Back to VS Hub
Overview

Datapoints and omissions

How the VS decides what you report, what is voluntary and what you may leave out.

In brief

The VS does not require a double materiality assessment. Each disclosure says what to report and when. Datapoints are essential, if applicable or voluntary, and some essential datapoints are voluntary for companies with 10 employees or less. An if-applicable item that is left out is assumed not to apply. Other information can be omitted only on four grounds, such as a trade secret, and every omission must be listed in the report.

How the VS handles materiality

Under the full ESRS, a company first assesses which topics are material and then reports on them. The VS works the other way round: the standard has already chosen the topics and sets out, disclosure by disclosure, when an item must be reported. The report should still show the company's positive and negative impacts on people and the environment, and how environmental and social issues affect its finances.

Where the company's sector or activities raise issues the standard does not cover, it is appropriate to add that information, for example Scope 3 emissions. Appendix B of the standard lists possible sustainability issues to consider.

Three kinds of datapoints

KindWhat it meansExample
Essential ("shall")Must be reported when the company applies the standard.Total energy consumption; employees by gender
If applicableReported only in the circumstances the disclosure names. If left out, it is assumed not to apply.Employees by country, if the company operates in more than one country
Voluntary ("may")Never required.Female-to-male ratio at management level (C5); Scope 3 emissions where they are relevant

Voluntary for companies with 10 employees or less

The VS marks some essential datapoints with the bracket "[Voluntary for undertakings with 10 employees or less]". These companies may leave them out:

  • B3 total energy consumption and GHG emissions
  • B6 water withdrawal and consumption
  • B7 circular economy, waste and material flows
  • C1 description of the business model and strategy
  • C3 GHG reduction targets
  • C4 climate risks
  • C5 employee turnover rate
  • C6 code of conduct or human rights policy, and the complaints-handling mechanism
  • C7 confirmed human rights incidents in own workforce and in the value chain

Everything else applies to them in full, including B1, B2, B4, B5, B8, B9, B10, B11, C2, C8 and C9.

What "if applicable" means in practice

  • B4 Pollution: reported only if the company already reports pollutants to authorities or under an environmental management system.
  • B6 Water consumption: reported only by companies whose production processes consume water significantly.
  • B8 Employees by country: reported only if the company operates in more than one country.
  • B10 Gender pay gap: reported only if EU or national law already requires the company to report it.
  • C3 Transition plan: a company in a high climate impact sector without a transition plan must say whether, and when, it will adopt one.
  • C9 Board gender diversity: reported only if the company has a governance body.

When information can be omitted

A company may omit information in four cases:

  1. in exceptional cases, information that would seriously harm its commercial position;
  2. a trade secret, such as know-how or the results of innovation;
  3. classified information;
  4. information protected by other EU or national law, or withheld to safeguard the privacy or security of a person or a company.

Two conditions apply. The company lists each omitted datapoint in B1, and it reassesses at every reporting date whether the information can still be omitted. Fatalities in B9 are also reported "subject to legal restrictions".

An item that does not apply to the company is not an omission. It is simply not applicable.

Comparatives and the statement of compliance

From the second year of reporting, each metric is shown with the previous year's figure, except metrics reported for the first time. In B1 the company states which option it applies and that it complies with the VS. A module is complied with in its entirety, apart from if-applicable items that do not apply.

VS Standard Reference

The official text of the Voluntary Standard, Annex I to Commission Delegated Regulation (EU) 2026/1560.

Selko Insights

How Selko applies it

Option B
Selko Report

Full report, no relief for small companies

Selko prepares every report in full, as Option B. The relief for companies with 10 employees or less is not used, so no item is marked voluntary because of company size. The report then answers what customers and banks most often ask.

If applicable
Selko Report

Not applicable comes from your answers

You never mark an item not applicable by hand. A question such as "Your company operates in more than one country" sets it, and the reason is recorded. Essential datapoints cannot be marked not applicable: they are either reported or omitted on a valid ground.

Paragraph 22
Selko Report

Omitting a disclosure

"Omit this disclosure…" asks for the ground: one of the four grounds in paragraph 22, a legal restriction (B9 fatalities only), or a voluntary item. A box in the dialog explains the rules. The downloaded report lists the paragraph 22 omissions and legal restrictions automatically. Skipped voluntary items are not listed. Statuses start fresh every year, so every omission is reassessed.

Paragraph 27
Selko Report

Statement of compliance and the Reporting index

The Reporting index shows every datapoint as reported, not applicable or omitted, and "Open essential items" shows what is still missing. The downloaded report prints the statement of compliance only when every essential datapoint is covered. Until then it lists the open items instead.

Voluntary datapoints
Selko Report

Voluntary items are available

Selko Report includes the standard's voluntary datapoints, such as the C5 gender ratio in management and non-employee workers. It also offers market-based Scope 2 emissions, which EFRAG's guidance mentions as an addition. You decide whether to disclose them. A voluntary item you skip is not counted as missing.

Frequently asked questions

Ready to make progress?

Let's discuss how Selko Insights can help your organization turn sustainability goals into practical action.