Do I have to report the gender pay gap in disclosure B10 of the European Union (EU) voluntary standard for small companies (VSME) if I have under 150 employees?
No. The standard says you may omit the gender pay gap when your headcount is below 150 employees, and notes the limit falls to 100 employees from 7 June 2031. At 150 or more, work it out from average hourly pay. VSME is the European Financial Reporting Advisory Group's Voluntary standard for non-listed micro-, small- and medium-sized undertakings.
The exact words
Disclosure B10 asks for the percentage gap in pay between female and male employees. It then says the undertaking may omit this disclosure when its headcount is below 150 employees, noting that this threshold will be reduced to 100 employees from 7 June 2031.
Headcount means the total number of people employed at a given time, not full-time equivalents.
If you do report it
- Work out the average gross hourly pay of male employees and, separately, of female employees. All employees are included.
- Take male average minus female average, divide by the male average, multiply by 100.
- The standard says gross pay includes base salary, cash allowances, bonuses and commissions, benefits in kind such as cars and health insurance, and long-term incentives.
- Average gross hourly pay is the weekly or annual gross pay divided by the average hours worked in the week or year.
What the number means
A positive gap means men are paid more on average per hour. The standard defines the gap as the difference in average pay as a percentage of the male average. Our reading: a gap is not by itself a finding that equal work is paid unequally; it compares averages across all jobs.
The other pay items in B10
- Whether employees get pay equal to or above the applicable minimum wage for the country, set by law or by a collective bargaining agreement.
- The percentage of employees covered by collective bargaining agreements.
- Average annual training hours per employee, by gender.
Example: the standard's pay gap
- Male average gross hourly pay: 15 euro. Female: 13 euro
- Gap: (15 minus 13) / 15 x 100 = 13.3%
- An example in rupees (Rs): male Rs 250 an hour, female Rs 230. (250 minus 230) / 250 x 100 = 8%
The euro figures are the standard's own. The rupee figures are an example.
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?
- Collective bargaining is not union membership
- Headcount or full-time equivalent 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.