What is the VSME standard, and should a small supplier use it to answer EU customers?
VSME is EFRAG's Voluntary Sustainability Reporting Standard for non-listed SMEs, published in December 2024. No Indian company is required to use it, but it suits answers to EU customers: it is short, large EU companies are expected to accept it, and its Basic Module covers the energy and emissions figures buyers ask for most.
How the standard is built
- Basic Module: eleven disclosures (B1 to B11) covering basis of preparation, practices and policies, energy and GHG emissions, pollution, biodiversity, water, waste, workforce, health and safety, pay, and governance matters such as corruption convictions.
- Comprehensive Module: extra disclosures (C1 to C9) for companies whose banks, investors or large customers want more, such as transition plans and targets.
- You may report the Basic Module alone, or Basic plus Comprehensive. Datapoints that do not apply to you can be left out with a note.
What B3 asks on energy and emissions
The Basic Module does not require Scope 3; the standard only encourages it. So a small supplier can answer B3 from its fuel invoices and electricity bills.
- Total energy consumption in MWh, split into renewable and non-renewable where you can.
- Gross Scope 1 emissions in tonnes CO2e.
- Gross location-based Scope 2 emissions in tonnes CO2e.
- GHG intensity, emissions per unit of turnover.
Why EU customers may point you to it
The Omnibus I changes to the CSRD, signed off by the Council in February 2026, limit what in-scope companies may demand from smaller companies in their value chain to what a voluntary standard covers. The European Commission's July 2025 Recommendation already invited SMEs and their customers to use VSME. In practice, a VSME report is a fair answer to an EU questionnaire that asks for more than it should.
Should you use it
- If two or more EU customers send different questionnaires, yes: one VSME Basic report answers most of them.
- If one buyer has its own portal, fill the portal, but keep a VSME report as your master copy.
- If you also report BRSR, reuse the same energy and emissions figures; the definitions are close enough that one data set serves both.
Worked example: B3 for a small forging unit
- Grid electricity: 300,000 kWh = 300 MWh
- Diesel for a generator: 10,000 L, energy about 10,000 x 0.0358 GJ = 358 GJ = 99.4 MWh (labelled estimate, IPCC net calorific value 43.0 MJ/kg at 0.832 kg/L)
- Total energy: 300 + 99.4 = 399.4 MWh, all non-renewable
- Scope 1: 10,000 x 2.68 = 26,800 kg = 26.8 t CO2
- Scope 2 location-based: 300,000 x 0.710 = 213,000 kg = 213.0 t CO2
- Intensity on turnover of Rs 20 crore (about EUR 2.0 million, illustrative rate): 239.8 t / 2.0 = about 120 t CO2 per EUR million
Fuel and grid factors here are CO2 factors; small amounts of methane and nitrous oxide are left out. State that in the report.
What Senseible does here
Senseible fills the energy and Scope 1 and 2 figures that VSME B3 asks for, from your bills and invoices, with each number traced to its document. The other VSME disclosures, such as workforce, pollution and governance, are outside Senseible.
Sources: EFRAG Voluntary Sustainability Reporting Standard for non-listed SMEs (VSME), December 2024, Council press release on simplification of sustainability reporting, 24 February 2026, European Commission explanatory information on the value chain cap, May 2026
Last reviewed 2026-10-15. The Commission's delegated act on the value chain standard may change what VSME covers; check it before relying on the module list.