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VSME vs CSRD: which report do you need?

After the Omnibus directive, the answer is simpler than it was in 2024. The CSRD is mandatory only for companies with more than 1,000 employees and over EUR 450 million net turnover, reporting under ESRS. The VSME is the EU's voluntary standard for SMEs, built to answer banks and customers. Most mid-size companies now need the second, not the first.

Side by side

The two frameworks compared.

CSRD (ESRS)VSME
Legal statusEU directive, mandatory for companies in scopeCommission Recommendation (EU) 2025/1710, voluntary
WhoMore than 1,000 employees and more than EUR 450m net turnover (Directive (EU) 2026/470); non-EU groups above EUR 450m EU net turnoverNon-listed SMEs and micro-undertakings
First report2028 on FY2027 for wave-2 companies in the new scopeAny time
StandardESRS; revised (simplified) ESRS mandatory from FY starting 1 January 2027EFRAG VSME: Basic Module (B1–B11), optional Comprehensive Module (C1–C9)
MaterialityDouble materiality assessment requiredNo full double materiality assessment
Climate dataESRS E1, including Scope 3 where materialScope 1 and 2; Scope 3 not required
AssuranceExternal limited assurance requiredNone required
Role in the value chainLarge companies collect supplier dataDesigned as the cap on what large companies and banks request from SMEs

Status 5 November 2026. Directive (EU) 2026/470 in force since 18 March 2026; transposition by 19 March 2027.

How to choose

Three questions decide it.

1. Are you over both thresholds? More than 1,000 average employees and more than EUR 450 million net turnover, at group level. If yes, you are in CSRD scope and report under ESRS; the VSME is not an alternative. If no, you have no CSRD duty once national transposition lands. Wave-1 companies below the thresholds should check their Member State's timing.

2. Who is asking you for data? A bank, a customer or a tender. Because the VSME is designed as the cap on value-chain requests, a clean VSME report is the efficient answer to most of them. One dataset instead of five questionnaires.

3. Does a customer need Scope 3 or targets? The Basic Module covers Scope 1 and 2. If a buyer asks for reduction targets, add the Comprehensive Module (C3). If they ask for Scope 3, add a Scope 3 inventory alongside.

Typical cases

Who ends up where.

Supplier, 120 staff

Customer questionnaire on emissions and labour data. → VSME Basic Module, plus Scope 1 and 2 inventory.

Manufacturer, 600 staff, bank loan

Bank ESG questionnaire with climate-risk questions. → VSME with Comprehensive Module (C3, C4).

Group, 1,400 staff, EUR 600m

Above both thresholds. → CSRD under ESRS, first report 2028 on FY2027, double materiality first.

Most mid-size companies left the CSRD in 2026. Their customers' questions did not.

FAQ

Frequently asked.

Is the VSME a replacement for the CSRD?
No. Companies in CSRD scope must report under ESRS. The VSME is a voluntary standard for SMEs that are not in scope; it helps them answer data requests from banks and customers.
Who has to report under the CSRD after the Omnibus?
Under Directive (EU) 2026/470, undertakings with more than 1,000 average employees and more than EUR 450 million net turnover, both criteria together. Listed SMEs are removed from mandatory scope. Wave-2 companies that meet the thresholds report first in 2028, on FY2027.
Does the VSME require Scope 3?
No. The VSME asks for Scope 1 and Scope 2 emissions. Scope 3 is not required, although some customers request it separately.
Does a VSME report need assurance?
No assurance is required because the standard is voluntary. Documented methods and sources make later verification possible if a customer or bank asks for it.
Can a company switch from VSME to CSRD later?
Yes. The data collected for a VSME report, especially energy, emissions and workforce data, feeds into ESRS disclosures. A company that grows into scope builds on its VSME dataset.
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