Does the European Union (EU) voluntary standard for small companies (VSME) want market-based Scope 2 as well as location-based?
Only location-based Scope 2 is required. Market-based is something the standard says a company may also want to provide. Location-based uses the average factor of your local grid. Market-based uses the terms of your own supply contract. VSME is the European Financial Reporting Advisory Group's Voluntary standard for non-listed micro-, small- and medium-sized undertakings.
What Scope 2 is
Scope 2 means the emissions from power, heat, steam or cooling that you buy, because the smoke comes from someone else's power station. The standard says it covers purchased or acquired energy that you consume.
The two methods, with an everyday comparison
- Location-based: the average for the grid where you use the power. Like paying the average fare for a bus route. The standard says it uses mostly grid-average emission factor data.
- Market-based: what your own contract says. Like paying the fare on your own travel pass. The standard says these factors reflect your contracts with energy suppliers, and can be supported by Energy Attribute Certificates, Power Purchase Agreements (PPAs) or residual-mix factors.
What the standard requires
Disclosure B3 says you shall disclose the location-based Scope 2 emissions. The guidance then says undertakings may also want to provide market-based figures. Our reading: market-based is optional. A buyer's own form may still ask for it, so check the form.
The arithmetic for an Indian unit
- Take the units on your electricity bills for the year, in kilowatt hours (kWh).
- Multiply by the grid factor for that year. The Central Electricity Authority (CEA) grid factor Senseible's calculators use is 0.675 kg of carbon dioxide (CO2) per kWh for financial year (FY) 2025-26.
- Divide kilograms by 1,000 for tonnes.
If you hold a green power contract or certificate
Keep the contract or certificate with the bill. The standard names the paper types, but the text we read does not say how to turn one into a factor. Report the location-based figure first, and give a market-based one next to it only if the buyer wants it and you can show the paper.
Example: a small plant
- Bills for the year: 300,000 kWh
- Location-based: 300,000 x 0.675 = 202,500 kg of CO2 = 202.5 tonnes
- The standard's own check: 282,000 kWh x 73 g a kWh = 20.6 tonnes (a French office, 2022 factor)
Units are an example. The French figure is the standard's own and is not an Indian factor.
What Senseible does here
Senseible reads fuel invoices and electricity bills into records, so the fuel and units you bought are on file for this disclosure. Tank dips, plant logs and meter readings stay with you, or can be connected as a custom meter integration on request.
- What is the VSME standard?
- Rooftop solar in the energy table
- Emissions intensity with turnover in rupees
- Free calculators
Sources: European Financial Reporting Advisory Group (EFRAG), Voluntary standard for non-listed micro-, small- and medium-sized undertakings (VSME), 2024 edition, 66 pages, paragraphs 30, 99 and 108 to 109, Central Electricity Authority (CEA), CO2 Baseline Database for the Indian Power Sector
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.