If a disclosure in the European Union (EU) voluntary standard for small companies (VSME) does not apply to me or is sensitive, what do I write?
If a disclosure's own instructions make it conditional and the condition does not fit you, you can leave it out. If you leave one out as classified or sensitive, say so under B1 and name it. VSME is the European Financial Reporting Advisory Group's Voluntary standard for non-listed micro-, small- and medium-sized undertakings.
Two different reasons for leaving something out
- Does not apply: the standard says certain disclosures only apply to specific circumstances, and the instructions in each disclosure say when. When one is omitted, it is assumed to be not applicable.
- Sensitive: the standard says that if a disclosure would require classified or sensitive information, you may omit it, and if you do, you shall state that under B1 and indicate the disclosure omitted. The standard defines 'classified' as EU classified information and does not define 'sensitive'. Do not assume ordinary commercial confidentiality qualifies; ask your buyer.
What the standard does not ask
The text on 'does not apply' does not ask for a written reason. Some summaries say to leave it out 'with a note'. The standard's own sentence is that an omitted disclosure is assumed not applicable. A short note is still useful to a buyer, and that is our suggestion, not a rule of the standard.
Which lines are mostly conditional
- B4, pollutants: only if you already report them by law or under an environmental management system; otherwise you state that you do not.
- B6, water consumption: only where your processes significantly consume water.
- B8, employee turnover rate: only with 50 or more employees.
- B10, gender pay gap: may be omitted below 150 employees.
- B11: only if there were convictions or fines in the year.
What you cannot drop
The Basic Module is a minimum requirement for undertakings other than micro ones, and the standard says that once you choose a module you comply with all of it, each item being provided only where applicable. Our reading: leaving out an applicable line because it is awkward is not what the standard allows. B3 carries no 'if applicable' condition in its wording, apart from the renewable split, which is only asked if you can get the information, so a plant that burns fuel gives its energy and its Scope 1 emissions, which means smoke from sources it owns.
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?
- Pollutant reporting in the EU standard
- Pay gap line for firms under 150 employees
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.