VSME Standard: A Supplier’s Guide to Modules B1–B11 and C1–C9

What is the VSME standard, and which text is the reference?

The VSME standard is the EU’s sustainability reporting standard for voluntary use: since 24 September 2026, its legal reference is Annex I of Delegated Regulation (EU) 2026/1560. It lets a company outside the scope of the CSRD (Corporate Sustainability Reporting Directive) publish a short, structured and comparable sustainability report.

The acronym comes from EFRAG’s Voluntary Sustainability Reporting Standard for non-listed SMEs. EFRAG is the technical adviser that drafts EU sustainability reporting standards for the European Commission. The standard went through three stages, all checked on official sites on 11 November 2026:

The regulation does three things. Article 2 allows undertakings that are not subject to the CSRD to report on a voluntary basis under the Annex I standard, and to rely on EFRAG’s practical guidance. Article 3 makes that standard the value-chain cap, whose exact content is listed in Annex II. Recital 5 removes any legal effect from the 2025 recommendation.

The standard is meant to meet the data needs of large corporate customers, banks and investors, and to help the company manage its own sustainability matters. It covers the same sustainability matters as the ESRS (European Sustainability Reporting Standards) in a proportionate form, and it imposes no legal reporting obligation.

Who is it for?

Undertakings that, on their balance sheet date, do not exceed an average of 1,000 employees during the previous financial year (Annex I, paragraph 2). That is a clear widening: the 2025 recommendation addressed non-listed micro, small and medium-sized undertakings.

For a supplier based in Morocco, the text sets no condition on place of establishment. The 2025 recommendation expressly said that SMEs from third countries could use it, and the delegated regulation does not restrict its scope by country. An exporter in Tangier, Agadir or Casablanca can state that its report complies with the voluntary standard in exactly the same terms as a European SME.

What the standard means in your dealings with a CSRD-reporting customer (right to refuse, headcount self-declaration, contract clauses) is covered on our supplier ESG questionnaires page. This guide is about the content of the standard itself.

How is the VSME standard structured?

The standard has two modules, an option to declare and four kinds of datapoints. The Basic Module is the target approach for micro-undertakings and the minimum for everyone else; the Comprehensive Module adds the data that banks, investors and corporate customers commonly ask for.

Two modules, two options

• Option A: Basic Module only. Disclosures B1 and B2 (general information), then metrics B3 to B11 (environment, social, governance).
• Option B: Basic Module and Comprehensive Module. Disclosures C1 to C9 on top of B1 to B11.

Three rules frame the choice. The Basic Module is a prerequisite for the Comprehensive Module (paragraph 7). A chosen module must be complied with in its entirety (paragraph 27). A company that has completed B1 to B11 may also add selected Comprehensive Module disclosures (paragraph 25); it then remains under Option A, since Option B means the whole Comprehensive Module.

Four kinds of datapoints

This is one of the regulation’s additions to the recommendation. Paragraph 8 of Annex I distinguishes:

1. essential datapoints, to be reported whenever the standard is applied;
2. datapoints needed only in specified circumstances, under the ‘if applicable’ principle;
3. voluntary datapoints, such as the female-to-male ratio at management level (C5);
4. datapoints to be considered for sector-specific information, such as Scope 3.

A proportionality rule sits on top: some essential datapoints are voluntary for undertakings with 10 employees or less. The text flags them in square brackets, ‘[Voluntary for undertakings with 10 employees or less]’. This applies to energy consumption and GHG emissions (B3), water withdrawal (B6) and most waste data (B7).

Three appendices

• Appendix A, defined terms, is an integral part of the standard. A ‘recordable work-related accident’, for instance, is one that results in death or more than three days of absence from work. Read the definitions before computing any metric.
• Appendix B, possible sustainability issues, lists topics (pollution, water, biodiversity, working conditions, business conduct, supplier relationships and so on) for drafting B2 and sector-specific information.
• Appendix C, reconciliation with other EU regulations, shows which datapoints feed the indicators of EU financial regulation (SFDR, the European Banking Authority’s Pillar 3, benchmark regulations). It is the key to reading bank questionnaires.

Which preparation principles must a VSME report follow?

A VSME report must provide information that is relevant, faithful, comparable, understandable and verifiable (paragraph 11). It covers both the company’s impacts on people and the environment and the effect of environmental and social matters on its financial position (paragraph 10), without requiring a materiality assessment.

The omission rules deserve a close read. A company may leave out, in exceptional cases, information whose disclosure would seriously prejudice its commercial position; information that is a trade secret (know-how, intellectual property, innovation results); classified information; and information protected by other laws or for a person’s privacy or safety. It must flag each omitted datapoint under B1 and reassess the omission at each reporting date. The 2025 recommendation only had a general clause on ‘classified or sensitive’ information.

What does the Basic Module require, disclosure by disclosure?

The Basic Module has eleven disclosures: two of general information (B1, B2) and nine metrics (B3 to B11). The table follows the wording of Annex I, the rule for undertakings with 10 employees or less, and the evidence a Moroccan supplier typically uses.

Four reading points come up in almost every plant we work with.

• B1 and the NACE code. The standard asks for a code from NACE, the EU’s statistical classification of economic activities. A Moroccan company has none assigned: pick the code that describes your main activity and record the mapping you used.
• B3 and electricity. The renewable/non-renewable split is based on ‘the invoices issued by the supplier’, and only if the company can obtain the information. If your invoices do not show it, do not rebuild it from a national average: give the total and explain. For Scope 2, state the source and year of the grid emission factor. Our ISO 14064-1 guide explains the inventory method.
• B9 and the accident definition. The standard’s threshold is death or more than three days’ absence. It may differ from your internal criteria or your reporting practice: recount from the register.
• B10 and the minimum wage. The question is yes or no: do your employees earn at least the minimum wage that applies in the country, set by law or by a collective agreement? In Morocco, you prove it from payroll, category by category, seasonal workers included.

What does the Comprehensive Module add, and for whom?

The Comprehensive Module adds nine disclosures aimed at investors, banks and corporate customers: strategy, climate targets, climate risks, more workforce data, human rights, certain sensitive activities and governance diversity. According to paragraph 44, they reflect these partners’ own obligations and what they need to assess your risk profile as a supplier or borrower.

Two points matter directly for Moroccan industry.

The transition plan (C3). ‘High climate impact sectors’ are those in NACE sections A to H and M, which include agriculture, manufacturing, construction and transport. A company in these sectors without a transition plan must state whether and, if so, when it will adopt one (paragraph 55). Under Option B, a manufacturer cannot skip the question. Our decarbonisation strategy page explains how to build that plan.

Scope 3. The standard does not require it, but asks companies to consider it depending on their business (paragraphs 49 to 52), naming manufacturing, food, real-estate construction and packaging as likely to have significant categories. If you report it, refer to the 15 categories of the GHG Protocol Corporate Value Chain (Scope 3) Standard, include those you assess as significant, and present them alongside Scope 1 and 2 under B3. The inventory method is on our GHG inventory and ISO 14064 page. For C4, see climate risk and IFRS S2; for C6 and C7, supply-chain due diligence.

What changed from Recommendation (EU) 2025/1710?

The substance is the 2025 standard: same modular structure, same disclosures B1 to B11 and C1 to C9. What changed is the legal status, the target companies, the typology of datapoints, the omission rules and some titles. We compared the two texts on EUR-Lex on 11 November 2026.

A report prepared in 2026 under the recommendation keeps its data. The next one should cite Annex I of Delegated Regulation (EU) 2026/1560 in its statement of compliance (B1), apply the new omission rules and check which items became voluntary if the company has 10 employees or less. Paragraph numbering also moved: the basis for preparation is paragraph 27 in the regulation, against 24 in the recommendation. Update your mapping tables.

Which VSME option should a Moroccan supplier choose?

Choose the option according to who will actually read the report, not the size of the company. For a CSRD-reporting customer, Option A is almost always enough, topped up with a few Comprehensive Module datapoints; for a bank or an investor, Option B quickly becomes necessary.

The most common trap is to assume the value-chain cap equals Option A. For an undertaking with more than 10 employees, Annex II keeps part of the Basic Module (B1, B3, B6, B7, B8, B9, B10) and some Comprehensive Module datapoints: C1 (products, markets, business relationships), C5 (turnover), C6 (code of conduct, grievance mechanism) and C7 (confirmed incidents). B2, B4, B5 and B11 are not in it. For an undertaking with 10 employees or less, the cap is limited to B1, B8, B9 and B10.

For a worked example of a Moroccan exporter facing several ESG questionnaires at once, see our CGEM CSR label case study.

Is your VSME report ready?

• The statement of compliance cites Annex I of Delegated Regulation (EU) 2026/1560, not Recommendation (EU) 2025/1710.
  
• Option A or B is stated under B1, together with the individual or consolidated basis.
  
• Average headcount for the previous financial year is calculated against the 10 and 1,000 employee thresholds.
  
• Every omitted ‘if applicable’ item has an internal justification.
  
• Every omission for trade secrets or protected information is declared under B1.
  
• Turnover, headcount and total assets match the financial statements.
  
• Scope 1 and Scope 2 are calculated under the GHG Protocol, location-based Scope 2, with dated and sourced factors.
  
• Accidents are recounted using the Appendix A definition (death or more than three days’ absence).
  
• Under Option B, C3 states whether and when a transition plan will be adopted.
  
• Annex II datapoints are available and evidenced, even under Option A.
  
• Methods are written down so comparatives can be produced from year two.