VS (VSME) Reporting: The Complete Guide for Mid-Sized Companies

The Voluntary Standard (VS, formerly VSME) is the EU's sustainability reporting standard for companies outside mandatory CSRD scope. It has two modules: a Basic Module of 11 disclosures and a Comprehensive Module adding 9 more. No materiality assessment is required.

What is the Voluntary Standard (VS)?

The Voluntary Standard is the EU's reporting standard for non-listed companies that fall outside mandatory CSRD scope. The European Commission adopted it on 3 July 2026, building on EFRAG's work under the working name VSME. It gives smaller companies one standard format for answering ESG data requests.

Before VS existed, a mid-sized company facing questions from three different customers answered three different questionnaires in three different formats. VS replaces that with a single report. That is the whole point of it, and it is worth keeping in mind when the disclosure list starts to look long.

Who needs to report under the Voluntary Standard?

Nobody is legally required to. VS is voluntary by design. In practice it applies to non-listed companies up to 1,000 employees and €450 million turnover whose customers, banks or investors ask for sustainability data, which after the Omnibus is most mid-sized companies in a European value chain.

The distinction matters. "Voluntary" describes your legal obligation, not your commercial reality. If you supply a CSRD-reporting customer, they need value-chain data from you to complete their own report. They will ask. See who must report under CSRD now if you are unsure which side of the line you sit on.

I prepared for CSRD and now fall outside scope. Is VS my answer?

Yes, for most companies in that position. The Voluntary Standard was built for exactly this group: non-listed companies that the Omnibus pushed out of mandatory CSRD scope, but whose customers, banks and investors still ask for sustainability data.

This is the situation I see most often, and the anxiety in it is usually misplaced. Companies tell me they wasted two years preparing for an obligation that evaporated. They did not. The data collection, the internal ownership, the stakeholder conversations and the emissions groundwork all carry over. What changes is how much of it you are required to present, and to whom.

The practical move is not to start again. It is to take what you built for CSRD and report it in a format your counterparties have agreed to accept. If you want the background on why the ground moved, see what the Omnibus changed for CSRD. If you are wondering whether the name change affects your plan, see VSME vs VS.

What are the two VS modules?

The Basic Module contains 11 disclosures (B1 to B11) covering general information, environment, social and governance basics. The Comprehensive Module adds 9 disclosures (C1 to C9) aimed at the data banks and investors need. Basic must be completed before Comprehensive.

Most companies start and stop at Basic. You move to Comprehensive when a specific counterparty needs it, typically a bank with Pillar 3 obligations or an investor subject to SFDR. The choice is covered in detail in Basic vs Comprehensive: which module do you need.

What does the Basic Module actually require?

The Basic Module covers basis for preparation, practices and policies, energy and greenhouse gas emissions, pollution, biodiversity, water, resource use and waste, workforce characteristics, health and safety, remuneration and training, and convictions for corruption or bribery.

Several of those apply only under specific conditions, which is why the effective burden is lighter than a list of eleven suggests. The full walkthrough is in what the Basic Module requires, disclosure by disclosure.

Does VS require a materiality assessment?

No. Unlike the ESRS, the Voluntary Standard does not require a double materiality assessment. Disclosures are reported where they are applicable to your operations. If a disclosure is omitted, the omission is taken to mean the topic does not apply, and no explanation is needed.

This is the single largest simplification versus ESRS, and the one most often missed by companies coming from CSRD preparation. See does the Voluntary Standard require a double materiality assessment.

How long does a VS report take?

For a mid-sized company with reasonably organised data, a first Basic Module report is a matter of weeks rather than the months an ESRS report demands. The variable is data availability, not the standard itself. Emissions data is usually the slowest part.

I have watched companies spend a year on CSRD readiness and then produce a credible VS Basic report in a fraction of that time, using the data they already collected. That is the point worth repeating: preparation done for CSRD is not sunk cost. It is your head start.

What does VS cost compared to enterprise ESG software?

There is no fee for using the standard itself. The cost sits in tooling and time. Enterprise ESG platforms were priced for companies with mandatory CSRD obligations and hundreds of datapoints, which is a poor fit for a Basic Module report.

This is the mismatch I keep seeing. Companies that bought heavy platforms for a CSRD obligation that no longer applies are now paying enterprise prices to produce a report a fraction of that size. Right-sizing the tooling is usually the fastest saving available.

How do I get started with VS reporting?

Start with the Basic Module and your existing data. Establish what you already have from any CSRD preparation, identify the gaps (usually energy and emissions), and produce a first report. Add the Comprehensive Module only when a counterparty specifically requires it.

Check how VS-ready your reporting is, free →

Frequently asked questions

Is VSME the same as VS?
Yes. VSME was EFRAG's working name. The European Commission adopted the standard as the Voluntary Standard (VS) on 3 July 2026, with the content and two-module structure largely unchanged.

Is VSME reporting mandatory?
No. It is voluntary in law. In practice, customers, banks and investors request the data, and VS is the agreed format for providing it.

I prepared for CSRD but fell outside scope. Should I use VS?
Yes, in most cases. The Voluntary Standard is designed for non-listed companies outside mandatory CSRD scope, and the data collection and stakeholder work done for CSRD carries over directly.

Do I have to complete the whole standard?
You must complete the Basic Module in its entirety, applying the "if applicable" principle. You cannot pick individual disclosures from the Comprehensive Module if you opt into it.