- The VS (formerly VSME) sets out a lighter regime for companies with 10 employees or fewer, established by Delegated Regulation (EU) 2026/1560.
- Up to 10 employees, energy, GHG emissions, water and waste become optional in the Basic Module.
- General information, workforce, health and safety, pay and corruption are still expected.
- From financial year 2027, a CSRD-subject client cannot require any environmental data from a micro-company under the value chain cap.
The VSME was already presented as a proportionate standard, but it asked for the same data from a 5-person company and a 200-employee SME. The VS (Voluntary Standard), in force since September 24, 2026, addresses this with a 10-employee threshold. Below it, reporting focuses on the company's identity, its practices and its social data.
Who does the 10-employee threshold cover?
The text covers companies with 10 employees or fewer. A company with exactly 10 employees therefore qualifies for the lighter regime. The Basic Module remains "the target approach for micro-undertakings," in the text's words, and the Comprehensive Module stays open to those who want to go further. Self-employed people and unincorporated businesses can also use VS. For the rest of the scope, our breakdown of who is concerned by VSME covers each case.
What becomes optional
The text flags each datapoint concerned with the words "voluntary for undertakings with 10 employees or less." Most of them are environmental datapoints that require quantified data collection.
| Disclosure | Optional up to 10 employees |
|---|---|
| B3 Energy and GHG | Total energy consumption and Scope 1 and 2 GHG emissions |
| B6 Water | Water withdrawal, water consumption and consumption in areas of water stress |
| B7 Waste | Circular economy principles, weight of waste, share recycled or reused, material flows |
| C1 Strategy | Products and services, markets, business relationships, sustainability-related strategy elements |
| C3 Climate | GHG emission reduction targets |
| C4 Climate risks | Identified hazards and transition events |
| C5 Workforce | Employee turnover rate |
| C6 and C7 Human rights | Code of conduct, complaints-handling mechanism, confirmed incidents |
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What is still expected
A micro-company publishing a VS report still needs to complete the Basic Module, minus the optional datapoints:
- B1: module selected, legal form, NACE code, turnover, balance sheet, headcount, country and site geolocation;
- B2: practices, policies and sustainability initiatives, if the company has any;
- B4 and B5: pollution and sites near biodiversity-sensitive areas, where these situations apply;
- B8 to B10: employees by contract and by gender, work-related accidents, minimum wage, collective bargaining and training hours;
- B11: convictions and fines for corruption, where applicable.
Each datapoint is detailed in our list of VSME indicators.
What your clients can still ask for
The 10-employee threshold also shapes the value chain cap. From financial year 2027, a CSRD-subject client can only require general information (B1), workforce data (B8), work-related accidents (B9) and three pay and training datapoints (B10) from a company with 10 employees or fewer. None of them are environmental. Small suppliers to large companies can therefore refuse a request for a carbon footprint made for a client's CSRD reporting.
Should you still track your environmental data?
The text makes this data optional, and each micro-company is free to report it. Several reasons argue for doing so as soon as the company has the means. Assessments such as EcoVadis take environmental indicators into account. Growing to 11 employees makes this data something clients can require. And energy use or waste tonnage is hard to reconstruct after the fact. Starting with energy from utility bills, then estimating Scope 1 and 2 emissions, is often enough for a first year. Ditto helps small teams centralize their CSR data without a separate tool for each framework.
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Choose the indicators that fit your size and your clients, VS included
Our full breakdown of what changes with VS covers the other changes in the text, and our guide to structuring a VSME report still applies for the method.
A VS report sized to your company
A Ditto expert helps you identify the data worth reporting for your size and your clients
FAQ
Does a company with 10 employees qualify for the lighter regime?
Does a micro-company need to calculate its carbon footprint to publish a VS report?
Can a client require environmental data from a micro-company?
Can micro-companies use the Comprehensive Module?
VSME for Micro-Companies: Key Takeaways
| Element | Key takeaway |
|---|---|
| Threshold | 10 employees or fewer, with no turnover or balance sheet criterion |
| Legal text | Delegated Regulation (EU) 2026/1560, in force since September 24, 2026 |
| Optional | B3 energy and GHG, B6 water, B7 waste, and in the Comprehensive Module C1, C3, C4, C5, C6 and C7 |
| Still expected | B1, B2, B4 and B5 where applicable, B8 to B11 |
| Value chain cap | B1, B8, B9 and B10 only, from financial year 2027 |
