Senseible

How do I answer disclosure B2 of the European Union (EU) voluntary standard for small companies (VSME) if I have no written sustainability policy?

B2 asks whether you have sustainability practices, policies, plans or targets. A written policy is only one. Switching to light emitting diode (LED) lights or cutting water use counts as a practice. If you have none, the table lets you say no. VSME is the European Financial Reporting Advisory Group's Voluntary standard for non-listed micro-, small- and medium-sized undertakings.

What B2 asks, in plain words

The standard says: if you have put in place specific practices, policies or future initiatives for moving to a more sustainable economy, you shall state so. In plain words: a practice is something you already do. A policy is something you have written down. A future initiative is a plan you are carrying out. A target is a number you are working towards.

So the question is not 'do you have a policy document'. It is 'what do you already do, and what have you written down'.

What counts as a practice

The standard's table

The standard offers a template. For each topic it asks three yes or no questions: do you have practices, policies or future initiatives; are they publicly available; do they have targets. The topics are 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, and business conduct.

The standard says undertakings may use this template, so it is optional. Our reading: where you have nothing, answering no is a straight answer, and it is better than inventing a policy.

Do not overstate

If you say yes to publicly available, a buyer may look for it. If you say yes to targets, a buyer may ask for the number and the year. Answer yes only where you can show the paper.

What Senseible does here

Senseible fills the energy and emissions disclosure from fuel invoices and electricity bills. This disclosure is not part of it today; it comes from your own registers and papers.

Sources: European Financial Reporting Advisory Group (EFRAG), Voluntary standard for non-listed micro-, small- and medium-sized undertakings (VSME), 2024 edition, 66 pages, paragraphs 26 to 28 and 78

Last reviewed 2026-11-07. Facts are from the standard's own text, with the paragraph numbers named in the source line. The European Commission adopted its own standard for voluntary use in a Delegated Regulation of 3 July 2026, which is not in force until it is published in the Official Journal and may differ from this text, so ask your buyer which one it means. Our own readings are marked as such.