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ESRS for SMEs explained: what it covers and what it doesn't

The ESRS for SMEs is the voluntary EU standard for sustainability reporting by non-listed small and medium-sized enterprises. This article explains what the standard requires, what deliberately remains outside its scope, and why that boundary is not arbitrary.

What is the VSME standard

VSME stands for Voluntary Sustainability reporting standard for non-listed SMEs: the voluntary EU standard for sustainability disclosure by non-listed small and medium-sized enterprises. The standard was developed so that smaller businesses can provide a fixed, limited and clear set of sustainability information to those who request it: a major customer, a bank, an insurer. Not a free-form list of questions that differs from company to company, but one defined set of topics that is the same everywhere.

The most important thing to remember: the VSME is a core module with a number of optional modules around it. The core module includes, among other things, energy consumption, greenhouse gas emissions at the level of the company's own operations, personnel data such as the number of employees and turnover, and a brief description of the company. The optional modules go further, for example on climate risks or on the value chain. A company decides for itself whether to complete those optional modules, and anyone asking for them cannot unilaterally override that choice — that is precisely where the boundary lies that has been set in the sustainability disclosure directive since March 2026 for suppliers with a thousand employees or fewer.

What is included

The core module is designed as something that can be completed with existing documents, not with a new measurement system. Energy consumption comes from the energy bill, fuel consumption from receipts or the fuel card, personnel data from payroll records. The standard does not ask for measurements that a company still needs to set up; it asks for what already exists, in a fixed format. That is also why the standard is called "voluntary": there is no obligation to use it, but whoever uses it uses a format that is tailored to what a small business can reasonably provide.

In addition, the core module contains a number of descriptive elements: where the company operates, how many employees it has, and whether there is a policy on a number of sustainability topics. The latter is often a simple yes/no with a brief explanation, not an elaborate policy document. broken down by topic to show what the standard exactly asks for provides an overview per theme, so you do not need to read the full standard to see what is relevant for your situation.

What is not included, and why that matters

What the VSME deliberately leaves out of the core module is at least as important as what it includes. The value chain beyond the company's own operations — the emissions of suppliers, working conditions at subcontractors, the full life cycle of a product — falls under an optional module. A comprehensive risk analysis of climate change on the company's own locations is not mandatory in the core either. This does not mean these topics are unimportant; it means that the legislator has placed them in a module that a company chooses to use, not in the part that counts as a standard requirement.

This distinction is the core of the supply chain requirement that has been in effect since March 2026: a company subject to disclosure obligations cannot demand more sustainability information from a supplier with a thousand employees or fewer than what is in the VSME. If a customer asks for something from an optional module that the company does not use, that question goes beyond what the standard identifies as core. Whether a specific question falls into that category must be assessed on a case-by-case basis — the regulator and the official text of the directive are the appropriate source for that, not a general rule of thumb.

Why this boundary is not arbitrary

The VSME is not designed as a minimum that automatically grows over time; it is designed as a ceiling for what a large buyer can pass down the chain to a small business. Without that limit, a supplier with twenty employees could receive the same questionnaire as a listed company with thousands of employees and its own sustainability department. The standard therefore exists not only to indicate what a small business can report, but also to establish what a large buyer can reasonably ask for.

For those who want to see how this works in practice — which question falls within the basic module and which does not — is get a first indication from a few questions a faster route than reading the full standard. And those who want to know exactly where the information on esgia.eu comes from will find that on the page showing where the information comes from.

Finally

The VSME standard is neither a mark of conformity nor an obligation in itself; it is a shared language between small businesses and the parties who ask them for sustainability information. What is in it can be traced back to the official text; what falls outside it is precisely the part over which a supplier can formulate a proper refusal. For questions that come up frequently, such as what that refusal looks like or what a bank does independently of it, is the overview of frequently asked questions a good starting point.

Do you want to know if a questionnaire you received stays within the VSME basics? Do the free quick-scan or browse through the topics — without an account, and with the location in the official text included.

This article is general information and not legal advice.