VSME Standard: Basic vs. Comprehensive Module Explained

The VSME Standard has two modules. The Basic Module (disclosures B1–B11) is the mandatory foundation — 11 disclosures covering core company information plus environmental, social, and governance metrics. The Comprehensive Module (disclosures C1–C9) adds 9 further disclosures aimed at the deeper questions banks, investors, and large corporate clients tend to ask.

Together, the two modules make up all 20 VSME disclosures.

Basic Module: what’s actually in it

The Basic Module is built to be achievable without a dedicated sustainability function, and is mostly quantitative.

General information

B1 – Basis for preparation (which module you’re using, reporting scope, company details: legal form, sector code, turnover, headcount, locations)
B2 – Practices, policies, and future initiatives for transitioning toward a more sustainable economy

Environmental metrics

B3 – Energy consumption and greenhouse gas emissions (Scope 1 and location-based Scope 2)
B4 – Pollution of air, water, and soil
B5 – Biodiversity (whether sites sit in or near biodiversity-sensitive areas)
B6 – Water withdrawal and consumption
B7 – Resource use, circular economy practices, and waste management

Social metrics

B8 – Workforce general characteristics (contract type, gender, country)
B9 – Workforce health and safety (recordable accidents, fatalities)
B10 – Remuneration, collective bargaining coverage, and training hours

Governance metrics

B11 – Convictions and fines for corruption and bribery

Note: Several Basic Module datapoints (parts of B3, B6, and B7) are explicitly marked voluntary for undertakings with 10 employees or fewer, even though they’re mandatory for everyone else applying the standard. The standard was deliberately built with that micro-enterprise carve-out.

Comprehensive Module: what it adds

The Comprehensive Module shifts from numbers to narrative. It’s designed to answer the kind of questions a bank or investor would ask in due diligence.

General information

C1 – Strategy: business model and sustainability-related initiatives
C2 – Further detail on the practices, policies, and initiatives introduced in B2

Environmental metrics

C3 – GHG reduction targets and climate transition planning
C4 – Climate-related risks (hazards, exposure, adaptation actions)

Social metrics

C5 – Additional workforce characteristics (turnover rate, gender ratio at management level)
C6 – Human rights policies and processes (code of conduct, complaints-handling mechanism)
C7 – Human rights incidents

Governance metrics

C8 – Revenue from certain sensitive activities (controversial weapons, tobacco, fossil fuels, chemicals production)
C9 – Gender diversity ratio in the governance body

As with the Basic Module, a number of Comprehensive Module datapoints are voluntary rather than mandatory for undertakings with 10 or fewer employees — including parts of C1, C3, C4, and C6.

Why the Comprehensive Module reads differently

The Basic Module can largely be filled in from data you already track, like utility bills, HR records, and waste logs, for example. The Comprehensive Module asks for things like a written climate transition plan, a documented human rights policy, or a target-setting exercise for emissions reduction.

These datapoints map directly onto information banks and investors already have to collect for their own regulatory obligations. The SFDR (Sustainable Finance Disclosure Regulation), EBA Pillar 3 templates, and the EU Benchmark Regulation all draw on specific VSME disclosures. If your bank or a large customer is asking for Comprehensive Module data, there’s usually a specific regulatory reason behind the question.

Which module do you actually need?

This depends on your specific counterparties and goals. Generally:

Basic Module is the right starting point for most non-listed SMEs, particularly if you’re reporting mainly to satisfy ad hoc questionnaires from customers or a bank relationship manager.
Comprehensive Module becomes relevant when a specific bank, investor, or large corporate customer explicitly asks for it — commonly tied to green financing applications, or when a large CSRD-reporting customer needs more detail than the Basic Module provides for their own value-chain disclosures.
No audit or assurance is required for either module. This keeps the compliance cost meaningfully lower than CSRD/ESRS reporting for large companies.

The value chain cap doesn’t cover the whole standard

The “value chain cap” introduced by the Omnibus I Directive doesn’t apply to all 20 VSME disclosures. Per the 3 July 2026 delegated act, only a specific, listed subset of disclosures counts toward the enforceable cap, dependent on company size:

Companies with more than 10 employees: the cap covers a broader list, including B3, B6, B7, B8, B9, B10, C1, C5, C6, and C7 (in addition to the general B1 disclosures).
Companies with 10 employees or fewer: the cap is narrower, covering essentially just the general B1 information plus core workforce disclosures (B8, B9, B10).

In practice: a large CSRD-obligated customer can still voluntarily ask a supplier for more than what’s on this list, but the supplier has a statutory right to decline anything beyond it, and the customer is required to tell them which parts of the request go beyond the cap.

How this differs from full ESRS (the CSRD standard)

	VSME	ESRS (under CRSD)
Applies to	Undertakings with ≤1,000 employees, voluntarily	Companies in CSRD’s mandatory scope
Legal obligation to report on	None (voluntary)	Mandatory
Double materiality assessment	Not required	Required
External audit/ assurance	Not required	Required
Total disclosures	20 (11 Basic + 9 Comprehensive)	Substantially more, across multiple topical standards
Scope 3 emissions	Optional (“if appropriate”)	Full 15-category screening required

Learn more on EFRAG’s VSME standard