VSME Indicators: Complete List and Practical Examples for SMEs

Understanding VSME indicators and their value for SMEs

The VSME (Voluntary Sustainability Reporting Standard for non-listed SMEs) is a voluntary framework published by EFRAG in December 2024. It helps non-listed SMEs structure their ESG reporting in a way that is proportionate to their resources.

The standard is organised into two modules:

• Basic Module (B1 to B11): 11 thematic blocks covering general information, environment, social and governance topics. This is the recommended minimum for all SMEs.
• Comprehensive Module (C1 to C9): 9 additional blocks for SMEs looking to meet the requirements of banks, investors and large corporate clients.

In the official EFRAG document, these indicators are referred to as "datapoints" — individual data items to be reported. Each thematic block breaks down into several datapoints. The Basic Module contains 56 in total. This is the count behind the figure of "around 60 datapoints" often cited in commentary on the standard.

These indicators serve as a response to the expectations of clients subject to 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 organises its 56 indicators into 11 thematic blocks:

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

This structure allows SMEs to take a step-by-step approach, depending on their maturity and available resources.

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)
• Disclosures omitted for confidentiality 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 (in euros)
• Net turnover (in euros)
• Number of employees (FTE or headcount)
• Country of primary operations and location of significant assets
• Geolocation of sites owned, leased or managed (coordinates)
• Sustainability-related certifications or labels obtained (description, issuer, date, score)

B2 — Practices, policies and transition initiatives

B2 asks the undertaking to describe what it is actually doing on ESG issues. For each of the 10 themes below, three datapoints are required: whether practices or policies exist, whether they are publicly available, and whether targets have been set.

The 10 themes covered:

• Climate change
• Pollution
• Water and marine resources
• Biodiversity and ecosystems
• Circular economy
• Own workforce
• Workers in the value chain
• Affected communities
• Consumers and end-users
• Business conduct

That makes 30 datapoints in total (3 per theme × 10 themes).

B3 — Energy and greenhouse gas emissions

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

Energy:

• Renewable electricity consumption (MWh)
• Non-renewable electricity consumption (MWh)
• Renewable fuel consumption (MWh)
• Non-renewable fuel consumption (MWh)
• Total energy consumption (MWh)

GHG emissions:

• Scope 1 emissions (tCO₂e) — direct emissions from owned or controlled sources
• Location-based Scope 2 emissions (tCO₂e) — purchased electricity, heat, steam and cooling

Intensity:

• GHG intensity: total emissions / net turnover (tCO₂e / €)

B4 — Pollution of air, water and soil

This disclosure only applies to undertakings already subject to a legal obligation to report pollutants to competent authorities (IED/IEPR directive) or that voluntarily report them under an Environmental Management System (ISO 14001, EMAS).

The datapoints are:

• Type of pollutant emitted
• Quantity emitted per pollutant (in kg or tonnes)
• Release medium (air, water, soil)

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

• Number of sites located in or near a biodiversity-sensitive area (Natura 2000, UNESCO, KBA, other protected areas)
• Total area of those sites (hectares)

Optional:

• Total land use (hectares)
• Total sealed area (hectares)
• Total nature-oriented area on-site (hectares)
• Total nature-oriented area off-site (hectares)

B6 — Water

• Total water withdrawal (m³)
• Water withdrawal at sites in areas of high water stress (m³)
• Water consumption (m³) — applicable to undertakings whose production processes consume significant amounts of water (drying, irrigation, food production, etc.)

For office-based companies that discharge water into the public sewer, consumption is close to zero and can be omitted.

B7 — Resources, circular economy and waste management

• Description of circular economy principles applied (qualitative)
• Total non-hazardous waste generated (tonnes)
• Total hazardous waste generated (tonnes)
• Total waste diverted to recycling or reuse (tonnes)
• Annual mass flow of significant raw materials and inputs used, by type (applicable to manufacturing, construction and packaging sectors)

B8 — Workforce — General characteristics

• Number of employees on permanent contracts (FTE or headcount)
• Number of employees on temporary contracts (FTE or headcount)
• Number of male employees (FTE or headcount)
• Number of female employees (FTE or headcount)
• Number of employees identifying as other / not reported (FTE or headcount)
• Number of employees by country of employment contract (if operating in more than one country)
• Employee turnover rate — applicable to undertakings with 50 or more employees

B9 — Workforce — Health and safety

• Number of recordable work-related accidents
• Rate of recordable work-related accidents (number of accidents / hours worked × 200,000)
• Number of fatalities resulting from work-related injuries
• Number of fatalities resulting from work-related ill health

B10 — Workforce — Remuneration, collective bargaining and training

• Are employees paid at least at the applicable statutory or collectively agreed minimum wage? (yes/no)
• Gender pay gap: difference between average gross hourly pay for male and female employees, expressed as a % of male pay — may be omitted if headcount is below 150 (threshold reduced to 100 from 7 June 2031)
• Percentage of employees covered by collective bargaining agreements
• Average number of annual training hours per male employee
• Average number of annual training hours per female employee

B11 — Convictions and fines for corruption and bribery

• Number of convictions for violation of anti-corruption and anti-bribery laws in the reporting period
• Total amount of corresponding fines (euros)

If no incidents occurred, this datapoint is not applicable.

Summary: the 56 Basic Module indicators

Comprehensive Module: the 9 additional indicators

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 sustainability-related initiatives: description of products/services, markets, key supplier and client relationships, strategy elements related to sustainability.

C2 — In-depth description of the ESG practices and policies reported under B2, with the most senior level accountable identified.

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

C4 — Identified climate-related hazards and transition events, exposure assessment, time horizons and adaptation actions taken.

C5 — Female-to-male ratio at management level (≥50 employees), number of exclusive self-employed workers and agency workers.

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

C7 — Confirmed severe human rights incidents in own workforce and value chain.

C8 — Revenues from sensitive sectors: controversial weapons, tobacco, fossil fuels, pesticides. Potential exclusion from EU Paris-aligned benchmarks.

C9 — Gender diversity ratio in the governance body (number of women / number of men).

How to prioritise 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

VSME 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.).
• Accepted formats include PDF, Excel, Word or XBRL for investors.

For a full comparison of available solutions, our article on VSME tools reviews the options for automating data collection. Companies looking to assess their compliance level before getting started will find our article on VSME audit useful.

Platforms like Ditto help automate data collection and organisation, reduce the administrative burden and ensure reporting consistency across frameworks like EcoVadis and CDP.

VSME Indicators — Key Takeaways