VSME:the10questionsyourcustomersarealreadyasking
The Omnibus took your company out of the CSRD, but customers and banks still want ESG data. Learn what the VSME is, what they can ask for, and where to start.
- Questions about the VSME, answered with official sources
- Of previously in-scope companies fall outside the CSRD after the Omnibus
- The VSME limits the most a customer can ask you for (value chain cap)
- To move from answering questionnaires to having a system
You were told that, after the Omnibus, your company was out of scope for the CSRD. That is true. But this week a large customer, or your bank, has sent you another ESG questionnaire. The same scene plays out at thousands of companies across the EU: outside the legal obligation, inside the real demand.
This guide answers the ten questions we hear most about the VSME, the European voluntary sustainability reporting standard for SMEs. By the end you will know what it is, what they can ask you for, what they cannot, and what to do this week.
What will you find in the guide?
The ten questions with a direct answer and an official source: whether you fall outside the CSRD, why customers keep asking for data, what the VSME is, how far they can go, what the basic module covers versus the comprehensive one, how much of it is genuinely new work, what is at stake, where to start, how it fits into your financing, and how to move from filling in forms by hand to having a system. It closes with a 5-step plan for this week.
Are you outside the CSRD after the Omnibus?
Most likely, yes. The Omnibus I directive raised the CSRD threshold to companies with more than 1,000 employees and more than 450 million euros in net turnover. With that bar, the European Commission estimates that around 80% of the companies that were previously going to be in scope now fall outside the mandatory scope.
If you are an SME, chances are you no longer have to publish a sustainability report by law. It is worth confirming, because final application depends on how the directive is transposed in your country. Your focus is no longer the law: it is who asks you for data.
Why customers keep asking you for ESG data
Because the demand has not disappeared, it has changed hands. The law no longer imposes it on you, your value chain does. According to EFRAG, the requests come from banks, investors and the large companies you supply. The requirement reaches you all the same, but now through contracts: a clause in your supplier agreement, a condition to renew your credit line.
Voluntary, yes. Optional, no. The best way to take control is to list, with a name and a date, every customer, bank or tender that has asked you for ESG data in the last twelve months. That list is your real calendar.
What the VSME is and when it starts to count
The VSME (Voluntary standard for SMEs) is the European voluntary sustainability reporting standard for SMEs that fall outside the mandatory scope of the CSRD. It exists to replace the chaos of different questionnaires that each customer and each bank used to send on their own, with a single common reference. The Commission first backed it through Recommendation (EU) 2025/1710 and then adopted it as a delegated act alongside the revision of the ESRS.
What really counts, more than a compliance date, is the moment your first customer or bank asks you for data using this framework. For many SMEs, that moment has already arrived.
How far they can go: the value chain cap
The rules introduce the value chain cap: companies subject to the CSRD cannot require the companies in their value chain to provide more information than the voluntary standard covers. The VSME is not only what they can ask you for, it is the ceiling on what they can ask you for.
If a customer sends you an endless questionnaire that goes beyond the standard, you have solid ground to answer with the VSME and stop there. Keep a line ready to copy and paste: “We report in line with the VSME voluntary standard, which EU rules set as the maximum scope that can be required from suppliers (value chain cap).”
Basic module vs. comprehensive
The VSME is organised into two modules with a proportionality logic: you start with the basics and expand only if you are asked to. The basic module resolves most of what you are asked for up front: Scope 1 and 2, energy, water and waste, applicable environmental matters and workforce data. The comprehensive module adds detail when a counterparty needs it: Scope 3, emissions reduction and climate transition targets, and more detailed social and governance indicators.
EFRAG does not publish an official number of indicators. Be wary of anyone selling you “it’s exactly X data points”: the structure matters, not a marketing figure. Much of what the basic module asks for you already handle, it is in your electricity bill, your waste records and your payroll. The challenge is rarely a missing data point, it is that the data is scattered.
Your 5-step plan
Five concrete moves, none longer than half an hour, that pull you out of “react to questionnaires” mode.
- Confirm your legal status: do you exceed 1,000 employees and 450 million euros in net turnover? If not, you are outside the CSRD obligation, depending on how the directive is transposed in your country.
- Map who asks you for data: a list with the name and date of every customer, bank and tender with ESG requests in the last twelve months.
- Cross-check requests against data: a two-column table, what they ask me for and what I already have, with a traffic-light status per basic-module indicator.
- Aim for the basic module: Scope 1 and 2, energy, water, waste and workforce. Remember the value chain cap.
- Move from questionnaire to system: decide the single place where your data lives and migrate the first one there.
How Dcycle helps
Answering every form by hand does not scale: each new customer means starting over. The alternative is a data infrastructure where you collect each data point once and answer any questionnaire, standard or framework from there. A single data point feeds more than 90% of the frameworks: the platform generates your VSME report, and also CSRD, GRI or CDP, without you entering anything again. That is where the VSME stops being a burden and becomes the natural by-product of having your data under control.
If you want to stop filling in questionnaires and start owning your ESG data, request a Dcycle demo.
Frequently asked questions (FAQs)
What happens if I don't do it or answer badly?
A non-listed company is not legally required to report under this framework, so no one is going to fine you. The risk is not legal, it is commercial: if you cannot answer your customer's ESG questionnaire, or you answer with inconsistent data, the business goes to the supplier who has their data in order. You can also drop out of tenders that score sustainability.
How much new work is this really?
Less than you think, though not zero. Much of what the VSME asks for you already handle: it is in your electricity bill, your waste records, your payroll and your accounts. The problem is almost never a missing data point, it is that it is scattered across spreadsheets and emails. It is more a challenge of organising and standardising than a mountain of work from scratch.
How does the VSME fit into my financing with the bank?
EFRAG points to banks and investors among those asking for ESG data and expects the VSME to improve access to finance. The difference is in the how: your data, in a standard format, stops being a last-minute PDF and enters the risk and pricing conversation. With your footprint and your workforce KPIs in order you are easier to assess and to finance on good terms.
Is the VSME the final destination?
No, it is the first step. If your company grows or your obligations change, the path leads up to the CSRD. What matters is that the same data moves up with you: you collect it once and report at each level, without redoing the work.
This guide is for information purposes and does not constitute legal advice. Its specific application may depend on the national transposition of EU directives. Always check your own case with your adviser.
Download the full resource for free.
Key highlights
Collect once. Use everywhere.
See how Dcycle cuts reporting time by 70%, surfaces operational savings, and gives your auditors what they need, the first time.
See Dcycle in action