If your company has fewer than 1,000 employees or turns over less than 450 million euros, the Omnibus has taken you out of the mandatory CSRD scope. Good news on paper.
But there is a detail that changes the story: the VSME, the Voluntary Standard for non-listed Small and Medium-sized Enterprises, is about to become the common language every large company will use to request data from you. The European Commission will publish the VSME Delegated Act on 19 July 2026. In practice, the word “voluntary” in the name carries less weight than it suggests.
What the VSME actually is
The VSME is a reduced set of sustainability disclosures designed specifically for SMEs that are not in the mandatory CSRD scope. It has three key characteristics.
First, it is proportional. Much lighter than the full ESRS: minimum datapoints, no mandatory double materiality analysis, no required external assurance.
Second, it is modular. A Basic Module for companies just starting out, and a Comprehensive Module for those that want to report more.
Third, it is the ceiling of the so-called value chain cap. And that is where the real shift happens.
The value chain cap: your shield and your floor
The Omnibus introduced a principle that changes the dynamic between large companies and their suppliers: CSRD-obligated companies cannot request from their SME suppliers more information than what is covered by the VSME.
This benefits you and binds you at the same time.
It benefits you because any customer that approaches you with a 400-question questionnaire has to stop at the VSME. It is the legal limit.
It binds you because to answer the VSME you actually need to have it prepared. If your customer asks and you cannot answer, the problem comes back to you.
Put differently: the VSME is at the same time a shield (it protects you from excessive requests) and a minimum floor (what you must be able to show).
Why report VSME even if no one forces you to
There are three practical reasons, not idealistic ones.
Your large customers will ask for it. A company reporting under CSRD needs value chain information (Scope 3, social risks, supplier data). The VSME is the standardised way to give it to them. Without VSME, every customer sends you their own questionnaire and you redo the work five times over.
Banks are integrating it. Conditions for green financing, sustainability-linked loans and banking KYC processes are already incorporating criteria aligned with the VSME. Having the data literally reduces the cost of capital.
The competitor who reports takes your contracts. In public and private tenders, ESG criteria are no longer a “nice-to-have”. They are awarding requirements. The company that shows data wins. The one that says “we are working on it” loses.
What the VSME actually asks for
The VSME Basic Module mainly covers:
- General company information and business model
- Energy consumption (electricity, fuels, heating)
- Greenhouse gas emissions (Scope 1 and 2 as a minimum)
- Water use and waste management
- Basic workforce information (headcount, training, health and safety)
- Anti-corruption and human rights policies
The Comprehensive Module adds:
- Scope 3 emissions (where relevant)
- Climate transition analysis
- Value chain information
- More detail on social aspects
Important: 80% of the information the VSME asks for already exists in your company. It is scattered across invoices, contracts, HR systems and payroll. It is not new work. It is connecting work.
The mistake many SMEs make
Here is the pattern that keeps repeating.
A 600-employee company receives an ESG questionnaire from its main customer. It improvises an answer with loose data. Three months later, another customer asks for something similar but with different questions. The exercise is repeated. Six months in, the company has three inconsistent versions of the same data floating around, none verifiable, none reusable.
What should have happened: report VSME once, have the data connected to real operations, and send the same package to every customer.
The difference between these two scenarios is not voluntariness. It is infrastructure.
Timeline
- 19 July 2026: Adoption of the VSME Delegated Act by the European Commission.
- September to December 2026: Adaptation period. The first large companies will start formally requesting VSME from their suppliers.
- 2027 onwards: VSME becomes the de facto standard in the large-company to SME relationship across the EU.
What to do now if you are an SME
Three steps.
Ask your three largest customers what they will request. Do not wait for the questionnaire. Get ahead of it.
Structure the physical data you already have: electricity consumption, fleet fuel, waste, headcount, training. The raw material of the VSME is already in your day-to-day operations.
Decide whether you report internally or automate with a platform. If you will do it every year and for several customers, doing it manually is the expensive option, not the cheap one.
How Dcycle helps with the VSME
Dcycle connects the physical data your company already has (purchases, suppliers, workforce, fleet, energy, water, waste) and layers the use cases you need on top: carbon footprint, VSME, CSRD if you grow into scope, CDP, EINF.
The same data answers multiple frameworks. You do not have to choose.
If you want to see what the VSME looks like inside Dcycle, request a demo and we will walk you through it in 30 minutes.