corporate customer receiving a VSME report in the official template can process it directly, rather than re-keying figures from a PDF.
Basic versus Comprehensive module
VSME is built as two modules that a company can use independently:
- Basic module: eleven disclosures, numbered B1 to B11, covering core information such as energy use, Scope 1 and 2 greenhouse gas emissions, workforce data, and basic governance and policy datapoints. This is the module most SMEs complete first, and often the only one a bank or customer actually needs.
- Comprehensive module: nine additional disclosures, numbered C1 to C9, going further into areas such as more detailed workforce and human rights information, biodiversity and additional governance detail. Some banks, investors or larger customers with more demanding due diligence processes ask for this module on top of the Basic one.
A company can report the Basic module alone, or both modules together, depending on what its counterparts are actually asking for.
Why customers and banks ask for it
The driver is not a new law aimed at SMEs directly. It is that large companies and financial institutions carry sustainability reporting and due diligence duties of their own, under CSRD and under banking and investor disclosure rules, and they discharge part of that obligation by collecting data from the businesses they lend to or buy from. Before VSME existed, that meant every bank, insurer and large customer sent its own bespoke questionnaire. VSME gives SMEs one standard answer that is designed to satisfy most of those requests at once, in a format the requester already recognises.
Relation to CSRD after the Omnibus, and where this is still moving
As of September 2026, the picture is this: CSRD’s mandatory scope has been narrowed by the EU’s 2026 Omnibus simplification package, so mandatory sustainability reporting now applies only to large undertakings above roughly 1,000 employees and around EUR 450 million turnover. A non-listed SME sitting below that threshold has no legal obligation to publish a sustainability report of its own.
The Omnibus changes also reinforced the “value chain cap” idea behind VSME: companies that remain in scope of mandatory reporting are limited in what sustainability information they may demand from value-chain partners with fewer than 1,000 employees, and that limit is set at VSME level. In other words, VSME is not a stepping stone toward CSRD compliance for an SME; it is the ceiling that protects SMEs from being asked for more than that.
This area moves quickly, and the exact thresholds and the pace of further Omnibus changes are still subject to EU-level negotiation, so treat any specific numbers here as accurate as of the check date rather than fixed indefinitely. Always verify current thresholds against EFRAG’s and the Commission’s own publications before relying on them for a specific filing decision.
Where Humboldt fits
Humboldt fills in the VSME Basic module in EFRAG’s official digital template, built from your existing records with an evidence trail per datapoint and a gap list for what cannot yet be evidenced. Details on the VSME report.