Is it possible to report on sustainability without obligation? The VSME standard offers a smart solution.
- Miranda Haak
- Jul 3
- 4 min read

Written by: Miranda Haak and Christiaan Mulder
Voluntary reporting, strategic thinking ahead
A growing number of organisations are keen to be transparent about their social and environmental performance. This is not because they have to, but because customers, financiers and supply chain partners demand it, or because they believe in responsible business practices. But how can you achieve this if you are not yet subject to the CSRD?
The VSME standard provides a smart, flexible and forward-looking alternative that sidesteps the onerous requirements of the CSRD.
Who is this relevant for?
The VSME standard was primarily developed for SMEs, and is particularly relevant to those that are:
Growing SMEs that are attracting the attention of larger chain partners
SMEs in sectors with increasing sustainability expectations, such as construction, manufacturing, retail, logistics and healthcare.
Companies that want to prepare for future legislation, tenders or chain obligations.
What is the VSME?
The Voluntary Sustainability Reporting Standard for SMEs (VSME) is a voluntary reporting framework specifically designed for organisations that want to share sustainability information without being directly subject to the obligations of the CSRD.
The standard was developed by EFRAG (the European Financial Reporting Advisory Group), which is responsible for developing sustainability reporting standards on behalf of the European Commission. Having previously drawn up the mandatory European Sustainability Reporting Standards (ESRS) for large companies, EFRAG is now working on practical alternatives for SMEs, such as this voluntary VSME standard.
What is the difference between B and C?
Many organisations get stuck here. 'Two modules? Which one should I choose? What exactly do they contain?'
The table below will help you get started.
Module B: Basic | Module C: Comprehensive | |
Purpose | Initial, concise report | More extensive communication with stakeholders |
Form | Table for entering basic data | Report with explanations, context and narrative |
Contents | Key figures on personnel, environment, policy | Broader: strategy, governance, impact, goal |
Needed for? | Questions from the chain, subsidy applications, first step | Reputation, partnership, preparation for CSRD |
Time investment | Low (several days) | Medium to high (several weeks) |
Stakeholder engagement | Limited | Active: retrieving input is recommended |
Example question | How much energy do we use? | How can we incorporate sustainability into our strategy? |
Impact of scope | Especially internally, but also with regard to chain partners. | Obligatory across the entire value chain (upstream and downstream). |
Frequency: | Recommended annually (repeatedly). | Mandatory annually |
How to choose the right module:
Module B is right for you if you...
are reporting for the first time and want to start small
mainly need to provide data to a CSRD-obligated customer
want to be able to repeat reporting without much effort
are looking for a practical “compliance light” solution
Module C is right for you if you...
make sustainability an explicit part of your mission
value stakeholder dialogue and reputation
are preparing for future CSRD obligations
want to explain your approach to financiers, partners or the government
Important: you can combine Module B with parts from C, making it scalable.
Why a (light) DMA is still a good idea
Although a Double Materiality Analysis (DMA) is not mandatory under VSME, it is recommended. It helps you to focus on what is relevant and prevents you from reporting just for the sake of it.
Examples:
If you select option C, a DMA will help you prioritise themes.
Are you being questioned by stakeholders? The DMA provides substantiation.
Do you want to be CSRD-proof? The DMA will lay the groundwork.
Element | VSME | CSRD (ESRS) |
DMA mandatory? | ❌ No | ✅ Yes |
DMA recommended? | ✅ Yes, especially with C module. | ✅ Yes, essential |
Focus on topics | Indirectly via the if applicable principle | Directly via Article 17 ESRS 1 |
Method prescribed? | ❌ No | ✅ Yes, including stakeholder dialogue |
Scope van impact | Internal with possibility of expansion | Full value chain (upstream and downstream). |
Frequency | Recommended annually | Mandatory annually |
When should the report be published?
Many entrepreneurs ask themselves this question. 'Does my sustainability report have to be published at the same time as the annual report?'
The answer is no.
With VSME, you can publish the report at a time that suits you, giving you peace of mind, clarity and flexibility.
You can publish the report separately, either in spring or autumn.
You don't need to have it reviewed by an accountant, saving you money.
You can choose when to communicate with your stakeholders.
While you can link the report to your annual report, you don't have to.
Get started today!
Choose your entry level: B or C (or a combination)
Conduct a brief DMA analysis to identify the key factors in your context.
Collect data, starting with what you have and expanding when necessary.
Create a report: choose a format that suits your target audience.
Repeat annually to stay up to date and keep it workable.
Dufinco helps you choose the right route
At Dufinco, we make sustainability reporting workable, scalable, and easy to understand.
What sets us apart?
We excel at providing structure. We take a structured approach to analysing legislation, conducting gap analyses, and implementing solutions. This makes things clear.
What the law says exactly.
What this means for your company in concrete terms.
How you can implement this in a targeted and effective manner
This approach prevents confusion, duplication of work and uncertainty about legal requirements. We ensure that you adhere to the intention of the law without doing more than is necessary.
All too often, legislation is either not read properly or interpreted too freely. By using the law as a framework, you can remain in control as an organisation and report in a sustainable and demonstrably effective manner.
Whether you opt for a practical B report or require guidance on a comprehensive C approach, we will support you in moving forward — clearly, purposefully, and with an eye for proportionality.
Whether you choose a practical B approach or need guidance on a comprehensive C approach, we will help you move forward clearly and purposefully, with an eye for proportionality.
Questions?
Email us at info@dufinco.nl or via Miranda.haak@dufinco.nl
Call us on +31 6 512 47 217
Want to find out how the VSME can help your organisation become more sustainable and transparent immediately? Get in touch today and we'll help you get started in just one conversation.
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