Who the VS is intended for
The VS is intended for companies that, on their balance sheet date, had an average of no more than 1,000 employees during the previous financial year. This includes self-employed people, non-incorporated businesses and listed micro companies.
- Micro companies usually start with the Basic Module, which is the standard's target approach for them.
- Companies with 10 employees or less may treat some datapoints as voluntary, for example energy, water, waste and parts of the Comprehensive Module. The full list is on the page Datapoints and omissions.
- Companies with more than 1,000 employees that are outside the CSRD because their turnover is €450 million or less can also use the VS. The value chain cap does not protect them, however.
The CSRD after Omnibus I
The Omnibus I Directive (EU) 2026/470 limited mandatory sustainability reporting to companies with more than 1,000 employees and more than €450 million in net turnover. According to the Commission, this reduces the number of companies in scope by about 85%. For the companies that fell out of scope, and for those that were never in it, the VS is the EU's own framework for voluntary reporting.
The VS suits, for example:
- non-listed SMEs that want a structured way to report;
- companies that prepared for the CSRD but are no longer in its scope;
- suppliers whose customers ask for sustainability data;
- companies that need sustainability information for a loan or other financing.
Why report if it is voluntary?
- Customer requests. Large companies need data from their suppliers for their own reports. One VS report answers most of these requests.
- Access to finance. Banks and investors use VS data in their risk assessments and their own reporting. The standard was built with their information needs in mind.
- Better management. Collecting the data shows where energy, materials and costs can be saved, and where risks lie.
- Ready for what comes next. Customer and financing requirements tend to grow. A company that reports every year builds the data and routines it needs.
The value chain cap
The value chain cap is the upper limit of sustainability information that a CSRD-reporting company may require from a company in its value chain that has up to 1,000 employees. It applies to financial years starting on or after 1 January 2027.
- The cap covers only essential datapoints, listed in Annex II of the regulation. The list is shorter for companies with 10 employees or less.
- It applies to information requested for CSRD reporting. Requests based on other EU or national law are outside the cap.
- A CSRD company should request only what it needs, and less than the cap if it does not need everything.
- Banks, investors and insurers are encouraged to limit their own requests to what the VS contains.
| Disclosure | Datapoints in the value chain cap | 10 employees or less | More than 10 employees |
|---|---|---|---|
| B1 | Selected option, reporting basis, company information (legal form, NACE code, balance sheet, turnover, employees, country, site geolocation) | ✓ | ✓ |
| B3 | Total energy consumption; Scope 1 and Scope 2 GHG emissions | – | ✓ |
| B6 | Total water withdrawal | – | ✓ |
| B7 | Whether circular economy principles are applied; total waste, hazardous and non-hazardous; share sent to recycling or reuse | – | ✓ |
| B8 | Employees by contract type and by gender | ✓ | ✓ |
| B9 | Number and rate of recordable work-related accidents | ✓ | ✓ |
| B10 | Minimum wage; collective bargaining coverage; average training hours | ✓ | ✓ |
| C1 | Products and services; markets; main business relationships | – | ✓ |
| C5 | Employee turnover rate | – | ✓ |
| C6 | Code of conduct or human rights policy; complaints-handling mechanism | – | ✓ |
| C7 | Confirmed human rights incidents in own workforce and in the value chain | – | ✓ |
Getting started
The first report is usually triggered by a request: a customer's supplier questionnaire, a bank's ESG question or a tender. Most of the data already exists in energy and water bills, payroll, the waste contractor's annual summary and the financial statements. Start from these and add the rest step by step.