VSME Indicators: Complete List and Practical Examples for SMEs

Understanding VSME indicators and their value for SMEs

The VSME, published by EFRAG in December 2024, became the VS (Voluntary Standard) with Delegated Regulation (EU) 2026/1560, in force since September 24, 2026. It helps companies with 1,000 employees or fewer structure their ESG reporting in a way that is proportionate to their resources.

The standard is organized into two modules:

• Basic Module (B1 to B11): 11 disclosures covering general information, environment, social and governance topics. This is the minimum for every company applying the standard.
• Comprehensive Module (C1 to C9): 9 additional disclosures for companies looking to meet the requirements of banks, investors and large corporate clients.

The official text refers to datapoints, the individual data items to report. It gives no total. Counting each item to disclose as one datapoint, the VS Basic Module contains 38, or around forty. The figure of 56, often quoted for the 2024 VSME, no longer matches the text in force.

These indicators serve as a response to the expectations of clients subject to the CSRD, an internal strategic compass and a lever for accessing sustainable finance. For a broader understanding of what VSME is and who it applies to, our article on VSME: understanding the European sustainability reporting standard covers the foundations.

The structure of VSME indicators

The Basic Module organizes its forty or so datapoints into 11 disclosures:

• 2 general disclosures: B1 (general information) and B2 (ESG practices and policies)
• 5 environmental disclosures: B3 to B7
• 3 social disclosures: B8 to B10
• 1 governance disclosure: B11

This structure allows SMEs to take a step-by-step approach, depending on their maturity and available resources. Our breakdown of what changes with VS compares the old and new versions disclosure by disclosure.

Basic Module indicators in detail

B1: General information (basis for preparation)

B1 sets the framework for the report. It contains the following datapoints:

• Module selected (Basic only or Basic + Comprehensive), with an explicit statement of compliance with the standard
• Disclosures omitted for confidentiality or trade secret reasons (if applicable)
• Report scope: individual or consolidated basis
• List of subsidiaries (if consolidated), with registered address
• Legal form
• NACE sector code(s)
• Balance sheet total
• Net turnover
• Number of employees (FTE or headcount)
• Country of primary operations and location of significant assets
• Geolocation of sites owned, leased or managed
• Sustainability-related certifications or labels obtained (description, issuer, date, score)

B2: Practices, policies and transition initiatives

B2 asks the company to state what it has put in place to move toward a more sustainable economy. Where it has any, it specifies:

• its practices (cutting water and electricity use or emissions, preventing pollution, working conditions, equal treatment)
• its sustainability policies, and whether they are public
• its future initiatives or plans
• its targets for monitoring how those policies are implemented

The list of possible sustainability issues (climate, pollution, water, biodiversity, circular economy, own workforce and value chain workers, communities, consumers, business conduct) serves as a reference, with no requirement to cover every topic.

B3: Energy and greenhouse gas emissions

This is the core of environmental reporting. The datapoints are:

• Total energy consumption (MWh), broken down where possible between electricity and fuels, renewable and non-renewable
• Scope 1 emissions (tCO₂e): direct emissions from owned or controlled sources
• Location-based Scope 2 emissions (tCO₂e): purchased electricity, heat, steam and cooling

GHG intensity (emissions divided by revenue), required by the 2024 VSME, has been removed. All three datapoints are optional for companies with 10 employees or fewer.

B4: Pollution of air, water and soil

This disclosure only applies to companies already required to report pollutant emissions to competent authorities, or that report them voluntarily under an Environmental Management System (ISO 14001, EMAS).

• Emissions of pollutants to air, water and soil from own operations

If the information is already publicly available, a reference or URL link is sufficient. Service companies not subject to these obligations simply state that the disclosure does not apply.

B5: Biodiversity

• Sites located in or near a biodiversity-sensitive area (Natura 2000, UNESCO, Ramsar sites, KBAs, other protected areas), with the name of the area

The number and area of sites, along with the optional land use, sealed area and nature-oriented area metrics, are no longer part of VS.

B6: Water

• Total water withdrawal (m³)
• Water consumption (m³), for companies whose production processes use significant amounts of water (drying, irrigation, food production, etc.)
• Share of that consumption at sites in areas of water stress

For office-based companies connected to the public network, consumption is close to zero and can be omitted. B6 datapoints are optional up to 10 employees.

B7: Resource use, circular economy and waste management

• Whether circular economy principles are applied, and how
• Total weight of waste generated, split between hazardous and non-hazardous
• Share of waste diverted to recycling or preparation for reuse
• Annual mass flow of relevant materials used (manufacturing, construction, packaging)

VS now expresses recycling as a share rather than a tonnage. These datapoints are optional up to 10 employees.

B8: Workforce, general characteristics

• Employees by type of contract: permanent and temporary (FTE or headcount)
• Employees by gender (FTE or headcount)
• Employees by country of employment contract (if operating in more than one country)

The employee turnover rate, previously required in B8 from 50 employees, moves to the Comprehensive Module (C5).

B9: Workforce, health and safety

• Number and rate of recordable work-related accidents
• Number of fatalities from work-related accidents or ill health, subject to legal restrictions

B10: Remuneration, collective bargaining and training

• Are employees paid at least the applicable statutory or collectively agreed minimum wage? (yes/no)
• Gender pay gap, only if the company is already required by law to report it
• Percentage of employees covered by collective bargaining agreements
• Average annual training hours per employee

VS no longer asks for training hours broken down by gender.

B11: Convictions and fines for corruption and bribery

• Number of convictions and total fines for violations of anti-corruption and anti-bribery laws, where convictions occurred in the period

Summary: the Basic Module datapoints

Comprehensive Module: the 9 additional disclosures

The Comprehensive Module addresses the requirements of banks, investors and large corporate clients subject to SFDR or EBA Pillar 3. It builds on the Basic Module. For practical guidance on producing your report from these indicators, our article on VSME reporting walks through each step of the process.

C1: business model and strategy: products and services, markets, key business relationships, strategy elements related to sustainability.

C2: description of the practices, policies and initiatives reported under B2, noting those that cover suppliers or clients and the related targets.

C3: Scope 1 and 2 GHG reduction targets (target year and value, base year, planned actions), and a transition plan for high climate impact sectors (NACE A to H and M).

C4: identified climate-related hazards and transition events, exposure assessment, time horizons and adaptation actions.

C5: employee turnover rate, plus optionally the female-to-male ratio at management level and the number of exclusive self-employed and agency workers.

C6: human rights policies: code of conduct covering child labor, forced labor, human trafficking, discrimination and accident prevention, plus a complaints mechanism for own workforce.

C7: confirmed human rights incidents in own workforce and in the value chain.

C8: revenue from sensitive sectors: prohibited weapons, tobacco, fossil fuels, chemicals production. The Paris-aligned benchmark exclusion disclosure has been removed.

C9: gender diversity ratio in the governance body.

Up to 10 employees, the datapoints in C1, C3, C4, C5 and part of C6 and C7 are optional. The datapoints your CSRD-subject clients can require under the value chain cap are listed in Annex II of the regulation and explained for suppliers to large companies.

How to prioritize the right indicators for your SME

VSME recommends a materiality-based approach to identifying the most relevant indicators. Three steps:

1. Assess your impacts on the environment, employees and society.
2. Identify ESG risks and opportunities likely to influence your financial performance.
3. Select your key indicators based on criticality, client expectations and your ESG maturity level.

Tools, formats and verification

VS leaves considerable flexibility in how the report is structured and validated:

• No external audit is required.
• Data can be verified internally from documentary sources (invoices, HR records, accident register, etc.).
• EFRAG provides a digital template and application guidance on its website.
• An EMAS-registered company can publish a single report combined with its environmental statement.

Our comparison of VSME tools reviews the options for automating data collection, and our article on VSME audit helps you assess your compliance level before getting started.

Platforms like Ditto help automate data collection and organization, reduce the administrative burden and keep reporting consistent across frameworks like EcoVadis and CDP.

VSME Indicators: Key Takeaways