The VSME — the EU's Voluntary Sustainability Reporting Standard for SMEs — is the simplified framework for small and mid-sized businesses. A European customer asking for VSME-aligned data means the Basic Module: eleven disclosures, B1 through B11.
Most of the data already exists in utility bills, HR records, payroll, and company registration documents. The work is knowing what each disclosure asks for and where to look.
| First question | Short answer |
|---|---|
| How many disclosures? | Eleven in the Basic Module. Most SMEs need nothing beyond it. |
| Do I need a materiality assessment? | No. The Basic Module is a fixed list; "not applicable" is a valid answer where a topic does not arise. |
| Where is the data? | B1 registration documents; B2 your policies; B3–B7 utility, waste, and permit records; B8–B10 HR and payroll; B11 legal records. |
| My questionnaire uses E1–E5, S1–S4, G1 instead. | Same standard grouped by topic. The starter statements guide follows that layout. |
| Which is hardest? | B3, energy and emissions, because it requires a calculation. Everything else is extraction. |
B1 — Basis for preparation
What it is. Basic company information framing the report.
Data. Legal name and legal form (GmbH, Ltd, SAS); NACE sector code; balance sheet total; net revenue; average number of employees; countries of operation; addresses of significant sites.
Where. Company registration documents, annual financial statements, tax filings. The NACE code is on EU business registration or in the Eurostat NACE database.
Note. The easiest disclosure. Every registered business has this. Do it first.
B2 — Practices, policies and future initiatives
What it is. Which sustainability policies exist and any planned initiatives.
Data. The list of sustainability-related policies (environmental, social, governance); whether sustainability is integrated into strategy; who is responsible for it; planned initiatives.
Where. Your own documents. An environmental policy, a health and safety policy, a code of conduct, an anti-corruption statement all count.
Note. A one-page sustainability statement signed by the managing director is a valid start. The disclosure asks what exists. If nothing exists yet, say so and describe what is planned. The ESG policy template guide provides an environmental policy to download.
B3 — Energy and greenhouse gas emissions
What it is. Energy consumption and carbon footprint.
Data. Total energy in MWh; renewable versus non-renewable; gross greenhouse gas emissions in tCO2e — Scope 1 and 2 at minimum; Scope 3 encouraged but voluntary; GHG intensity (emissions per revenue or per employee).
Where. Electricity bills give kWh (divide by 1,000 for MWh). Gas bills and fuel receipts cover heating and vehicles. Multiply consumption by published emission factors (DEFRA or the national environment agency) for tCO2e. The electricity provider can state the renewable share of supply.
Note. Twelve months of bills and fuel receipts cover Scope 1 (fuel combustion, company vehicles) and Scope 2 (purchased electricity). For most SMEs those two are what is required. The free carbon calculator does the conversion. Do not let Scope 3 stop you reporting what can be measured now.
B4 — Pollution
What it is. Pollutants emitted to air, water, and soil.
Data. Pollutants to air (NOx, SOx, particulates); to water (heavy metals, chemicals in wastewater); to soil (spills, contamination); in kilograms or metric tons.
Where. Environmental permits, emissions monitoring reports, wastewater discharge records. A holder of an industrial emissions permit already reports these figures to a regulator.
Note. Most service and light-commercial businesses have minimal or zero pollution to report. Disclose it and state that operations do not generate significant pollutant releases. Manufacturing, chemical, and heavy-industry companies should check their permits; those documents often contain the exact figures.
B5 — Biodiversity
What it is. Whether any site is in or near a biodiversity-sensitive area.
Data. Number of sites in or adjacent to sensitive areas; their total hectares; any protection or restoration measures.
Where. The EU Natura 2000 network viewer (natura2000.eea.europa.eu) by site address. Outside the EU, national protected-area databases or the World Database on Protected Areas (protectedplanet.net).
Note. Many businesses report zero. If no site is near a protected area, report zero. The disclosure exists for mining, agriculture, construction, and other sectors operating in sensitive locations.
B6 — Water
What it is. Water withdrawal and whether any comes from water-stressed areas.
Data. Total withdrawal in cubic meters; withdrawal from high-stress areas if applicable; sources (municipal, groundwater, surface).
Where. Water bills show consumption in cubic meters (convert from gallons if needed). The WRI Aqueduct Water Risk Atlas (wri.org/aqueduct) shows the stress level for site coordinates.
Note. Office-based businesses have small, municipal-only consumption; report the bill figure and the source. Manufacturers using water in production should track process water separately from domestic use where possible. The water tracking guide covers it.
B7 — Resource use, circular economy and waste
What it is. Waste generated and what happens to it.
Data. Total waste in metric tons; diverted from disposal (recycling, reuse, recovery); directed to disposal (landfill, incineration); circular economy practices (design for durability, take-back, recycled materials).
Where. Waste collection invoices and transfer notes. Most providers issue annual summaries by stream; a recycling contractor confirms diverted volumes.
Note. If tonnage is unknown, ask the contractor; they track it. For circular economy, describe actual practice: recycled packaging, design for repair, avoidance of single-use materials. If nothing yet, say so and describe plans. The waste reporting guide covers it.
B8 — Workforce: general characteristics
What it is. Who works for you.
Data. Headcount at year end; by contract type (permanent, temporary); by gender; by country of operation.
Where. HR system, payroll records, or personnel files. A payroll provider can generate the breakdown.
Note. Straightforward extraction. Without a formal HR system, a spreadsheet of employees with these attributes takes an hour.
B9 — Workforce: health and safety
What it is. Workplace accident and injury data.
Data. Number of recordable work-related accidents; rate per 200,000 or 1,000,000 hours worked; work-related fatalities.
Where. The accident log or incident register most countries require employers to keep. Reports to a national authority (OSHA in the US, HSE in the UK) contain the figures.
Note. Zero recordable accidents is reported as zero. Check that "recordable" matches the standard: generally, any work-related injury or illness needing treatment beyond first aid. Track hours worked to calculate the rate.
B10 — Workforce: remuneration, collective bargaining and training
What it is. Pay, representation, and development.
Data. Whether all employees are paid at or above the applicable minimum wage; the gender pay gap where applicable; collective bargaining coverage; average training hours per employee, by gender.
Where. Payroll for wage compliance and pay gap; training records or a learning management system for hours. Where training is tracked informally, estimate total hours delivered and divide by headcount.
Note. The gender pay gap is the difference between average male and average female pay as a percentage of average male pay. Many SMEs have never calculated it; doing so may reveal gaps, which is the purpose. Training hours include all structured learning: courses, workshops, on-the-job programs, safety training, e-learning.
B11 — Convictions and fines for corruption and bribery
What it is. Whether the company has been convicted or fined for corruption or bribery.
Data. Number of convictions; total fines; whether anti-corruption and anti-bribery policies exist.
Where. Legal and compliance records. Confirm with counsel if there is any doubt.
Note. Most SMEs report zero convictions and zero fines. The important part is the policy: an anti-bribery statement in the employee handbook or code of conduct satisfies it. If none exists, a basic anti-corruption policy is a quick addition.
Putting it together
The VSME asks for nothing exotic: company facts, utility bills, HR records, safety logs, basic policies. The sources are things every business already touches. They have not been organized for sustainability reporting before.
The first cycle is the slow one. Later years are faster because the sources are known and the collection habit exists.
To see where you stand before collecting, the free VSME readiness assessment shows which disclosures are already covered and which need work. For ongoing tracking, ESG Passport organizes all eleven disclosures in one place, stores supporting documents, and generates reports when customers or auditors ask.
For a startup preparing for investor due diligence, see what investors actually check. For why customers request this data, double materiality for SMEs. To start collecting, the 20-minute tracking setup guide.