- Three levels to distinguish: CSRD (the regulatory directive), ESRS (technical standards) and the VS (formerly VSME), a voluntary standard for companies with 1,000 employees or fewer.
- CSRD requires several hundred data points from companies with more than 1,000 employees and more than €450M net turnover; VSME relies on around forty datapoints across 11 disclosures (B1 to B11) in its Basic module.
- VSME is a fully voluntary framework with no audit, open to any company not subject to CSRD with 1,000 employees or fewer.
- An SME can use VSME without ever being subject to CSRD, notably to respond to requests from clients or financiers.
Understanding the European Sustainability Reporting Landscape
To navigate the European ESG ecosystem, three levels need to be distinguished: the directive (CSRD), the technical standards (ESRS), and the voluntary standard — the VSME.
- CSRD (Corporate Sustainability Reporting Directive): the European regulatory framework that requires companies with more than 1,000 employees and more than €450M net turnover to publish comprehensive sustainability reports.
- ESRS (European Sustainability Reporting Standards): the technical standards developed by EFRAG that define what must be disclosed under the CSRD. The revised ESRS (Delegated Regulation (EU) 2026/1563) apply to financial years starting on or after January 1, 2027 and, according to the Commission, cut mandatory datapoints by more than 60%.
- VSME (Voluntary Sustainability Reporting Standard for SMEs): an independent, voluntary standard created by EFRAG for companies with 1,000 employees or fewer, offering a proportionate and practical approach to ESG reporting. Since September 24, 2026, it has been set out in Delegated Regulation (EU) 2026/1560 under the name VS (see what changes with the VS).
CSRD vs VSME: Two Approaches, Two Purposes
| Criterion | CSRD / ESRS | VSME |
|---|---|---|
| Nature | Mandatory | 100% voluntary |
| Scope | More than 1,000 employees and more than €450M net turnover | Companies with 1,000 employees or fewer not subject to CSRD, including suppliers and subcontractors |
| Value-chain requests | Collect ESG data from suppliers for their report | From FY2027, CSRD clients cannot require more than Annex II of the VS from companies with 1,000 employees or fewer |
| Number of datapoints | Several hundred (mandatory datapoints cut by more than 60% in the revised ESRS) | Around forty (Basic Module) |
| External audit | Mandatory | Not required |
| Double materiality analysis | Required | Recommended |
| Format and publication | Structured, published according to ESRS standards | Flexible (PDF, Word, etc.), no imposed format |
Companies subject to CSRD must report on actual and potential ESG impacts, audited in line with ESRS. By contrast, the VSME acts as a voluntary guide enabling SMEs to structure their reporting without going through a complex regulatory process or formal audit.
17 Essential Documents to Formalise Your CSR Approach
Download the full list of documents to produce when structuring your ESG approach — whether you're using VSME or another framework.
Why VSME Is Becoming Strategic for SMEs
The value of the VSME goes well beyond compliance — it turns what could be a burden into a commercial and financing advantage.
- Meeting client expectations: large companies subject to CSRD are already requesting ESG data from their suppliers. The VSME provides a standardised format to meet those demands. For financial years starting on or after January 1, 2027, these clients cannot require from a supplier with 1,000 employees or fewer more information than Annex II of the VS lists: this is the value chain cap.
- Access to financing: banks and investors are increasingly factoring ESG criteria into their decisions; clear, credible reporting improves extra-financial ratings.
- Structuring your CSR strategy: the standard helps define a realistic ESG roadmap and track progress over time.
How Double Materiality Fits into VSME
While not mandatory, the double materiality approach is strongly recommended within the VSME framework. Our guide on double materiality in VSME sets out a simplified method tailored to SMEs.
- Impact materiality: how the company influences ESG issues (e.g. emissions, human rights).
- Financial materiality: how those same issues, in turn, affect business performance or the operating model.
This approach helps prioritise ESG actions and transforms reporting into a strategic management tool. More mature organisations can opt for the VSME's Comprehensive module to incorporate this deeper level of analysis.
Structuring Your VSME Reporting: Tools, Indicators and Validation
The VSME is built around two modules:
- Basic: around forty datapoints across 11 disclosures (B1 to B11) covering the three ESG pillars, designed for a first reporting exercise.
- Comprehensive: adds 9 disclosures (C1 to C9) for companies looking to go further.
Companies with 10 employees or fewer can leave out the more complex environmental data, such as energy and GHG emissions (B3), water (B6) and waste (B7). Our article on optional data for micro-companies details the rule.
No specific report format is required; EFRAG does however provide an Excel template and recommends the XBRL format for financial stakeholders. Verification remains internal — the focus is on data readability and traceability rather than formal certification. To get started quickly, a ready-to-use VSME template is available to help structure your data.
Tools like Ditto automate evidence collection and alignment with VSME or EcoVadis, reducing administrative burden while maintaining ESG consistency over time.
The Complete Action Plan to Succeed in Your CSR Assessments
A practical guide to managing your ESG approach end to end — applicable whether you're working on VSME, EcoVadis or CSRD.
VSME, CSRD and ESRS: Complementarities and Bridges
The VSME is not a competitor to the CSRD — it's a logical extension of it:
- It aligns with the thematic structure of the ESRS (governance, environment, social).
- It speaks the same language as the CSRD, making data sharing across the value chain easier.
- It sets the limit on what CSRD clients can require from value-chain companies with 1,000 employees or fewer.
An SME can therefore rely on VSME reporting as long as it has 1,000 employees or fewer and stays outside the CSRD. If it grows past the CSRD thresholds, its VSME data gives it a base for ESRS-compliant reporting.
Use Cases and Implementation by Company Profile
- Industrial suppliers: VSME consolidates data requested by multiple large clients, replacing a patchwork of questionnaires.
- Startups and fast-growing SMEs: early adoption of the framework builds credibility with investors.
- Exporting companies: facilitates ESG dialogue with European partners subject to CSRD.
- Local service-based SMEs: enables a proportionate CSR approach without excessive administrative constraints.
Manage Your VSME Reporting with Ditto
Our experts show you how to automate data collection and produce your VSME report in just a few weeks.
VSME vs CSRD and ESRS — Key Takeaways
| Key element | Practical insight |
|---|---|
| Nature | CSRD is mandatory; VSME remains voluntary. |
| Purpose | VSME helps SMEs structure their ESG approach and respond to value chain requirements. |
| Complexity | VSME significantly reduces reporting burden (around forty datapoints in the Basic Module vs several hundred). |
| Audit | No external audit required for VSME. |
| Double materiality | Recommended under VSME, mandatory under CSRD. |
| Recommended tools | Ditto, to centralise data, generate a VSME-aligned report and track progress. |
| Use cases | Supplier SMEs, fast-growing startups, companies seeking financing or ESG structure. |
