In short
- The two modules are sequential, not alternative. Basic is a prerequisite for comprehensive.
- The definitive datapoint list is not law yet, so build the data, not the document.
- Almost nobody needs the comprehensive module because a customer asked for it.
VSME has a basic module and a comprehensive module, and the relationship between them is sequential rather than alternative: reporting the basic module is a prerequisite for the comprehensive one. So the real question is not which one to pick. It is whether anything in your commercial situation justifies doing the second one on top of the first, and for most SME suppliers in 2027 the honest answer is no.
This page is about making that call deliberately instead of by default, and about a complication most guides skip.
How do the two modules actually relate?
They stack. You cannot report the comprehensive module instead of the basic module, because the basic module is the foundation the comprehensive one is built on. Anyone who tells you to "go straight to comprehensive because your customer is big" is describing a report that does not exist.
That has a practical consequence for scheduling. The first year of VSME reporting is the basic module regardless of ambition, so the decision about the comprehensive module is not a decision you have to take before you start. It is a decision you can take in month nine, once you know what the data collection actually cost you.
Why is the datapoint list not settled yet?
Here is the complication, and it is the reason to be sceptical of any page that hands you a confident table of comprehensive-module datapoints.
VSME is an EFRAG standard, not a Commission act. Its only status in EU law today is Commission Recommendation (EU) 2025/1710 of 30 July 2025, which reproduces the standard in Annex I and the practical guidance in Annex II, and which is non-binding.
What is coming is different. Article 29ca of Directive 2013/34/EU, inserted by Directive (EU) 2026/470, requires the Commission to establish sustainability reporting standards for voluntary use by delegated act, based on Recommendation (EU) 2025/1710 in its original version. The Commission adopted that act on 3 July 2026 as C(2026) 5011, and its Article 4 says Article 3 shall apply from the financial years beginning on or after 1 January 2027. On 28 August 2026 it was still in Parliament and Council scrutiny, which means it was not law and could not be cited as such.
So the shape of VSME is settled and the legally fixed content is not. That is a reason to build your underlying data rather than to optimise a document against a datapoint list that has not been published in the Official Journal.
One thing that is settled, and it saves money on either module: there is no obligation to have the information assured. Recital 16 of the Recommendation says in terms that a self-declaration by the SME is sufficient. If a counterparty asks you to have a VSME report audited, that is their commercial request, not a requirement of the standard.
Which module does the value chain cap point at?
Worth reading the statutory language carefully here, because a lot of commercial argument is going to be built on it.
Directive (EU) 2026/470 gives a protected undertaking, meaning one that does not exceed an average of 1,000 employees in the preceding financial year and sits in a reporting undertaking's value chain, the right to decline to provide information exceeding the information specified in the voluntary standards. The reporting undertaking must not require more than that, and any contractual provision to the contrary is not binding.
The text refers to the voluntary standards. It does not, in the wording available, carve the ceiling at the basic module and leave the comprehensive module compellable. Treat anyone who asserts otherwise as making a prediction rather than quoting a directive, and treat the cap as a floor for your negotiating position rather than a settled boundary you can map module by module.
Who genuinely asks for the comprehensive module?
Not, in our experience, procurement. Bespoke supplier questionnaires are usually chasing an emissions figure and a handful of policies, which is basic-module territory.
The requests that reach further tend to come from a different direction.
| Who is asking | What they usually want | Which module that implies |
|---|---|---|
| A corporate customer collecting value chain data | An emissions figure and a few policies, reusable | Basic |
| A tender where sustainability is scored | A credible published artefact with real numbers | Basic |
| A bank or lender pricing sustainability-linked terms | More depth than the basic layer offers | Possibly comprehensive |
| An investor doing pre-transaction diligence | Depth, plus the ability to answer follow-ups | Possibly comprehensive |
| A customer who has never pruned its questionnaire | Everything, because nobody removed anything | Neither. Triage first |
The fifth row is the most common one and the one worth naming out loud. A questionnaire that asks for everything is not evidence that your customer needs the comprehensive module. It is usually evidence that a template was written once and inherited.
How should you decide?
Four questions, in order.
Has anybody actually asked? If no named counterparty has requested the extra depth, the comprehensive module is a solution looking for a problem. Report basic and see what comes back.
Is the asker a customer or a financier? Customer requests are shaped by their own reporting obligation and are subject to the value chain cap. A bank or an investor is negotiating with you commercially and the cap has nothing to say about it, because it bites only on information gathering for the purpose of sustainability reporting under the Accounting Directive.
Can you produce the data without a new project? The comprehensive module costs data, not writing. If the answer involves a system you do not have, price the project honestly before committing to a deadline.
Will you still be able to do it next year? Sustainability reporting is an annual routine. A comprehensive report you can produce once and not repeat damages you more than a basic report you produce consistently, because the year-on-year series is where the credibility lives.
What does the extra depth cost in practice?
The writing is not the cost. The data is.
Whatever module you land on, the greenhouse gas disclosure is the item that needs a genuine calculation rather than a policy statement, and it is where the extra depth bites first. Scope 1 and 2 from fuel, energy and mileage is a contained exercise. Anything reaching into your own supply chain is a different size of problem, and scope 3 is where that goes.
Two practical suggestions. Keep the calculation somewhere repeatable so that adding depth in year two does not mean rebuilding year one, which is the case for a platform over a spreadsheet. And when you do add depth, add it to the emissions disclosure first, because that is the disclosure every counterparty presses on.
Hedgehog covers the emissions half. The platform guides you through the GHG Protocol with an AI guide and human GHG experts reachable in-app, carries more than 20,000 spend-based and activity-based factors, supports multiple entities with roles for data owners, auditors and managers, and serves 5,000+ users. A free account needs no sales call and Pro starts at EUR 1,200 per year.
One limitation to weigh if you are considering the comprehensive route: a Small-Business reviewer on G2 said in August 2026, rating us 5 out of 5, that it takes a lot of manual labour to load data, and that once the data is there it works perfectly, but getting it loaded is the challenging part. More depth means more of exactly that work.
For the non-emissions disclosures and for the judgement call on module scope, VSME consulting is the shorter route, or book a call and we will tell you which module your situation actually needs.
Sources: Directive (EU) 2026/470 for Articles 19a(3) and 29a(3) and recital 12, Directive 2013/34/EU Article 29ca, Commission Recommendation (EU) 2025/1710 including recital 16, and Commission Delegated Regulation C(2026) 5011 as adopted on 3 July 2026 and not in force, read against the Official Journal text on 28 August 2026. Hedgehog platform and Hedgehog on G2, both read on 27 August 2026. Page verified 17 September 2026.
Facts on this page were last verified on 2026-09-17.
