ESRS vs VSME vs GRI vs ISSB: which ESG reporting framework?

ESRS vs VSME vs GRI vs ISSB: who reads each framework?

Each framework was written for a different reader, and that reader should drive your choice. This comparison of ESRS vs VSME vs GRI vs ISSB therefore starts with one question: who is the report for?

Under ESRS 1, the European Sustainability Reporting Standards (ESRS) address both investors and lenders and business partners, social partners and NGOs. The VSME (Voluntary Sustainability Reporting Standard for non-listed SMEs) is built to answer customers and banks; Delegated Regulation (EU) 2026/1560 even encourages financial institutions to keep their requests to companies with 1,000 employees or fewer within its datapoints. GRI addresses every stakeholder affected by an organisation’s impacts. IFRS S1 and S2, issued by the International Sustainability Standards Board (ISSB), target those who decide whether to finance the company.

The table summarises the status of each framework as we read it on the official websites on 11 November 2026.

The CSRD itself, Directive (EU) 2022/2464, is not a framework: it is the directive that obliges certain companies to report under the ESRS. Since Directive (EU) 2026/470, known as Omnibus I, it only covers companies exceeding both EUR 450 million net turnover and an average of 1,000 employees. What this means for suppliers is set out on our page on supplier ESG questionnaires, CSRD and VSME.

Double materiality, impact or financial materiality: what changes?

The framework decides what you disclose. The ESRS ask what matters to society and to the company, GRI what matters to society, IFRS S1 and S2 what matters to the company’s accounts. The VSME sets a list and spares you a materiality assessment.

ESRS: double materiality. Under ESRS 1, as replaced by Delegated Regulation (EU) 2026/1563, a company discloses its material impacts on people and the environment, and the material risks and opportunities it faces. Impact materiality and financial materiality are assessed together, because an impact can become financial.

GRI: impacts. The GRI Standards cover an organisation’s impacts on the economy, the environment and people. A company identifies its material topics from the perspective of those impacts, then explains how it manages them.

IFRS S1 and S2: financial materiality. According to ifrs.org, IFRS S1 requires disclosure of sustainability-related risks and opportunities that could reasonably be expected to affect cash flows, access to finance or cost of capital over the short, medium or long term; IFRS S2 does the same for climate. An impact on a river appears only if it can affect the company.

VSME: “if applicable”. The voluntary standard requires no materiality assessment. Some information is disclosed only in circumstances defined in each section; when it is omitted, the standard presumes it does not apply (paragraph 15 of Annex I). For an SME, this is the most practical difference from the ESRS.

What does each framework ask on climate?

All four ask for your greenhouse gas emissions, but not with the same scope. The VSME stops at Scopes 1 and 2 in its Basic Module; the ESRS, IFRS S2 and GRI 102 go as far as Scope 3 and targets.

• VSME, section B3: total energy consumption in MWh, broken down where possible into electricity and fuels, renewable or not; an estimate of gross Scope 1 and location-based Scope 2 emissions, taking into account the GHG Protocol Corporate Standard (2004 version). Section C3 adds reduction targets, and Scope 3 targets if the company has set any; C4 describes climate risks.
• ESRS E1: eleven disclosure requirements, from the transition plan (E1-1) to anticipated financial effects (E1-11), including energy (E1-7) and gross Scope 1, 2 and 3 emissions (E1-8). Scope 3 starts with a screening of the 15 GHG Protocol categories; significant categories are updated every year and the full inventory at least every three years.
• IFRS S2: four pillars, governance, strategy, risk management, and metrics and targets. The standard integrates the recommendations of the TCFD and industry-based requirements derived from the SASB Standards. Its December 2025 amendments on greenhouse gas emissions apply to annual periods beginning on or after 1 January 2027.
• GRI 102 (climate) and GRI 103 (energy): issued in June 2025, effective for reporting from 2027 and, according to GRI, fully aligned with the GHG Protocol. GRI 102 adds “just transition” metrics on workers and communities.

One detail matters for suppliers. Under ESRS 1, your customer may estimate value-chain data using sector averages or spend-based data. If you do not answer, your emissions will still appear in its report, calculated without you. A documented figure from your own carbon footprint under ISO 14064 is a better answer; our ISO 14064-1 guide explains how such an inventory is built.

The GHG Protocol Corporate Standard remains the common method: Revised Edition of 2004, now under revision with ISO towards a consolidated standard whose publication is estimated for the fourth quarter of 2028, according to the GHG Protocol development plan. Nothing has been published yet.

Are the frameworks compatible with each other?

Largely, yes, and the standard setters have said so in writing. Three official bridges let you reuse the same work.

The simplified ESRS point the same way. Recital 2 of Delegated Regulation (EU) 2026/1563 lists interoperability with other sustainability reporting standards among the aims of the revision. And ESRS 1 allows companies to draw on IFRS industry-based guidance and on GRI Standards for entity-specific information.

The VSME has no formal bridge with GRI or the ISSB. It has a decisive one with the ESRS: under ESRS 1, the value-chain cap covers only the datapoints listed in Annex II of Delegated Regulation (EU) 2026/1560, and this limit also applies to companies from outside the EU. A Moroccan, Egyptian or Kenyan supplier with 1,000 employees or fewer is therefore covered.

Which framework should you choose for your situation?

The one used by your most demanding reader, presented in the format of the others. For most suppliers in Morocco and Africa, that means the VSME as the base, with a cross-reference table.

For listed companies in Morocco, the circulars page of the AMMC (Autorité marocaine du marché des capitaux, the capital market authority) listed no text after 2023 on 11 November 2026, and no circular imposes IFRS S2. Circular No. 03/19 of 20 February 2019, amended by Circular No. 02/20 of 22 December 2020, remains the applicable framework. What banks expect on climate, including the directives of Bank Al-Maghrib, Morocco’s central bank, is set out on our page on IFRS S2 and climate risk.

How can one dataset serve four frameworks?

By collecting each data point once, with its evidence, then presenting it in each reader’s structure. In our assignments, the problem is rarely a framework that asks too much; it is different figures sent to different readers.

1. List your readers: customers, group, bank, AMMC, development lender, supplier ESG rating platforms.
2. Start from the VSME: its 20 sections cover most questions; Annex II first.
3. Add full climate data: Scopes 1, 2 and 3 under the GHG Protocol, with sourced and dated emission factors.
4. Build cross-reference tables: VSME to ESRS, GRI and IFRS S2, section by section.
5. Document your choices: materiality for the ESRS or GRI, risks retained for IFRS S2, “not applicable” items for the VSME.
6. Archive every submission by reader and by date.

How the CSRD reaches suppliers outside the EU, and what Moroccan companies are doing about it, is covered in our article on CSR in Morocco in 2026-2027.

Before you choose a framework: checklist

• Every reader of your ESG data is identified, with the framework it uses.
  
• Your average headcount for the previous financial year is calculated against the 10- and 1,000-employee thresholds.
  
• Questions that go beyond Annex II of Delegated Regulation (EU) 2026/1560 are flagged.
  
• Scope 1 and 2 emissions are calculated under the GHG Protocol, with a location-based Scope 2.
  
• Scope 3 is at least screened across the 15 categories if a customer or investor asks.
  
• A cross-reference table links your data to the ESRS, GRI and IFRS S2.
  
• Questionnaires that still cite Recommendation (EU) 2025/1710 are reread against Delegated Regulation (EU) 2026/1560.