In short
- A VSME report is self-declared. There is no assurance obligation and no filing portal.
- The order matters: fix the boundary and period first, because everything else inherits them.
- The greenhouse gas figures are the only step with a lead time measured in weeks rather than days.
A VSME report comes together in a fixed order. Fix the reporting boundary and period, decide whether you are doing the basic module alone, collect the qualitative disclosures, calculate the greenhouse gas figures, assemble the document, sign it off yourself. There is no auditor to satisfy and no portal to file in. Commission Recommendation (EU) 2025/1710 says plainly that there is no obligation to provide assurance on information reported by non-listed SMEs and that a self-declaration by the SME is sufficient. The sequence is entirely yours to run, and only one step is genuinely slow.
What are you actually producing?
A document about your own company, written by your own company, published or sent wherever it is useful.
VSME is an EFRAG standard. EFRAG developed it at the European Commission's request and delivered it in December 2024. Its only standing in EU law today is Commission Recommendation (EU) 2025/1710 of 30 July 2025, which reproduces the standard in its Annex I and recommends its use. A recommendation binds nobody. Nothing about a VSME report is legally compulsory.
The standard has two modules. There is a basic module, and there is a comprehensive module, and reporting the basic module is a prerequisite for the comprehensive one. That structure decides your first scoping question, because it means you cannot cherry-pick the comprehensive disclosures your biggest customer wants while skipping the basics underneath them.
We cover what the standard is and where it came from in VSME: what it is and what your customer may actually ask you for. This page is about the production run.
Who decides that you need one?
Your customers, and to a lesser extent your bank. Never a regulator.
Since Directive (EU) 2026/470 of 24 February 2026, CSRD reporting applies only to undertakings exceeding both a net turnover of EUR 450 million and an average of 1,000 employees, for financial years starting on or after 1 January 2027. The companies still caught by that have to report on their value chains, which means they have to ask suppliers. You are the supplier.
The commercially useful part is the ceiling on those questions. Directive (EU) 2026/470 gives an undertaking in a reporter's value chain that does not exceed an average of 1,000 employees a statutory right to decline information exceeding the voluntary standard, and makes any contract clause to the contrary non-binding. Two dates sit behind that right and they belong to different instruments. The right itself reaches you through national law, which Member States must transpose by 19 March 2027. The standard that fixes where the ceiling sits, C(2026) 5011, is written to apply from financial years beginning on or after 1 January 2027, and it was still in Parliament and Council scrutiny on 28 August 2026. It also bites only on requests made for the purpose of CSRD sustainability reporting, so it does nothing about due diligence, risk management or ordinary procurement questions. We work through that distinction in which ESG questions you can decline.
So the practical decision rule is simple. If a customer above those thresholds is going to ask you, produce the report before the questionnaire arrives rather than after.
What is the production sequence?
Six steps, and the order is not negotiable, because each one inherits decisions from the one above it.
| Step | What it produces | Who owns it | What blocks it |
|---|---|---|---|
| 1. Scope the report | Reporting period, legal entities and sites included, basic module only or basic plus comprehensive | Whoever owns the customer relationship, with finance | Nobody has decided which entities count as "the company" |
| 2. Map the disclosures | A list of every disclosure with a named owner beside it | One coordinator | Treating it as one person's job |
| 3. Collect the qualitative material | Policies, practices, workforce and governance descriptions | HR, operations, whoever holds the policies | Documents exist but nobody knows who has the current version |
| 4. Build the emissions inventory | Scope 1 and scope 2 figures, plus any scope 3 your customers ask for | Finance and facilities, jointly | Source data has to be gathered from outside the finance system |
| 5. Assemble and check | The draft report, with each figure traceable to its source | The coordinator | Late changes to the boundary from step 1 |
| 6. Sign off and publish | The final self-declared report | A director | Nobody wants to be the one who signs |
Steps 3 and 4 can run in parallel and should. They involve different people and different source systems, and running them in series is the most common reason a first report takes two quarters instead of one.
Which step actually takes the time?
Step 4, every time, and by a wide margin.
Everything else in a VSME report is a description of things you already do. You have a health and safety practice; the disclosure asks you to describe it. You have a governance arrangement; the disclosure asks you to state it. Those steps are slow only because they involve chasing colleagues, which is a scheduling problem rather than a technical one.
The emissions figures are different. They require a calculation, a stated boundary, an emission factor for every activity, and a source record behind every input. There is nothing to describe until the arithmetic has been done, and the arithmetic cannot start until fuel data, energy meter readings and purchase data have been pulled together from systems that were not built to produce them. If you have never built one, carbon accounting from scratch is the right starting point, and if your customers are pushing into value chain categories specifically, scope 3 is the conversation that follows.
Our own customers say the same thing about the data. A small business reviewer wrote on G2 in August 2026 that once the data is loaded everything works perfectly, and that getting it loaded is the challenging part. That is true of every tool in this market. Plan the calendar around it.
What goes wrong on a first report?
Four things, and three of them happen in step 1.
The boundary is decided late. Somebody adds a subsidiary in week six, and every figure calculated so far has to be redone. Decide which legal entities and which sites are in, write it down, and do not reopen it.
The reporting period does not match the financial year. Aligning the two costs nothing at the start and is painful to fix afterwards, because the comparison your customer wants is against your accounts.
Comprehensive disclosures get promised before the basic module exists. A single large customer asks for something from the comprehensive module, somebody says yes, and the report acquires a dependency nobody scoped. The basic module comes first by design.
The method lives in one spreadsheet on one laptop. Next year the person has moved on, the method is unreconstructable, and the year-on-year series breaks. That series is most of what a repeat report is worth.
Who signs it off, and what does done look like?
You do, and that is the whole point.
Because there is no assurance obligation, the quality bar is set by the reader rather than by an auditor. The reader is a procurement or sustainability person at a customer, deciding whether to accept your numbers or push back. What convinces them is not a bigger document. It is a stated boundary, a stated period, a named method, and figures they can see the derivation of.
Practically, a finished report is done when a colleague who did not write it can pick any single number and follow it back to a source record without asking you. If that test fails, the report will pass this year and fail next year, when you are not in the room.
Where should you start?
Start with step 1, on paper, in an hour. Entities, sites, period, basic or basic plus comprehensive. It is the cheapest hour in the project and it prevents the two most expensive mistakes.
Then start the emissions work immediately and let the qualitative collection run alongside it. Building the inventory on a platform rather than in a spreadsheet matters less for the first report than for the second, when the value is in the method having stayed still.
If you would rather have someone run the sequence with you, that is what VSME consultancy is for, or book a call and we will tell you honestly whether your deadline is reachable.
Sources: Commission Recommendation (EU) 2025/1710, Directive (EU) 2026/470, Directive 2013/34/EU as amended, verified against the Official Journal text on 28 August 2026. Hedgehog platform and Hedgehog on G2, verified 27 August 2026.
Facts on this page were last verified on 2026-08-27.
