VSME explained: CSRD reporting for SMEs.

What VSME is.

VSME is the Voluntary Sustainability Reporting Standard for non-listed micro, small and medium-sized undertakings, developed by EFRAG and published in late 2024. It is voluntary by name, but increasingly mandatory in practice: large companies in CSRD scope use it as the structured data ask they push down their value chain.

The standard is modular. The Basic module is the minimum disclosure set most SMEs will be asked for. The Comprehensive module adds the data points that financial institutions, insurers and large listed clients typically require for their own ESRS and SFDR reporting.

What happened to LSME.

LSME — the standard for Listed SMEs — was originally scheduled to enter into force alongside the main ESRS. Under the Omnibus I simplification package, the LSME track has been paused and the development mandate withdrawn. Listed SMEs no longer have a dedicated proportionate standard on the EFRAG roadmap.

In practice, listed SMEs that fall outside the revised CSRD thresholds are expected to use VSME — the same voluntary framework as non-listed SMEs — when their customers, lenders or investors request structured sustainability data.

You may not be in scope — but your customers are.

The Omnibus I thresholds removed most mid-market companies from direct CSRD scope. That does not remove the data requests. CSRD-scoped customers still need value chain data to satisfy ESRS E1–S4 and their own double materiality assessments. CSDDD-scoped customers still need due diligence evidence from their suppliers. NIS2-scoped customers still need control evidence from their service providers.

VSME is the language they will use to ask. A supplier that can answer a VSME Basic request in days instead of weeks wins the contract renewal. A supplier that cannot answer at all becomes a procurement risk.

Basic vs Comprehensive — what's inside.

The Basic module covers around eleven disclosure blocks (B1–B11): general information, practices for transitioning to a more sustainable economy, energy and greenhouse gas emissions, pollution, biodiversity, water, resource use and waste, workforce, and basic governance metrics.

The Comprehensive module adds nine further blocks (C1–C9): strategy and business model resilience, transition plan for climate, additional GHG breakdowns, climate risks, mechanisms to identify ESG risks, additional workforce indicators, human rights incidents, revenues in controversial sectors, and gender diversity at the governance level.

Most customer requests start with Basic. Financial counterparties and large listed customers escalate to Comprehensive when the relationship is material to their own reporting.

The operational reality for suppliers.

Most SMEs receive overlapping data requests from multiple customers, in multiple formats, on different cycles. The same underlying evidence — energy bills, workforce data, supplier lists, incident logs — gets re-extracted and re-formatted for every requester.

The fix is not another spreadsheet template. It is a single evidence model that can answer VSME, the customer's bespoke ESG questionnaire, CSDDD due diligence requests and NIS2 control evidence from the same source of truth. Reuse is the only way the workload becomes sustainable.

What to do this quarter.

A practical operating model for mid-market suppliers responding to VSME covers five steps:

• Map the requesters — list the customers, banks and insurers that already ask for sustainability data, and capture the format each one uses today.
• Anchor on VSME Basic — treat B1–B11 as the canonical datapoint set. Translate every incoming custom questionnaire back to those datapoints.
• Bind datapoints to evidence — for each B-block, name the system or document that produces the number, the owner, and the refresh cadence.
• Industrialise the response — answer the next request from the structured datapoint set, not from scratch. Reuse the same evidence across CSRD, CSDDD and NIS2 asks.
• Make gaps visible — when a datapoint is missing or estimated, document the method and the outreach. Defensibility comes from a documented trail, not from a clean spreadsheet.

How Regweaver helps.

Regweaver is value chain-native. It is built for the operating layer behind VSME: a structured datapoint register, evidence bound to owners, customer requests answered from one source of truth, and a trail that holds up under customer audit.

For mid-market suppliers, this turns VSME from a one-off scramble into a repeatable response capability — and turns every customer ESG questionnaire into a quick reuse of evidence you already have.