Senseible

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

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

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.

Sources: European Financial Reporting Advisory Group (EFRAG), Voluntary standard for non-listed micro-, small- and medium-sized undertakings (VSME), 2024 edition, 66 pages, paragraphs 5, 13, 19, 24(b) and 45

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.