VSME Basic vs Comprehensive Module: Which to Choose?

The VSME (Voluntary Sustainability Reporting Standard for SMEs) offers two reporting modules. The Basic Module covers 11 disclosures (B1–B11) across general, environmental, social, and governance topics. The Comprehensive Module adds 9 further disclosures (C1–C9) for businesses that need more depth. Both are voluntary; neither is a CSRD filing, but both are built so the data answers what CSRD-reporting customers and banks ask smaller businesses for.

Which module fits your business depends on three things: the size and complexity of your operations, the detail larger clients are asking for, and how much time your team can invest. Most small and growing businesses (SMEs) start with Basic and extend to Comprehensive only when buyers, investors, or banks request it.

This guide compares the two modules side by side — showing what each includes, who it fits, and how to choose without overbuilding. For a plain-language overview of CSRD itself, see CSRD for Beginners.

1. What Is the VSME Standard?

The VSME (Voluntary Sustainability Reporting Standard for SMEs) was developed by EFRAG in 2024 to help non-listed SMEs align voluntarily with the Corporate Sustainability Reporting Directive (CSRD).

It’s designed for companies that are not legally required to publish CSRD sustainability reports but still need to respond to client or lender data requests driven by their customers’ own obligations. Since the Omnibus I directive, the VSME-based voluntary standard (VS) is also the legal ceiling on what a CSRD reporter may require from a business partner with an average of 1,000 or fewer employees, for financial years starting on or after 1 January 2027.

The VSME lets SMEs:

• Disclose key ESG data in a proportionate and standardised format
• Reuse the same data across multiple client or supplier questionnaires
• Build trust and readiness for future sustainability expectations

The VSME has two levels of detail — the Basic Module (B1–B11) and the Comprehensive Module (C1–C9).

2. Overview: Basic vs Comprehensive

Both are fully voluntary and compatible with ESRS, meaning SMEs can start simple and scale up when needed.

3. The Basic Module (B1–B11): The Foundation for All SMEs

The Basic Module is designed to be achievable by any SME, even without a sustainability department. It focuses on what’s material, measurable, and manageable.

Structure of the Basic Module

What Makes the Basic Module Ideal for SMEs

• Quick to complete – can be prepared using existing data (invoices, HR records, policies)
• Minimal technical language – no need for a sustainability expert
• Flexible – applicable to any sector, from law firms to manufacturers
• Reusable – data can be shared with multiple CSRD-reporting clients

Tip: A Basic Module report is usually short, because many disclosures are single figures. Use our CSRD requirements checklist to track your progress.

4. The Comprehensive Module (C1–C9): Going Deeper into ESG

The Comprehensive Module is optional. It builds on the Basic Module for SMEs that:

• Work with large CSRD-reporting customers;
• Seek green loans or ESG-linked finance; or
• Already collect detailed environmental or social data.

Structure of the Comprehensive Module

C3 and C4 deserve special attention: climate targets and climate risks are the two disclosures banks and large customers request most, and both sit outside the value-chain cap, so they appear in requests whichever module you choose.

When to Choose the Comprehensive Module

• You’re part of a supply chain for listed or multinational clients;
• You want to align with ESRS standards without being legally bound by CSRD;
• You already have a certified system (ISO 14001, ISO 45001, or CSR policy) and want to consolidate disclosures;
• You’re preparing for sustainability-linked loans or ESG ratings.

5. Which Module Should You Choose?

Practical approach: Start with Basic to create your first sustainability statement. Then, when clients ask for details (e.g. Scope 3 emissions or human rights policies), add relevant Comprehensive sections. You can also consider using software tools versus manual reporting to streamline data collection.

Whichever module you choose, the report itself need not cost anything: a free VSME report tool generates the finished document, Basic or Comprehensive, from your answers, and keeps those answers in an ESG answer bank for the next request that arrives.

6. Effort and Time Comparison

The figures below are indicative planning ranges, not survey results; actual effort depends on how organised your records are.

7. Common Mistakes When Choosing a Module

1. Over-reporting too early: Starting with Comprehensive before your firm has data systems in place can lead to incomplete or unreliable results.

2. Ignoring client expectations: Some SMEs stick to Basic even when key clients already request Scope 3 data — leading to repeated follow-up requests.

3. Treating reporting as a one-time exercise: Both modules expect annual updates and continuous improvement — even if small steps each year.

8. How to Transition from Basic to Comprehensive

1. Finish your Basic Module (B1–B11) — this builds your sustainability foundation.
2. Collect data gradually — expand to Scope 3 emissions, risk assessments, and diversity tracking.
3. Add Comprehensive sections (C1–C9) as your data maturity grows.
4. Optional: seek limited assurance or external validation once you publish Comprehensive data.

Tip: A common pattern is a Basic report in year one, then the few Comprehensive disclosures your customers or bank actually ask for in year two.

9. Example: A Practical SME Pathway

10. Key Takeaways

• Start with Basic: it’s accessible, low-cost, and covers all major ESG topics.
• Upgrade to Comprehensive: when your clients, investors, or lenders need deeper data.
• Both modules are voluntary: choose based on your firm’s size, data availability, and client expectations.
• The path is flexible: you can transition at any time — the structure is designed to scale with you.

Frequently Asked Questions

Can I start with Basic and upgrade to Comprehensive later?

Yes — that is the recommended path for most small and growing businesses (SMEs). The Comprehensive Module (C1–C9) builds on Basic rather than replacing it, so the data you gather in year one forms the foundation. Businesses typically upgrade when a client, bank, or investor explicitly requests deeper disclosures.

Does my business need to report every B1–B11 disclosure in Basic?

Yes — once you choose the Basic Module you apply it in full, covering general information, environment, social, and governance. But each disclosure is given only where it applies to your business: B4 (pollution), for example, applies only if you already report pollutants under law or an environmental management system. A disclosure you leave out is assumed not to apply, though a one-line note helps the reader.

Is VSME Comprehensive the same as full CSRD/ESRS reporting?

No. Comprehensive adds depth but stays proportionate for SMEs — it does not require the full ESRS rulebook, double materiality assessment, or XBRL tagging that listed and large companies face. It is a middle path for businesses whose clients or investors want more than Basic without the full CSRD burden.

How long does a Basic Module report typically take to produce?

There is no published benchmark. As a planning range, allow a few weeks of part-time effort in the first year (in line with the table above), mostly spent gathering utility bills, payroll data, and waste records. Later years are faster once the data collection routine is in place, and the standard lets you note where a figure has not changed since last year.

Sources

1. EFRAG, Voluntary Sustainability Reporting Standard for non-listed SMEs (VSME), delivered 17 December 2024: paragraph 5 (a module, once chosen, is complied with in its entirety, but each item is provided only when applicable); paragraph 13 (an omitted disclosure is assumed not applicable); B4, paragraph 32 (pollution reported only where already required by law or an environmental management system); paragraph 16 (unchanged datapoints may refer to the previous year); C3, paragraph 54 (targets for Scope 1 and 2, and for significant Scope 3 where Scope 3 targets are set).
2. European Commission, Delegated Regulation C(2026) 5011 of 3 July 2026 (the voluntary standard; published as Delegated Regulation (EU) 2026/1560): Article 1 (cap protects undertakings with an average of 1,000 employees or fewer); Article 4 (cap applies from financial years beginning on or after 1 January 2027); recital 5 (no obligation to seek assurance).
3. EFRAG Knowledge Hub, Voluntary Standard, Annex II: the Comprehensive Module disclosures inside the cap are C1, C5, C6 and C7, so C3 and C4 sit outside it.

Key Terms

For a complete explanation of CSRD terminology, see our glossary: CSRD, VSME, ESRS explained in plain English.

• CSRD – Corporate Sustainability Reporting Directive (EU 2022/2464)
• VSME – Voluntary Sustainability Reporting Standard for SMEs (EFRAG, 2024)
• Basic Module (B1–B11) – Core disclosures for all SMEs: energy, waste, workforce, governance
• Comprehensive Module (C1–C9) – Advanced disclosures covering strategy, targets, value chain, and risks
• ESRS – European Sustainability Reporting Standards (used under CSRD)
• Scope 1–3 emissions – Direct and indirect greenhouse gas emissions
• Materiality – Determining which ESG issues are most relevant to your business
• Turnover – Total annual revenue, used to calculate GHG intensity