CSRD Requirements Checklist (for the VSME Basic Module)

If you run a small and growing business (SME) in Europe, you won’t usually be required to publish a full Corporate Sustainability Reporting Directive (CSRD) report. However, your bank or a large customer may ask you for certain sustainability data. The easiest way to prepare is to follow the Voluntary Sustainability Reporting Standard for SMEs (VSME), starting with the Basic Module.

This checklist gives you a practical step-by-step list of what to collect and keep on file.

1. Company Information

• Basic details — company name, address, legal form, number of employees.
• Ownership and governance — who owns the business, and who makes decisions (e.g. managing director, board).

2. Energy Use

• Electricity invoices for the last 12 months.
• Gas, oil, or heating fuel bills for the last 12 months.
• Fuel use for company-owned vehicles (petrol, diesel, LPG).

3. Greenhouse Gas Emissions

(You don’t have to calculate emissions yourself. Keeping fuel and energy data is usually enough — banks or clients may calculate the emissions for you.)

• Scope 1 (direct emissions): fuel use in company vehicles or onsite boilers. Learn more about what counts as Scope 1 vs Scope 2.
• Scope 2 (indirect emissions): purchased electricity, district heating, or cooling. See our step-by-step guide to reporting Scope 1 and 2 emissions and how to report electricity use.

4. Waste and Materials

• Waste invoices or records — e.g. recycling collections, landfill, hazardous waste.
• Basic notes on materials used — if significant (e.g. tonnes of raw materials).

5. Workforce Data

• Total headcount at year-end.
• Breakdown by contract type — permanent vs temporary staff.
• Number of hires and leavers during the year.
• Gender balance (optional but often useful).

6. Policies and Governance

• Basic policies (if available) — e.g. health and safety, anti-discrimination, environmental practices.
• Confirmation of decision-making roles — who is responsible for sustainability in the company (even if it’s just the owner or manager).

How to Use This Checklist

• Start by collecting 12 months of invoices and workforce data — that’s already most of the work done.
• Save everything in one digital folder, with clear file names (e.g. “Electricity_Jan2025.pdf”).
• Update the folder once a year — this will keep you ready for any client or bank requests.

Key Terms

• Corporate Sustainability Reporting Directive (CSRD) — An EU law that requires large companies — and eventually some medium-sized ones — to report on their environmental and social impacts. Smaller suppliers are not directly in scope but may be asked for CSRD-style data by banks or bigger clients.
• Voluntary Sustainability Reporting Standard for SMEs (VSME) — A simplified framework designed to help SMEs share sustainability information. It is voluntary but can help SMEs respond to client or bank requests.
• Basic Module — The minimum set of sustainability disclosures under the VSME. It covers essential topics such as energy use, greenhouse gas emissions, waste, workforce data, and basic governance issues.
• Comprehensive Module — An extended version of the VSME reporting standard. It includes additional details on strategy, transition plans, and targets. Banks or large clients may request this level of detail.
• European Sustainability Reporting Standards (ESRS) — The detailed reporting rules that apply to large companies under CSRD. The VSME is a simplified, proportionate version for smaller businesses.
• SME (Small and Medium-sized Enterprise) — A business with fewer than 250 employees, a turnover under €50 million, or a balance sheet total under €25 million. Micro-enterprises are even smaller (fewer than 10 employees).
• Scope 1 and Scope 2 emissions — Scope 1 refers to greenhouse gas emissions from sources a company directly controls (like fuel used in company vehicles). Scope 2 refers to emissions from purchased energy (like electricity or heating). SMEs may only need to report these two.
• Turnover — The total income a company earns from its normal business activities, usually measured over one year.

Before you start collecting data, it’s helpful to know whether you should follow the Basic Module or Comprehensive Module. Use our interactive recommender to determine which module fits your company’s needs:

This will help you understand the scope of data collection required and ensure you’re following the right reporting standard for your business size and situation.