- VSME is now VS (Voluntary Standard): Delegated Regulation (EU) 2026/1560, published in the Official Journal on September 21, 2026, has been in force since September 24, 2026.
- VS is open to any company with 1,000 employees or fewer, with no revenue criterion.
- The structure stays the same (B1 to B11, C1 to C9), but several datapoints change: GHG intensity and sealed area are gone, and employee turnover moves from B8 to C5.
- Companies with 10 employees or fewer can skip the more complex environmental data, and from financial year 2027 a CSRD-subject client can no longer require more than VS from a company with 1,000 employees or fewer.
The VSME has a new name and a new legal status. Adopted by the European Commission on July 3, 2026 as part of the Omnibus I package, VS (Voluntary Standard) replaces the 2025 recommendation and becomes legally applicable. The name changes, the scope widens, several datapoints are removed or moved, and the standard now caps the ESG data large clients can require.
An EU regulation in force since September 24, 2026
The Commission first endorsed EFRAG's VSME as a non-binding recommendation on July 30, 2025. The Omnibus I Directive (EU) 2026/470 then required the Commission to adopt a voluntary standard by delegated regulation, based on the VSME. Delegated Regulation (EU) 2026/1560 was adopted on July 3, 2026, published in the Official Journal on September 21, and entered into force on September 24, 2026. The 2025 recommendation no longer has any legal effect.
The text sets two dates. Companies that want to report voluntarily can apply VS as soon as it enters into force. The value chain cap applies to financial years starting on or after January 1, 2027.
Who can use VS?
VS is intended for companies that are not subject to the CSRD and do not exceed an average of 1,000 employees over the previous financial year. The text sets no revenue or balance sheet criterion for VS: the €450 million threshold only applies to the CSRD. Self-employed people, unincorporated businesses and listed micro-companies are also in scope. Mid-sized companies with several hundred employees, too large to count as SMEs under the EU definition, can now rely on the same standard.
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What changes in the indicators
The Commission kept the VSME architecture: a Basic Module of 11 disclosures (B1 to B11) and a Comprehensive Module of 9 disclosures (C1 to C9). It aligned the content with the simplified ESRS and cut the number of datapoints. These are the changes that affect the VSME indicators the most.
| Disclosure | VSME (EFRAG, December 2024) | VS (Regulation 2026/1560) |
|---|---|---|
| B3 Energy and GHG | Energy, Scope 1 and 2 emissions, GHG intensity (emissions / revenue) | Energy and Scope 1 and 2 emissions. GHG intensity is removed. |
| B5 Biodiversity | Number and area of sites in sensitive areas, plus optional land use, sealed area and nature-oriented area | List of sites in or near a sensitive area, with the name of the area. Area metrics are gone. |
| B7 Waste | Tonnage of waste recycled or reused | Share of waste recycled or prepared for reuse |
| B8 Workforce | Employee turnover rate from 50 employees | Turnover rate leaves the Basic Module |
| C5 Workforce (comprehensive) | No turnover rate | Employee turnover rate, expected above 10 employees |
| B10 Pay and training | Gender pay gap (could be omitted below 150 employees), training hours by gender | Gender pay gap only where the law already requires it, training hours without a gender breakdown |
| C8 Revenue from certain activities | Revenue by sector and exclusion from Paris-aligned benchmarks | Revenue by sector, without the benchmark exclusion disclosure |
The text also adds an explicit statement of compliance in B1, an omission regime for sensitive information (trade secrets, classified information) and the option of a single report combined with an EMAS environmental statement. No third-party assurance is required.
A lighter regime for companies with 10 employees or fewer
VS introduces a 10-employee threshold. A company with 10 employees or fewer can leave out the most demanding environmental data: energy consumption and GHG emissions (B3), water withdrawal and consumption (B6), and waste and circular economy (B7). In the Comprehensive Module, business model descriptions (C1), GHG reduction targets (C3), climate risks (C4), turnover rate (C5) and several human rights questions (C6, C7) also become optional. The Basic Module remains the target for these companies: general information, practices and policies, workforce, health and safety, pay and corruption. Our guide to VSME for micro-companies details each optional datapoint.
VS now caps what your clients can ask for
VS has a second role, tied directly to the CSRD value chain. From financial year 2027, a company subject to the CSRD can no longer require a supplier or customer with 1,000 employees or fewer to provide sustainability information beyond what VS lists. Annex II of the regulation sets that list in two versions: one for companies with more than 10 employees, and a shorter one for companies with 10 employees or fewer, with no environmental data at all. The full list is set out in our article on the VSME value chain cap.
A protected company has a legal right to refuse any request that goes beyond the cap, and a client that makes such a request must tell it so. The cap only covers requests made for CSRD reporting: obligations under other laws (deforestation regulation, forced labor) and contract clauses still apply. For suppliers to large companies, a VS report becomes the reference answer to ESG questionnaires.
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Do you need to redo a report produced under the VSME name?
A VSME report you already published is still useful, but it no longer matches VS exactly. For the next financial year, three adjustments cover most cases: remove GHG intensity and the biodiversity area metrics, move the turnover rate to the Comprehensive Module, and add the statement of compliance in B1. Companies with 10 employees or fewer can also narrow the scope of their environmental data. The guide to structuring a VSME report still applies to the rest of the process, and Ditto's VSME page explains how we can help.
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FAQ
Are VSME and VS the same standard?
When does VS apply?
Is my VSME report still valid?
Does VS apply above €450 million in revenue?
Can a CSRD-subject client still send me a full ESG questionnaire?
VSME Renamed VS: Key Takeaways
| Element | Key takeaway |
|---|---|
| Official name | VS (Voluntary Standard), formerly VSME |
| Legal text | Delegated Regulation (EU) 2026/1560, adopted July 3, 2026, published in the OJ on September 21, 2026 |
| Entry into force | September 24, 2026; value chain cap for financial years starting on or after January 1, 2027 |
| Scope | Companies with 1,000 employees or fewer not subject to the CSRD, with no revenue criterion |
| Indicators | B1 to B11 and C1 to C9 structure kept; GHG intensity and B5 area metrics removed; turnover rate moved to C5 |
| 10-employee threshold | Complex environmental data and several Comprehensive Module datapoints become optional |
| Value chain cap | A CSRD-subject client cannot require more than Annex II of VS from a company with 1,000 employees or fewer |
