VSME Basic vs Comprehensive module: what to report and when

The VSME standard is structured around two reporting tiers: a Basic Module of 11 disclosures and a Comprehensive Module that adds 9 more. For most SMEs, the central question is straightforward — which module do you actually need, and what does each one require? The answer depends on who is requesting your data, what regulatory obligations they face, and how mature your sustainability reporting already is.

This article breaks down both modules disclosure by disclosure, maps the applicability conditions that determine what you must report, and shows where the Comprehensive Module aligns with specific regulatory datapoints that banks and investors need.

When the Basic Module is enough

The Basic Module was designed as an entry point. For micro-undertakings — those with fewer than 10 employees, under €900,000 in turnover and €450,000 in balance sheet — EFRAG’s guidance is that Basic is the target level. It covers the essential sustainability metrics that any business counterpart would expect: energy consumption, GHG emissions (Scope 1 and 2), water usage, waste volumes, workforce breakdowns, health and safety data, and anti-corruption compliance.

If your ESG data requests come primarily from corporate clients seeking basic supply chain transparency, or from a bank performing initial sustainability screening, the Basic Module is likely sufficient. During EFRAG’s public consultation, both preparers and users confirmed that the Basic Module covers the minimum information needed for a credible ESG profile.

When you need the Comprehensive Module

The Comprehensive Module becomes necessary when your business partners are financial institutions or large corporates with specific regulatory obligations. Banks reporting under EBA Pillar 3 need datapoints on climate transition plans, controversial sector revenues and human rights incidents. Asset managers subject to SFDR need principal adverse impact data including gender diversity ratios, GHG reduction targets and exposure to fossil fuels. The Comprehensive Module was specifically built to cover these requirements.

EFRAG’s analysis of 12 ESG questionnaires found that the combined Basic and Comprehensive Modules cover approximately 80% of recurring data requests from business partners. The remaining 20% tends to be sector-specific information that falls outside the scope of any sector-agnostic standard.

Full disclosure comparison

The interactive table below lists all 20 VSME disclosures. Use the filters to narrow by module or ESG pillar. Click any row to see the applicability condition — the specific circumstances under which each disclosure must be reported.

Understanding “if applicable” conditions

Unlike ESRS for large companies, the VSME does not require a double materiality assessment. Instead, it uses an “if applicable” principle: disclosures are reported only when the undertaking’s circumstances trigger them. If a disclosure is omitted, the omission is assumed to mean the topic is not applicable — no explanation is required.

Several disclosures have explicit thresholds or conditions. The cards below highlight the ones that are not universally required.

Tracking these conditions across 20 disclosures — especially where thresholds change over time (as with the gender pay gap) — is where manual processes break down. A reporting platform that encodes these conditions and auto-filters applicable disclosures based on your company profile eliminates this complexity entirely.

How the Comprehensive Module maps to financial regulation

The Comprehensive Module was not designed in isolation. Its disclosures were built to satisfy specific regulatory datapoints that banks, asset managers and benchmark administrators need. During the public consultation, banking associations confirmed the necessity of four additional datapoints that were ultimately integrated: radioactive waste, female-to-male management ratio, exclusion from EU reference benchmarks, and GHG intensity.

For asset managers subject to SFDR, the Comprehensive Module covers principal adverse impact indicators including GHG emissions, fossil fuel exposure, controversial weapons involvement, gender diversity and human rights violations. For banks, it provides the climate risk and transition data required under EBA Pillar 3 templates. This alignment is deliberate — EFRAG’s Annex 7 in the Basis for Conclusions provides a detailed mapping of SFDR, Benchmark Regulation and Pillar 3 datapoints to VSME disclosures.

Companies already reporting under GRI standards will find significant overlap. The VSME environmental disclosures map to GRI 301–306, social disclosures to GRI 401–405, and governance metrics to GRI 205. An SME that has invested in GRI-based data collection can reuse most of that infrastructure for VSME reporting without starting from scratch.

Choosing your reporting path

The decision between Option A (Basic only) and Option B (Basic + Comprehensive) should be driven by the data demands you actually face. If your primary counterparts are corporate procurement teams requesting supply chain ESG data, the Basic Module is likely sufficient. If you are a borrower of a bank with active Pillar 3 obligations, or a portfolio company of an SFDR-reporting fund, the Comprehensive Module is the practical choice.

Once chosen, a module must be complied with in its entirety — you cannot cherry-pick individual disclosures from the Comprehensive Module. However, the “if applicable” principle means that disclosures irrelevant to your circumstances are simply omitted. This makes the effective reporting burden lighter than the total datapoint count suggests.

At Generation Impact Global, our platform manages both modules in a single workspace, pre-filters disclosures based on your company profile, tracks year-on-year changes for comparative reporting, and maps your VSME data to ESRS, SFDR and GRI simultaneously — so a single data entry serves multiple frameworks.