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CSRD Requirements Checklist: the VSME Basic Data List

If you are searching for a CSRD requirements checklist for a small and growing business (SME), here is the honest starting point: since the Omnibus I directive (in force 18 March 2026), no SME reports under CSRD at all. Mandatory scope is limited to companies with more than 1,000 employees and net turnover above €450 million.

What an SME actually faces is a bank or large customer asking for sustainability data, and since Omnibus I those requests are capped at what the Voluntary Sustainability Reporting Standard for SMEs (VSME) covers. So the checklist that applies to you is the VSME one, starting with the Basic Module.

This checklist gives you a practical step-by-step list of what to collect and keep on file, whether you are answering a single questionnaire or preparing a full VSME report.

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.)

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 is already most of the work done.
  • Save everything in one digital folder, with clear file names (e.g. “Electricity_Jan2026.pdf”).
  • Update the folder once a year to stay ready for any client or bank request.
  • The sections above map onto the VSME Basic Module disclosures (B1–B11): company information feeds B1, energy and emissions feed B3, waste and materials feed B7, workforce data feeds B8–B10, and policies and governance feed B2 and B11.

Frequently Asked Questions

Does every item on the checklist apply to every business?

No. The checklist covers the full VSME Basic Module (B1–B11). Where a category is not material to your business — for example, biodiversity for an office-only consultancy — a short “not material” statement with reasoning is a valid disclosure. The point of the checklist is to make sure nothing is missed, not to force every section to be filled.

What is the minimum I need to start?

Twelve months of utility bills, a payroll export with headcount and hours, a waste-contractor statement, and a single page listing governance practices (who owns sustainability, any policies that exist). That alone covers 70–80% of VSME Basic for most small and growing businesses (SMEs).

Can I share this checklist with my team to divide the work?

Yes, and that is how it usually works. Finance typically handles energy and emissions data (B3), HR handles workforce (B8–B10), operations handles waste and any water or pollution data (B4–B7), and the owner or manager handles governance (B11). Most SMEs complete Basic in 2–6 weeks of part-time effort spread across the team.

Key Terms

  • Corporate Sustainability Reporting Directive (CSRD) — An EU law that requires the largest companies (more than 1,000 employees and net turnover above €450 million since the Omnibus I directive) to report on their environmental and social impacts. SMEs are not in scope but may be asked for 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) — Under the EU Accounting Directive, a business that stays within at least two of: 250 employees, €50 million turnover, €25 million balance sheet. 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.

Next Steps

Before you collect data, see VSME Basic vs Comprehensive Module to choose the reporting level that fits your business, and Is My Company Too Small for CSRD? if you want to double-check that no direct obligation applies to you.

Once the folder exists, turning it into a shareable document is the easy part: free VSME report tools now generate a finished Basic Module report at no cost, and an ESG answer bank stores each answer once so it can be reused for every new request.

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