The 11 VSME Disclosures Explained Simply

The VSME — the EU's Voluntary SME Standard — is a simplified sustainability reporting framework designed for small and mid-sized businesses. If a European customer asks you to report using VSME, you'll encounter the "basic module": 11 disclosures labeled B1 through B11.

Eleven disclosures sounds like a lot. It isn't. Most of the data already exists somewhere in your business — in utility bills, HR records, payroll systems, or company registration documents. The challenge is knowing what each disclosure asks for and where to look.

This guide walks through all 11, one at a time, in plain language.

B1 — Basis for Preparation

What it is: Basic company information that identifies who you are and how your report is framed.

What data you need:

Legal name and legal form (e.g., GmbH, Ltd, SAS)
NACE sector code (EU industry classification)
Balance sheet total
Net revenue
Average number of employees (headcount)
Countries where you operate
Addresses of significant sites

Where to find it: Your company registration documents, annual financial statements, and tax filings. Your NACE code is on official EU business registration or can be looked up on the Eurostat NACE database.

Practical tip: This is the easiest disclosure. Every registered business already has this information. Fill it in first to build momentum — it takes ten minutes.

B2 — Sustainability Practices and Policies

What it is: A description of what sustainability policies you have and whether you've set any transition plans or targets.

What data you need:

List of sustainability-related policies (environmental, social, governance)
Whether you have a transition plan for climate change
Whether sustainability topics are integrated into your strategy
Who is responsible for sustainability in your organization

Where to find it: Your own internal documents. If you have an environmental policy, a health and safety policy, a code of conduct, or an anti-corruption statement — those count.

Practical tip: This doesn't need to be complex. A one-page sustainability statement signed by your managing director is a valid starting point. The disclosure asks what you have, not whether it's perfect. If you have nothing yet, say so honestly and describe what you plan to do. Transparency matters more than perfection.

B3 — Energy and Greenhouse Gas Emissions

What it is: Your energy consumption and carbon footprint numbers.

What data you need:

Total energy consumption in MWh (megawatt hours)
Energy from renewable vs. non-renewable sources
Gross greenhouse gas emissions in tCO2e (tonnes of CO2 equivalent) — Scope 1 and Scope 2 at minimum
Scope 3 emissions (encouraged but voluntary for SMEs under VSME)
GHG intensity ratio (emissions per revenue or per employee)

Where to find it: Electricity bills give you kWh consumed (divide by 1,000 for MWh). Gas bills and fuel receipts cover heating and vehicles. Multiply consumption by published emissions factors (from DEFRA or your national environment agency) to get tCO2e. Your electricity provider may also tell you the renewable share of your supply.

Practical tip: Start with 12 months of utility bills and fuel receipts. That covers Scope 1 (direct fuel combustion, company vehicles) and Scope 2 (purchased electricity). For most SMEs, these two scopes are all that's required. Don't let Scope 3 complexity stop you from reporting what you can measure today.

B4 — Pollution

What it is: Quantities of pollutants your operations emit to air, water, and soil.

What data you need:

Pollutants released to air (e.g., NOx, SOx, particulate matter)
Pollutants released to water (e.g., heavy metals, chemicals in wastewater)
Pollutants released to soil (e.g., chemical spills, contamination)
Amounts in kilograms or tonnes

Where to find it: Environmental permits, emissions monitoring reports, wastewater discharge records, or environmental compliance documentation. If you hold an industrial emissions permit, you likely already report these numbers to regulators.

Practical tip: Most service-based and light-commercial businesses have minimal or zero pollution to report. That's perfectly fine — you still disclose it and state that your operations don't generate significant pollutant releases. Manufacturing, chemical, and heavy industry companies should check their environmental permits carefully, as those documents often contain the exact figures needed.

B5 — Biodiversity

What it is: Whether any of your operational sites are located in or near biodiversity-sensitive areas.

What data you need:

Number of sites in or adjacent to biodiversity-sensitive areas
Total hectares of those sites
Whether you have measures to protect or restore biodiversity

Where to find it: Check the EU Natura 2000 network viewer (natura2000.eea.europa.eu) by entering your site addresses. For non-EU locations, check national protected area databases or the World Database on Protected Areas (protectedplanet.net).

Practical tip: Many businesses score zero here, and that is a completely normal result. If none of your sites are near protected areas, you report zero and move on. Don't overthink this one. The disclosure exists because some industries (mining, agriculture, construction) operate in ecologically sensitive locations — if that's not you, a brief statement is sufficient.

B6 — Water

What it is: How much water your business uses and whether any of it comes from water-stressed regions.

What data you need:

Total water withdrawal in cubic meters (m3)
Water withdrawal from areas of high water stress, if applicable
Water sources (municipal supply, groundwater, surface water)

Where to find it: Water utility bills show your consumption in cubic meters (or gallons — convert as needed). To check whether your location is in a high water-stress area, use the free WRI Aqueduct Water Risk Atlas (wri.org/aqueduct). Enter your site coordinates and it tells you the stress level.

Practical tip: For office-based businesses, water consumption is typically small and entirely from municipal supply. Report the numbers from your bills and note the source. For manufacturers using water in production processes (cooling, cleaning, processing), track process water separately from domestic use if possible — it shows you understand where your consumption sits.

B7 — Waste and Resource Use

What it is: How much waste you generate and what happens to it.

What data you need:

Total waste generated in tonnes
Waste diverted from disposal (recycling, reuse, recovery) in tonnes
Waste directed to disposal (landfill, incineration) in tonnes
Whether you apply circular economy principles (product design for durability, take-back schemes, use of recycled materials)

Where to find it: Waste collection invoices and waste transfer notes from your waste management provider. Most providers issue annual summaries showing tonnages by waste stream. If you sort recycling separately, your recycling contractor can confirm diverted volumes.

Practical tip: If you don't have exact tonnage figures, ask your waste contractor — they track it. For circular economy, describe what you actually do: using recycled packaging, designing products for repair, minimizing single-use materials. Even basic practices count. If you haven't started, say so and describe any plans.

B8 — Workforce Characteristics

What it is: A breakdown of who works for you.

What data you need:

Total headcount at year-end
Employees by contract type (permanent vs. temporary)
Employees by gender (male, female, other/not disclosed)
Employees by country of operation

Where to find it: Your HR system, payroll records, or personnel files. If you use a payroll provider, they can typically generate this breakdown on request.

Practical tip: This is straightforward data extraction. Most payroll systems can filter by contract type, gender, and location. If your company is small enough that you don't have a formal HR system, a simple spreadsheet listing employees with these attributes takes an hour to assemble.

B9 — Health and Safety

What it is: Workplace accident and injury data.

What data you need:

Number of recordable work-related accidents
Rate of recordable work-related accidents (per 200,000 or 1,000,000 hours worked)
Number of work-related fatalities

Where to find it: Your accident log or incident register. Most countries require employers to maintain one. If you report workplace injuries to a national authority (like OSHA in the US or HSE in the UK), those records contain what you need.

Practical tip: If you had zero recordable accidents, report zero. That's a good result. Make sure your definition of "recordable" matches the VSME standard — generally, any work-related injury or illness requiring medical treatment beyond first aid. Track hours worked during the year to calculate the rate accurately.

B10 — Remuneration and Training

What it is: Fair pay and development metrics.

What data you need:

Whether all employees are paid at or above the applicable minimum wage or living wage
Gender pay gap as a percentage (mean or median difference between male and female pay)
Average training hours per employee, broken down by gender

Where to find it: Payroll data for wage compliance and gender pay calculations. Training records or your learning management system for training hours. If you track training informally, estimate total hours delivered and divide by headcount.

Practical tip: For the gender pay gap, calculate the difference between average male and average female compensation as a percentage of average male compensation. Many SMEs have never calculated this before — doing so may reveal gaps you weren't aware of, which is the point. For training hours, include all structured learning: courses, workshops, on-the-job training programs, safety training, and e-learning modules.

B11 — Governance and Business Conduct

What it is: Whether your company has been involved in corruption or bribery.

What data you need:

Number of convictions for violations of anti-corruption and anti-bribery laws
Total fines paid for such violations
Whether you have anti-corruption and anti-bribery policies in place

Where to find it: Legal records and compliance files. If you have legal counsel, confirm whether any convictions or fines exist.

Practical tip: Most SMEs will report zero convictions and zero fines. That's expected. The important part is demonstrating that you have policies to prevent corruption — even a simple anti-bribery statement in your employee handbook or code of conduct satisfies the requirement. If you don't have one yet, creating a basic anti-corruption policy is a quick win.

Putting It All Together

Reading through all 11 disclosures, you'll notice a pattern: the VSME doesn't ask for anything exotic. It asks for company facts, utility bills, HR records, safety logs, and basic policy documents. The data sources are things most businesses already touch — they just haven't been organized for sustainability reporting before.

The hardest part isn't finding the data. It's doing it the first time. After your first reporting cycle, subsequent years become significantly faster because you know where everything lives and you've built the collection habit.

If you want to see where you stand before diving into data collection, try the free VSME readiness assessment. It walks through the key requirements and tells you which disclosures you're already prepared for and which need work.

For ongoing tracking and reporting, ESG Passport helps you organize all 11 disclosures in one place, store supporting documents, and generate reports when customers or auditors request them. It's built specifically for suppliers dealing with frameworks like VSME, so you don't need to figure out the structure from scratch.

If you're a startup preparing for investor due diligence, see our guide on what investors actually ask for at each funding stage. For a deeper understanding of why customers request this data, read about double materiality for SMEs. And if you're ready to start collecting data now, follow our 20-minute tracking setup guide.

The VSME standard is designed to be achievable for small businesses. Take it one disclosure at a time, start with what you already have, and build from there.