What is the VSME standard? A practical guide for non-listed SMEs.

Perché è stato creato il VSME

CSRD doesn’t apply to non-listed SMEs directly — but the pressure to report still lands on them. Banks need the data to meet their own SFDR and EBA Pillar 3 obligations. Investors need it for the EU Benchmark Regulation. And large corporates reporting under ESRS need it to cover their value chain disclosures. Before the VSME existed, that meant a different spreadsheet or portal for every counterparty, each asking for roughly the same information in a slightly different shape

EFRAG reviewed 12 of the ESG questionnaires already circulating among roughly 26,000 SMEs — the ones banks, rating agencies and supply-chain programmes were actually using — and built the VSME around the datapoints that kept recurring. The goal: one structured report that an SME can hand to any counterparty, instead of filling out the same information a dozen different ways.EFRAG VSME Feedback Statement

Quali aziende possono avvalersi del VSME?

Eligibility is based on the EU Accounting Directive’s size categories. A company falls into a category — and can use the corresponding module — if it stays under two of the three thresholds:

That said, the thresholds aren’t a hard ceiling on who benefits. The Omnibus I simplification package (February 2025) proposes raising the CSRD headcount threshold to 1,000 employees. If that goes through, mid-sized companies who fall out of CSRD scope as a result would land without a dedicated framework of their own — and the VSME, or a delegated act built on it, is the most likely candidate to fill that gap.

Due moduli: Base e Completo

Structurally, the VSME is two layers. Basic covers the minimum set most micro and small companies will be asked for. Comprehensive builds on top of it with the datapoints banks, investors and larger corporate clients tend to want for their own due diligence. You can’t report Comprehensive without first covering Basic — it’s additive, not a separate track. Use the explorer below to see what’s actually in each one:

None of this requires a formal double materiality assessment. Instead, each disclosure follows an ‘if applicable’ logic: if it doesn’t reflect your circumstances, you skip it, and the absence is read as ‘not applicable’ rather than an incomplete report. That was a deliberate response to the consultation — 311 respondents specifically called out materiality assessments as too costly and technical for a company this size to run.

Come il VSME si integra con altri framework

Interoperability was a design goal from the start, not an afterthought. The Comprehensive Module’s datapoints are built to line up directly with SFDR’s principal adverse impact indicators, EBA Pillar 3 disclosures and the EU Benchmark Regulation — so the same report can answer more than one counterparty’s request.

It’s also mapped against ESRS Set 1, so a supplier reporting under VSME gives its corporate customers data that’s already consistent with what those customers need for their own ESRS filings. And if your company already reports against GRI, most of the ground is covered: the environmental disclosures line up with GRI 301, 302, 303, 304, 305 and 306, and the social disclosures with GRI 401, 403, 404 and 405.

Reportistica digitale: la tassonomia XBRL e il modello Excel

For the actual mechanics of filing, EFRAG maintains a free Excel-based Digital Template — version 1.2.0 as of February 2026 — built around an XBRL taxonomy so the output is machine-readable. It handles validation, auto-calculation and a fuel-to-MWh conversion out of the box, and EFRAG’s own converter tool turns a completed file into an Inline XBRL report. It’s released under an MIT licence and available in 11 EU languages.

It’s worth knowing what the template doesn’t do, though. It only handles one reporting period at a time, so there’s no built-in year-on-year comparison; it doesn’t calculate GHG emissions for you; it can’t consolidate multiple entities; and as a spreadsheet, it’s inherently less usable than a purpose-built tool. EFRAG has been upfront that this is meant as a reference implementation, not a production tool — the taxonomy is the standard, and software providers are expected to build the actual reporting experience on top of it.

Cosa comporta il VSME per le banche, gli investitori e le grandi imprese

The Commission Recommendation goes further than just proposing the standard — it actively encourages banks, asset managers and large corporates to build their ESG data requests around it. In practice that means: credit teams get a standardised input for Pillar 3 reporting, asset managers get portfolio-level data that already lines up with SFDR PAI indicators, and procurement teams get supplier data that plugs directly into their own ESRS value chain disclosures — without a bespoke questionnaire for each supplier

What that unlocks is scale. A bank with a few thousand SME borrowers no longer needs to manually process a few thousand different questionnaire formats — it can standardise intake around the VSME structure and automate ingestion straight from the XBRL file. If you’d like to see how that works in practice, the assessment below is a good place to start:

L'ecosistema VSME e le prospettive future

Beyond the standard itself, EFRAG is building out support infrastructure: an SME Forum, a map of national sustainability tools, outreach events, an ongoing acceptance survey, and additional guidance on transition plans, pollution and human rights. That support programme now runs through the end of 2026.

The bigger shift, if it happens, is legal standing. Omnibus I proposes turning a VSME-based framework into a delegated act covering companies up to 1,000 employees — which would formalise it as the basis for the ‘value chain cap’ limiting what larger companies can ask their suppliers for. Whether and when that happens still depends on how the Parliament and Council negotiations land.

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