New Business Asked for CSRD Data? A VSME Starter Guide
Starting a business is hard enough without a sustainability questionnaire landing in your inbox. So here is the first thing to know: a newly founded small business does not report under the Corporate Sustainability Reporting Directive (CSRD). Since the Omnibus I directive (in force 18 March 2026), CSRD applies only to companies with more than 1,000 employees and over €450 million turnover.
What a new business can face instead is an ESG data request from a large customer, a bank, or an investor that does report. The practical answer to that request is the Voluntary Sustainability Reporting Standard for SMEs (VSME), published by EFRAG: a short, proportionate format built for small businesses.
A young company actually has an advantage here. You can build simple data habits from day one instead of fixing bad ones later. This guide walks you through your first request and your first VSME report, without consultants or large systems.
1. Understand What You Actually Face
There is no filing deadline and no regulator involved for you. The pressure, when it comes, arrives commercially:
- A large customer collecting value-chain data for its own CSRD report
- A bank asking ESG questions as part of lending
- A public tender or procurement portal with a sustainability section
EU law also protects you here. Under the value-chain cap, what a CSRD-reporting customer may require from a smaller supplier is capped at the VSME standard, so one VSME report can answer nearly every request. If no request has arrived yet, you can wait, or prepare a light report now so the first one is easy.
2. Start With the Core Data You Already Have
New businesses rarely have a full year of data, and that is fine. For a first report, collect what is available and reliable, even if partial. Begin with:
| Area | Example Data | Where to Find It |
|---|---|---|
| Energy use | Electricity and gas invoices | Utility provider or landlord |
| Workforce | Number of employees, contract types, gender balance | Payroll or HR records |
| Waste | Collection records, recycling estimates | Facility manager or waste contractor |
| Governance | Code of conduct, anti-corruption policy, risk procedures | Company handbook or director’s notes |
If you do not have a baseline yet, use estimates based on available records or operational assumptions, and note how you arrived at them. Transparent estimation is accepted practice for a first report.
3. Choose the Right Starting Point: The VSME Basic Module
The VSME Basic Module is designed exactly for a business your size. It contains eleven disclosures (B1 to B11) covering the environmental, social, and governance topics most relevant to small businesses:
- Basis for preparation (what the report covers)
- Energy and greenhouse gas emissions
- Pollution, water, waste, and biodiversity basics
- Workforce composition, health and safety, pay and training
- Convictions or fines for corruption and bribery
It is short, achievable, and aligned with what larger customers need for their own reporting. Start with the Basic Module now; you can add the Comprehensive Module (C1 to C9) later if a bank or customer asks for more, such as emission-reduction targets or climate risks.
4. Build Simple Data Collection Habits Early
Instead of waiting until year-end, record sustainability data as part of normal operations. A shared spreadsheet or a simple SME-focused tool is enough at this stage.
Set a monthly reminder to:
- Record energy and waste figures
- Update workforce data
- Note any new policies or certifications
This rhythm avoids last-minute stress when a request arrives with a four-week deadline, and it keeps your answers consistent from one request to the next.
5. How to Report With Less Than 12 Months of Data
If your business started mid-year, report the data you have and state the timeframe in the basis-for-preparation section (VSME disclosure B1). Example wording:
“The company began operations in April 2026. This report covers the nine-month period from April to December 2026. Comparative data for prior years is not available.”
A clearly stated partial period is entirely acceptable in a voluntary report. What matters is that the reader knows exactly what the figures cover.
6. Keep Governance Simple but Visible
Even a small business benefits from showing it manages sustainability responsibly. Include a short section on:
- Who oversees sustainability (often the founder or finance lead)
- How decisions are made on environmental or social topics
- Any basic policies or training you have introduced
A one-page governance statement shows accountability, and it answers the policy questions that appear in almost every customer questionnaire.
Frequently Asked Questions
What if I have almost no data yet?
That is completely acceptable in your first year. You can disclose qualitative information such as policies or intentions (for example, “energy data will be collected from next quarter onwards”). The aim is transparency, not perfection.
Do I need special software for a first report?
Not necessarily. A structured spreadsheet is enough to start, and free tools now generate a complete VSME report at no cost. As you grow, tools that store answers for reuse save time when several customers ask similar questions.
How should I handle estimates?
Mark them clearly and explain the basis (for example, average monthly consumption multiplied by months of operation). Revisit estimates next year once full data is available.
Can I skip topics that do not apply?
Yes. VSME works on an applicability principle: you report the disclosures that apply to your business. Where a topic is not relevant, a short note explaining why (for example, “no water-intensive processes”) keeps the report credible.
Key Terms
- CSRD: Corporate Sustainability Reporting Directive (EU 2022/2464). Applies to large companies, not SMEs.
- VSME: Voluntary Sustainability Reporting Standard for SMEs (EFRAG). The format small businesses use to answer ESG requests.
- Basic Module: The core eleven VSME disclosures (B1 to B11) for a first report.
- Value-chain cap: The post-Omnibus rule capping what CSRD reporters may request from smaller suppliers at the VSME standard.
- Estimate: A documented approximation used where measured data is not yet available.
Conclusion: Start Simple, Grow Confidently
A new small business owes nobody a CSRD report. What it can do is be ready for the first ESG request: collect the straightforward data you already hold, keep clear records, and shape them into a VSME Basic Module report when a customer or bank asks.
You do not need perfection, just clarity, honesty, and a consistent routine. A free VSME report tool can turn that first dataset into a finished report at no cost, so the first request never has to feel like a crisis.