No double materiality
The VS does not require the double materiality analysis that weighs on large companies under ESRS. It's the difference between a months-long project and a weeks-long exercise.
VSME · Voluntary Standard (VS)
VSME: the voluntary standard that now binds whoever asks you for data
The VSME is now the VS. It stopped being a recommendation and became a delegated regulation. What has changed is not how much you have to report: it's who decides where the limit sits. Have you already received your first ESG questionnaire and don't quite know what to answer?
- Reporting is still voluntary. What binds is the cap
- It sets a limit on what your clients can ask you
- One VS report a year, reusable with every client and your bank
Voluntary on paper, expected in the market
≤1,000Employees: from here the cap protects you
1 report/yearReusable with every client and your bank
B1–B11 · C1–C9The standard's Basic and Comprehensive modules
WeeksA data-gathering exercise, not a months-long project
The standard, in plain terms
What is the VSME?
The VSME (Voluntary SME standard) is the European sustainability reporting standard for non-listed companies. It simplifies ESG reporting into a common, proportionate format aligned with the European standards, so you answer your clients', bank's and investors' data requests once. After the delegated regulation of 3 July 2026, it becomes the VS (Voluntary Standard).
What it is
A voluntary European sustainability standard, simple and modular, built on EFRAG's technical work.
Who it applies to
Non-listed companies up to 1,000 employees. Reporting is voluntary; the standard is your reference format.
What it includes
A Basic Module (B1–B11) with the key indicators and a Comprehensive Module (C1–C9), with an Excel template and XBRL taxonomy.
What it's for
Answering ESG questionnaires consistently, improving your access to finance and positioning you as a reliable supplier.
From recommendation to regulation
What has changed with the VSME
The VSME hasn't just changed its name. It has changed its legal nature: from a recommendation with no force to a delegated regulation, EU law that is directly applicable.
| Before · VSME | Now · VS | |
|---|---|---|
| Name | VSME | VS (Voluntary Standard) |
| Legal nature | Non-binding recommendation | Delegated regulation, EU law |
| Reference | Recommendation (EU) 2025/1710 · 30.07.2025 | C(2026) 5011 final · adopted 03.07.2026 |
| Who it serves | SMEs under 250 employees | Non-listed companies up to 1,000 employees |
| Transposition | Not applicable | None: directly applicable |
The value chain cap
The cap: what they can ask you and what they can't
The standard doesn't work as a minimum you must reach. It works as a maximum they can't push past.
Above the cap
You're not required to provide it
- Bespoke proprietary questionnaires
- Definitions that diverge from the VS
- Made-up additional datapoints
- Scope 3 breakdown per item
- Extended "group" requirements
- A different template for each client
Below the cap
The data model they can ask you for
- Basic Module B1–B11
- Comprehensive Module C1–C9
- The VS definitions and units
- EFRAG Excel template
- The VS XBRL taxonomy
The cap doesn't remove the conversation with your client: it reframes it. You stop arguing about how many questions you answer and start discussing a common data model, defined by the Commission, that you control and prepare once a year.
The precise answer
Is the VS already law?
The headline going around is "the VS has been law since 3 July". It's almost true, and the difference matters if you're negotiating with a client. The regulation is adopted, in the scrutiny period, and not yet published in the OJEU.
"The Voluntary Standard has been adopted as a delegated regulation since 3 July 2026 and is in the scrutiny period. The content is closed (Parliament and Council cannot amend it) and its entry into force is expected after publication in the OJEU."
Legal snapshot
- Instrument
- Commission delegated regulation of 3 July 2026 · C(2026) 5011 final
- Basis
- Directive (EU) 2026/470 "Omnibus I" · Directive 2013/34/EU · Recommendation (EU) 2025/1710
- Status (as of 5 Aug 2026)
- Adopted by the Commission · in the scrutiny period · not yet published in the OJEU
Timeline
The cap was created in March. In July it got substance.
The right not to provide more information doesn't come from the VS regulation: it comes from Omnibus I, in force since 18 March 2026. The 3 July regulation only sets what data fits beneath it.
- 26 Feb 2026
Omnibus I in the OJEU
Directive (EU) 2026/470. Narrows the scope of CSRD and creates the value chain cap.
- 18 Mar 2026
The cap is born
The directive enters into force: companies of ≤1,000 employees gain the right to limit what they provide.
- 3 Jul 2026
It gets substance
The delegated regulation C(2026) 5011 final is adopted: the standard becomes EU law.
- Autumn 2026
Publication in the OJEU
Legal analyses expect entry into force here, subject to the scrutiny period.
- Sep–Dec 2026
Preparation window
Large companies redesign their value-chain data collection. This is where what they will ask you gets decided.
- 1 Jan 2027
Revised ESRS mandatory
Applies to companies in CSRD scope. The wave of supplier requests arrives.
Scope
Does this apply to me?
| Your situation | What it means | What you do with the VS |
|---|---|---|
| More than 1,000 employees AND more than €450M | Subject to CSRD (both thresholds are cumulative) | You don't apply the VS: you apply the revised ESRS. The VS is what you can ask your own suppliers |
| 1,000 employees or fewer (yearly average) | Outside the mandatory scope. Protected by the cap | Reporting is voluntary. The VS is your reference format and your limit against client and bank requests |
| More than 1,000 employees but €450M or less | Outside scope: one of the two thresholds is missing | You can report voluntarily. Review your position against the cap, which is defined by headcount |
| Listed SME | Omnibus I removed it from the mandatory scope | The VS is the orderly way to serve investors and financiers |
The two thresholds don't measure the same thing. CSRD requires both conditions at once (more than 1,000 employees and more than €450M). The cap is defined by headcount alone (an average of 1,000 or fewer). Don't mix them.
The standard's content
What they'll ask you: Basic and Comprehensive Module
Basic Module · B1–B11
The starting point
The minimum and a prerequisite for the Comprehensive one. It covers most corporate client requests and is the natural target for micro-enterprises.
- B1 · Basis for preparation
- B2 · Practices, policies and future initiatives
- B3 · Energy and GHG emissions, scopes 1 and 2
- B4 · Pollution of air, water and soil
- B5 · Biodiversity
- B6 · Water
- B7 · Resource use, circular economy and waste
- B8 · Workforce general characteristics
- B9 · Health and safety at work
- B10 · Remuneration, collective bargaining and training
- B11 · Convictions and fines for corruption and bribery
Comprehensive Module · C1–C9
When the bank steps in
Nine additional disclosures, designed for what banks, investors and large clients usually ask for above the Basic.
- Business strategy and model tied to sustainability
- Expanded transition policies and practices
- GHG reduction targets and climate transition
- Physical and transition climate risks
- Scope 3 emissions and the value chain
- Additional workforce characteristics
- Human rights policies and processes
- Severe human rights incidents in the value chain
- Revenue from certain sectors and board gender diversity
Final numbering and titles to be checked against the delegated regulation's annex once published in the OJEU. The topic areas are stable; the exact labelling of some Comprehensive disclosures may change from the 2025 version.
Why it's cheaper than you think
A data-gathering exercise, not a consulting project
The "if applicable" principle
Each disclosure is reported only if relevant to your activity. If you omit one from the Comprehensive Module, it's understood not to apply: no justification needed.
No external assurance
The VS does not impose third-party assurance. Your client may request it by contract, but you don't owe it by rule.
Data checklist
The raw material is already yours
The Basic Module is designed to be completed without a sustainability department: most of the data is already in your invoices and payroll. Gather the most recent complete financial year.
Energy and climate
- Electricity (kWh for the year, all sites)
- Gas and other stationary fuels
- Fleet fuel (litres)
- Refrigerant gases
- Renewable energy contracts (GoO or PPA)
Resources and waste
- Waste (tonnes by type and destination)
- Water (m³ consumed, and discharge if relevant)
- Materials and % recycled
- Sites and biodiversity
People
- Workforce (number, contract type, gender, country)
- Turnover (joiners and leavers)
- Accident rate and hours worked
- Pay and gender pay gap
- Collective agreement and training
Governance
- Policies (ethics, environment, whistleblowing)
- Convictions and fines for corruption
- Certifications (ISO 9001, 14001, 45001)
- Governing body by gender
A cap properly understood
The five limits of the cap
An overrated cap gets you into trouble. Here's what the cap does not do.
1. It doesn't stop them asking
It's your right not to provide information above the VS, not a ban on asking the question. You'll keep receiving questionnaires; you can decline the part that exceeds the standard, on legal grounds.
2. It doesn't force you to report
Neither the VS nor the cap forces you to publish anything. But if you provide no data at all, your client can simply pick another supplier. The cap protects the scope, not the commercial outcome.
3. It doesn't cover what you agree to
If you sign a contract or supplier code committing to extra information, you've waived your own protection. Review the ESG clauses before signing, not after.
4. It doesn't neutralise other regimes
Due diligence, your bank's prudential requirements, taxonomy, product rules or public tenders follow their own path. The cap operates on requests derived from your client's sustainability reporting.
5. It has a contested area
There's open debate about sector-specific information critical to large contractors. Expect friction in automotive, construction, agri-food and energy.
Actionable
Three things to do this quarter
- 1
Ask your three biggest clients
What they'll ask you and when. Don't wait for the questionnaire: the September conversation is far cheaper than the March one, and it positions you as the supplier who's ahead.
- 2
Close your Basic Module data
Electricity, fuel, waste, workforce, accident rate, training. A single annual close, with documented sources.
- 3
Decide: by hand or systematise it
If you'll repeat it every year and for several clients, doing it by hand is the expensive option, not the cheap one.
Collect once, answer everyone
Collect once. Use everywhere.
The VS is an exercise you repeat every year and for several clients. Doing it by hand is the expensive option. Dcycle's software collects the data once, from your invoices, payroll and records, and reuses it in the standard's format for every client and your bank.
You still decide what you report; the software takes away the time of gathering and reconciling twenty questionnaires. Delivering in the standard's template and in machine-readable format makes you the easy supplier in the file. And with multi-framework reporting, the same data feeds the VS, CSRD and the rest.
Recopilación
FuentesArchivosProcesados
Fuentes conectadas
SAP Business One
ERP · 342 rows
T
TravelPerk
Viajes · 89 trips
Datadis
Eléctrica · Auto
Google Drive
Archivos · 12 files
Clasificado y validado
Electricity · 45,320 kWh
Natural Gas · 12,100 m³
Fleet diesel · 8,400 L
Business travel · 89 trips
Water use · Review
Waste · Pending
Common questions
Frequently asked questions about the VSME
What is the VSME?
The VSME (Voluntary SME standard) is the European sustainability reporting standard for non-listed companies. After the Commission's delegated regulation of 3 July 2026 (C(2026) 5011 final) it becomes the VS (Voluntary Standard) and serves all non-listed companies up to 1,000 employees, not just SMEs under 250. It stopped being a recommendation to become a delegated regulation: EU law that is directly applicable, with no national transposition.
Is reporting with the VSME or VS mandatory?
No. Publishing a VS report is still voluntary for you. What's binding is the other side: the value chain cap that limits what your CSRD-subject clients can ask you. With 1,000 employees or fewer you're not required to provide sustainability information beyond what the VS covers.
What is the value chain cap?
It's the limit that Directive (EU) 2026/470 (Omnibus I) places on what a large company can require from its suppliers of ≤1,000 employees. It doesn't work as a minimum you must reach, but as a maximum they can't push past. The cap has existed since 18 March 2026; the 3 July regulation sets exactly what data fits beneath it.
Is the VS already law?
Almost. The delegated regulation has been adopted since 3 July 2026 and is in the European Parliament and Council's scrutiny period (two months, extendable by two more). The content is closed (they can't amend it, only reject it in full) and entry into force is expected after publication in the OJEU. As a delegated regulation, it needs no national transposition.
How does the VS differ from the ESRS?
The VS requires no double materiality analysis, follows the 'if applicable' principle and imposes no mandatory external assurance. It's a weeks-long data-gathering exercise, not a months-long consulting project. It's also 100% compatible with the ESRS: the same data model your client needs for its value chain.
What modules does the VS have?
Two. The Basic Module (B1–B11) is the starting point and covers most corporate client requests; it's the natural target for micro-enterprises. The Comprehensive Module (C1–C9) adds what banks, investors and large clients usually ask for. Final numbering and titles are to be checked against the regulation's annex when published in the OJEU.
Who does CSRD affect and who does the VS cap protect?
To be subject to CSRD you need two conditions at once: more than 1,000 employees and more than €450M in 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's a common mistake that can lead you to accept requests you're not required to meet.
No commitment
Book a 30-minute session
Get ready for this autumn's wave of questionnaires. In 30 minutes:
- A read on your position: in or out of CSRD scope
- A review of the questionnaires you've already received
- A data-collection plan for your year-end close
Once a year, one format, every client
That's the whole goal. Measure your Scope 3 and get ahead of this autumn's conversation.
Scope 3 calculator