A Voluntary Standard (VS) project with the datapoints of the Basic Module (B1 to B11) and the Comprehensive Module (C1 to C9), organised by category in Data to report. Leia reads your documents and proposes an answer for each datapoint; you see what the standard requires and what the document states, and confirm. Those figures answer your clients and your bank.
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After Omnibus I most companies are outside the CSRD, but their large clients are still in it and need your data for their value chain.
The Voluntary Standard (VS) is a project type of its own in Dcycle. In Data to report, its datapoints are organised by category (General information, Environmental, Social and Governance) and each disclosure, from VS-B1 to VS-C9, expands into its datapoints with response, owner, data status and progress. With “Draft answers with Leia”, Leia reads your documents and leaves a proposal on every datapoint she can answer. You review what the standard requires and what the document states, and confirm.
B3 asks for energy use and scope 1 and 2 emissions. You upload the electricity, gas or diesel invoices for each site and Leia extracts the period, quantity and amount. Each reading shows its confidence field by field and the PDF is kept as the source of the consumption. The same tabs collect water and waste, the data for B6 and B7.
The VSME requires no external assurance, but a client or a bank may ask for it by contract. The Control tab of the footprint project tells you how much data is processed, to review or processing, and which site has not uploaded its consumption for a given month. One click launches a pre-audit and you download the report.
The footprint project dashboard shows impact by scope, the comparison with the previous year and the categories that weigh most. B3 asks for scope 1 and 2. Scope 3 is optional in the standard, but it is what clients reporting on their value chain ask for most.
The VSME (Voluntary SME standard) is the voluntary sustainability reporting standard EFRAG published in December 2024 for non-listed SMEs. The Commission recommended it in July 2025 and, after Omnibus I, turned it into the Voluntary Standard (VS) through a delegated regulation. It lets you answer clients, banks and investors with a single report.
Employees on average
Up to that headcount, a CSRD-reporting client cannot require more from you than the standard sets.
Basic Module
Eleven disclosures. The starting point and the natural target for micro-enterprises.
Comprehensive Module
Nine more disclosures: the ones banks, investors and large clients usually ask for.
| VSME | VS (Voluntary Standard) | |
|---|---|---|
| Legal nature | Non-binding recommendation | Delegated regulation, EU law |
| Reference | Recommendation (EU) 2025/1710 of 30 July 2025 | C(2026) 5011, adopted on 3 July 2026 and published in the OJEU |
| Who can use it | Non-listed SMEs | Companies outside the mandatory CSRD scope with up to 1,000 employees on average |
| Transposition | Not applicable | None: the regulation applies directly |
The Basic Module is the minimum and the prerequisite for the Comprehensive one. Each disclosure is reported only if it applies to your business, and omitting one from the Comprehensive Module means it does not apply.
| Code | Disclosure | What it asks for |
|---|---|---|
| B1 | Basis for preparation | Module chosen, individual or consolidated scope, legal form, NACE code, balance sheet, turnover, headcount, sites and certifications. |
| B2 | Practices, policies and future initiatives | Whether you have practices, policies or initiatives on climate, pollution, water, biodiversity, circular economy, people and business conduct, and whether they have targets. |
| B3 | Energy and GHG emissions | Total energy use in MWh, renewable and non-renewable, gross scope 1 and 2 emissions and GHG intensity per turnover. |
| B4 | Pollution of air, water and soil | The pollutants you already report under a legal requirement or an environmental management system. |
| B5 | Biodiversity | Sites in or near biodiversity-sensitive areas, with their surface area. |
| B6 | Water | Total water withdrawal and consumption at sites in areas of high water stress. |
| B7 | Resource use, circular economy and waste | Whether you apply circular economy principles, and waste generated, hazardous and non-hazardous, and how much is recycled or reused. |
| B8 | Workforce: general characteristics | Employees by contract type, gender and country, and turnover rate. |
| B9 | Workforce: health and safety | Number and rate of recordable work-related accidents, and fatalities. |
| B10 | Remuneration, collective bargaining and training | Whether you pay at least the minimum wage, the gender pay gap, collective bargaining coverage and average training hours by gender. |
| B11 | Convictions and fines for corruption and bribery | Number of convictions and amount of fines. |
| Code | Disclosure | What it asks for |
|---|---|---|
| C1 | Strategy: business model and sustainability initiatives | Products and services, markets, key business relationships and which parts of the strategy relate to sustainability. |
| C2 | Practices, policies and future initiatives | The detail behind B2 and the most senior role accountable for each topic. |
| C3 | GHG reduction targets and climate transition | Targets with a base year and values and, if you have one, your transition plan. |
| C4 | Climate risks | Physical and transition risks, your exposure and your adaptation actions. |
| C5 | Additional workforce characteristics | Ratio of women to men in management, and self-employed and agency workers. |
| C6 | Human rights policies and processes | A code of conduct or human rights policy, and a grievance mechanism. |
| C7 | Severe human rights incidents | Confirmed cases in your workforce or value chain and what you did about them. |
| C8 | Revenues from certain sectors | Revenue from controversial weapons, tobacco, fossil fuels or chemicals, and exclusion from Paris-aligned benchmarks. |
| C9 | Gender diversity in the governance body | Ratio of women to men on the board or governance body. |
Large companies reporting under the CSRD need data from their value chain. The VS sets how far they can ask and gives you one format to answer them all.
If you have 1,000 employees or fewer on average, a CSRD-reporting client cannot require more for its report than the datapoints in Annex II of the VS. If it asks for more, it must tell you which part exceeds the standard and that you have the right to decline it.
The cap applies to financial years starting on or after 1 January 2027, when large companies report under the revised ESRS. Member States have until 19 March 2027 to transpose Omnibus I.
You prove your size with a headcount self-declaration, and your client can rely on it unless it knows it is manifestly incorrect.
Your client should only ask for the Annex II datapoints it actually needs for its report, not the whole standard by default.
Requests made for other purposes follow their own path: due diligence, your bank's risk assessment, public tenders, EcoVadis or CDP.
Neither the VS nor the cap requires you to publish anything or have your data assured. But if you provide no data at all, your client can pick another supplier.
| Your situation | What it means | What you do with the VS |
|---|---|---|
| More than 1,000 employees and more than €450M turnover | Subject to the CSRD: both thresholds are cumulative | You apply the revised ESRS. The VS is the most you can ask of your protected suppliers |
| 1,000 employees or fewer on average | Outside the mandatory scope and protected by the cap | Reporting is voluntary. The VS is your reference format and your limit with clients |
| More than 1,000 employees but €450M or less | Outside scope: one of the two thresholds is missing | You can report voluntarily, but the cap does not protect you: it is defined by headcount alone |
| Listed SME | Omnibus I removed it from the mandatory scope | The VS is the orderly way to answer investors and lenders |
The Commission adopted the delegated regulation on 3 July 2026 and, after scrutiny by the Parliament and the Council, it has been published in the OJEU. As a regulation it applies directly, with no national law, and replaces the 2025 recommendation.
| Date | What happens | What it means |
|---|---|---|
| Dec 2024 | EFRAG publishes the VSME | A voluntary standard for non-listed SMEs, with a Basic and a Comprehensive Module. |
| 30 Jul 2025 | Recommendation (EU) 2025/1710 | The Commission recommends the VSME as the reference while the CSRD is revised. |
| 18 Mar 2026 | Omnibus I enters into force | Directive (EU) 2026/470 raises the CSRD threshold and creates the value chain cap. |
| 3 Jul 2026 | The VS is adopted | Delegated regulation C(2026) 5011: the VSME becomes the Voluntary Standard. |
| 19 Mar 2027 | Omnibus I transposition deadline | Member States must apply its rules, including the cap. |
| FY 2027 | The value chain cap applies | Financial years starting on or after 1 January 2027, the first under the revised ESRS. |
The Basic Module is designed to be completed without a sustainability department. Most of the data is already in your invoices and payroll.
Download: 10 VSME questions your clients will askThe VS does not require the double materiality assessment of the ESRS. That is the difference between a months-long project and a weeks-long exercise.
Each disclosure is reported only if it is relevant to your business. If you omit one from the Comprehensive Module, it is understood not to apply.
The VS does not impose third-party assurance. Your client may ask for it by contract, but you do not owe it by rule.
| Area | What data to gather |
|---|---|
| Energy and climate | Electricity in kWh for every site, gas and other fuels, fleet diesel, refrigerant gases and renewable contracts (guarantees of origin or PPAs). |
| Resources and waste | Waste in tonnes by type and destination, water in m³, materials with their recycled share and sites near protected areas. |
| People | Headcount by contract, gender and country, joiners and leavers, accidents and hours worked, pay, collective agreement and training. |
| Governance | Ethics, environmental and whistleblowing policies, convictions and fines for corruption, ISO certifications and governance body composition. |
The VSME (Voluntary SME standard) is the European voluntary sustainability reporting standard EFRAG published for non-listed SMEs. After the Commission's delegated regulation of 3 July 2026 (C(2026) 5011) it becomes the VS (Voluntary Standard) and serves companies outside the mandatory CSRD scope with up to 1,000 employees on average, not just SMEs under 250. It stopped being a recommendation and became directly applicable EU law.
No. Publishing a VS report is still voluntary. What is binding is the other side: the value chain cap limits what your CSRD-reporting clients can require from you. With 1,000 employees or fewer on average, you are not obliged to give them more information for their sustainability report than the standard covers.
It is the limit Directive (EU) 2026/470 (Omnibus I) places on what a CSRD-reporting company can require from value chain companies with up to 1,000 employees. The datapoints under the cap are listed in Annex II of the VS regulation. If the client asks for more, it must point out which part exceeds the standard and tell you that you may decline it. It applies to financial years starting on or after 1 January 2027 and does not cover requests made for other purposes, such as due diligence.
Yes. The Commission adopted the delegated regulation on 3 July 2026 and, after the scrutiny period of the European Parliament and the Council, it has been published in the OJEU. As a delegated regulation it needs no national transposition and replaces Recommendation (EU) 2025/1710. The value chain cap applies from financial year 2027.
The VS requires no double materiality assessment, follows the 'if applicable' principle and imposes no mandatory external assurance. It is a weeks-long data-gathering exercise, not a months-long consulting project. It is also aligned with the ESRS: it uses the definitions your client needs for its value chain reporting.
Two. The Basic Module (B1 to B11) is the starting point and covers most corporate client requests; it is the natural target for micro-enterprises. The Comprehensive Module (C1 to C9) adds strategy, reduction targets, climate risks, human rights and board diversity, which is what banks, investors and large clients usually ask for.
To be subject to the CSRD you need two conditions at once: more than 1,000 employees and more than €450M in net turnover. To be protected by the cap the reference is headcount alone: an average of 1,000 employees or fewer. Don't mix the thresholds: it is a common mistake that can lead you to accept requests you are not required to meet.
Leia reads the documents you give her, such as your annual report, invoices or equality plan, and proposes an answer for each VS datapoint she can answer from them. Next to each proposal you see what the standard requires and what the document states. You confirm or dismiss each one: what you report is still your decision.
Yes. The same energy, emissions, workforce and governance data answers client questionnaires, EcoVadis or CDP without collecting it again.
30 minutes: a VS project with its data to report and Leia’s proposals, invoice reading for B3 and the data pre-audit, with a real case adapted to your sector.
Draft answers with Leia