1. What the Voluntary Standard is, and why it exists
The Voluntary Standard (VS) is the EU's official reporting standard for companies that are not covered by mandatory CSRD reporting. It replaces the VSME standard that EFRAG published in December 2024.
VSME was a standard published by EFRAG and endorsed by a Commission recommendation. It carried no legal force. The VS is a Commission Delegated Regulation that supplements the Accounting Directive.
The reason for the change is the value chain cap introduced through the Omnibus I package. Under the cap, companies that report under the CSRD may not require sustainability information from business partners with 1,000 employees or fewer that goes beyond what the VS contains. For the cap to be legally enforceable, the limit has to be written into a legal act rather than a recommendation.
This has a practical consequence. Applying the VS remains voluntary for your company. Respecting its limits is not voluntary for your large customers and banks, if they are looking to use the sustainability data collected in relation to their own sustainability statements. However, your clients and stakeholders are still perfectly allowed to ask you to provide sustainability information outside the scope of the VS standard if it is related to their risk management processes.
Further, the scope of the VS is also wider than VSME. VSME was aimed at non-listed micro, small and medium companies, broadly up to 250 employees. The VS covers all undertakings that did not exceed an average of 1,000 employees in the preceding financial year.
2. What changes
We compared the two standards datapoint by datapoint. Across the VSME datapoints, roughly half are left completely unchanged, while the other half have been slightly modified. A few datapoints were completely removed, and one datapoint was moved from the basic to the comprehensive module. There are no new reportable datapoints.
If you have reported under VSME, the work carries over. Four types of change are worth knowing.
A new size threshold at 10 employees
This is the most far-reaching change. Around a third of the disclosures are now marked essential only for companies with more than 10 employees and voluntary for companies with 10 or fewer. This applies to total energy consumption, Scope 1 and Scope 2 emissions, water withdrawal, waste figures, circular economy practices, business model descriptions, climate targets and climate risk. VSME applied these to all sizes.
We will, however, continue to recommend that even companies with fewer than 10 employees continue to report these basic sustainability metrics, as they are essential for any company who is genuinely striving towards improving the sustainability of their operations.
Datapoints that disappear
- GHG intensity per turnover is gone.
- Four voluntary land use metrics under B5: Biodiversity are gone.
- The disclosure on exclusion from EU Paris-aligned benchmarks is gone.
Metrics that were redefined
- Waste diverted to recycling or reuse changes from an absolute amount to a proportion.
- Training hours no longer need a gender breakdown.
- The water stress split moves from water withdrawn to water consumed.
- For biodiversity-sensitive areas, the requirement to report the number of sites and the area in hectares is replaced by naming the area concerned.
- The gender pay gap is now reported only where EU or national law already requires it, instead of applying to all companies above 150 employees.
Structural changes
- Every datapoint now carries a category: essential, if applicable, voluntary, or a sector-specific consideration.
- The rules for omitting information are broader and now cover trade secrets and serious commercial prejudice rather than only classified or sensitive information.
- Employee turnover moves from the Basic Module to the Comprehensive Module.
3. Timeline
- 6 May 2026: the Commission published the draft delegated act on the Voluntary Standard and opened public consultation.
- 3 June 2026: the consultation closed.
- 3 July 2026: the Commission adopted the delegated act, C(2026) 5011 final, and transmitted it to the European Parliament and the Council.
- Now: the scrutiny period. Parliament and Council have two months to object, extendable by a further two months at the request of either institution. Neither can amend the text. They can only accept it or reject it in full. On the standard two-month period, scrutiny ends in early September 2026. If extended, it runs to early November 2026.
- After scrutiny: if there is no objection, the act is published in the Official Journal and enters into force on the third day after publication. From that point the VS is available to any company with 1,000 employees or fewer.
- Financial years beginning on or after 1 January 2027: Article 3, the value chain cap, starts to apply.
Objections at this stage are uncommon, but the outcome is not formally settled until the period ends.
4. What this means for your company
If you already report under VSME, your data and processes stay valid. The changes are removals, softer thresholds and adjusted metrics. Further, even though a large portion of the reporting disclosures technically become voluntary for companies with 10 employees or fewer, at Selko we will strongly recommend to continue reporting these highly relevant sustainability metrics.
Our platform will be updated to the VS standard when it will be confirmed into law. In practice, this means that most companies will report their 2026 fiscal years against the VS standard.
If you want to know how this change might affect you, contact us and we can consider the implications on your company!
Filip Kaila — Selko Insights