# Which fines and convictions count in disclosure B11 of the European Union (EU) voluntary standard for small companies (VSME)?

Canonical: https://senseible.earth/answers/vsme-b11-which-fines-and-convictions-count

Only convictions and fines for breaking anti-corruption and anti-bribery laws. A conviction is a criminal court verdict on a corruption or bribery offence. A fine counts if it is a mandatory penalty for such a violation, paid to a public treasury. VSME is the European Financial Reporting Advisory Group's Voluntary standard for non-listed micro-, small- and medium-sized undertakings.

## What B11 says

In case of convictions and fines in the reporting period, you shall disclose the number of convictions and the total amount of fines for violating anti-corruption and anti-bribery laws.

Our reading: if there were none in the year, there is nothing to list, and you can write none.

## What counts as a conviction

The guidance says any verdict of a criminal court against an individual or an undertaking, for a criminal offence related to corruption and bribery. Its example is a court decision entered in the criminal record of an EU Member State.

## What counts as a fine

The guidance says fines are mandatory monetary penalties for violations of anti-corruption and anti-bribery laws, imposed by a court, commission or other government authority, and paid to a public treasury.

## What we think does not count (our reading)

- A tax late fee, a pollution penalty or a labour inspection fine: these are not penalties for anti-corruption or anti-bribery laws, so they do not belong in B11.
- A settlement paid to a private party, because the standard says the fine is paid to a public treasury.
- If you are unsure about a case, keep the order and ask your lawyer, then tell your buyer what you decided.

## 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?](https://senseible.earth/answers/vsme-standard-for-small-suppliers)
- [If a disclosure does not apply, what do I write?](https://senseible.earth/answers/vsme-disclosure-does-not-apply-or-is-sensitive)
- [Pay gap line for firms under 150 employees](https://senseible.earth/answers/vsme-pay-gap-below-150-employees)

Sources: [European Financial Reporting Advisory Group (EFRAG), Voluntary standard for non-listed micro-, small- and medium-sized undertakings (VSME), 2024 edition, 66 pages, paragraphs 43 and 206 to 209](https://www.efrag.org/sites/default/files/sites/webpublishing/SiteAssets/VSME%20Standard.pdf)

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.