VSME Basic Module

VSME Basic Module Data Checklist

Use this checklist to collect every data point you need for a VSME Basic Module sustainability report. Sections are ordered to match the in-app survey, so you can walk down the list and the survey in lockstep.

Source: EFRAG VSME Standard (2024) · csrdpro.com · Updated May 2026
How to use this checklist: Work through each section. For each item, note the data value and the document it came from. Most data lives in utility bills, payroll records, and waste invoices. When complete, click Save as PDF above to save or print.
IDENTITY

Identity: company foundation data

Collect company foundation data B1
Easy

Document your company legal form, NACE code(s), entity identifier (LEI, DUNS, EUID or equivalent), reporting basis (individual or consolidated), countries of operation, and the sites you own, lease or manage. If you report on a consolidated basis, also gather a list of subsidiaries with their registered addresses.

Where to find it: Company registration documents, legal records Frequency: Annually
FINANCIALS

Financials: balance sheet and turnover

Collect financial and employee metrics B1
Easy

Balance sheet total, turnover, number of employees (headcount or FTE), and any sustainability certifications. Use the same reporting period as your financial statements.

Where to find it: Financial statements, accounting records, HR system Frequency: Annually
PRACTICES

Practices: policies and future initiatives

Document environmental practices, policies, and future initiatives B2
Moderate

Document the practices, written policies, and any future initiatives you have for each environmental topic below. Include any targets you have set (e.g. emissions cuts, packaging reduction). A short paragraph per topic is enough. "None in place" is a valid answer.

  • Climate change — Energy efficiency, switching to renewable electricity, fleet electrification, building retrofits, or any GHG-reduction commitment.
  • Pollution prevention and control — Air, water, or soil pollutants from your operations: filters, spill controls, low-VOC materials, or substitutions for hazardous substances.
  • Water and marine resources — Water-saving measures, recycling, leak detection, or discharge-quality controls. Most relevant if you have water-using production.
  • Biodiversity and ecosystems — Site-level habitat protection, no-pesticide grounds, certified supplier sourcing (FSC, MSC), or biodiversity offsets.
  • Circular economy — Reuse, repair, recycled-content inputs, take-back schemes, packaging redesign, or waste-diversion targets.
Where to find it: Operations records, management, strategic planning Frequency: Annually
Document social practices, policies, and future initiatives B2
Moderate

Document the practices, written policies, and any future initiatives you have for each social topic below. Include any targets. A short paragraph per topic is enough. "None in place" is a valid answer.

  • Own workforce: working conditions and rights — Working hours, wages above the legal minimum, health and safety beyond the legal floor, training, diversity, parental leave, freedom of association.
  • Workers in the value chain — How you check labour conditions at suppliers and subcontractors: supplier code of conduct, audits, modern-slavery checks.
  • Affected communities — Engagement with local residents around your sites (noise, traffic, dust), community investment, indigenous-rights commitments where relevant.
  • Consumers and end-users — Product safety, accurate marketing, data protection, accessibility, protections for vulnerable customers.
Where to find it: HR, supply chain management, community relations Frequency: Annually
Document governance and business conduct practices B2
Moderate

Document your practices, policies, and future initiatives on business conduct, plus any sustainability certifications held during the reporting year.

  • Business conduct and ethics — Anti-bribery and anti-corruption rules, whistleblowing channel, conflict-of-interest policy, gifts-and-hospitality limits, supplier ethics standards.
  • Sustainability certifications and labels — Third-party certifications held during the year: ISO 14001, ISO 45001, B Corp, EU Ecolabel, EMAS, Fairtrade, FSC. Note the scope and certifying body.
Where to find it: Compliance, management, strategic planning Frequency: Annually
PEOPLE

People: workforce data

Collect workforce demographics data B8
Easy

Headcount by contract type (permanent and temporary), by gender, and by country if you operate in more than one. Once total headcount (permanent plus temporary) reaches 50, also collect the year's employee turnover and the average headcount across the reporting year.

Where to find it: HR system, payroll Frequency: Annually Note: Employee turnover and average headcount only required for organisations with 50 or more employees. Headcount and average-headcount tracking is naturally a monthly exercise even though the disclosure is annual.
Track health and safety metrics B9
Moderate

Number of recordable work-related accidents, total hours worked, fatalities from work-related injury, and fatalities from work-related ill health. Document your safety programmes alongside the numbers. For total hours, use the country-norm hours per worker (around 1,645 in France, 1,750 in Germany, 1,800 in Italy) rather than a flat figure.

Where to find it: Safety logs, incident reports, HR system, timesheets Frequency: Annually
Collect remuneration and training data B10
Moderate

Average training hours per year for male and female employees (recorded separately), the percentage of employees covered by collective bargaining agreements, minimum-wage compliance, and the gender pay gap.

Where to find it: Training records, HR system, payroll, union records Frequency: Annually Note: Gender pay gap only required for organisations with 150 or more employees (threshold drops to 100 from 7 June 2031).
CLIMATE

Climate: energy, emissions and targets

Collect energy consumption data B3
Easy

Monthly energy use covering electricity (kWh), natural gas (m³ or kWh), heating oil (litres), and any other fuels (diesel, petrol, propane, biomass). Track the renewable and non-renewable split for electricity.

Where to find it: Utility bills, fuel invoices, supplier records Frequency: Monthly
Calculate GHG emissions B3
Moderate

Calculate Scope 1 emissions from fuel consumption and Scope 2 emissions (location-based) from electricity consumption, plus GHG intensity (total emissions ÷ turnover). Use GHG Protocol methodology.

Where to find it: Energy consumption data, emission factors, turnover Frequency: Annually
ENVIRONMENT

Environment: pollution, biodiversity, water and waste

Track pollutant emissions B4
Complex

Track pollutant releases to air, water and soil by substance and quantity. Document the public disclosure URL if your pollutants are already publicly disclosed under another regime (E-PRTR, national equivalents).

Where to find it: Environmental permits, monitoring systems, compliance reports Frequency: Annually Note: Only required if your activities already trigger pollutant reporting (E-PRTR or equivalent national regimes), or you voluntarily report pollutants under an environmental management system such as EMAS. Typical for transport, construction, chemical and similar industries. E-PRTR submissions are annual; internal monitoring cadence varies by pollutant.
Assess biodiversity-sensitive areas B5
Moderate

Identify sites located in or near biodiversity-sensitive areas (Natura 2000, Key Biodiversity Areas, nationally protected areas). Record site areas in hectares and, optionally, land-use metrics such as sealed area and nature-oriented area.

Where to find it: Site locations, protected area maps, environmental assessments Frequency: Annually
Track water usage B6
Moderate

Total water withdrawal per site, and a flag for whether the site sits in a water-stress area. For each site, decide whether it has production processes that significantly consume water (thermal energy, manufacturing, agricultural irrigation). Water discharge and the resulting consumption figure (withdrawal minus discharge) are only required for those sites; offices and warehouses without water-consuming processes can skip the discharge measurement.

Where to find it: Water utility bills, process monitoring, discharge permits Frequency: Monthly
Track waste generation and classification B7
Moderate

Classify waste as hazardous or non-hazardous and track quantities by type (mixed municipal, paper and cardboard, plastics, metals, food waste, and so on).

Where to find it: Waste contractor, compliance records Frequency: Monthly
Track waste diversion and circular economy principles B7
Moderate

Quantify the total waste diverted to recycling or reuse, and document which circular-economy principles you apply (reuse, repair, remanufacture, recycling, and similar).

Where to find it: Waste contractor, recycling records, operations Frequency: Monthly
Track material mass-flow B7
Complex

Annual mass-flow of the significant materials you use (steel, aluminium, plastics, paper, food, and so on).

Where to find it: Procurement, production records Frequency: Annually Note: Only required for sectors with significant material flows (manufacturing, construction, packaging and similar).
GOVERNANCE

Governance: conduct, restricted sectors and diversity

Document business conduct compliance B11
Easy

Number of convictions for corruption or bribery violations during the reporting year, and the total amount of fines for those violations. If none, record "zero" for transparency.

Where to find it: Legal records, compliance Frequency: Annually
SENSITIVE

Sensitive: classified or sensitive information

Note any classified or sensitive information you intend to omit B1
Easy

Decide whether your report will leave anything out under EU classified-information rules (Council Decision 2013/488/EU) or sensitive-information rules (Regulation (EU) 2021/697). If yes, a short note describing which disclosure was omitted is enough. The standard asks you to indicate that something was withheld, not to disclose the content itself.

Where to find it: Compliance officer, legal counsel Frequency: Annually Note: Most small and growing businesses (SMEs) will answer no and skip the rest of this item.

Source: EFRAG Voluntary Sustainability Reporting Standard for SMEs (VSME), published 2024. This checklist covers the Basic Module only. For the Comprehensive Module variant or a personalised checklist for your industry, visit csrdpro.com/tools/data-checklist-generator.

Download the Comprehensive Module checklist →