Does a small factory have to report pollutants under disclosure B4 of the European Union (EU) voluntary standard for small companies (VSME)?

Only if you already report pollutants to an authority, because the law or national rules require it, or voluntarily under an environmental management system. If you do not report them and are not required to, you simply state that. VSME is the European Financial Reporting Advisory Group's Voluntary standard for non-listed micro-, small- and medium-sized undertakings.

The rule in plain words

B4 does not ask you to start measuring smoke, effluent or soil pollution. It asks you to pass on what you already report. Think of a school report card: it shows the marks already earned and does not add a new exam.

The standard says: if you are already required by law or other national rules to report your emissions of pollutants to the competent authorities, or you report them voluntarily under an Environmental Management System, you shall disclose the pollutants you emit to air, water and soil in your own operations, with the amount for each.

If you do not report any

The guidance says that if you do not yet report such information and are not legally required to, you are simply required to state that this is the case.

What an environmental management system means here

The guidance names the EU's Eco-Management and Audit Scheme (EMAS) and certification to the International Organization for Standardization (ISO) standard 14001 as examples. It says that pollutants you must monitor and report under such a system are in principle relevant to include.

Our reading for an Indian unit

• If your unit sends pollutant figures to an authority, those are the figures B4 means. Which Indian rules count is for you to read; we have not checked each rule.
• If you hold ISO 14001 and monitor named pollutants under it, list those.
• If neither applies, write that you do not report pollutants and are not required to.

Shortcuts the standard allows

• If the figures are already public, you may refer to the document by a link instead of repeating them.
• If you have one facility and its data is public, you may refer to that document. The standard says the same for an organisation-wide report such as an EMAS report.
• If you have several facilities, the standard says it asks for the total of all of them, not one facility at a time.

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.

• What is the VSME standard?
• If a disclosure does not apply, what do I write?
• What counts as near a protected area?

Sources: European Financial Reporting Advisory Group (EFRAG), Voluntary standard for non-listed micro-, small- and medium-sized undertakings (VSME), 2024 edition, 66 pages, paragraphs 32 and 110 to 113

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.