What workplace safety data do SMEs need to collect?

Workplace health and safety is one of the social disclosures under the Corporate Sustainability Reporting Directive (CSRD) and the Voluntary Sustainability Reporting Standard for SMEs (VSME). Even if your small and medium-sized enterprise (SME) is low-risk or office-based, you are expected to collect and report some basic safety information. See our CSRD requirements checklist for all data you need.

What counts as an accident?

A reportable accident is any incident at work that causes injury and leads to an employee being absent for at least one working day.

This includes slips, falls, cuts, or other incidents in a shop, warehouse, factory, or office. Minor incidents that do not cause absence do not need to be reported, though you may wish to log them internally for prevention.

👉 If you have zero accidents, that is still a valid disclosure. Many SMEs will simply report “0 accidents, 0 fatalities”.

What the standards require

Under the VSME Basic Module – Workforce: Health and safety (B9), SMEs must disclose:

• The number of work-related accidents that caused absence from work.
• The number of fatalities due to work-related accidents.

If you use the Comprehensive Module (C6), you may also report:

• Accident frequency rate (accidents per hours worked).
• Breakdowns by gender, contract type, or location.

What SMEs should collect

To prepare your disclosure, log:

1. Total number of employees (to give context).
2. Number of accidents with absence.
3. Number of fatalities (if any).
4. (Optional) Total hours worked (for frequency rate).
5. (Optional) Brief notes on major incidents, useful for explaining data to banks or clients.

Example

A warehouse employs 40 staff. In the reporting year:

• 2 employees had accidents that caused absence.
• 0 fatalities.

Disclosure (B9 Basic Module):

• Accidents with absence: 2
• Fatalities: 0

Optional (Comprehensive Module): Frequency rate = 2 accidents ÷ (40 × 1,800 hours) = 0.028 per 100,000 hours worked.

Practical tips for SMEs

• Use existing HR/sick leave records — no special system is needed.
• Keep it simple: you only need to log accidents that cause absence.
• Be consistent: record data the same way each year.
• Add context: if you operate in a very low-risk setting (e.g. offices), explain that zero accidents is expected.

Frequently Asked Questions

Does near-miss reporting count for CSRD or VSME?

Near-misses (incidents that could have caused injury but did not) are not required under VSME Basic B9 or CSRD ESRS S1. They are best practice for internal prevention and may help tell a positive safety-culture story in your narrative, but they do not need to appear in the formal disclosure.

What if an accident happens to a subcontractor or agency worker on our site?

Report it separately from your own-workforce figures. VSME B9 covers employees only. Incidents affecting value-chain workers sit under Comprehensive Module C7 (workers in the value chain) — disclose them if material, particularly for construction, manufacturing, and logistics businesses.

How do I calculate the accident frequency rate for a small business?

Divide the number of accidents with absence by total hours worked, then multiply by 100,000 to get “accidents per 100,000 hours”. For a 40-person business working 1,800 hours each, that is 72,000 annual hours — 1 accident = 1.39 per 100,000 hours. The frequency rate is optional in Basic and standard in Comprehensive.

Key Terms

• Corporate Sustainability Reporting Directive (CSRD) — An EU law requiring large companies — and eventually some medium-sized ones — to report on environmental and social impacts. SMEs may be asked for CSRD-style data by banks or clients.
• Voluntary Sustainability Reporting Standard for SMEs (VSME) — A simplified reporting framework for SMEs. It helps respond to bank or client requests.
• Basic Module — The minimum reporting set most SMEs are expected to provide.
• Comprehensive Module — An extended reporting set sometimes requested by banks or large clients.
• Workplace accident — An incident at work that results in at least one day of employee absence.
• Accident frequency rate — Number of accidents relative to hours worked, often expressed per 100,000 hours.