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CSRD Reporting for Small Energy Suppliers and Solar Installers

Europe’s energy transition relies heavily on small and medium-sized energy suppliers, solar installers, and renewable technology providers. Many of these businesses are not directly in scope of the Corporate Sustainability Reporting Directive (CSRD), but they play a crucial role in the energy value chain and will increasingly be asked to provide sustainability data to larger corporate clients, municipalities, and financiers.

This guide explains how small energy providers and solar installers can report effectively under the Voluntary Sustainability Reporting Standard for SMEs (VSME) — making CSRD compliance simpler and more transparent for their customers. For related guidance, see renewable energy SMEs reporting and waste and material reporting for solar panel installers.


1. Who Needs to Report and Why It Matters

Under CSRD

Large energy companies, utilities, and listed groups must report detailed sustainability information under Directive (EU) 2022/2464. This includes:

  • Energy generation and supply emissions (Scopes 1–3)
  • Environmental and social impacts
  • Transition and resilience plans

For SMEs

Most independent energy suppliers, installers, and micro-grid developers fall below CSRD thresholds:

  • Fewer than 250 employees
  • Less than €40 million turnover
  • Less than €20 million in total assets

However, they are often part of CSRD-regulated value chains — supplying power, equipment, or services to large utilities or municipalities. These clients need sustainability data for their own reporting.

The VSME Standard (EFRAG, 2024) offers a proportionate framework for such SMEs to disclose this data voluntarily, helping maintain partnerships and access to finance.


2. Choosing the Right Reporting Approach

The VSME Standard provides two modules:

ModuleDescriptionBest for
Basic Module (B1–B11)Core disclosures: general info, energy, emissions, workforce, and governanceSolar installers, local energy co-ops
Comprehensive Module (C1–C9)Adds targets, climate risks, human rights, and diversity dataGrowing energy SMEs or suppliers to listed utilities

Start with the Basic Module; add selected Comprehensive disclosures as your reporting matures.


3. Core Reporting Topics for Energy SMEs

Below are the most relevant VSME Basic Module disclosures for energy-sector SMEs:

CodeTopicExample Data for Small Energy Firms
B1Basis for preparationLegal form, NACE 35.14 (electric power distribution) or 43.21 (electrical installation)
B2Sustainability practicesRenewable sourcing, grid loss reduction, worker training
B3Energy and GHG emissionsOwn energy use, emissions from vehicles, and purchased electricity
B4PollutionFuel storage, air emissions, refrigerant leaks
B5BiodiversityImpact of solar farms or installations on land use
B7Resource use and wasteSolar panel packaging, cable waste, battery recycling
B8–B10WorkforceHealth & safety, fair pay, training hours
B11GovernanceAnti-corruption and compliance statements

4. Step-by-Step: How to Report Energy and Emissions (B3)

Step 1 – Collect Data

Record your direct energy use (Scope 1) and purchased electricity (Scope 2):

  • Vehicle fuel use (litres)
  • Office/workshop electricity and heating
  • Generator use (for off-grid operations)

Step 2 – Convert to MWh

Use standard conversion factors:

  • 1 kWh = 0.001 MWh
  • 1 litre diesel = 0.010 MWh
  • 1 m³ natural gas = 0.011 MWh

Step 3 – Estimate GHG Emissions

Apply CO₂ conversion factors:

  • Electricity: 0.25 kg CO₂/kWh (EU average)
  • Diesel: 2.68 kg CO₂/litre
  • Natural gas: 0.20 kg CO₂/kWh

Step 4 – Calculate GHG Intensity

Divide total CO₂ emissions by turnover to show efficiency (kg CO₂ per €1,000 turnover).

Example: GreenSpark Solar Ltd emitted 24 tonnes CO₂e in 2024 on €3.2 million turnover = 7.5 kg CO₂/€1,000 turnover

Step 5 – Describe Improvement Measures

Under B2, outline how you’re reducing emissions:

  • Upgrading to EV vans or hybrid vehicles
  • Powering offices and depots with renewables
  • Training teams in energy-efficient installations

5. Reporting Resource Use and Waste (B7)

Solar and electrical SMEs handle materials with recycling obligations.

Waste TypeCommon SourceGood Practice
PackagingPanels, batteries, invertersUse certified recycling partners
Scrap cablesInstallationsSort and sell to recyclers
Solar modulesEnd-of-life panelsPartner with WEEE-compliant collectors
BatteriesEnergy storage systemsReturn to manufacturer take-back schemes

Disclose:

  • Total waste generated (hazardous vs. non-hazardous)
  • Recycling rate (%)
  • Circular practices (e.g., component reuse)

Example: “In 2024, 3.4 tonnes of installation waste were recycled (92% recovery rate).”


6. Workforce and Safety Reporting (B9–B10)

Energy fieldwork involves height, electrical, and thermal hazards. Report annually on:

  • Number of employees and contractors
  • Training hours (especially safety and electrical certification)
  • Recordable incidents and lost-time accidents
  • Pay equality and minimum wage compliance

Example summary:

“Our team of 28 employees completed 320 safety training hours with zero lost-time injuries in 2024.”


7. Governance and Ethics (B11)

Under B11, disclose:

  • Any convictions or fines for corruption/bribery (if none, state this)
  • Certification (e.g., ISO 9001, ISO 14001)
  • Internal controls on procurement and ethical sourcing

This strengthens transparency when working with public authorities or large corporate customers.


8. Example VSME Summary for a Solar SME

Company: SunPeak Installations Ltd NACE Code: 43.21 – Electrical installation Employees: 35 Reporting Year: 2024 Module: Basic

DisclosureIndicator2024 Result
B3 – Energy use118 MWh (100% renewable electricity)Scope 1: 7.2 tCO₂e; Scope 2: 0 tCO₂e
B7 – Waste4.2 tonnes (non-hazardous)96% recycled
B9 – Health & Safety1 recordable accident320 hours training
B10 – Pay EquityFemale pay gap: 4%Above minimum wage
B11 – GovernanceNo fines/convictionsISO 14001 certified

SunPeak aims to reduce fleet fuel emissions by 20% by 2025 through EV adoption.


9. Linking to CSRD Value Chain Reporting

Under Articles 19a and 29a of the CSRD, large utilities must disclose sustainability impacts across their value chains, including subcontractors and suppliers.

By adopting the VSME structure:

  • Small suppliers provide standardised, verifiable data
  • Large clients can easily integrate this into ESRS E1 (Climate) and E5 (Resource Use) disclosures
  • The SME demonstrates responsible partnership and readiness for future sustainability obligations

10. Quick Wins for Energy SMEs

AreaActionBenefit
Fleet ManagementSwitch to EVs or biofuelsCut Scope 1 emissions
ProcurementChoose recycled or low-carbon materialsStrengthen circular economy score
Office EnergyInstall rooftop solar or LED systemsReduce operating costs
Customer ServicesOffer lifecycle emissions estimatesImprove transparency
Data ManagementUse digital meter and fuel appsSimplify VSME reporting

Key Terms

  • CSRD – Corporate Sustainability Reporting Directive (EU 2022/2464).
  • VSME – Voluntary Sustainability Reporting Standard for SMEs (EFRAG 2024).
  • Basic Module – Entry-level sustainability reporting for SMEs.
  • Comprehensive Module – Optional advanced disclosures for larger SMEs.
  • Scope 1, 2, 3 Emissions – Direct, energy-related, and value-chain emissions.
  • GHG Intensity – Emissions relative to turnover.
  • WEEE – Waste Electrical and Electronic Equipment Directive.
  • ESRS – European Sustainability Reporting Standards for large companies.

The CSRD Brief — Sustainability, Simplified

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